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Risk

Bulletin

Fire Safety in Shipyards


and Lay-By Berths

Number 13
Sept 2010

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.

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.

Graham Bell
Senior Risk Consultant
Marine
Tel: +44.20.3451.3772
graham.bell@allianz.com
www.agcs.allianz.com

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

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:

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.

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

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).

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.

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.

In the UK, there are National Occupational Standards (NOS)


published by OPITO 8 for The Testing for Oxygen, Toxic and
Flammable Gases.

Fire watch not remaining on site after cessation of


hot work, allowing a fire to generate from hot slag or
residual heat.

This identifies three certificate levels for authorized Gas


Testers:

Insufficient cleaning of coatings and/or residual product


remaining on adjacent bulkheads or decks in way of hot
work.

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

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: h
 ttp://www.ocimf.com/Library/OcimfViews-And-Comments
[2] U
 K Health and Safety Executive, Information Sheet
no.6

Hot Work in Docks

Available at: http://www.hse.gov.uk/pubns/dis6.pdf
[3] I nternational Safety Guide for Oil Tankers and
Terminals (ISGOTT)

London: Witherby and Co.

Chapter 9 Management of Safety and Emergencies
[4] UK Maritime and Coastguard Agency (MCGA)
Code of Safe Working Practices for Merchant Seamen

Chapter 23 Hot Work
[5] UK Health and Safety Executive

Confined Spaces Regulations 1997

Available at: h
 ttp://www.hse.gov.uk/confinedspace/
[6] International Maritime Organisation (IMO)
Resolution A684 (20) Recommendations for
Entering Enclosed Spaces on Ships

Available at: h
 ttp://www.ibsnet.gr/pdf/
library/18_864(20)%20-%20
Enclosed%20Space%20Entry.pdf

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.

[7] 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
[8] 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

 rticle produced in association with:


A
Captain David Smith, CMIOSH, MIMarEST, Blair Marine Ltd

ARC-RB-13-en

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