Fire Protection in Shipyard Employment

General provisions Purpose and Scope 501 Fire safety plan 502 Precautions before hot work 503 Fire watches 504 Fire response 505 Hazards of fixed extinguishers on board vessel 506 Landside fire protection system 507 Training 508

Purpose Requires employers to protect all employees from fire hazards in shipyard employment, including employees engaged in fire response activities Provides increased protection for shipyard employment workers from the hazards of fire on vessels and vessel sections and at land-side facilities Reflects new technologies and national NFPA consensus standards

Scope Covers employers with employees engaged in Shipyard employment aboard vessels and vessel sections Land - side operations Regardless of geographic locations

Employee participation Employer’s must provide for employees or employee representatives to participate in developing and reviewing programs and policies to comply with this subpart

Multi-employer worksites Host employer responsibilities Inform employers about the content of the fire safety plan including hazards, controls, fire safety and health rules, and emergency procedures Ensure safety and health responsibilities for fire protection are assigned as appropriate to other employers at the worksite

Multi-employer worksites (cont’d) Contract employer responsibilities Ensure host employer knows about the fire-related hazards associated with the contract employer's work and what the contract employer is doing to address them Advise the host employer of any previously unidentified fire- related hazards that the contract employer identifies at the worksite

Fire safety plan 29 CFR 1950-502 Employer responsibilities Plan elements Reviewing the plan with employees Additional employer requirements Contract employers

Plan elements Plan must include: Identification of significant fire hazards Procedures for recognizing and reporting unsafe conditions Alarm procedures Procedures for notifying employees of a fire emergency Procedures for notifying fire response organizations of a fire emergency Procedures for evacuation Procedures to account for all employees after an evacuation; and Names, job titles, or departments or individuals who can be contacted for information about the plan

Reviewing the plan with employees The employer must review the plan with each employee at the following times: By March 14, 2004, for current employees Upon initial assignment for new employees; and When the actions the employee must take under the plan change because of a change in duties or a change in the plan.

Additional plan requirements Must be accessible to employees, employee representatives and OSHA Review and update at least annually Document affected employees have been informed about the plan Give a copy to outside fire response organizations that will respond to fires

Contract employers Contract employers in shipyard employment must have a fire safety plan for their employees, and the plan must comply with the host employer's fire safety plan The contract employer can adopt the host employers fire safety plan to meet this requirement

Precautions for hot work 29 CFR 1915 – 503 General requirements Designated areas Non-designated areas Specific requirements Maintaining fire hazard free conditions Fuel gas and oxygen supply line and torches

General requirements - designated areas The employer may designate areas that are free of fire hazards for hot work in sites such as: Vessels Vessel sections Fabricating shops Subassembly areas

Non-designated areas Visually inspect area where hot work will be performed, including adjacent areas unless Marine Chemist’s certificate or Shipyard Competent person’s logs is used for authorization Perform hot work only in areas that are free of fire hazards, or controlled by physical isolation, fire watches, etc. Maintain fire hazard-free conditions

Precautions for hot work – specific requirements Fuel gas and oxygen supply lines and torches No unattended lines in confined spaces No unattended charged lines in enclosed spaces for more than 15 minutes Fuel gas and oxygen hose lines disconnected at end of each shift

Precautions for hot work – specific requirements (cont’d) Roll lines back to supply manifold or open air and then disconnect torch, or Disconnect extended fuel gas and oxygen hose lines at the the supply manifold Only if the lines are given a positive means of identification Use a drop test or other positive means to ensure the integrity of fuel gas and oxygen burning system before resuming hot work

Fire watches 29 CFR 1915 - 504 Written policy Posting fire watches Assigning employees to fire watch duty

Written policy Detailed fire watch training Identifies duties employees will perform and equipment they will be given Includes personal protective equipment (PPE) that must be made available and worn

Posting fire watches Must post a fire watch during hot work if any of the following are present: Slag, weld splatter, or sparks might pass through an opening and cause a fire Fire-resistant guards or curtains are not used to prevent ignition of combustible materials on or near decks, bulkheads, etc Combustible material is closer than 35 ft. and cannot be removed, shielded or protected

Posting fire watches (cont’d) Hot work is carried out on or near insulation, combustible coatings that cannot be shielded, cut back, removed, or inerted Combustible materials adjacent to the opposite sides of bulkheads, decks, etc. may be ignited by conduction or radiation The hot work is close enough to cause ignition through heat radiation or conduction on: Insulated pipes, bulkheads, decks, partitions, or overheads; or Combustible materials and/or coatings

Posting fire watches (cont’d) The work is close enough to unprotected combustible pipe or cable runs to cause ignition A Marine Chemist, a Coast Guard-authorized person, or a shipyard Competent Person requires that a fire watch be posted

Assigning employees to fire watch duty Employees must not be assigned additional duties while the hot work is in progress Employees must be physically capable of performing fire watch duties Employees assigned to fire watch duty must: Have a clear view and immediate access to all areas included in the fire watch Be able to communicate with workers exposed to hot work Be authorized to stop work and restore safe conditions within hot work area

Assigning employees to fire watch duty (cont’d) Remain in the hot work area for 30 minutes after completion of the hot work - Unless the employer or its representative surveys the exposed area and makes a determination that there is no further fire hazard Be trained to detect fires in areas exposed to the hot work Extinguish incipient stage fires in the hot work area Alert employees of any fire beyond the incipient stage; and If unable to extinguish fire, activate the alarm

Fire response 29 CFR 1915 – 505 Employer responsibilities Written policy information Internal response External response Medical requirements for shipyard response employees Organization of internal fire response functions Personal protective clothing and equipment for fire response employees Equipment maintenance (PPE)

Employer responsibilities Decide what type of response will be provided and who will provide it Internal fire response Outside fire response Create, maintain, and update a written policy that: Describes the internal and outside fire response organizations that the employer will use; and Defines evacuation procedures, if the employer chooses to require a total or partial evacuation of the worksite at the time of a fire

Written policy – internal response The basic structure of the fire response organization Number of trained fire response employees The fire response functions that will be carried out Minimum number of fire response employees necessary Type, amount, and frequency of training that must be given to fire response employees Procedures for using protective clothing and equipment

Written policy – outside response Types of fire suppression incidents to which the fire response organization is expected to respond at the employer's facility Liaisons between the employer and the outside fire response organizations

Written policy – outside response (cont’d) A plan for fire response functions that: Addresses procedures for obtaining assistance from the outside fire response organization Familiarizes the outside fire response organization with the layout of the employer's facility or worksite Sets forth how hose and coupling connections will be made compatible and location of adapter couplings States employer will not allow use of incompatible hose connections

Written policy – combination of internal and outside response The basic organizational structure of the combined fire response Number of combined trained fire responders Fire response functions that may need to be carried out Minimum number of fire response employees necessary Number and types of apparatuses, and Description of the fire suppression operations established by written standard operating procedures for each particular type of response at the worksite Type, amount, and frequency of joint training with outside fire response organizations

Employee evacuation Emergency escape procedures Procedures to be followed by employees who remain at worksite to perform critical operations during the evacuation Procedures to account for all employees after emergency evacuation is completed Means of reporting fires and other emergencies Names or job titles of employees or departments to be contacted for further information or explanation of duties

Written emergency response The employer must include the following information in the employer's written policy: A description of the emergency rescue procedures; and Names or job titles of the employees who are assigned to perform them

Medical requirements for shipyard fire response employees The employer must ensure that: Fire response employees receive medical exams to assure they are physically and medically fit for duties expected to perform Fire response employees, required to wear respirators meet the medical requirements Each fire response employee has an annual medical examination; and Medical records are kept on fire response employees

Organization of internal fire response functions Organize fire response functions to ensure adequate resources for emergency operations Establish lines of authority and assign responsibilities to ensure components of the internal fire response are accomplished Set up incident management system to coordinate and direct fire response functions, including: Specific fire emergency responsibilities Accountability for all fire response employees participating in an emergency operation; and Resources offered by outside organizations Provide information as required to the outside fire response organization to be used

PPE for fire response employees General requirements Thermal stability and flame resistance Respiratory protection Interior structural firefighting operations Proximity firefighting operations Personal alert safety system (PASS) devices Life safety ropes, body harnesses and hardware

General requirements Employer must: At no cost, supply all fire response employees appropriate personal protective clothing and equipment they need to perform expected duties Ensure employees wear the appropriate PPE and use the equipment, when necessary, to protect them from hazardous exposures

Thermal stability and flame resistance Ensure each fire response employee exposed to flame hazards do not wear clothing that could increase the extent of injury Prohibit wearing clothing made from acetate, nylon, or polyester, either alone or in blends, unless it can be shown that: The fabric will withstand the flammability hazard that may be encountered; or The clothing will be worn in such a way to eliminate the flammability hazard that may be encountered

Personal Alert Safety System (PASS) devices Provide each fire response employee involved in firefighting operations with a PASS device; and Ensure that each PASS device meets the recommendations in NFPA 1982-1998 Standard on Personal Alert Safety Systems (PASS)

Life safety ropes, body harnesses and hardware The employer must ensure that: All life safety ropes, body harnesses, and hardware used by fire response employees for emergency operations meet the applicable recommendations in NFPA 1983-2001 Fire response employees use only Class I body harnesses to attach to ladders and aerial devices; and Fire response employees use only Class II and Class III body harnesses for fall arrest and rappelling operations

Equipment maintenance Personal protective equipment Employer must inspect and maintain PPE used to protect fire response employees to ensure that it provides the intended protection Fire response equipment. Keep fire response equipment in a state of readiness Standardize all fire hose coupling and connection threads throughout the facility Ensure all fire hoses and coupling connection threads are the same throughout the facility as those used by the outside fire response organization, or Supply suitable adapter couplings if such an organization is expected to use the fire response equipment within a facility or vessel or vessel section

Hazards of fixed extinguishing systems on board vessels and vessel sections – 29 CFR 1915 - 506 Employer responsibilities Requirements for automatic and manual systems Sea and dock trials Doors and hatches Testing the system Conducting system maintenance Using fixed manual extinguishing systems for protection

Employer’s responsibilities The employer must comply with the provisions of this section whenever employees are exposed to fixed extinguishing systems that could create a dangerous atmosphere when activated in vessels and vessel sections, regardless of geographic location

Requirements for automatic and manual systems Before working in a a space with a fixed system, either: Physically isolate the systems or use other positive means to prevent the systems' discharge; or Ensure employees are trained to recognize: Systems' discharge and evacuation alarms and the appropriate escape routes; and Hazards associated with the extinguishing systems and agents including the dangers of disturbing system components and equipment

Sea and dock trials and door hatches During trials, the employer must ensure that all systems remain operational Take protective measures to ensure all doors, hatches, scuttles, and other exit openings remain working and accessible for escape in the event the systems are activated; and

Sea and dock trials and door hatches (cont’d) Ensure that all inward opening doors, hatches, scuttles, and other potential barriers to safe exit are removed or blocked open, if systems' activation could result in a positive pressure in the protected spaces sufficient to impede escape

Testing the system When testing a fixed extinguishing system involves a total discharge of extinguishing medium into a space, employer must: Evacuate all employees from space and assure no employees remain in the space during the discharge Retest the atmosphere to ensure that the oxygen levels are safe for employees to enter When testing a fixed extinguishing system does not involve a total discharge of the systems extinguishing medium, employer must: Ensure system's extinguishing medium is isolated All employees not directly involved in the testing are evacuated from the protected space

Conducting system maintenance Before conducting maintenance on a fixed extinguishing system, the employer must ensure that the system is physically isolated

Using fixed manual extinguishing systems for fire protection If fixed manual extinguishing systems are used to provide fire protection for spaces in which the employees are working, the employer must ensure that: Only authorized employees are allowed to activate the system Authorized employees are trained to operate and activate the systems; and All employees are evacuated from the protected spaces, and accounted for, before the fixed manual extinguishing system is activated

Land-side fire protection systems 29 CFR 1915 - 507 Employer responsibilities Portable fire extinguishers and hose systems Fixed extinguishing systems

Employer responsibilities Ensure all fixed and portable fire protection systems needed to meet OSHA standard for employee safety or employee protection from fire hazards in land- side facilities meet the requirements, including, but not limited to: Buildings Structures Equipment

Portable fire extinguishers and hose systems Employer must select, install, inspect, maintain, and test all portable fire extinguishers according to NFPA 10-1998 Standard for Portable Fire Extinguishers Class II or Class III hose systems permitted as fire extinguishers if the employer selects, installs, inspects, maintains, and tests those systems according to the specific recommendations in NFPA 14-2000 Standard for the Installation of Standpipe, Private Hydrant, and Hose Systems

General requirements for fixed extinguishing systems Ensure any fixed extinguishing system component or extinguishing agent is approved by an OSHA Nationally Recognized Testing Laboratory Notify employees and take necessary precautions to ensure employees are safe from fire if for any reason a fire extinguishing system stops working, until the system is working again Ensure repairs to fire extinguishing systems and equipment are done by a qualified technician Provide and ensure employees use PPE when entering discharge areas in which the atmosphere remains hazardous to employee safety or health

General requirements for fixed extinguishing systems (cont’d) Post hazard warning or caution signs at entrance to and inside of areas protected by fixed extinguishing systems that use extinguishing agents in concentrations known to be hazardous to employee safety or health Select, install, inspect, maintain, and test all automatic fire detection systems and emergency alarms according to NFPA 72-1999

Fixed extinguishing systems Standpipe and hose systems IAW NFPA 14 -2000 Automatic sprinkler systems IAW NFPA 25-2002, and either NFPA 13 – 1999, or NFPA 750 – 2000 Fixed extinguishing systems that use water or foam agent IAW NFPA 15-2001 Fixed extinguishing systems using dry chemical IAW NFPA 17-2002 Fixed extinguishing systems using gas IAW NFPA 12-2000

Training 29 CFR 1915 - 508 Training All - employee training Additional training requirements for employees expected to fight incipient stage fires Additional training requirements for shipyard employees designated for fire response Additional training requirements for fire watch duty Records

Training Current employees by 03/15/2005 New employees upon initial assignment When necessary to maintain proficiency for employee previously trained

Employee training (cont’d) Employer must train all employees on Emergency alarm signals, including system discharge alarms and employee evacuation alarms The primary and secondary evacuation routes that employees must use in the event of a fire in the workplace

Training for employees expected to fight incipient stage fires Principles of using fire extinguishers or hose lines Hazards involved with incipient firefighting, and the procedures used to reduce these hazards Hazards associated with fixed and portable fire protection systems Activation and operation of fixed and portable fire protection systems that the employer expects employees to use in the workplace

Requirements for shipyard employees designated for fire response Have a written plan stating fire response employees are trained and capable of carrying out their duties Update plan to address anticipated emergencies Review training programs and hands-on sessions before their use in training and ensure employees are protected from hazards associated with response training Provide training that ensures employees are capable of carrying out their duties Train new employees before they engage in emergency operations

Requirements for shipyard employees designated for fire response (cont’d) At least quarterly, provide training on written operating procedures Use qualified instructors to conduct the training Conduct training that involves live fire response exercises IAW NFPA 1403-2002 Conduct semi-annual drills according to employer’s written procedures Prohibit use of smoke generating devices in training exercises

Additional training for fire watch duty The employer must ensure that each fire watch is trained by an instructor with adequate fire watch knowledge and experience: Before being assigned as a fire watch Whenever there is a change in operations that presents a new or different hazard Whenever employer believes fire watch’s skills are inadequate Annually

Additional training for fire watch duty (cont’d) Basics of fire behavior Different classes of extinguishing agents Stages of a fire Methods for extinguishing fires Adverse health effects caused by fire Physical characteristics of hot work area Extinguishing live fire scenarios Unless prohibited by local and federal law Extension to July 1, 2005

Additional training for fire watch duty (cont’d) Hazards associated with fire watch duties PPE and its use Selection and use of extinguishers and hoses Location and use of barriers Means of communication When and how to start fire alarm procedures Employer’s evacuation plan Vessel sections Land-side

Additional training for fire watch duty (cont’d) Alert others to exit the space when The fire watch perceives an unsafe condition Fire watch perceives a worker is in danger Employer or employer’s representative orders an evacuation An evacuation signal is activated

Records Training records must include: Employee’s name Trainer’s name Type of training Dates training took place Records must be maintained for one year, or until replaced by new record, whichever is shorter

For More Help Contact your local OSHA office OSHA Web site (www.osha.gov) Maritime Page http://www.osha.gov/dts/maritime/index.html 1-800-321-OSHA