NFPA 306STANDARD FOR THE CONTROL OF GAS HAZARDS ON VESSELS 2013 REVISION CYCLE
Scope 126.96.36.199 When requested, the Marine Chemist shall apply this standard to other spaces to ensure and promote safe working conditions
Adjacent Spaces Changed Definition 3.3.1 Adjacent Spaces. Those spaces in all directions from subject space, including all points of contact, corners, diagonals, decks, tank tops, and bulkheads, and including areas affected by hot work, where slag, products of combustion, and sparks would be expected to fall or accumulate. (Current wording) 3.3.1Adjacent Spaces. Those spaces in all directions from subject space, including all points of contact, corners, diagonals, decks, tank tops, and bulkheads. Pipelines are not adjacent spaces and are considered Not Safe for Hot Work unless noted on the Marine Chemist Certificate. (ROC 306-3, pg. 2) (This definition reverts back to a point of contact definition, addressing areas affected by hot work has been moved to 4.2.2.)
You asked for it – you got it • Chemists have been asking: • Why do we have to treat a passageway or pilot house like an adjacent space to a cargo tank? It’s ridiculous! • Why do we have to inspect all spaces adjacent to the i.e. pilot house when the hot work doesn’t affect them? • Answer • Because 306 doesn’t address those types of spaces. • It was never intended to address “combustible materials”. The Committee tried to change that
Procedures Prior to Issuance of a Certificate Old 306 4.2.2 • The Marine Chemist’s determinations shall include a visual inspection and tests of the spaces to be certified: and for repairs involving hot work, all adjacent cargo tanks, spaces adjacent to cargo tanks and other adjacent spaces containing or having contained flammable or combustible cargo, fuels, or oils in accordance with 4.3.4(4) . The determination shall include the following: • Note that this entire paragraph addresses spaces that are either cargo tanks or their adjacent spaces or other spaces that contain or have contained nasties. • What about the spaces that don’t contain nasties and are not adjacent to those spaces? Like the pilot house!
We now have the new 6.2.1/6.2.2 • 6.2.1 The Marine Chemist’s determinations shall include a visual inspection and tests of the spaces to be certified and for repair or alterations involving hot work, all adjacent spaces/areas that can be affected by the hot work shall be treated in accordance with 7.1.4.(4) and 7.1.4.(5). The inspection shall include spaces or areas where products of hot work such as sparks, slag or embers can act as ignition sources. • 7.1.4(4) spaces adjacent to cargo tanks • 7.1.4(5) non cargo tank spaces adjacent to cargo tanks • 6.2.2 In spaces that are not cargo tanks or are not adjacent to cargo tanks, the Marine Chemist shall carry out tests to determine the atmospheric or fire hazards that could exist within each affected compartment or space and any adjacent spaces that could be affected by hot work, ensuring compliance with the minimum applicable requirements prior to issuing a certificate.
SFHW Designation • 7.1.4(6) Spaces such as passageways living spaces, or store rooms that are not adjacent to cargo tanks and are undergoing hot work, meet the requirements of 7.1.4(1) and 7.1.4(2). These spaces, along with any adjacent spaces shall be treated in accordance with the Marine Chemist’s instructions and be free of materials that could ignite under conditions of work or be protected with barriers to prevent the spread of fire. • 188.8.131.52 Oxygen • 184.108.40.206 LEL
SFLHW Designation • 7.1.6(d) In compartments or spaces on vessels that are not considered cargo or fuel tanks and have not contained and are not subject to concentrations of combustible, flammable , or toxic liquids, vapors, or gases the Marine Chemist shall survey the spaces and adjacent spaces in accordance with 6.2.1. The certificate shall include a statement under the heading “Limitations” that describes the locations and type of hot work and instructions for the Competent Person to maintain safe working conditions.
SCP Instructions • Possible Instructions: • 1) SCP to verify that combustibles materials remain covered, are removed from space prior to hot work, or the hot work remains shielded in accordance with Subpart P. • 2) SCP to verify that combustible materials remain in a protected/covered (with fire resistant material) condition. • 3) SCP to verify that the hot work remains shielded from any combustible materials.
Scenario • You have been asked by your customer to certify spaces on a privately owned berthing barge that is going through some minor upgrades. A subcontractor will be doing the upgrades. There is no fuel or cargo on the barge, just living spaces. The job consists of welding new florescent lights to the overhead stringers in all the berthing spaces. Two spaces can be done during the course of one day. The berthing spaces contain new linen, new desks and new carpeting. The lighting contractor consists of two employees who will do all the work and one of them is a SCP. Your customer also has SCPs on staff at the shipyard.
Questions • Do you write a certificate for the two spaces that will be done today and come back tomorrow for the next two spaces and every subsequent day until the job is complete? • Do you permit the contractor to prepare one space to your liking and tell him to see that all subsequent spaces must be in the same condition? Basically leaving the verification that combustible materials are protected up to the SCP. • Do you specify on your certificates that a SCP must check/verify to ensure that the combustible materials remain covered/protected? • Do you feel that a small hot work job that will be done in several compartments, in a “complete one before you start the next”, job fashion should require the chemist to inspect each compartment after all precautions in place?
Questions 5. Do you feel that a SCP can adequately and safely prescribe or verify that the protection of combustible materials has been performed? 6. Do you feel this is the only place in 306 where a chemist can prescribe precautions to the SCP without actually seeing them carried out? 7. Is there a better way to handle situations that involve hot work in spaces that are not within the scope of 306. (not cargo or fuel tanks, not adjacent spaces to cargo or fuel tanks) 8. If these spaces were adjacent to a fuel tank would you handle it differently? 9. What if there were only two berthing spaces to be worked – would you handle it differently? 10. Do you feel that we have always been able to prescribe instructions to SCPs without actually seeing them done?