SCP’s Instructions

The 2001 edition for the first time defined the well-established relationship between the Marine Chemist and the Shipyard Competent Person and the frequency of retesting confined spaces.

3.3.6 Competent Person. A person who is designated in writing by their employer in accordance with 29 CFR 1915.7.

4.1 Determining ConditionsThe Marine Chemist shall carry out tests in each space ensuring compliance with the minimum applicable requirements.

Maine Chemist -Ensures4.5 Issuance of Certificates.

.... a signature for receipt of the Certificate shall be obtained, signifying understanding of the conditions and limitations and the requirements for maintaining conditions under which it is issued.

SCP - Maintains

OSHA 1915.15Maintenance of Safe Conditions

a. Isolation of pipingb. Alteration of conditionsc. Test to maintain conditionsd. Change of conditions (marine chemist)e. Tests to maintain findingsf. Change of conditions (SCP)

~ Synopsis of SCP Duties ~

4.6.2 Maintaining the Certificate

1. Conditions shall be inspected by the SCP within 1 day.

2. Conditions shall be maintained .

3. Spaces shall be inspected daily or more often.

4. Certificates not maintained are voided.

5. Shifting must be authorized with re-inspection by SCP and nature of tests included on certificate.

6. Calibration of instruments used to maintain certificate shall be verified each day.

~ Synopsis ~

NFPA-306

4.6.2 Maintaining the Certificate2009 NFPA-306:4.6.2(3)*Unless otherwise stated on the Certificate, all spaces including adjacent spaces documented on the Marine Chemist Certificate shall be reinspected daily, or more often as necessary, by the shipyard competent person in support of work prior to entry or recommencement of work.

2014 NFPA-3064.6.2(3)* Unless otherwise stated on the Certificate, certified spaces including spaces adjacent to hot work, where work is being done shall be re-inspected daily, or more often as necessary, by the shipyard competent person, prior to entry or external hot work.

Annex to 4.6.2(3) Spaces shall be inspected daily ...

The intent of this wording is to clarify that spaces listed on the Marine Chemist Certificate do not need to be tested by the competent person unless work is being done on or in a space. For example, spaces on a certificate do not need to be tested and inspected on a weekend if no work or entry is taking place. However, nothing shall prevent a competent person from testing more frequently than the minimum...

2014 NFPA-306

“Unless otherwise stated on the Certificate, all spaces and affected adjacent spaces are to be re-inspected daily or more often as necessary by the competent person … in support of work prior to entry or recommencement of work.”

“In support of work” is the spin.

Small Print

NAVSEA 009-35 FY-13 CH-2

3.1.3.2 For those certified spaces which employees will enter, a Competent Person 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.

3.1.3.3 For those certified spaces affected by hot work, a Competent Person 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.

USCG Safety & Environmental Health Manual CH-118. Vessels Afloat Entry/Repair

C (3) If the Competent Person has not properly maintained the Marine Chemist Certificate, the Marine Chemist is

required to reissue the certificate prior to reentry into the confined space.

NFPA rules require a Competent Person to reexamine the confined space at least every 24 hours or if conditions

under which the certificate was issued under change.

(d) In compartments/spaces on vessels, that are not considered cargo or fuel spaces and have not contained and are not subject to concentrations of combustible, flammable or toxic liquids, vapors, or gases.... The Certificate shall include a statement under the heading "Limitations" describing the locations and type of Hot Work along with any directions for the Competent Person to maintain safe work conditions.

Safe for Limited Hot Work:

Submitted: Alan Bonds, A. Bonds Chemist, LLC - Recommendation: Revise text to read :

The term “maintain” is consistent with the requirement in Section 4.5 of the Standard and with the requirement for the competent person to maintain safe conditions in 29 CFR 1915.15, Maintenance of Safe Conditions.

2014 NFPA -306

ObjectiveFit these SCP requirements on a certificate.

What is the proper language ?

SFLHW4.3.6.3The Certificate shall include a statement under the heading "Limitations" describing the locations and type of Hot Work along with any directions for the Competent Person to maintain safe work conditions. The Certificate shall include a statement describing limitations

1. Specific location2. Type of hot work. 3. Permitted to list any areas to be excluded from hot work.4. These areas shall be listed on the Certificate under “Limitations.”

~ and ~ No work will take place on the weekends

Provide these directions on a certificate for limited hot work

Insert proper limitations and instructions for this normally occupied space on certificate.