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Proceedings is published bimonthly by the Coast Guard's Office of Marine Safety, Security and Environmental Protection, in the interest of safety at sea under the auspices of the Marine Safety Council. Special permission for republication, either in whole or in part, with the exception of copyrighted articles or artwork, is not required provided credit is given to this magazine. The views expressed are those of the authors and do not represent official Coast Guard policy. All inquires and requests for subscriptions should be addressed to Editor, Proceedings Magazine, U.S. Coast Guard (G-MP-4), 2100 Second Street, SW, Washington, DC 20593-0001; (202) 267-1408. Please include mailing label when sending a change of address. The Office of the Secretary of Transportation has determined that the publication of this periodical is necessary in the transaction of the public business required by law of this agency.

Admiral J. William Kime, USCG Commandant

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THE UWVERSITY OF MICHIGAN

30 1992

ENGINEERING LIBRARY

Marine chemists provide safer workplace

By CDR Kevin J. Eldridge and LT John C. Edgar

Who is the marine chemist?

A marine chemist is the primary professional responsible for maintaining a safe environment for "hot work" and the entry into confined spaces on vessels and vessel sections in shipyards, which had contained toxic materials. The Occupational Safety and Health Administration (OSHA) has issued regulations requiring the inspection by marine chemists certified by the National Fire Protection Association (NFPA) prior to many shipyard activities. By protecting people from shipyard hazards, the chemists are the cornerstone of the Coast Guard's confined space entry program.

How are they used?

The services of marine chemists are required by government regulations and, in some cases, by Coast Guard policy as follows:

1) It is mandatory that a marine chemist test and certify a space safe for hot work and safe for workers in shipyards under Title 29 of the Code of Federal Regulations 1915.14 (29 CFR 1915.14), when either of these two conditions are met: a) When hot work (any construction, alteration, repair or shipbreaking involving riveting, welding, burning or similar fire-producing operations) is to be performed in a space. Grinding, drilling, sand or shot blasting, or similar spark-producing operations are also considered hot work under most circumstances. Many shipyard operations fall under the definition of hot work, and must be certified by a marine chemist before commencing. Continued on page 2

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MIT Stolt Aspiration, 12,009 dwt medium-size parcel tanker, carries a variety of bulk liquids, including chemicals. Marine chemists must keep its spaces safe for shipyard "hot work" and inspections. Photo courtesy of Stolt-Nielsen, Inc.

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b) When the space to be entered by workers had contained toxic materials and could have a toxic atmosphere. This would include most cargo or fuel tanks on board vessels in shipyards, and any preservative coated spaces which had been closed and secured without ventilation.

2) Before non-emergency entry into cargo space that had been fumigated, a marine chemist or qualified person under 46 CFR 147A.25 must test the space.

3) Before hot work is performed on Coast Guard-certified vessels in waterfront facilities in the United States or its territories or possessions, the operator must have the vessel inspected by a NFPAcertified marine chemist. (Sources of this requirement are in 46 CFR 35.01-1, 76.11, 91.50-1, 109.573 and 169.236.) The inspection must be completed and a certificate issued before any alterations, repairs or other such operations involving riveting, welding, burning or similar fire-producing actions.

4) Coast Guard policy requires a marine chemist to evaluate work to be conducted at waterfront facilities approved for the handling and storage of flammable or combustible liquids in bulk. The chemist must issue a certificate authorizing hot work before a hot work permit is issued under 33 CFR 126.

There are many other situations when the use of a marine chemist is not mandatory, but, nevertheless, desirable. For example, the Coast Guard has approved testing by a marine chemist prior to entry into pumprooms on tank vessels, as a way of complying with OSHA's benzene exposure limits for Coast Guard personnel. Also, a marine chemist could be used during response operations involving confined spaces.

History

A large increase in explosions on vessels under repair during World War I provided the impetus for establishing a national certification program for hot work. This increase was attributed to changes in construction and repair methods, combined with the shipment of more flammable materials, such as fuels. Insurance underwriters, shipyard operators, vessel owners and government officials agreed that an effective method of reducing the number of explosions and fires should be developed.

The NFPA formed a marine committee in 1916 to draft an initial standard for shipyard fire safety. Appendix A of NFPA Marine Regulations was published by the committee in 1922. It was the predecessor of the present NFPA 306, "Control of gas hazards on vessels."

Also in 1922, the American Bureau of Shipping (ABS) certified the first 25 marine chemists. This initial certification was relatively informal compared to today's process, and the early chemists used Appendix A as their guidelines to issue certificates for hot work.

This system of shipyard fire safety continued until the early 1960s, when the Department of Labor and the Coast Guard expressed concern over the lack of a formal standard for certifying and monitoring marine chemists. In April 1963, the Marine Chemist Qualification Board was established by NFPA to certify and recertify marine chemists according to clearly defined parameters.

In 1970, OSHA was established by the Occupational Safety and Health Act to set and administer worker health and safety standards. Their jurisdiction included shipyard workers.

By the end of 1971, OSHA declared many industry voluntary standards mandatory, including the certification by marine chemists of spaces before hot work can be performed. This requirement, in essence, made the NFPA 306 standard mandatory for shipyards. Amendments to this standard are now being finalized and are scheduled to be published early in 1993. Following a 1975 explosion, which claimed four lives, aboard the barge B-924 in Greenville, Mississippi, the Coast Guard joined the Marine Chemist Qualification Board, actively participating in certification procedures.

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Voluntary membership includes representatives from the Coast Guard, Navy and OSHA.

During the past ten years, the board has had an active role in addressing and preventing occupational exposures to hazardous chemicals, and reducing potential hazardous conditions on board vessels and vessel sections in shipyards. Here are some of the board's accomplishments.

A) The board found the certificate issued by a marine chemist in compliance with NFPA 306 following a barge explosion in a Louisiana shipyard in 1989. (See "Casualty lessons" in the JanuaryFebruary 1991 issue of Proceedings.) However, it determined that there was extra "boiler plate" language on the certificate, which might have been misunderstood by shipyard workers. In order to determine whether the use of such language was a common practice among marine chemists, the board required that all certificates issued during the month of August 1990 be forwarded for review. Consequently, direct feedback was provided for all marine chemists on how to avoid language, which, though in compliance with NFPA 306, might confuse shipyard personnel.

A complete review of all marine chemist certificates has been conducted twice during the past five years, and observations from the reviews have been discussed at the annual Marine Chemist Association training workshop. The board feels that, as a result, marine chemist certificates have become clearer and more concise.

B) A Coast Guard marine inspector in Louisiana requested the board clarify what is meant by "local shifting" or vessel movement permitted by NFPA 306. The board forwarded the request along with its recommendations to the NFPA Technical Committee on Gas Hazards, which develops all revisions to the NFPA 306 standard. Subsequently, this committee clarified the term, which will be published in the new edition of NFPA in 1993.

C) In 1989, Coast Guard marine inspectors in Louisiana lodged two complaints on methods used by a marine chemist in testing confined spaces on board offshore drilling rigs in the Gulf of Mexico. One complaint concerned improper testing of the oxygen content, and the other involved testing for hydrogen sulfide in spud cans (confined spaces normally under water which provide the basis of stability for certain offshore drilling rigs). After a thorough study of the complaints, the board required the marine chemist to review several modules of the Marine Chemist Training Curriculum and be examined on each one. It was believed that this technical refresher could avoid possible injuries in the future. The chemist successfully completed the review and subsequent examinations.

D) Two other incidents of alleged nonper

formance by a marine chemist were filed
with the board during 1991. A Coast
Guard marine inspector on the East
Coast lodged the first complaint, which
alleged that the chemist did not enter the
cargo tanks he certified as safe for hot
work. The same marine chemist was the
subject of the second complaint by a
Navy safety supervisor alleging that a
certificate was issued allowing hot work
in a Navy vessel's engine room with
diesel fuel in the bilges directly below.
The board conducted formal hear-
ings on the complaints and subsequently
suspended the marine chemist's certifi-
cation for six months. In addition, the
board required the individual to satis-
factorily complete two weeks of on-the-
job-training with marine chemists out-
side his geographical location as a con-
dition for recertification.

E) During 1991, the board denied recertification to one marine chemist based on his failure to attend the required number of training courses for continuing education. The board considers this to be a critical condition for maintaining certification.

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