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OSHA 1915SubpartBAppB

Coast Guard regulations reprint

Subpart B

20 Questions & Answers

Questions & Answers

Under Title 46 CFR 35.01-1(a) (hot work on tank vessels), what publication should be used as a guide for inspections and certificates before hot work?

Use NFPA 306, "Standard for the Control of Gas Hazards on Vessels to be Repaired," as the guide for those inspections and certificates. Requirement in 1915SubpartBAppB cites NFPA 306 as the referenced guide.

  • NFPA 306 provides the procedures and criteria used to determine whether hot work in tanks and other spaces can be done safely.

Under Title 46 CFR 35.01-1(b), when can riveting, welding, burning, or other fire-producing operations be performed inside cargo or fuel tanks?

Those operations cannot be done until an inspection determines the work can be done safely and a certificate is issued. Requirement in 1915SubpartBAppB clearly states no hot work is allowed within cargo tanks, fuel tanks, or connected appurtenances until a safety inspection is completed.

Under Title 46 CFR 35.01-1(b)(1)-(3), which specific areas are explicitly restricted from hot work until an inspection is performed?

Hot work is explicitly restricted (until inspection) in: cargo tanks that carried flammable or combustible liquids or chemicals in bulk, spaces adjacent to such cargo tanks, fuel tanks, and pipelines/heating coils/pumps/fittings connected to those tanks. Requirement in 1915SubpartBAppB lists these areas as off-limits until a safe-condition inspection is completed.

Under Title 46 CFR 35.01-1(c)(1), who must perform inspections in U.S. ports to allow hot work on tank vessels?

A Marine Chemist certificated by the National Fire Protection Association must perform the inspection in U.S. ports when available. Requirement in 1915SubpartBAppB specifies the inspection be made by an NFPA-certified Marine Chemist unless such services are not reasonably available.

Under Title 46 CFR 35.01-1(c)(1), what happens if a certified Marine Chemist is not reasonably available?

If a certified Marine Chemist isn't reasonably available, the Officer in Charge, Marine Inspection may select an authorized person to perform the inspection upon recommendation from the vessel owner and contractor or their representative. Requirement in 1915SubpartBAppB allows this alternative selection process.

Under Title 46 CFR 35.01-1(c), what must the inspecting Marine Chemist or authorized person provide before hot work begins?

They must issue a written certificate stating the operations can be undertaken with safety, and include any qualifications required to maintain safe conditions. Requirement in 1915SubpartBAppB requires the certificate be issued before work starts.

Under Title 46 CFR 35.01-1, what kinds of qualifications or requirements may be included with the safety certificate?

Qualifications may include requirements to maintain safe conditions during the entire operation, additional tests or certifications, and precautions to eliminate or minimize hazards from protective coatings or cargo residues. Requirement in 1915SubpartBAppB specifies these elements as part of the certificate's qualifications.

Under Title 46 CFR 71.60(c)(1) (hot work on passenger vessels), does the same NFPA guidance and inspection requirement apply as for tank vessels?

Yes. The NFPA 306 guide and the requirement that no hot work be done until an inspection and certificate are provided apply similarly to passenger vessels. Requirement in 1915SubpartBAppB reprints the passenger-vessel provisions consistent with the tank-vessel requirements.

Under Title 46 CFR 91.50-1(c)(1) (hot work on cargo and miscellaneous vessels), who is authorized to inspect when NFPA-certified Marine Chemists are unavailable?

When NFPA-certified Marine Chemists are unavailable, the Officer in Charge, Marine Inspection may select a qualified person to serve as the authorized inspector after recommendations from the vessel owner and contractor or their representative. Requirement in 1915SubpartBAppB describes this selection process.

Under the reprinted Coast Guard rules, does the inspection certificate have to be written or can it be verbal?

The certificate must be written. Requirement in 1915SubpartBAppB states a certificate setting forth the fact in writing shall be issued before work is started.

Under the Coast Guard regulations reprinted for Subpart B, must precautions address hazards from protective coatings and cargo residues?

Yes. The certificate's qualifications and requirements must include precautions necessary to eliminate or minimize hazards from protective coatings or residues from cargoes. Requirement in 1915SubpartBAppB explicitly includes these precautions.

Under the Coast Guard rules in this reprint, do the inspection qualifications cover conditions only at the time of inspection or throughout the entire hot work operation?

Qualifications must include requirements to maintain, as far as reasonably possible, safe conditions throughout the entire operation. Requirement in 1915SubpartBAppB requires maintaining safe conditions during the work, not just at inspection time.

Under the reprinted provisions, who can recommend a person when a Marine Chemist is not available?

The vessel owner and his contractor or their representative may recommend a person to the Officer in Charge, Marine Inspection for selection as the authorized inspector. Requirement in 1915SubpartBAppB describes this recommendation role.

Under the reprinted Coast Guard rules, are pipelines and appurtenances connected to cargo or fuel tanks included in the hot-work inspection restrictions?

Yes. The restriction covers pipeline, heating coils, pumps, fittings, and other appurtenances connected to cargo or fuel tanks. Requirement in 1915SubpartBAppB lists these items along with tanks and adjacent spaces.

Under the reprinted regulations, does the Officer in Charge, Marine Inspection have final authority to select an authorized person when a certified Marine Chemist is unavailable?

Yes. The Officer in Charge, Marine Inspection may select the authorized person after considering recommendations from the vessel owner and contractor or their representative. Requirement in 1915SubpartBAppB gives the Officer in Charge that selection authority.

Under the Coast Guard reprint, do the inspection and certificate requirements differ between tank, passenger, and cargo/miscellaneous vessels?

The same basic scheme applies: NFPA 306 serves as the guide; no hot work until an inspection and written certificate; inspections by NFPA-certified Marine Chemists or, if unavailable, an authorized person selected by the Officer in Charge on recommendation. Requirement in 1915SubpartBAppB reprints consistent provisions for the different vessel types.

Under the reprinted text, what additional tests or certifications might be required before hot work can begin?

The text allows the inspecting Marine Chemist or authorized person to require any additional tests and certifications considered necessary to maintain safe conditions during the operation. Requirement in 1915SubpartBAppB does not list specific tests but permits the inspector to require them as needed.

Under Title 46 CFR reprinted in Subpart B, can an individual vessel have its owner or contractor's representative act as the authorized inspector when no Marine Chemist is available?

Potentially yes—if the Officer in Charge, Marine Inspection, upon recommendation of the vessel owner and contractor or their representative, selects that person and authorizes them to make the inspection for that individual vessel. Requirement in 1915SubpartBAppB allows selection of an authorized person in such cases.

Under the Coast Guard provisions reprinted in Subpart B, must the certificate include measures to control hazards that may develop during the operation?

Yes. The certificate must include any qualifications necessary to maintain safe conditions throughout the operation, which implies measures to control hazards that could develop during work. Requirement in 1915SubpartBAppB requires these ongoing safeguards.

Under the reprinted rules, is the NFPA certificate itself sufficient or must the inspecting person still add operation-specific qualifications?

The inspecting Marine Chemist or authorized person must issue a written certificate and may add operation-specific qualifications and requirements necessary to maintain safety for that particular job. Requirement in 1915SubpartBAppB states the certificate should be "qualified as may be required."