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. Merriam. Webster’s Collegiate Dictionary, 11 th 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 O 2, LEL, toxics, residues ¶ 7. 1. 3 (EWR) Conditions of PPE, clothing, time Implied/Indirect Conditions: Maintain Conditions O 2, 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 O 2 (¶ 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% O 2) 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) O 2, (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% O 2 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 CO 2 flow is required to maintain O 2 level below 6% (<½ of 12. 5%) for a n-Hexane pipeline running up a hill. Is disconnecting the CO 2 bottle & reconnecting another CO 2 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. 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 O 2, 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 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 MCC still valid NC=SAFE 55 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 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
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