SURVEY RESULTSA QUESTIONER WAS PASSED OUT AT THE 2012 MINI SEMINARS. THE RESULTS WERE TABULATED AND ARE

PROVIDED WITH THE INTENT OF REVIEWING HOW CHEMISTS TREAT SPACES WHEN USING SAFE FOR HOT

WORK AND SAFE FOR LIMITED HOT WORK

OBJECTIVE

To develop an understanding on the treatment of adjacent spaces when using Safe for Hot

Work and Safe for Limited Hot Work

What does a space certified as

“Safe for Hot Work” Mean to

You? Does it Mean

Something Else to a Welder?

In the first situation all you are told is that the

spaceis

Safe for Hot Work There are no restrictions or limitations listed.

The response requested is:What is the minimum requirement in 306.

306 MINIMIUM REQUIREMENTS

Question 1. 1C is certified, Atmosphere Safe for Workers, Safe for Hot Work.

What is (are) the hot work spaces? Product = FP 97°F

Space Number of Responses

FORWARD RAKE 10

1P 19

1C 50

1S 8

SSV/DB-1 8

2P 8

2C 8

2S 8

SSV/DB-2 8

3P 1

3C 1

3S 1

SSV/DB-3 1

AFT RAKE 1

Fwd Rake, 1C,P,S - 2C,P,S Double Bottom Voids 1,2 } ASFW/SFHW

Adjacent spaces 3C,P,S Double Bottom Void 3, written below the test result section with test instrument readings.

1C } ASFW/SFHW Adjacent spaces, Fwd

Rake, 1C,P,S - 2C,P,S Double Bottom Voids 1,2. written below the test result section with test instrument readings.

This would not allow access into the adjacent spaces, and would not permit hot work on bulkheads

Void 3 Void 2 Void 13P 2P 1P3C 2C 1C3S 2S 1S

Void 3 Void 2 Void 1

ASFW SFHWASFW NSFHW

Void 3 Void 2 Void 13P 2P 1P3C 2C 1C3S 2S 1S

Void 3 Void 2 Void 1

Aft Rake Fwd Rake

Aft Rake Fwd Rake

Question 1b. Question 1b. What are the adjacent What are the adjacent

spaces? spaces? Space Number of

ResponsesFORWARD RAKE 44

1P 23

1C 4

1S 49

SSV/DB-1 45

2P 49

2C 49

2S 48

SSV/DB-2 46

3P 2

3C 2

3S 2

SSV/DB-3 0

AFT RAKE 0

Response Number of Responses

Fully clean all adjacent spaces

31

Partially clean some adjacent spaces

9

Partially clean all adjacent spaces to prevent the spread

of fire

20

Inert all adjacent spaces

15

Secure 4

Other Test spaces only (1)

4.3.4.(4)*All spaces adjacent to cargo tanks certified "SAFE FOR HOT WORK" have been cleaned sufficiently of residues, scale, or preservative coatings to prevent the spread of fire, or are inerted.

Area Number of Responses

Under the SSD 14

In with the SSD’s 3

In body following SSD’s 16

At the bottom in a separate section

16

In with the safety instructions

1

Certificate of Style

Method Number of ResponsesSecure piping to 1C and tag out with no

hot work on piping 3Secure and tag out all piping with no hot

work on piping 13Clean and blown down and test to make

all piping SFHW 10Clean and blow down and test piping to

1C only to make SFHW 9Isolate piping from hot work in 1C with

partitions 5Drain and secure piping to 1C and tag

out with no hot work on piping 11Drain, secure and tag out all piping with

no hot work on piping 6

This will change with the next edition of 306

Response Number of ResponsesNo 46Yes 4

One person noted that this was an improper use of the SFHW designation and SFLHW should have been used.

Best response: Since you use the Safe for Hot Work designation and it is a tank vessel then 306 states: 4.3.4.(4)*All spaces adjacent to cargo tanks certified "SAFE FOR HOT WORK" have been cleaned sufficiently of residues, scale, or preservative coatings to prevent the spread of fire, or are inerted.

So, the treatment of adjacent spaces should not have changed.

Response Number of Responses

No 16Yes 25

Maybe 1

Best Response: Since you use the Safe for Hot Work designation and it is a tank vessel then 306 states: 4.3.4.(4)*All spaces adjacent to cargo tanks certified "SAFE FOR HOT WORK" have been cleaned sufficiently of residues, scale, or preservative coatings to prevent the spread of fire, or are inerted.So, cleaning should not have changed and no is the correct response. It should be noted that 7 chemists did not respond to this question.

Question 2 1C is certified as Atmosphere Safe for Workers and Safe for

Limited Hot Work, and the hot work is limited to burning and welding to cut out and install an insert on the bulkhead between

1P and 1C and all hot work will stay 3 feet away from 2P and 2C.( See right hand note on diagram.)

Question 2aWhat is the hot work space(s)?

Space Number of ResponsesFORWARD RAKE 3

1P 491C 501S 4

SSV/DB-1 32P 32C 32S 3

SSV/DB-2 33P 03C 03S 0

SSV/DB-3 0AFT RAKE 0

Best Response: The majority of chemists indicated the correct response, 1C and 1P. This could indicate that the concept of Safe for Limited Hot Work is better understood than Safe for Hot Work and Safe for Hot Work with Restrictions.

Question 2bWhat are the adjacent space(s)?

Space Number of ResponsesFORWARD RAKE 45

1P 81C 41S 45

SSV/DB-1 462P 462C 462S 46

SSV/DB-2 463P 13C 13S 1

SSV/DB-3 1AFT RAKE 1

Best Response: If 1C is certified for SFLHW and the hot work is on the bulkhead with 1P then theyare both hot work spaces and the adjacent spaces become:

Forward Rake1S

SSV/DB 1 and 22C,S,P

Question 2cHow do you treat the adjacent spaces?

Response Number of ResponsesFully clean all adjacent spaces 21

Partially clean some adjacent spaces 6Partially clean all adjacent spaces to prevent the

spared of fire20

Inert all adjacent spaces 4Secure 0Other 0

Best Response: Following the reasoning below, the correct response is to clean all adjacent spaces to prevent the spread of fire or inert. 4.3.6 SAFE FOR LIMlTED HOT WORK indicates that all of the following criteria shall be met at the time the Certificate is issued:(1) Any compartment or space so designated meets the requirements of 4.3.4(1) and 4.3.4(2) (unless inerted in accordance with 4.3.8). (2) The Certificate shall include a statement describing the specific location and type of the hot work. The Marine Chemist shall also be permitted to list any areas to be excluded from hot work. These areas shall be listed on the Certificate under the heading "limitations." (3) The space meets one of the following conditions: (a) The space or compartment is inerted in accordance with 4.3.8, adjacent spaces shall be treated in accordance with 4.3.4( 4), and the hot work shall be limited to the specific location or locations described in the "limitations" in 4.3.6(2). (b) The space or compartment meets the requirements of 4.3.4 (1), (2), (3), and (4); the hot work shall not be allowed on adjacent spaces or pipelines, or both as applicable; and the hot work limitations shall be described in the "limitations" in 4.3.6(2). (c) Portions of the space or compartment meet the requirements of 4.3.4(3) and (4), as well as the applicable portions of 5.1.3, and the hot work shall be limited to the location or locations described in the "limitations" in 4.3.6(2).4.3.4.(4)*All spaces adjacent to cargo tanks certified "SAFE FOR HOT WORK" have been cleaned sufficiently of residues, scale, or preservative coatings to prevent the spread of fire, or are inerted. (States SFHW, not SFLHW)

Question 2dHow do you treat the pipelines?

Method Number of ResponsesSecure piping to 1C and tag out with no hot work on

piping 6Secure and tag out all piping with no hot work on

piping 4Clean and blown down and test to make all piping

SFHW 7Clean and blow down and test piping to 1C only to

make SFHW 13

Isolate piping from hot work in 1C with partitions 8Drain and secure piping to 1C and tag out with no hot

work on piping 11Drain and secure and tag out all piping with no hot

work on piping 5

Best Response: Section 5.1.3 describes cleaning for limited hot work, however this section provides no instructions on how to treat pipelines. Since you may assume that the hot work spaces were fully cleaned then section 5.1 will be invoked. 5.1 Where a Safe Condition Is to Be Obtained Entirely by Cleaning. [See Figure B.I, part (b).] 5.1.1 All cargo pumps, cargo lines, inert gas lines, crude oil wash lines, piped cargo fire-extinguishing lines, vapor control and recovery lines, and vent lines shall have been flushed with water, blown with steam or air, or inerted.It could be possible to confuse this requirement with section 4.2.2(5) which states: 4.2.2(5) Verification that pipelines that could release hazardous materials into spaces that will be certified ATMOSPHERE SAFEFOR WORKERS or SAFE FOR 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, operation

QUESTIONS?

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