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OSHA3732

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Longshoring

in Marine
Fact Sheet Terminals

Safely Performing Hot Work on


Hollow or Enclosed Structures
OSHA requires employers to provide workplaces that are free of recognized hazards. Hot work
performed on hollow or enclosed structures in marine terminals can present hazards to marine terminal
workers. OSHA defines hot work to include riveting, welding, flame cutting, or similar fire- or spark-
producing operations. Requirements for hot work are in 29 CFR 1917.152.

Hollow or Enclosed Structures


Hollow or enclosed structures are objects on which marine terminal
employees work, but that are not large enough for them to enter.
These structures are not vented to the atmosphere and may be
filled with foam or preservatives to prevent corrosion. Hollow or
enclosed structures in marine terminals come in a variety of sizes
and shapes. Examples include, but are not limited to, drums,
inaccessible voids, pipe stanchions, booms, lampposts, crane
pedestals, crane-portal beams, doubler plates, railings, mooring
bitts and bollards, vents, and container frames. Requirements for
performing hot work on or in tanks or confined spaces, including
testing the atmosphere in confined spaces, are in 29 CFR 1917.152.

Explosion and Fire Hazards • Flammable material – This hazard can be created when
insulating foam or other commonly used materials catch fire
During hot work on hollow or enclosed structures, employers must and release noxious gases when exposed to an ignition source
take precautions to protect workers from exposure to a range of such as hot work.
hazards such as flammable or toxic gases, liquids, or residues;
combustible preservatives; saltwater; fuel oils; solvents, degreasers
Sources of Flammable or Explosive
or cleaning chemicals; and high-pressure or vacuum effects due to
fluctuating temperatures. However, employers must pay particular Atmospheres
attention to these known hazards: Flammable or explosive atmospheres in hollow or enclosed
structures can result from many sources, including:
• Explosive atmosphere – This hazard can be created when
there is a presence of flammable gases or dust in the air and an • Cargo containers may contain various types of chemicals. The
ignition source such as hot work is introduced. structure of the container or the container coating can absorb
chemicals and emit toxic gases.
• As a result, when a worker removes a stored product from, or
Note: States with OSHA-approved state plans may have different
cleans the container, the toxic gases in the container may create
requirements. See www.osha.gov.
a flammable or explosive atmosphere.

U.S. Department of Labor t www.osha.gov t (800) 321-OSHA (6742)


Control Measures Required for Hot Work on Hollow or Enclosed Structures
Prior to starting hot work operations, employers must:
• Have a designated person test the atmosphere in a hollow or enclosed structure to determine that the atmosphere is not
hazardous, 29 CFR 1917.152(c)(8)(i). [An NFPA-certified Marine Chemist may perform the tasks assigned to a designated person.]
• Ensure that suitable fire-extinguishing equipment is immediately available and ready for use at all times, 29 CFR 1917.152(c)(3).
• Train workers involved in hot work operations on the fire hazards of hot work and the use of firefighting equipment, 29 CFR
1917.152(c)(4).
• Ensure that workers wear proper personal protective equipment (PPE), clothing, gloves, and eye protection during hot work
operations, 29 CFR 1917, Subpart E.
• If normal fire-prevention precautions are not sufficient, assign additional personnel to guard against fires during hot work and for
a sufficient time after completing the work, 29 CFR 1917.152(c)(4).
• Make safe any hollow structure that previously contained flammable or combustible substances by cleaning the structure or filling
it with water and then ventilating the structure, 29 CFR 1917.152(c)(8)(i).
• Open the hollow structure to release pressure that builds up during heat application, 29 CFR 1917.152(c)(8)(ii).

• Rusting metals caused by oxidation can create an explosive • File a complaint asking OSHA to inspect their workplace if
atmosphere due to the release of hydrogen gas. they believe there is a serious hazard or that their employer
• Carbon monoxide gas released when welding on a hollow is not following OSHA’s rules. OSHA will keep all identities
or enclosed structure can accumulate to a high enough confidential.
concentration to become explosive. • Exercise their rights under the law without retaliation, including
• Flammable liquefied gas may leak from cargo containers, such reporting an injury or raising health and safety concerns with
as reefer units. If the flammable liquefied gas enters a hollow their employer or OSHA. If a worker has been retaliated against
or enclosed structure, an explosion can occur when an ignition for using their rights, they must file a complaint with OSHA as
source such as welding is present. soon as possible, but no later than 30 days.
For additional information, see OSHA’s Workers page.
Workers’ Rights
Workers have the right to: How to Contact OSHA
• Working conditions that do not pose a risk of serious harm. For questions or to get information or advice, to report an
• Receive information and training (in a language and vocabulary the emergency, fatality, inpatient hospitalization, amputation, or loss
worker understands) about workplace hazards, methods to prevent of an eye, or to file a confidential complaint, contact your nearest
them, and the OSHA standards that apply to their workplace. OSHA office, visit www.osha.gov or call OSHA at 1-800-321-
• Review records of work-related injuries and illnesses. OSHA (6742), TTY 1-877-889-5627.

This is one in a series of informational fact sheets highlighting OSHA programs, policies or standards. It does not impose any
new compliance requirements. For a comprehensive list of compliance requirements of OSHA standards or regulations, refer
DSG FS-3732 05/2014

to Title 29 of the Code of Federal Regulations. This information will be made available to sensory-impaired individuals upon
request. The voice phone is (202) 693-1999; teletypewriter (TTY) number: 1-877-889-5627.

U.S. Department of Labor t www.osha.gov t (800) 321-OSHA (6742)

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