Welding near preservative coatings

A competent person must test the coating to determine its flammability before starting any hot work. See 1915.53(b).

• The shipyard rules use the term “competent person”; OSHA explains that for Subpart D the competent person must be able to recognize and evaluate hazards and specify protections (Competent person requirements in shipyards).
• A practical test is to scrape a small sample: coatings that "burn with extreme rapidity" are considered highly flammable per 1915.53(b).

A preservative coating is considered highly flammable when scrapings of the coating "burn with extreme rapidity." See 1915.53(b).

• If scrapings ignite and burn very quickly in a small test, the coating meets the standard's definition of highly flammable.
• When coatings are judged highly flammable, follow the precautions in 1915.53(c).

You must prevent ignition by stripping the highly flammable coating from the area to be heated, or for shipbreaking you may burn it away under controlled conditions. See 1915.53(c).

• Stripping removes the fuel source next to the hot work.
• For shipbreaking only, the standard allows burning away coatings "under controlled conditions," but you must ensure the burning is done safely and with fire controls in place.

In enclosed spaces, you must either strip toxic preservatives at least 4 inches from the heat area or protect employees with air-line respirators that meet [1915.154]. See 1915.53(d)(1).

• The respirators referred to are the supplied-air (air-line) types covered by 1915.154.
• The decision (strip vs. respirator) should be made by a competent person capable of evaluating the hazard (Competent person requirements in shipyards).

In the open air, employees must be protected by a filter‑type respirator in accordance with the requirements of [1915.154]. See 1915.53(d)(2).

• Employers should consult 1915.154 to select an appropriate filter cartridge and ensure the respirator program (fit testing, maintenance) is followed.
• If a competent person determines the filter respirator is not adequate for the contaminant or concentrations, supplied-air may still be required (Competent person requirements in shipyards).

A competent person must test the atmosphere in the enclosed space to ensure it does not contain explosive vapors before any welding, cutting, or heating begins. See 1915.53(e)(1).

• The competent person should use appropriate instruments (e.g., combustible gas indicator) and be qualified as described in the competent person interpretation.
• If vapors are present, follow 1915.53(e)(2) and 1915.34(b)(2).

If explosive vapors are found, no hot work shall be commenced until precautions are taken so the welding, cutting, or heating can be done safely. See 1915.53(e)(2).

• Precautions can include ventilating and purging the space, removing preservative coatings, or other measures that a competent person determines will make the operation safe (Competent person requirements in shipyards).
• The prohibition in 1915.34(b)(2) also applies, so follow that section's controls on hot work in dangerous atmospheres.

Preservative coatings must be removed for a sufficient distance so that the temperature of the unstripped metal will not be appreciably raised by the hot work. See 1915.53(e)(2).

• The standard does not prescribe a single distance; the removal extent depends on the work, heat input, and metal thickness.
• You may use artificial cooling of surrounding metal to limit the area that must be cleaned, per 1915.53(e)(2).

A competent person must test immediately after hot work begins and at frequent intervals thereafter to ensure no flammable vapors are being produced; if vapors are found, stop the work immediately. See 1915.53(f).

• The competent person should decide the testing frequency based on hazards and past test results (Competent person requirements in shipyards).
• If tests show flammable vapors, operations must be stopped until additional precautions render the work safe per 1915.53(f).

The requirement that a 1½ inch or larger fire hose with a fog nozzle be uncoiled, placed under pressure, and immediately available in the immediate vicinity of hot work is part of the welding and preservative coatings rules at [1915.53]. See 1915.53.

• The hose must be ready for instant use while being positioned to avoid freezing.
• This is a minimum equipment readiness requirement; employers should also use other fire control measures as appropriate.

No—paragraphs (e) and (f) apply to ship repairing and shipbuilding but do not apply to shipbreaking. See 1915.53(a).

• Shipbreaking still must follow other applicable parts of 1915.53, such as testing flammability under 1915.53(b) and stripping highly flammable coatings under 1915.53(c).

Yes, artificial cooling of the metal surrounding the heated area may be used to limit the size of the area that must be cleaned. See 1915.53(e)(2).

• Cooling lowers heat spread and therefore reduces how far coatings must be removed to prevent the unstripped metal from being appreciably heated.
• Use cooling methods that a competent person approves and that keep the worksite safe.

Yes — a competent person may determine and specify the necessary protection for hazardous exposures, including whether to strip coatings or provide respirators. See 1915.53(d)(1) and the Competent person requirements in shipyards interpretation.

• The competent person must be capable of recognizing hazards and specifying protections as required by Part 1915 (Competent person requirements in shipyards).
• Their decision should follow the respirator requirements in 1915.154 where respirators are used.

A "filter type respirator" means a negative-pressure respirator that uses cartridges or filters to remove contaminants; program requirements (selection, fit testing, maintenance) are in [1915.154]. See 1915.53(d)(2) and 1915.154.

• Use the cartridge/filter appropriate for the contaminant(s) and concentrations.
• Follow the respiratory protection program elements in 1915.154 (medical evaluation, fit testing, training, cleaning, and maintenance).

A competent person should use appropriate detection instruments (for example, a combustible gas indicator or explosion monitor) and recognized sampling procedures to verify the atmosphere does not contain explosive vapors, as required by [1915.53(e)(1)]. See 1915.53(e)(1) and consult the Competent person requirements in shipyards for competency expectations.

• Instruments should be calibrated and appropriate for the preservation solvents or vapors expected.
• If readings indicate explosive concentrations, do not start hot work until the area is made safe per 1915.53(e)(2).

If a competent person's tests show flammable vapors are being produced, the operation must be stopped immediately; work cannot resume until additional precautions make the operation safe. See 1915.53(f).

• The competent person conducts the tests and communicates results; employers are responsible for stopping work and implementing corrective actions (Competent person requirements in shipyards).
• Corrective steps may include ventilation, further stripping, cooling, or changing work methods.

No — if flammability is unknown, a competent person must first test the coating before welding, cutting, or heating begins. See 1915.53(b).

• Do not start hot work on a coated surface until the competent person has determined the coating's flammability and appropriate precautions are in place.
• If testing shows the coating is highly flammable, follow 1915.53(c).

No — even when burning away coatings during shipbreaking is allowed under 1915.53(c), employers must perform the burning under controlled, safe conditions and use appropriate fire controls and respiratory protections as needed.

• "Controlled conditions" means the employer must plan the burn, provide fire suppression (e.g., the required hose), and prevent hazards to workers and property.
• Use a competent person to plan and supervise the operation (Competent person requirements in shipyards).

Yes — the prohibition in 1915.34(b)(2) applies when doing hot work near preservatives, as referenced in 1915.53(e)(2).

• Follow the controls in 1915.34(b)(2) for hot work in atmospheres that could become hazardous.
• Use competent-person testing and take required corrective measures before resuming hot work.

Yes—1915.53(d)(1) requires stripping toxic coatings for at least 4 inches from the heat area in enclosed spaces, unless you instead protect employees with air-line respirators meeting 1915.154.

• The 4-inch minimum is explicit for toxic preservatives in enclosed spaces per 1915.53(d)(1).
• If you believe more removal is necessary based on the coating, metal thickness, or heat input, a competent person should make that determination (Competent person requirements in shipyards).

When toxic preservatives cannot be stripped in an enclosed space, air‑line (supplied‑air) respirators meeting [1915.154] are required. See 1915.53(d)(1) and 1915.154.

• Supplied‑air respirators provide a clean breathing source independent of the contaminated atmosphere in the space.
• Ensure your respirator program follows the procedures and protections in 1915.154 (medical evaluation, fit testing, training, etc.).

Yes — a competent person may use recognized occupational exposure limits (such as ACGIH TLVs) or other objective data to evaluate hazards where OSHA PELs do not exist, provided they are capable of specifying necessary protections. See 1915.53(e)(1) and the Competent person requirements in shipyards interpretation.

• The competent person must be able to recognize and evaluate exposures and specify protections as required by Part 1915 (Competent person requirements in shipyards).
• Document the basis for protective measures and keep monitoring records as appropriate.