Transcript Maintenance of Conditions - Marine Chemist Association

Maintenance of Conditions
Robbie Walker | Marine Chemist Service Inc. | 2014 MCA Sectional Seminars
Half full or half empty?
*
If not six of one, then half dozen . . .
*from Stephen King’s Under the Dome
Change in (of) Conditions
Objectives
• Review – Maintenance of Conditions and (its inverse) Change in Conditions
factual information: “just the facts ma’am, just the facts”
in a logical progression: if A = B then B = C
i.e. remember A to fully appreciate and apply C
The Review will include rhetorical questions due to:
time constraints
“maintain” impartiality (unbiased opinions)
∑ All will be given opportunity to “respond” . . .
• Survey (opinions of specific scenarios)
involving aforementioned rhetorical questions
5
References/Resources
EMCC/MCC
6
NFPA 306
OSHA 1915
SI 009-07
In the beginning . . .
¶ 1.1 Scope.
¶ 1.1.2 This standard describes the conditions required
before a space can be entered or work
can be started
¶ 1.1.7 This standard applies to
Marine Chemists
performing activities
related to inspection
and certification procedures . . .
¶ 1.2 Purpose. The purpose of this standard is to provide minimum
requirements . . .
7
“Serious” business
Chapter 3 Definitions
¶ 3.2.2 Shall. Indicates a mandatory requirement.
¶ 3.2.3 Standard. A document, the main text of which
contains only mandatory provisions using the
word “shall” to indicate requirements . . .
8
The Certificate
Chapter 3 Definitions
¶ 3.3.2 Certificate. See 3.3.14, Marine Chemist’s Cert.
¶ 3.3.14 Marine Chemist’s Certificate (Certificate).
A document issued by a Marine Chemist, on a
form authorized by the National Fire Protection
Association, stating the conditions that the
Marine Chemist found at the time of inspection.
9
Words, and their meaning
Chapter 3 Definitions
¶ 3.1 The definitions contained in this chapter shall apply
to the terms used in this standard. Where terms
are not defined in this chapter or within another
chapter, they shall be defined using their ordinarily
accepted meanings within the context in which they
are used. MerriamWebster’s Collegiate
Dictionary, 11th edition,
shall be the source for
the ordinarily accepted
meaning.
10
Words, and their meaning
Definitions
Maintain: to cause something to continue without changing
to keep in an existing state
Same old – Same old
Same ole – Same ole
Same ol’ – Same ol’
11
Words, and their meaning
Definitions
Change:
to become different
a shift from one to another
a modification, substitution, transformation
synonyms: to alter, modify, revise
No Qualifications:
Quantitative
A little
A lot
12
Qualitative
Traditional Wedding Vow
I, (name),
take you (name),
to be my (wife/husband),
to have and to hold
from this day forward,
for better or worse . . .
Words, and their meaning
Definitions
Change:
matter of degree
accept/reject
(opposites; no “gray areas”)
opinion vs fact
13
Words, and their meaning
Various examples found within NFPA 306
Explicitly Stated Conditions:
¶ 3.3.14 Conditions found by a Marine Chemist at the time
of inspection. (also on EMCC/MCC)
EMCC/MCC Atmospheric Changes & Alter Conditions
¶ 6.2 Personally determine conditions
¶ 7.1.1(4) (ASFW/residues) Atmospheric Conditions
¶ 7.1.1.1 (NSFW) Conditions of O2, LEL, toxics, residues
¶ 7.1.3 (EWR) Conditions of PPE, clothing, time
Implied/Indirect Conditions:
Maintain  Conditions  O2, water level, etc.
¶ 8.4 Maintaining the Responsibility for Conditions
14
Summary:
OSHA 1915
Definitions
NFPA 306
Definitions
M-Webster
Definitions
MC
Instructions
USCG/USN
Definitions
NFPA 306
Descriptions
Explicit
Implied
__________________________
If definitions, instructions , etc.
are a moving target how much
more is the Application?
15
Application
Baseline
The Certificate(s)
MCC & EMCC
Conditions
Maintenance
In the event of physical or atmospheric changes affecting the STANDARD
SAFETY DESIGNATIONS assigned to any of the above spaces, this
certificate is voided; spaces not listed on the Certificate are not to be entered
unless authorized on another Certificate and/or maintained in accordance
with OSHA 29 CFR 1915; or if in any doubt, immediately stop all work and
contact the undersigned Marine Chemist. Unless otherwise stated on the
Certificate, all spaces and affected adjacent spaces are to be reinspected
daily or more often as necessary by the competent person in support of work
prior to entry or recommencement of work.
Conditions
Maintenance
1915 Subpart B App A Compliance Asst Guidelines
• Sections 1915.11 through 1915.16. These standards are minimum safety
standards for entering and working safely in vessel tanks and compartments.
• After a tank has been properly washed and ventilated, if the oxygen content
is lower than 20.8%, the reasons for this deficiency should be determined and
corrective action taken.
• An oxygen level greater than 20.8% should alert the CP to look for the cause
of the oxygen-enriched atmosphere and correct it prior to entry.
Not “worse case scenario”
– still within criteria of Standard Safety Designation
19
1915 Subpart B App A Compliance Asst Guidelines
• During hot work, more than 20.8 percent oxygen by volume can be unsafe
since it extends the normal flammable range. The standard permits the oxygen
level to reach 22 percent by volume in order to account for instrument error.
However, the cause of excess oxygen should be investigated and the source
removed.
Not “worse case scenario”
– still within criteria of Standard Safety Designation
20
1915 Subpart B App A Compliance Asst Guidelines
• Atmospheres at or above 10% LEL are considered hazardous when located in
confined spaces. However, atmospheres with flammable vapors below 10
percent of the LEL are not necessarily safe.
• When a space contains or produces measurable flammable vapors below the
10% LEL, it might indicate that flammable vapors are being released or
introduced into the space and could present a hazard in time. Therefore, the
cause of the vapors should be investigated and, if possible, eliminated prior to
entry.
Not “worse case scenario”
– still within criteria of Standard Safety Designation
21
• An atmosphere with a concentration of a flammable substance below 10% LEL
may be above the OSHA PEL.
Conditions
Maintenance
QUALIFICATIONS: Transfer of ballast, cargo, fuel, or manipulation of valves
or closure equipment tending to alter conditions in pipelines, tanks, or
compartments subject to gas accumulation, unless specifically approved on
this Certificate, requires inspections and a new Certificate for the spaces so
affected. All lines, vents, heating coils, valves, and similar enclosed
appurtenances shall be considered “not safe” unless otherwise specifically
designated. Movement of the vessel from its specific location voids the
Certificate unless shifting of the vessel within the facility has been
specifically authorized on this Certificate.
Words, and their meaning
Definitions
Tending (tend):
to exhibit an inclination (a tendency to a particular state) or
tendency (a quality that makes something likely* to happen)
*not a guarantee a change will occur
not a “done deal”
“New Certificate”
only for the spaces so affected?
what happened to old certificate?
23
NFPA 306
Chapter 6
6.2.1 The Marine Chemist’s determinations shall include . . .
(5) Verification that pipelines that could release hazardous materials into
spaces that will be certified for entry and/or hot work are either disconnected,
blanked off, or otherwise blocked by a positive method, or the valves are
positioned and tagged in such a manner to prevent, or by written notice restrict
operations.
Since a MC is required (shall) to make pipeline determinations, COULD “manipulating valves”
change the validity of the Certificate? No mention of affecting Standard Safety Designations.
1915.15 Maintenance of Safe Conditions
• Preventing hazardous materials from entering: Pipelines shall be
disconnected, blanked off, or otherwise blocked by a positive method
• Alteration of existing conditions. When a change that could alter
conditions within a tested confined or enclosed space or other dangerous
atmosphere occurs, work in the affected space or area shall be stopped.
Work may not be resumed until the affected space or area is visually
inspected and retested and found to comply with 1915.12, 1915.13, and
1915.14.
• Note to above paragraph: Examples of changes that would warrant the stoppage
of work include the: opening manholes, or
opening other closures, or
adjusting a valve regulating flow of hazardous materials
25
1915.15 Maintenance of Safe Conditions
• Tests to maintain the conditions of a Marine Chemist's certificate. A CP
shall visually inspect and test each space certified as "Safe for Workers" or
"Safe for Hot Work," as often as necessary to ensure that atmospheric
conditions within that space are maintained within the conditions established
by the certificate after the certificate has been issued.
• Change in the conditions of a Marine Chemist's certificate. If a CP finds
the atmospheric conditions within a certified space fail to meet the applicable
requirements of 1915.12, 1915.13, and 1915.14, work in the certified space
shall be stopped and may not be resumed until the space has been retested
by a Marine Chemist and a new certificate issued in accordance with
1915.14(a).
26
1915 Subpart B App A Compliance Asst Guidelines
Some situations that have produced measurable concentrations of flammable
vapors that could exceed 10 percent of the LEL in time are:
1. Pipelines that should have been blanked or disconnected have opened,
allowing product into the space.
2. The vessel may have shifted, allowing product not previously cleaned and
removed during washing to move into other areas of the vessel.
3. Residues may be producing the atmosphere by releasing flammable vapor.
27
1915 Subpart B App A Compliance Asst Guidelines
The frequency with which a tank is monitored to determine if atmospheric
conditions are being maintained is a function of several factors:
1. Temperature: Higher temperatures – potentially more vapor
2. Work in the tank. Activities in a tank can change the atmospheric conditions:
leaking oxyfuel hose or torch, welding with inert gas, tank cleaning with high
pressure spray devices can stir up residues and result in exposures to toxic
contaminants.
3. Period of time elapsed, Unattended tanks or spaces, Work breaks
28
4. Ballasting or trimming. Moving the vessel in any way could release cargo that
had been previously trapped, and can produce an atmospheric change. The
atmosphere should be retested after move and prior to entry or work.
Conditions
Maintenance
Chapter 1
Chapter 2
Chapter 3
Chapter 4
Chapter 5
Chapter 6
Chapter 7
Chapter 8
Chapter 9
Administration
Referenced Publications
Definitions
Vessels Required to Have a Marine Chemist’s Certificate
Preparing Vessels by the Vessel Owners . . . for Issuance of a MCC
Procedures for the Marine Chemist Prior to Issuance of a Certificate
Standard Safety Designations and Conditions Required
The Marine Chemist’s Certificate
Additional Requirements for Flammable Cryogenic Liquid Carriers
NFPA 306 (2014 ed)
NFPA 306
Chapter 6
6.2 Determination of Conditions. The Marine Chemist shall personally
determine conditions, and shall be permitted to issue a Marine Chemist’s
Certificate setting forth in writing that the prescribed work to a vessel can be
undertaken with safety . . . The Marine Chemist shall carry out tests within each
compartment or space, ensuring compliance with the minimum applicable
requirements prior to issuing a Certificate.
Who, How, Why (and when)?
NFPA 306
Chapter 6
Who determines the conditions:
How are the conditions determined:
Why is this determination done:
(When is this done:
Marine Chemist, personally
by carrying out tests
(and visual inspection)
to compare test results to see if they
comply with minimum NFPA 306
requirements
at the time of the MC inspection)
NFPA 306
Chapter 7
– Atmospheric –
O
2
L
E
L
T
O
X
R
E
S
7.1.1.1 If any of the conditions of 7.1.1(1), (2), (3), or (4) do not exist, then the
designation NOT SAFE FOR WORKERS or ENTER WITH RESTRICTIONS
shall be used
The concentrations of O2 (¶1), LEL (¶2), and toxics (¶3), defined by numerical limits, and
amount of residues remaining (¶4), determined by professional judgments, are “conditions”
NFPA 306
Chapter 7
7.1 General. The standard safety designations in 7.1.1 through 7.1.10 shall be
used where applicable in preparing Certificates.
7.1.1 ATMOSPHERE SAFE FOR WORKERS
(1) Oxygen content: at least 19.5% and not greater than 22%
(2) Flammable materials: less than 10% LEL
(3) Toxic chemicals: within permissible concentrations at the time of inspection
Numerical test results are either within or outside of the acceptable range:(ASFW vs. NSFW)
Is CP test result (20.7%;19.5%, 22% O2) a change in conditions from MC test result (20.8%)?
NFPA 306
Chapter 7
7.1.1 ATMOSPHERE SAFE FOR WORKERS
(3) Toxic chemicals: within permissible concentrations at the time of inspection
Exception: Further testing for toxic materials shall not be required if pervious
testing indicates that these materials have been eliminated or are not capable
of regeneration to hazardous levels while maintained as directed on the Marine
Chemist’s Certificate.
Previous testing by MC (at the time of his/her inspection). Further testing by CP.
If properly maintained on EMCC/MCC (instructions), “not capable” (impossible) of regeneration
NFPA 306
Chapter 7
7.1.1 ATMOSPHERE SAFE FOR WORKERS
(4) The residues or chemicals remaining in a certified space are not capable of
producing toxic materials that exceed permissible concentrations under existing
atmospheric conditions while maintained as directed on the certificate.
Not capable = impossible? Conditions (atmospheric). Maintained (instructions).
(Toxic materials . . .” = “toxic concentrations” do not exceed “permissible limits”)
NFPA 306
Chapter 7
7.1.3 ENTER WITH RESTRICTIONS indicates . . . entry for work shall be
permitted only if conditions of PPE, clothing, time, or any or all of the
aforementioned . . . are as specified. . . (IDLH)
7.1.3.1 The Certificate shall include a statement describing the specific
conditions of PPE, clothing, time, or any or all of the aforementioned. These
areas shall be listed on the Certificate under the heading “Restrictions.”
PPE, clothing, and time are “conditions” which make using this designation appropriate/safe
Could not using these “conditions” violate the Certificate in which they were required?
NFPA 306
Chapter 7
7.1.4 SAFE FOR HOT WORK. Following criteria:
(1) O2, (2) LEL
(3) The residues, scale, or soft and greasy preservative coatings in the entire
space are cleaned sufficiently to prevent the spread of fire and are not capable
of producing a higher concentration than permitted by 7.1.4(1) or (2) under
existing atmospheric conditions in the presence of hot work and while
maintained as directed on the Certificate.
(4) Adj Spc, (5) – (7) treated in accordance with MC’s requirements, instructions
NFPA 306
Chapter 7
7.1.4 SAFE FOR HOT WORK. Criteria:
(6) Passageways, living spaces, store rooms . . . shall be treated i/a/w MC’s
instructions and be free of material that could ignite under conditions of work or
be protected with barriers to prevent the spread of fire.
7.1.6 SAFE FOR LIMITED HOT WORK. Criteria:
(3)(d) Non-cargo, fuel, combustible/flammable liquids, vapors, gases:
Limitations heading with location, type of hot work, and “instructions for the
competent person to maintain safe work conditions.”
Subpart P:
Non-Designated Areas
• Before authorizing hot work in a non-designated
area, the employer must visually inspect the area
where hot work is to be performed, including
adjacent spaces, to ensure the area is free of fire
hazards, unless a Marine Chemist's certificate or
Shipyard Competent Person's log is used for
authorization.
• Maintaining fire hazard-free conditions. The
employer must keep all hot work areas free of new
hazards that may cause or contribute to the spread
of fire.
Subpart P:
• Sparks might pass through an opening
• Fire-resistant guards or curtains are not used
• Unprotected combustible material closer than 35 ft
• Hot work on or near insulation, combustible
coatings, or sandwich-type construction that is not
removed or inerted;
Posting Fire Watches
• Combustible materials on opposite side
• Potential ignition through heat radiation or
conduction on insulated pipes, bulkheads, decks, etc
• Combustible materials and/or coatings
• Unprotected combustible pipe or cable runs
• Marine Chemist or CP requirement
NFPA 306
Chapter 7
7.1.6 SAFE FOR LIMITED HOT WORK. Criteria:
(3)(a) Inerted spaces i/a/w 7.1.8:
7.1.8 INERTED.
(1) <6% O2 or 50% support combustion (found in Annex E) ,
(2) maintained water level to overflow,
(3) maintained >3 feet water level above exterior hot work and <10% LEL
headspace,
(4) valves, etc. positioned and tagged
CO2 flow is required to maintain O2 level below 6% (<½ of 12.5%) for a n-Hexane pipeline
running up a hill. Is disconnecting the CO2 bottle & reconnecting another CO2 bottle a change?
NFPA 306
Chapter 8
8.1 Preparation of Certificates. When the Marine Chemist is satisfied that
the related requirements necessary for the safe conduct of the work have or
have not been met, a Certificate shall be prepared in accordance with this
standard.
If original (MC) determinations of the requirements are no longer met, is the work still safe?
Is met a one-time event? If no longer met, is the Certificate still valid?
NFPA 306
Chapter 8
8.1.3 Any additional requirements or qualifications issued by the Marine
Chemist shall be specified on the Certificate, such as the following:
(1) Frequency and type of such additional tests, inspections, qualifications, and
other instructions as the Marine Chemist specifies
(2) Conditions under which the Marine Chemist shall be consulted or recalled
Specified = requirements, qualifications, instructions
NFPA 306
Chapter 8
8.3.4 Only one requester shall be listed on the Certificate. The requester shall
be responsible for providing a statement of the scope of the work at the time of
the Marine Chemist’s inspection. The requester listed on the Certificate shall be
responsible for maintaining the Certificate in accordance with Section 8.4 and
with 29 CFR 1915.15. If the requester is a host employer in a multi-employer
workplace, then the host employer shall be responsible for maintaining the
Certificate for all contract employers unless the host employer requires contract
employers to obtain and maintain their own Certificate.
Coming Up: NFPA 306 ¶8.4 is the “Granddaddy” of Certificate Maintenance
NFPA 306
Chapter 8
8.4 Maintaining the Responsibility for Conditions. In order for the
Certificate to be maintained, the following conditions shall be met by the
Certificate requester, vessel owner, or their representative:
(6) Certificates not maintained according to the requirements in 8.4(1)
through (5) shall be void.
∑ There are five conditions required to be maintained in order to keep the Certificate valid.
NFPA 306
Chapter 8
8.4
(1)
(2)
(3)
(4)
(5)
Maintaining the Responsibility for Conditions. *
Documented conditions inspected by SCP within 1 day
Conditions maintained by testing and visually inspecting
Reinspected daily, or more often by SCP prior to entry or hot work
Prescribed work is carried out at the original location w/i the facility
SCP instrument calibrations shall be verified (w/ cal or test gas) before each
day’s use and a record maintained (for at least 3 months)
*Any exceptions to (1), (3), or (4) must be noted on the Certificate (i.e. in writing; requirements)
(2) & (3) includes certified spaces, adjacent spaces, pipelines, etc. (all part of original inspection)
2.2 miles long pier
few hundred feet marine railway
Potential & Actual Change in Conditions
“could,” “tending”
Opening
Valves
Vessel
Movement
∆Test
Results
Change
∆ Work
Processes
Not insp/reinsp
Not Calib Inst.
49
1915.11(b) Definitions
• Inert: atmospheric condition
• SFW & SFHW (residues): existing atmospheric conditions
• Inert, Safe for Hot Work, Safe for Workers: oxygen, flammable vapor
concentrations maintained; release of uncontrolled toxics is maintained
• Not Safe for Hot Work, Not Safe for Workers: “ . . . conditions do not meet
the criteria . . .” (not within the acceptable range of O2, LEL, toxics; residues)
50
1915.12 Precautions & Testing (ES/CS)
Oxygen Content: ventilation shall be provided to ensure the oxygen content is
maintained at or above 19.5% and below 22%
Oxygen
Flammable Vapors: ventilation shall be provided to ensure the concentration
of flammable vapors maintained below 10% LEL
LEL
Atmospheres at or above the UEL are maintained
LEL
exception
Toxics
Toxic
exception
51
Toxic, Corrosive, Irritant, or Fumigated Atmospheres or Residues: ventilation shall be
provided to ensure air concentrations are maintained within the PEL or, in the case of
contaminants for which there is no established PEL, below the IDLH.
The warning label may be removed when the concentration
of contaminants is maintained within the PEL or below IDLH
level.
1915.13 Cleaning & Cold Work
Continuous ventilation shall be provided to ensure that the concentration of:
LEL
Flammable Vapors are maintained below 10% LEL
Toxics
Toxic, Corrosive, or Irritant vapors are maintained within the PEL and
below IDLH levels
Testing shall be conducted by the CP as often as necessary
to ensure air concentrations are below 10% LEL, w/i PELs,
and below IDLH levels
52
NAVSEA Standard Items 009-07
• Initial certification of spaces that require a Certified MCC shall be effective
until conditions change which would void the certificate.
• (Entry) CP shall visually inspect, test and record each space certified as
ENTER WITH RESTRICTIONS or SAFE FOR WORKERS as often as
necessary, and as a minimum, prior to entry by employees on a daily basis.
If a space is not to be entered on any given day, it is not required to be
inspected and tested by a Competent Person. The initial MCC remains valid
if conditions have not changed, unless noted on the MCC.
53
• (Hot Work) CP shall visually inspect, test, and record each space certified as
SAFE FOR HOT WORK as often as necessary and, as a minimum, daily
prior to commencement of hot work to ensure that conditions established by
the certificate are maintained. When hot work is continuous, the affected
spaces shall be visually inspected, tested, and recorded on a daily basis to
maintain the SAFE FOR HOT WORK certification.
NAVSEA Standard Items 009-07
• If a CP finds that the conditions within a certified space fail to meet the
applicable requirements for which it was certified, work in the space shall be
stopped and may not be resumed until the space has been recertified by a
Marine Chemist.
54
OSHA 1915 & NAVSEA Standard Item 009-07
Summary of who is required to make the inspection after a change:
Marine Chemist
55
MCC still valid
NC=SAFE
MCC VOID
NOT SAFE
CP to Update
STOP: call MC
MC to cert (new)
Shipyard Competent Person
NC=SAFE
NOT SAFE
CP to Update
STOP: call CP
CP to test/insp
NOT SAFE
STOP: call MC
MC to cert (initial)
OSHA 1915 & NAVSEA Standard Item 009-07
Hot Work Requiring Testing by a Competent Person (e.g. bridge, passageway):
Marine Chemist
MCC still valid
NC=SAFE
MCC VOID
MCC VOID
NOT SAFE
NOT SAFE
Shipyard Competent Person
CP was on another jobsite during initial MC inspection
CP instrument was being repaired during initial MC insp
Maybe a “corporate decision” (want MC insurance)
Maybe want “third-party oversight”
Maybe requester just likes MC (nepotism)
56
CP to Update
STOP: call CP
STOP: call MC
CP another insp MC another cert
OSHA 1915 & NAVSEA Standard Item 009-07
Work & Hot Work Requiring Testing by a Competent Person (e.g. bridge, passageway):
Marine Chemist
Shipyard Competent Person
MCC still valid
NC=SAFE
”SAFER”
Initial MC Certificate of fuel tank (EWR) – ½ face OV respirator
Diesel Fuel: 30 ppm (MC)  2 ppm (CP)
1. original MCC (EWR)
2. new MCC (ASFW)
3. CP (SFW – no respirator) ≠ MC (EWR – resp required)
Initial MC Certificate of passageway (SFLHW) – cutting with a grinder
1. original MMC (SFLHW)
57
CP to Update
2. new MCC (SFHW)
3. CP (SFHW – torch) ≠ MC (SFLHW – grinder)
Survey
• Could = allowed by NFPA 306 and OSHA 1915 (meets minimum requirements)
= not prohibited
-----------------------------------------------------------------------• The survey is not trying to determine whether you like the action.
There may be extenuating circumstances such as:
• Require more than the minimum requirements (clean entire gasoline barge)
• Poor contractor safety record (always on the local news)
• Just won the lottery (do not need $), or need to “pad wallet” (need $ braces)
The survey is not attempting to measure exceptions, extenuating circumstances,
etc.
58
We are all in this together
Thank you!