Risk Bulletin

Number 13 Sept 2010

Fire Safety in Shipyards and Lay-By Berths

Report published by Allianz Risk Consulting
clearly identified, the intense and often round-the-clock repair activity will not only affect the vessels normal routine but may also introduce a myriad of perils which the ship would not normally encounter. The Oil Companies International Forum (OCIMF)1 document referenced at the end of this bulletin highlights this problem of abnormal perils and gives appropriate advice. The repair process can generate many hazards to a vessel, including welding, grinding and burning all of which provide an ignition source for fires. Unless the vessel is handed over completely under contract to the repair organization, the master remains responsible for the vessel and its crew and must consider additional fire hazards that can imperil the vessel. The control of hazards such as fire within shipyards and docks is referenced in the Health Safety Executive (HSE) Docks information sheet No.6 found below2. This document outlines the need for robust communication between masters of ships and companies that perform hot work on board. Communication is made more difficult when the yard and the ship owner use outside contractors along with regular staff. Repair services should be an integral part of a formal, comprehensive safety plan drawn up between the repair facility and the ship owner. Such a plan should be overseen by the master and the shipyards safety representative. Principle and secondary contractors must provide Method Statements or Safe Systems of Work declarations in advance of any work commencing, so that specific precautions such as work permits can be implemented. Where there is a reason to apply or produce heat during work activities, a Hot Work Permit should be used to recognize and diminish the hazard-to-risk ratio. Hot Work Permits may be seen as a panacea to overcome difficult circumstances when elevated temperature work is required in areas of flammable risk but Chapter 9 of ISGOTT3 points out that:

Introduction
The introduction of the International Safety Management (ISM) Code has resulted in vessels being operated under a procedural process which examines all areas of potential risk. For most masters and crew on well-run and responsibly-managed vessels, daily routines are regimented by company procedure manuals that give guidance and instruction in the day-to-day operational aspects of the ship on which they serve. The company superintendent and master may feel assured that such a detailed approach provides a safeguard against accidents during normal vessel business, but one of the requirements of the ISM Code is to have procedures for controlling so-called hot work. Hot work is defined as the use of open flames and the application of heat by means of tools or equipment, including the accidental application of heat via the use of power tools or hot particles falling into areas with concentrations of flammable material or gas. When a vessel enters a dry dock or proceeds to a lay-by berth for repair work, however, this feeling of comfort often is turned on its head. For the master and crew who are used to a daily routine where risks are known and

Graham Bell Senior Risk Consultant Marine Tel: +44.20.3451.3772 [email protected] www.agcs.allianz.com

A Hot Work Permit does not guarantee safety

There are two major limitations to be considered with a Hot Work Permit system: It is a snapshot of conditions at the time. Its validity is based on the competence of the issuing authority. When the permit is first drawn up, the conventional format will consider items such as those highlighted by Chapter 23 of the UK MCGA Code of Practice4 where checks are required for the presence of combustible solids, liquids or gasses at, below or adjacent to the work area. Inspections will ensure the use of correct and intrinsically safe equipment along with the positive confirmation of isolations and lock-outs to prevent the future introduction of flammables into the work area.

exist within the space as a result of residues from previous contents, or may enter the space via pipelines or other connections. IMO Resolution A.684 6 lists recommendations for entering enclosed spaces aboard ships. In all cases, a safe system for hot work in such a space will require adequate cleaning and ventilation followed by a combination of: A Gas Free (Safe to Enter) Certificate - Issued by a competent person. This takes into account previous tank contents (last 3 cargoes) and checks for sufficient oxygen content with toxicity levels below the relevant occupational exposure limits, which are time weighted. This certificate allows for tank entry and inspection only, and may require that entry is only authorized with personal protective equipment or other restrictions. Followed by: A Hot Work Permit - Issued by a competent person. This analyses the people, processes and procedures along with the control measures to be maintained such as the periodic monitoring for hydrocarbon gas, such as before start of work each day, before each shift change, and if the vessel is shifted or moved. Having considered the efficacy of a Hot Work Permit in terms of prevailing conditions and possible changes, the soundness of such a permit, particularly when issued in conjunction with a Safe to Enter certificate is wholly reliant on the proficiency of the person issuing it. Again, the ISM Code will require that each ship has Confined Space Entry procedures and it is imperative that the ships crew adhere to these procedures. In the United States, for a person to be deemed competent to determine that a space in a vessel is safe for entry or for hot work, the individual must be a Certified Marine Chemist, who must conduct inspections & tests and prepare certificates in accordance with the National Fire Protection Association (NFPA) 306 7 Standard for Control of Gas Hazards aboard vessels. This requires a Bachelors Degree with required courses in Chemistry, followed by a two-year period of practical training in marine and shipyard safety with a Certified Marine Chemist and employment with an analytical laboratory. Candidates must also complete the NFPA Marine Chemist training course curriculum, and pass a final oral examination and certificate writing exercise given by the Marine Chemist Qualification Board (MCQB).

The signing and issue of the Permit only represents the state of affairs at that moment in time
It subsequently requires a degree of awareness by all workers undertaking the task to recognise any changes which may alter the hazard level. This starts with the process for handling and communicating the gas free certificate. The certificate contains critical information and instructions that must be clearly understood and communicated, such as location or compartment aboard the vessel that is safe for hot work, the type of hot work permitted and scope of work, any controls needed (ventilation, fire watch, etc.) and instructions for handling any change in conditions. Similarly, when a permit overlaps from one shift to another, there needs to be a positive handover and affirmation of existing conditions to verify the on going validity of the permit criteria. Both the repair supervisor and the vessel Master should be fully aware of the limitations contained within the certificate and a copy of the certificate or permit should be posted aboard the vessel, in a conspicuous place. Hot Work may be required within an enclosed space such as a cleaned fuel or cargo tank where there is the risk of flammable or toxic vapors. Safe work in such a confined space is the subject of an HSE Approved Code of Practice5 which considers the risk of fire or explosion arising from the presence of combustible substances. Gas or fumes may

Thereafter, Marine Chemists are subject to continuing education requirements, re-certification every five years and random monitoring by the MCQB with any incidents subject to investigation with possible further training requirements or disciplinary procedures, up to and including revocation of their certification. This sets a high standard for certification and control of individuals that issue hot work permits, which may not be fully matched by other authorities throughout the world; however, the procedures contained within NFPA 306 is the standard that is widely practiced and/or referenced by shipyards worldwide. In the UK, there are National Occupational Standards (NOS) published by OPITO 8 for The Testing for Oxygen, Toxic and Flammable Gases. This identifies three certificate levels for authorized Gas Testers: Level 1 For confined space entry, oxygen, flammable and toxic gases up to confined space entry. Course Time: 12 Hours Level 2 Testing of Flammable Gases for Hot Work. Course Time: 7 hours Level 3 Providing Safety Watch duties. Course Time: 4 hours. An OPITO certificate is not awarded as an assessment of competence. Where there is a need to have such competence formally confirmed this can be done at the workplace through a companys competence management system against the NOS. Some shipyards may employ their own industrial chemist or analyst. Where external contractors are used to carry out hot work, particularly if at a lay-by berth and not within a recognized repair facility, they may choose to have gas testing carried out by persons with varying industrial qualifications. In addition to the competence and qualification of the person issuing the gas free and/or safe for hot work certificates, two other critical areas are the maintenance of testing equipment and training of the Fire Watch. Oxygen meters and combustible gas indicators are sensitive equipment that must be carefully maintained; otherwise, inaccurate readings may be made. Maintenance should be as per manufacturers recommendations, which includes schedules for replacement of sensors and other critical elements. Also, the equipment should be tested daily or before each use, and a log of test results should be maintained by the shipyard. Maintenance records and test logs should be available for review by the vessel Master. Hot work permits or certificates normally require a Fire Watch with a charged fire hose or suitable fire suppression equipment. Some shipyards believe that a welder can act as his own fire watch, but this should never be accepted. Also, the fire watch should have adequate training and

be required to remain on duty for at least 1 hour after cessation of hot work, to ensured that a fire does not start due to hot slag landing on combustible materials or a slow burning or smouldering fires starting in common combustibles or an adjacent space.

Procedural Problems in Shipyards

To illustrate the procedural problems in shipyards, below are some common causes of fires aboard vessels in shipyards. Insufficient clearing and/or protection of common combustibles from hot work sparks or slag and/ or insufficient clearing along bulkheads of adjacent spaces. Fire watch not remaining on site after cessation of hot work, allowing a fire to generate from hot slag or residual heat. Insufficient cleaning of coatings and/or residual product remaining on adjacent bulkheads or decks in way of hot work. Failure to maintain conditions in a space and not following permit instructions. Welders entering and starting hot work in the wrong compartment or space Person issuing the certificate not understanding the scope of work Change in scope of work and repairs beginning without any inspection or testing. Improper inspection and testing by person issuing certificate, including use of improperly maintained equipment. Insufficient cleaning (scraping) of rust scale within a tank (impregnated with product), which leads to vapour regeneration, during hot work. Failure to lock out and secure a compartment, allowing the introduction of combustible product from inadvertent opening of valves or pumping product...

Summary
In ship repair contracts, it is normal for the Master to retain responsibility for his ship and crew. To maintain this control, he must integrate the ships safety regime with that of the repair contractors. Information exchange briefings and the setting up of a central information control point are invaluable. The Master should ensure that regular checks on all contractors safety performance are carried out. When there are observed breaches of health and safety standards, or concerns about the competence of workers, the Master has the right at any time to demand that the work ceases immediately until suitable remedies are found. For Hot Work and Confined Space Entry, the credentials of the issuing authority of the relevant certificates and permits should be challenged if they are not of a recognised standard. Also, the certificate requirements for controls and re-inspections must be followed throughout the course of repairs to maintain the initial safe condition.

List of references
[1] Oil Companies International Forum (OCIMF) Health Safety and Environment at New-Building and Repair Shipyards and during Factory Acceptance Testing Available at: http://www.ocimf.com/Library/OcimfViews-And-Comments UK Health and Safety Executive, Information Sheet no.6 Hot Work in Docks Available at: http://www.hse.gov.uk/pubns/dis6.pdf International Safety Guide for Oil Tankers and Terminals (ISGOTT) London: Witherby and Co. Chapter 9 Management of Safety and Emergencies UK Maritime and Coastguard Agency (MCGA) Code of Safe Working Practices for Merchant Seamen Chapter 23 Hot Work UK Health and Safety Executive Confined Spaces Regulations 1997 Available at: http://www.hse.gov.uk/confinedspace/ International Maritime Organisation (IMO) Resolution A684 (20) Recommendations for Entering Enclosed Spaces on Ships Available at: http://www.ibsnet.gr/pdf/ library/18_864(20)%20-%20 Enclosed%20Space%20Entry.pdf US National Fire Protection Association (NFPA) 306 Standard for the Control of Gas Hazards on Vessels Available for purchase at: http://www.nfpa.org/aboutthecodes/ AboutTheCodes.asp?DocNum=306 The Oil and Gas Academy (OPITO) National Occupational Standards for the Testing for Oxygen, Toxic and Flammable Gases Available at: http://www.opito.com/international/ library/industry_training_standards/ authorised_gas_tester.pdf

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AGCS Marine Risk Control Recommendations

1. For whenever hot work and confined space entry is being considered by a ships Master, the credentials of the issuing authority of the relevant certificates and permits should always be challenged if they are not of a recognised standard. 2. Where the ships Master retains responsibility for his ship and crew whilst in a shipyard or at a repair berth, he should ensure he maintains his own fire and safety watch patrols in order to monitor the activities of the shipyard workers and any of its subcontractors, especially whenever hot work and/or confined space entry is in progress.

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Article produced in association with: Captain David Smith, CMIOSH, MIMarEST, Blair Marine Ltd

ARC-RB-13-en

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