SAFETY ISSUES

1
SAFETY ISSUES

• Confined Space many versions
• Lockout/Tagout three versions

2
Confined Space Programs

• Shore (29 CFR 1910.146)
• Vessel (NSTM 074, vol 3)
• Shipyard (29 CFR 1915)
• Aircraft (maintenance procedures)
• MSO (CG competent person)

3
Shore Scope

• All shore-side entries except
• Shipyard
• Shipyard employment
• Coast Guard aircraft
• MSO (maybe)

4
Permit Required SpacesMajor Program Elements

• Appoint manager
• ID, evaluate, and post spaces
• Document basis for characterizations
• Develop procedures
• OSHA defines some of these
• Implement program
• Audit certificates

5
Permit Required Confined Space Choices

• Contract all entries
• Full program
• Bring spaces up to alternate procedures
  standards
• Hazard controlled by ventilation alone
• Continuous ventilation, periodic monitoring
• No other significant safety hazard

6
Permit Required Confined Space Choices (/-)

• Full program (s)
• Ability to address changing environment
• Greater skills of workforce
• Good entry documentation (certificates)
• Full program (-s)
• Money
• Time
• Turnover

7
Permit Required Confined Space Choices (/-)

• Alternate procedures (s)
• Correct minor issues
• Reduced personnel commitment
• Does not require team
• Does not require rescue drills
• Alternate procedures (-s)
• Poorer documentation
• Less flexibility

8
Vessel Gas Free Engineering

• Specific training (NSTM 074, v. 3)
• Regular entries (v. difficult in CG)
• Designated by ship
• Restrictions on entry types and circumstances
  (unless emergency)
• Underway (some exceptions)

9
Shipyard

• Shipyard competent person
• No toxic cargoes
• No hot work w/in flammables boundary (extends
  beyond bulkheads)
• Follow up on Marine Chemist certificates
• Program includes shore facilities (shipyard
  employment)

10
Coast Guard Aircraft

• Defined by maintenance cards
• Specific ventilation requirements
• Rescue plan

11
MSO

• Draft notice
• Permits designation as CG competent person
• Not finalized
• Some LANT units using
• Many of same restrictions as shipyard competent
  person

12
Lockout/Tagout

• Coast Guard (COMDTINST 9077.1)
• OSHA
• 1910.147
• 1910.331-.335

13
Vessel

• COMDTINST 9077.1
• Requires tags encourages locks
• Biweekly log audit
• Index
• Record sheet

14
Shore (OSHA)

• 1910.147
• Mechanical work only
• No electrical exposure possible
• 1910.331-.335
• Electrical exposure possible
• Qualified person (might not include
  electrician/EMs)

15
Lockout/Tagout 1910.147

• Identify all energy sources to which personnel
  may be exposed
• Define lockout equipment (locks, tags, etc.)
• Develop deenergizing procedures
• Develop reenergizing procedures
• Train personnel

16
Lockout/Tagout 1910.147

• Challenges
• ID all maintenance activities (including
  facility-related)
• ID all energy sources (including multiple)
• Develop isolation techniques (breaker locks,
  double block and bleed, barriers (e.g., prevent
  movement of press brake ram), etc.)
• Clear ID of each activity

17
Training (1910.147)

• Authorized employees Recognize energy sources,
  their type and magnitude, and isolation and
  control procedures.
• Affected employees Purpose and use of energy
  control procedures.
• All others in affected areas Procedures and
  prohibition against violating lockout/tagout.

18
Lockout/Tagout 1910.331-.335

• Lock and tag
• Electrical exposure possible
• Qualified person
• Basic electrical skills PLUS additional training
  and skills

19
Training 1910.331-.335

• All employees affected on the job
• Unqualified persons
• Trained in and familiar with any electrically
  related safety practices necessary for their
  safety

20
Training 1910.331-.335

• Qualified persons (in addition to that required
  of unqualified persons)
• Skills/techniques to distinguish live parts from
  others
• Skills/techniques to determine nominal voltages
• Clearance distances found in .333(c)
• Use of tools, PPE, insulating/shielding
  materials, insulating tools