Quiz 3
Level 1 Challenge
A Competent Person needs to be professionally trained in order to adequately protect workers’ health and lives as well as vessels from fire and explosions. Are there any training differences between what OSHA and the U.S. Navy require and, if so, what are those differences?
Level 2 Challenge
Competent Persons (as well as Marine Chemists and Industrial Hygienists) use many resources to Recognize, Evaluate, and Control different hazards found on various types of vessels. Where on a Safety Data Sheet (SDS) should Competent Persons look for the following information? (Hint: if you are not sure, just Google something like “diesel fuel Safety Data Sheet”)
SDS section where this is found:
- Common everyday name(s) of the toxic material, if any
- Whether it is a liquid and, if so, what does it look like
- Whether it is a gas and, if so, is it heavier than air
- Whether it is flammable, or not
- If flammable, how much so (another hint: flashpoint)
- Whether it has an 8-hr TWA PEL, or TLV, or both
- Type of gloves to protect a worker’s skin from contamination
Level 3 Challenge
Which of the following are unsafe practices of using fire-retardant chemical gels (abbreviated FRG) and solutions?
- Applying FRG 360-degrees around a pipe to prevent heating the inside while brazing only a pinhole leak
- Saturating a fire-resistant blanket and wrapping greasy cables with it to prevent the ignition from incidental contact of a rosebud flame with the grease
- Troweling FRG near a deck weld to prevent heat transfer to the overhead of the backside (opposite side)
- Spraying a bulkhead that is only one-half inch from a sink’s hot water tubing in order to shield the adjacent space from the flame of a soldering torch
- Saturating “fire cloth” and placing it over a few boxes in a storeroom to prevent fire from nearby carbon arcing (gouging)
To check your answers, or have a friendly philosophical discussion, please email RWalker@marinechemist.com
Quiz 2 – Answers
Level 1 Challenge
(easy as inspecting a weather deck, during the spring, for grinding metal in a portable vise)
Yes, or No: Do the requirements of 29 CFR 1915 to use Competent Persons and Marine Chemists for both entry and hot work apply to land-side spaces located in shipyards (such as above-ground storage tanks, crawlspaces, manholes, power plant boilers, tank trucks, etc.)?
Answer: Yes, according to 1915.11(a) Scope and application, “This subpart applies to work in confined and enclosed spaces and other dangerous atmospheres in shipyard employment, including vessels, vessel sections, and on land-side operations regardless of geographic location.” The National Fire Protection Association explains this further in NFPA 306 1.1.6. “This Standard applies to land-side confined spaces, located within the boundaries of a waterfront facility, shipyard, or ship repair facility, and related shipyard employment – regardless of geographic location, whether stationary or mobile – including, but not limited to, the following:
- Underground and aboveground storage tanks
- Other hollow structures such as tank trucks, railroad tank cars, power plant fuel tanks, storage tanks, dip and laundry tanks, vaults, and tunnels
- Other spaces that could contain dangerous atmospheres.”
Level 2 Challenge
(a bit more involved, like inspecting two enclosed spaces in order to weld a stuffing tube through their shared bulkhead)
Is a Competent Person required to test for the same toxic materials that were originally tested and recorded on a Marine Chemist Certificate? If so, can a Competent Person test for even more toxics than what a Marine Chemist originally tested? If the former is not always true, under what condition can an exception be used?
Answer: Yes, according to NFPA 306, one of the responsibilities for maintaining the conditions on a Marine Chemist Certificate (MCC) is found in 8.4 (2): “Throughout the course of repairs or alterations, conditions on the Certificate shall be maintained on the vessel by testing and visually inspecting all certified spaces, including all adjacent spaces, accessory piping, valves, coils, and so on, that were part of the original inspection. In addition, for those CPs involved with inspections on USN vessels, the following wording is found in NSI 009-07 3.1.3.1 “A Competent Person must conduct the same atmospheric testing as required on the MCC” (Marine Chemist Certificate).
Regarding the second part of the question: Yes, a Competent Person is not limited to a maximum number of tests he/she can conduct. This might even be considered going “above and beyond” the call of duty, albeit not required. The only requirement is making sure the minimum number of tests are performed.
Lastly, in answer to the third part of the question, there is an exception in NFPA 306 7.1.1 under the ATMOSPHERE SAFE FOR WORKERS section. Here the Competent Person is referred to the directives (instructions) written on the Marine Chemist to be followed. Maintaining continuous, low-point exhaust ventilation, for example, might be one of those directives; and there could be others that need to be explicitly followed. Note: this exception is being considered for editing/rewording in the next (2024) edition of NFPA 306.
Level 3 Challenge
(extreme, but not as difficult as crawling on hands and knees around a mogas cofferdam, and during a heatwave, in order to allow entry and hot work)
Which of the three regulations define a specific lower temperature that constitutes hot work: OSHA 29 CFR 1915, NFPA 306, USN Technical Manual S6470-AA-SAF-010 (“Safe Ten”). What is that temperature(s) and is it (are they) exactly the same?
Answer: This question was made Level 3 due to needing knowledge of other regulations besides OSHA. Other than that, the question is not difficult. Only two regulations, NFPA 306 and USN “Safe Ten,” have definitions associating heat with Hot Work. In both cases, temperatures of 400oF and above are considered Hot Work. In order for the back (or opposite) side temperature to rise to that kind of temperature via heat conduction, heat from the actual operation will have to be even hotter. Some welding arcs, for example, can exceed 10,000oF. OSHA specifically lists welding, burning, and other activities, as well as similar flame- and spark-producing operations, as being Hot Work; but it does not mention heat at all.
Quiz 1 – Answers
Level 1 Challenge
(easy as inspecting a weather deck, during the spring, for grinding metal in a portable vise)
What Standard Safety Designation(s) allow 22% Oxygen?
Answer: OSHA’s 29 CFR 1915 (Safe for Hot Work) and NFPA 306 (Safe for Hot Work, Safe for Limited Hot Work, and Atmosphere Safe for Workers) stipulate the oxygen content “does not exceed” and is “not greater than” 22% respectively. Hence, 22% oxygen is allowable for these Standard Safety Designations (However, according to Appendix A of Subpart B, “any oxygen level greater than 20.8 percent by volume should alert the competent person to look for the cause of the oxygen-enriched atmosphere and correct it prior to entry” RW: and/or hot work, as applicable). Interestingly, OSHA does not allow 22% oxygen for Safe for Workers. In this one case, the oxygen content must be “below 22%” (i.e. 21.9% to 19.5%).
Level 2 Challenge
(a bit more involved, like inspecting two enclosed spaces in order to weld a stuffing tube through their shared bulkhead)
Is 9% LEL on a Combustible Gas Indicator (CGI) the upper limit allowed for Safe for Workers and Safe for Hot Work?
Answer: Both 29 CFR 1915 and NFPA 306 stipulate the concentration of flammable vapors or materials respectively must be “below” or “less than” 10% LEL. Therefore, 9% LEL < 10% LEL; and, thus, 9% LEL is the allowable upper limit (Again, however, according to Appendix A of Subpart B, “when a space contains or produces measurable flammable vapors below the 10 percent 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” RW: and/or hot work, as applicable).
Level 3 Challenge
(extreme, but not as difficult as crawling on hands and knees around a mogas cofferdam, and during a heatwave, in order to allow entry and hot work)
According to NFFA 701, what happens to the fire-retardancy of poly when it is painted?
Answer: In Appendix D of NFPA 701 is the following statement: “It should be noted that painting or coating a treated or FR fabric or film could impair its flame-resistant qualities unless the coating itself is flame resistant.”