CERTIFICATE CRITIQUE EXERCISEMARINE CHEMIST ASSOCIATION

SECTIONAL SEMINARS 2015Norfolk, VA. 3/7/15

New Orleans, LA. 3/28/15Seattle, WA. 3/29/15

Review of MCQB Certificate Issues Certifying spaces SFHW or SFLHW in which “lines, vents, heating

coils, valves, and similar enclosed appurtenances” are located, and allowed hot work to such appurtenances in the narrative only. That is, permission was given in paragraph form to conduct hot work on appurtenances when the “QUALIFICATIONS” section of the Certificate explicitly states these areas “shall be considered ‘not safe’ unless otherwise specifically designated.” In each example below, neither SFHW or SFLHW was used for the

narratively described appurtenances, nor was any test results recorded for the appurtenances. Thus, it appears the appurtenances were never considered and/or tested.

“chilling line” “existing split rails” “rolling chock” “chill water piping” “hot work inspection to accomplish pipe work in ballast tanks” but

pipes were not tested, designated SFHW

Review of MCQB Certificate Issues Certifying inaccessible voids, pipelines,

etc. as ASFW, in addition to SFHW (which is correct)“Stbd cooler void”“NH3 pipelines”“keel”“water pipe”“P/S exhausts”“skeg”

REVIEW OF MCQB CERTIFICATE ISSUES

• Improper Standard Safety Designation. These were designations, not narratives.

• “Atmospheres Safe For Workers”• “SFHW”• “Space Not Safe For Hot Work”

PID <5ppm” vs Diesel, JP-5 (actual toxic) <5ppm; also, if benzene for example, PEL could be exceeded

Review of MCQB Certificate Issues

• Using Safe For Limited Hot Work and giving limitations, but no “limitations” heading– Sometimes this is even accompanied by no type or

location of hot work– Writing “repair” as the limitation

Review of MCQB Certificate Issues Using Inerted, but no maintenance or

safe disposal of inert gas. Not using Inerted (but did use SFHW)

when asphalt was covered with water (3’ water blanket)

Mentioning liquids, etc. in narrative, but not in

last three loadings: “Pot Water” “Diesel Fuel” “Ballast Water” (two examples) “mud” “fuel” and “fuel oil” “black water (sewage)” “lube oil”

Review of MCQB Certificate Issues

Hot work on deck of tanker, but no mention of

maintaining cargo tanks closed After authorizing local shifting of vessel, no

instructions of subsequent “nature of tests” No designation of weather deck, even though

narrative allows hot work there

Review of MCQB Certificate Issues

Review of MCQB Certificate Issues• Confusing/Incorrect narratives:

• Certifying space NSFHW, yet writing“(SCP) shall re test and inspect all areas prior to entry and hot work”

• In narrative, space is identified as an adjacent space, but “repair crack in weld on angle bracket” is also written right beside the same. The space was not certified SFHW.

• “SCP to re-inspect daily” literally could mean “after” entry and hot work on the next day, not “before”

• “SCP to re-inspect daily in accordance with OSHA” is not correct (306 and USN – yes; OSHA – “as often as necessary”)

• Using 35 foot rule for flammables, instead of combustibles

Certifying a space EWR, yet not writing about any PPE, clothing, and/or time

Writing LOD for O2 and LEL Detector Limit for a specific PID and

correction factor will not get below PEL, but certified ASFW

Generally mentioning “FO” or “Fuel Oil” but not specifying which type. Since ASFW was used and the “VOC > 15 ppm,” this might not have been correct. Kerosene (No. 1) = 30 ppm, Diesel Fuel (No. 2) = 15 ppm

Not testing for toxics No JP-5 test, yet “JP-5 as fuel for No. 1 ETGT”

and “No. 1 ETGT SHALL remain covered with fireproof cloth” – not air tight

No H2S test, yet CHT tank Petroleum cargo ppm and associated LEL

do not equal 311 ppm and 100% LEL 830 ppm and 0% LEL (Example: 5% LEL of Diesel should equal

about 300ppm)(0.6 LEL)

Missing information◦ Vessel location◦ Using SFHW, yet inerted designation not used.

Narrative mentioned and test indicated space was inerted.

◦ MC signature◦ Vessel owner/agent