Marine coatings exposures, coatings removal and confined-space safety during ship demolition are facing new federal scrutiny as the Occupational Safety and Health Administration implements a revised National Emphasis Program on Shipbreaking.
“OSHA has determined that this NEP is needed because of the continuing high incidence of injuries and illnesses related to shipbreaking operations,” according to the new program, issued and effective Nov. 4.
The program updates policies and procedures to reduce and eliminate the workplace hazards associated with shipbreaking operations.
‘Ongoing Effort’ Cited
“Shipbreaking of obsolete vessels presents many challenges, including the structural complexity of the ships themselves and environmental, safety, and health issues,” according to the NEP. “Although many recognized problems with past practices have been addressed, an ongoing effort is required to further improve the process and ensure continued success.”
The revisions override the last Shipbreaking NEP issued in March 2005. They are the latest in a program that began with a 1999 agreement involving OSHA, the Department of Defense, the federal Maritime Administration, and the Environmental Protection Agency.
The NEP provides a national reporting system for all OSHA shipbreaking inspections and updates guidance pertaining to IMIS recording of shipbreaking operations.
The program also supports OSHA’s ongoing effort to reduce injuries and illnesses among Latino workers, who make up a significant portion of the shipbreaking workforce. Those efforts include an OSHA enforcement memorandum directed at protecting non-English-speaking workers by, among other things, ensuring that they receive OSHA training in a language they understand.
The NEP specifies comprehensive inspections, scheduled and unscheduled, that focus on hazards and activities in several areas.
Asbestos Exposure: This focus includes permissible exposure limits, exposure assessments and monitoring, respiratory protection, communication of hazard to workers, methods of compliance, protective clothing, hygiene facilities and practices, medical surveillance, training for workers and supervisors, housekeeping and recordkeeping.
Targeted exposures include asbestos insulation on pipes and hull, asbestos adhesives, and asbestos mastic under insulation.
Polychlorinated Biphenyls (PCBs) Exposure: This focus includes exposure limits, inhalation and dermal protection, and training of workers and supervisors.
Targeted areas include PCBs in silver paint, habitability paint and primary paint on hull steel, as well as PBCs in cables, plastic foam insulation and rubber products such as hoses and gaskets.
Lead: The focus includes burning through lead-coated surfaces, permissible exposure limits, exposure assessments and monitoring, respiratory protection, protective clothing, hygiene facilities and practices, medical surveillance, and training for workers and supervisors. Lead/chromate paint is a key targeted area.
Confined, enclosed and other dangerous atmospheres—all significant hazards—are targeted per 29 CFR Part 1915, Subpart B and the guidance detailed in OSHA’s Confined or Enclosed Spaces and Other Dangerous Atmospheres and Shipyard Fatality Videos.
Personal protective equipment (PPE) is targeted per 29 CFR Part 1915, Subpart I and the OSHA eTool called Personal Protective Equipment.
Scaffolds, ladders and working surfaces are targeted per 29 CFR Part 1915, Subpart E and the eTools Scaffolds (Staging) and Ladders.
Paint Removal: Paint removal operations are covered by 29 CFR Part 1915, Subpart C and the eTool Surface Preparation for Removal of Hazardous Materials. (Although 1915 Subpart C does not apply to shipbreaking operations, OSHA recommends many of the precautions in the module as good work practices.)