ARC-RB-13-En Fire Safety in Shipyards 1h

8/6/2019 ARC-RB-13-En Fire Safety in Shipyards 1h

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Introduction

The introduction of the International Safety Management

(ISM) Code has resulted in vessels being operated

under a procedural process which examines all areas of

potential risk. For most masters and crew on well-run

and responsibly-managed vessels, daily routines are

regimented by company procedure manuals that give

guidance and instruction in the day-to-day operational

aspects of the ship on which they serve.

The company superintendent and master may feel assured

that such a detailed approach provides a safeguard against

accidents during normal vessel business, but one of therequirements of the ISM Code is to have procedures for

controlling so-called “hot work.” Hot work is dened as

the use of open ames and the application of heat by

means of tools or equipment, including the accidental

application of heat via the use of power tools or hot

particles falling into areas with concentrations of

ammable material or gas.

When a vessel enters a dry dock or proceeds to a lay-by

berth for repair work, however, this feeling of comfort

often is turned on its head. For the master and crew who

are used to a daily routine where risks are known and

Report published byAllianz Risk Consulting

Fire Safety in Shipyardsand Lay-By Berths

RiskBulletin

clearly identied, the intense and often round-the-clock

repair activity will not only affect the vessel’s normal

routine but may also introduce a myriad of perils which the

ship would not normally encounter.

The Oil Companies International Forum (OCIMF)1

document referenced at the end of this bulletin highlightsthis problem of abnormal perils and gives appropriate

advice.

The repair process can generate many hazards to a vessel,

including welding, grinding and burning – all of which

provide an ignition source for res. Unless the vessel is

handed over completely under contract to the repair

organization, the master remains responsible for the vessel

and its crew and must consider additional re hazards that

can imperil the vessel.

The control of hazards such as re within shipyards

and docks is referenced in the Health Safety Executive

(HSE) Docks information sheet No.6 found below2. Thisdocument outlines the need for robust communication

between masters of ships and companies that perform

hot work on board. Communication is made more difcult

when the yard and the ship owner use outside contractors

along with regular staff.

Repair services should be an integral part of a formal,

comprehensive safety plan drawn up between the repair

facility and the ship owner. Such a plan should be overseen

by the master and the shipyard’s safety representative.

Principle and secondary contractors must provide

Method Statements or Safe Systems of Work declarations

in advance of any work commencing, so that specicprecautions such as work permits can be implemented.

Where there is a reason to apply or produce heat during

work activities, a Hot Work Permit should be used to

recognize and diminish the hazard-to-risk ratio. Hot

Work Permits may be seen as a panacea to overcome

difcult circumstances when elevated temperature work

is required in areas of ammable risk but Chapter 9 of

ISGOTT3 points out that:

Number 13Sept 2010

Graham BellSenior Risk ConsultantMarine

Tel: +44.20.3451.3772

[email protected]

www.agcs.allianz.com



exist within the space as a result of residues from previous

contents, or may enter the space via pipelines or other

connections. IMO Resolution A.684 6 lists recommendations

for entering enclosed spaces aboard ships.

In all cases, a safe system for hot work in such a space will

require adequate cleaning and ventilation followed by a

combination of:

• A Gas Free (Safe to Enter) Certicate - Issued by acompetent person. This takes into account previous

tank contents (last 3 cargoes) and checks for sufcient

oxygen content with toxicity levels below the relevant

occupational exposure limits, which are time weighted.

This certicate allows for tank entry and inspection

only, and may require that entry is only authorized with

personal protective equipment or other restrictions.

Followed by:

• A Hot Work Permit - Issued by a competent person.

This analyses the people, processes and procedures

along with the control measures to be maintained such

as the periodic monitoring for hydrocarbon gas, such asbefore start of work each day, before each shift change,

and if the vessel is shifted or moved.

Having considered the efcacy of a Hot Work Permit in

terms of prevailing conditions and possible changes, the

soundness of such a permit, particularly when issued in

conjunction with a ‘Safe to Enter’ certicate is wholly

reliant on the prociency of the person issuing it. Again,

the ISM Code will require that each ship has Conned

Space Entry procedures and it is imperative that the ship’s

crew adhere to these procedures.

In the United States, for a person to be deemed competent

to determine that a space in a vessel is safe for entry or for

hot work, the individual must be a Certied Marine Chemist,

who must conduct inspections & tests and prepare

certicates in accordance with the National Fire Protection

Association (NFPA) 306 7 Standard for Control of Gas

Hazards aboard vessels. This requires a Bachelors Degree

with required courses in Chemistry, followed by a two-year

period of practical training in marine and shipyard safety

with a Certied Marine Chemist and employment with an

analytical laboratory. Candidates must also complete the

NFPA Marine Chemist training course curriculum, and pass

a nal oral examination and certicate writing exercise

given by the Marine Chemist Qualication Board (MCQB).

A Hot Work Permit does not guarantee safety

There are two major limitations to be considered with a

Hot Work Permit system:

• It is a snapshot of conditions at the time.

• Its validity is based on the competence of the issuing

authority.

When the permit is rst drawn up, the conventional

format will consider items such as those highlighted byChapter 23 of the UK MCGA Code of Practice4 where

checks are required for the presence of combustible solids,

liquids or gasses at, below or adjacent to the work area.

Inspections will ensure the use of correct and intrinsically

safe equipment along with the positive conrmation of

isolations and lock-outs to prevent the future introduction

of ammables into the work area.

The signing and issue of the Permit onlyrepresents the state of affairs at thatmoment in time

It subsequently requires a degree of awareness by all workers

undertaking the task to recognise any changes which may

alter the hazard level. This starts with the process for

handling and communicating the gas free certicate. The

certicate contains critical information and instructions

that must be clearly understood and communicated, such

as location or compartment aboard the vessel that is safe

for hot work, the type of hot work permitted and scope of

work, any controls needed (ventilation, re watch, etc.) and

instructions for handling any change in conditions.

Similarly, when a permit overlaps from one shift to another,

there needs to be a positive handover and afrmation of

existing conditions to verify the on going validity of thepermit criteria. Both the repair supervisor and the vessel

Master should be fully aware of the limitations contained

within the certicate and a copy of the certicate or permit

should be posted aboard the vessel, in a conspicuous place.

Hot Work may be required within an enclosed space such

as a cleaned fuel or cargo tank where there is the risk of

ammable or toxic vapors. Safe work in such a conned

space is the subject of an HSE Approved Code of Practice5

which considers the risk of re or explosion arising from

the presence of combustible substances. Gas or fumes may



be required to remain on duty for at least 1 hour after

cessation of hot work, to ensured that a re does not start

due to hot slag landing on combustible materials or a

slow burning or smouldering res starting in common

combustibles or an adjacent space.

Procedural Problems in Shipyards

To illustrate the procedural problems in shipyards, below are

some common causes of res aboard vessels in shipyards.• Insufcient clearing and/or protection of common

combustibles from hot work sparks or slag and/ or

insufcient clearing along bulkheads of adjacent spaces.

• Fire watch not remaining on site after cessation of

hot work, allowing a re to generate from hot slag or

residual heat.

• Insufcient cleaning of coatings and/or residual product

remaining on adjacent bulkheads or decks in way of hot

work.

• Failure to maintain conditions in a space and not

following permit instructions.

• Welders entering and starting hot work in the wrong

compartment or space

• Person issuing the certicate not understanding the

scope of work

• Change in scope of work and repairs beginning without

any inspection or testing.

• Improper inspection and testing by person issuing certicate,

including use of improperly maintained equipment.

• Insufcient cleaning (scraping) of rust scale within a

tank (impregnated with product), which leads to vapour

regeneration, during hot work.

• Failure to lock out and secure a compartment,

allowing the introduction of combustible product from

inadvertent opening of valves or pumping product...

Summary

In ship repair contracts, it is normal for the Master to

retain responsibility for his ship and crew. To maintain

this control, he must integrate the ship’s safety regime

with that of the repair contractors. Information exchange

briengs and the setting up of a central information

control point are invaluable. The Master should ensure that

regular checks on all contractors’ safety performance are

carried out.

When there are observed breaches of health and safety

standards, or concerns about the competence of workers,

the Master has the right at any time to demand that the

work ceases immediately until suitable remedies are found.

For Hot Work and Conned Space Entry, the credentials of

the issuing authority of the relevant certicates and

permits should be challenged if they are not of a

recognised standard. Also, the certicate requirements for

controls and re-inspections must be followed throughout

the course of repairs to maintain the initial safe condition.

Thereafter, Marine Chemists are subject to continuing

education requirements, re-certication every ve years

and random monitoring by the MCQB with any incidents

subject to investigation with possible further training

requirements or disciplinary procedures, up to and

including revocation of their certication.

This sets a high standard for cert ication and control of

individuals that issue hot work permits, which may not be

fully matched by other authorities throughout the world;however, the procedures contained within NFPA 306 is

the standard that is widely practiced and/or referenced by

shipyards worldwide.

In the UK, there are National Occupational Standards (NOS)

published by OPITO 8 for The Testing for Oxygen, Toxic and

Flammable Gases.

This identies three certicate levels for authorized Gas

Testers:

• Level 1 – For conned space entry, oxygen, ammable

and toxic gases up to conned space entry.

Course Time: 12 Hours• Level 2 – Testing of Flammable Gases for Hot Work.

Course Time: 7 hours

• Level 3 – Providing Safety Watch duties.

Course Time: 4 hours.

An OPITO certicate is not awarded as an assessment of

competence.

Where there is a need to have such competence formally

conrmed this can be done at the workplace through a

company’s competence management system against the

NOS.

Some shipyards may employ their own industrial chemistor analyst.

Where external contractors are used to carry out hot work,

particularly if at a lay-by berth and not within a recognized

repair facility, they may choose to have gas testing carried

out by persons with varying industrial qualications.

In addition to the competence and qualication of the

person issuing the gas free and/or safe for hot work

certicates, two other critical areas are the maintenance of

testing equipment and training of the Fire Watch.

Oxygen meters and combustible gas indicators

are sensitive equipment that must be carefullymaintained; otherwise, inaccurate readings may be

made. Maintenance should be as per manufacturer’s

recommendations, which includes schedules for

replacement of sensors and other critical elements. Also,

the equipment should be tested daily or before each

use, and a log of test results should be maintained by the

shipyard. Maintenance records and test logs should be

available for review by the vessel Master.

Hot work permits or certicates normally require a Fire

Watch with a charged re hose or suitable re suppression

equipment. Some shipyards believe that a welder can act

as his own re watch, but this should never be accepted.Also, the re watch should have adequate training and



AGCS Marine Risk Control -Recommendations

1. For whenever ‘hot work’ and ‘conned space entry’ is

being considered by a ships Master, the credentials of

the issuing authority of the relevant certicates and

permits should always be challenged if they are not of a

recognised standard.2. Where the ships Master retains responsibility for his

ship and crew whilst in a shipyard or at a repair berth,

he should ensure he maintains his own re and safety

watch patrols in order to monitor the activities of

the shipyard workers and any of its subcontractors,

especially whenever ‘hot work’ and/or ‘conned space

entry’ is in progress.

List of references

[1] Oil Companies International Forum (OCIMF)

‘Health Safety and Environment at New-Building and

Repair Shipyards and during Factory Acceptance Testing’

Available at: http://www.ocimf.com/Library/Ocimf-

Views-And-Comments

[2] UK Health and Safety Executive, Information Sheet

no.6‘Hot Work in Docks’

Available at: http://www.hse.gov.uk/pubns/dis6.pdf

[3] International Safety Guide for Oil Tankers and

Terminals (ISGOTT)

London: Witherby and Co.

Chapter 9 – ‘Management of Safety and Emergencies’

[4] UK Maritime and Coastguard Agency (MCGA)

‘Code of Safe Working Practices for Merchant Seamen’

Chapter 23 – ‘Hot Work’

[5] UK Health and Safety Executive

‘Conned Spaces Regulations 1997’

Available at: http://www.hse.gov.uk/connedspace/

[6] International Maritime Organisation (IMO)

Resolution A684 (20) ‘Recommendations for

Entering Enclosed Spaces on Ships’

Available at: http://www.ibsnet.gr/pdf/

library/18_864(20)%20-%20

Enclosed%20Space%20Entry.pdf

[7] US National Fire Protection Association (NFPA)

306 – ‘Standard for the Control of Gas Hazards onVessels’

Available for purchase at:

http://www.nfpa.org/aboutthecodes/

AboutTheCodes.asp?DocNum=306

[8] The Oil and Gas Academy (OPITO)

‘National Occupational Standards for the Testing for

Oxygen, Toxic and Flammable Gases’

Available at: http://www.opito.com/international/

library/industry_training_standards/

authorised_gas_tester.pdf

Disclaimer & Copyright

Copyright © 2010 Allianz Global Corporate & Specialty AG. All rights reserved.

The material contained in this publication is designed to provide general information only. Please be aware that information relating to policy coverage, terms and conditions is

provided for guidance purposes only and is not exhaustive and does not form an offer of coverage. Terms and conditions of policies vary between insurers and jurisdictions.

Whilst every effort has been made to ensure that the information provided is accurate, this information is provided without any representation or warranty of any kind about its

accuracy and Allianz Global Corporate & Specialty cannot be held responsible for any mistakes or omissions.

Article produced in association with:

Captain David Smith, CMIOSH, MIMarEST, Blair Marine Ltd

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ARC-RB-13-En Fire Safety in Shipyards 1h

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