Transcript - Marine Chemist Association

2013 REVISION CYCLE
1.1.5.1 When requested, the Marine
Chemist shall apply this standard to
other spaces to ensure and promote
safe working conditions
Adjacent Spaces
Changed Definition
3.3.1 Adjacent Spaces. Those spaces in all directions from subject
space, including all points of contact, corners, diagonals, decks, tank
tops, and bulkheads, and including areas affected by hot work,
where slag, products of combustion, and sparks would be expected
to fall or accumulate. (Current wording)
3.3.1 Adjacent Spaces. Those spaces in all directions from subject
space, including all points of contact, corners, diagonals, decks, tank
tops, and bulkheads. Pipelines are not adjacent spaces and are
considered Not Safe for Hot Work unless noted on the Marine
Chemist Certificate. (ROC 306-3, pg. 2)
(This definition reverts back to a point of contact definition,
addressing areas affected by hot work has been moved to 4.2.2.)
You asked for it – you got it
• Chemists have been asking:
– Why do we have to treat a passageway or pilot house
like an adjacent space to a cargo tank? It’s ridiculous!
– Why do we have to inspect all spaces adjacent to the
i.e. pilot house when the hot work doesn’t affect
them?
• Answer
– Because 306 doesn’t address those types of spaces.
– It was never intended to address “combustible
materials”. The Committee tried to change that
Procedures Prior to Issuance of a
Certificate
Old 306 4.2.2
• The Marine Chemist’s determinations shall include a visual
inspection and tests of the spaces to be certified: and for repairs
involving hot work, all adjacent cargo tanks, spaces adjacent to
cargo tanks and other adjacent spaces containing or having
contained flammable or combustible cargo, fuels, or oils in
accordance with 4.3.4(4) . The determination shall include the
following:
• Note that this entire paragraph addresses spaces that are either
cargo tanks or their adjacent spaces or other spaces that contain or
have contained nasties.
• What about the spaces that don’t contain nasties and are not
adjacent to those spaces? Like the pilot house!
We now have the new 6.2.1/6.2.2
• 6.2.1 The Marine Chemist’s determinations shall include a visual
inspection and tests of the spaces to be certified and for repair or
alterations involving hot work, all adjacent spaces/areas that can be
affected by the hot work shall be treated in accordance with 7.1.4.(4)
and 7.1.4.(5). The inspection shall include spaces or areas where
products of hot work such as sparks, slag or embers can act as
ignition sources.
– 7.1.4(4) spaces adjacent to cargo tanks
– 7.1.4(5) non cargo tank spaces adjacent to cargo tanks
• 6.2.2 In spaces that are not cargo tanks or are not adjacent to cargo
tanks, the Marine Chemist shall carry out tests to determine the
atmospheric or fire hazards that could exist within each affected
compartment or space and any adjacent spaces that could be
affected by hot work, ensuring compliance with the minimum
applicable requirements prior to issuing a certificate.
SFHW Designation
• 7.1.4(6) Spaces such as passageways living
spaces, or store rooms that are not adjacent to
cargo tanks and are undergoing hot work, meet
the requirements of 7.1.4(1) and 7.1.4(2). These
spaces, along with any adjacent spaces shall be
treated in accordance with the Marine Chemist’s
instructions and be free of materials that could
ignite under conditions of work or be protected
with barriers to prevent the spread of fire.
– 7.1.4.1 Oxygen
– 7.1.4.2 LEL
SFLHW Designation
• 7.1.6(d) In compartments or spaces on vessels
that are not considered cargo or fuel tanks and
have not contained and are not subject to
concentrations of combustible, flammable , or
toxic liquids, vapors, or gases the Marine
Chemist shall survey the spaces and adjacent
spaces in accordance with 6.2.1. The certificate
shall include a statement under the heading
“Limitations” that describes the locations and
type of hot work and instructions for the
Competent Person to maintain safe working
conditions.
SCP Instructions
• Possible Instructions:
• 1) SCP to verify that combustibles materials
remain covered, are removed from space prior
to hot work, or the hot work remains shielded in
accordance with Subpart P.
• 2) SCP to verify that combustible materials
remain in a protected/covered (with fire resistant
material) condition.
• 3) SCP to verify that the hot work remains
shielded from any combustible materials.
Scenario
• You have been asked by your customer to certify spaces
on a privately owned berthing barge that is going through
some minor upgrades. A subcontractor will be doing the
upgrades. There is no fuel or cargo on the barge, just
living spaces. The job consists of welding new florescent
lights to the overhead stringers in all the berthing
spaces. Two spaces can be done during the course of
one day. The berthing spaces contain new linen, new
desks and new carpeting. The lighting contractor
consists of two employees who will do all the work and
one of them is a SCP. Your customer also has SCPs on
staff at the shipyard.
Questions
1.
Do you write a certificate for the two spaces that will be done today and
come back tomorrow for the next two spaces and every subsequent day
until the job is complete?
2.
Do you permit the contractor to prepare one space to your liking and tell
him to see that all subsequent spaces must be in the same condition?
Basically leaving the verification that combustible materials are protected
up to the SCP.
3.
Do you specify on your certificates that a SCP must check/verify to
ensure that the combustible materials remain covered/protected?
4.
Do you feel that a small hot work job that will be done in several
compartments, in a “complete one before you start the next”, job fashion
should require the chemist to inspect each compartment after all
precautions in place?
Questions
5.
Do you feel that a SCP can adequately and safely prescribe or verify that the
protection of combustible materials has been performed?
6.
Do you feel this is the only place in 306 where a chemist can prescribe
precautions to the SCP without actually seeing them carried out?
7.
Is there a better way to handle situations that involve hot work in spaces that are
not within the scope of 306. (not cargo or fuel tanks, not adjacent spaces to cargo
or fuel tanks)
8.
If these spaces were adjacent to a fuel tank would you handle it differently?
9.
What if there were only two berthing spaces to be worked – would you handle it
differently?
10.
Do you feel that we have always been able to prescribe instructions to SCPs
without actually seeing them done?