Quiz 4
Level 1 Challenge
(easy as inspecting a weather deck, during the spring, for grinding metal in a portable vise)
One of the sensors a Competent Person and Marine Chemist have in their instrument measures H2S. Which of the following names are synonymous with H2S?
- Sour Gas
- Stink DAMP
- Hydrogen Sulfide
- Hydrogen Monosulfide
- Dihydrogen Monosulfide
- Dihydrogen Sulfide
- Hydrogen Sulfuric Acid
- Hydrosulfuric Acid
Level 2 Challenge
(a bit more involved, like inspecting two enclosed spaces in order to weld a stuffing tube through their shared bulkhead)
If a Competent Person or Marine Chemist tests a dry fuel tank and obtains an instrument reading of 28 ppm Diesel Fuel, can entry be allowed. If entry can be allowed, under what conditions can that happen and what Standard Safety Designation should be used? If entry cannot be allowed, why not and what Standard Safety should be used?
Level 3 Challenge
(extreme, but not as difficult as crawling on hands and knees around a mogas cofferdam, and during a heatwave, in order to allow entry and hot work)
After a tank has been painted, a Competent Person is requested to test the tank to see if it is safe to enter. Not knowing what toxics are in the paint, the CP reviews its SDS and discovers the paint contains Toluene. After calibrating the instrument, without making any further adjustments, the following test results were determined: 20.8% oxygen, 0% LEL, and 240 ppm VOC (PID still set to Isobutylene). The PEL for Toluene is 200 ppm. Is the tank Safe for Workers?
To check your answers, or have a friendly philosophical discussion, please email RWalker@marinechemist.com
Quiz 3 – Answers
Level 1 Challenge
(easy as inspecting a weather deck, during the spring, for grinding metal in a portable vise)
A Competent Person needs to be professionally trained to adequately protect workers’ health and lives, as well as vessels from fire and explosions. Are there any training differences between what OSHA and the U.S. Navy require and, if so, what are those differences?
Answer: Yes, there are differences. OSHA has specific criteria for employees to be trained as Competent Persons and requires the date of training to be recorded on a Roster. OSHA also requires Competent Persons to have the following skills and knowledge:
- Ability to understand and carry out written or oral information or instructions left by Marine Chemists
- Knowledge of subparts B, C, D and H (RW: this does not exclude knowing Subpart P for Fire Protection in Shipyard Employment or Subpart Z for Toxic and Hazardous Substances if a Competent Person needs to be “capable” in those areas)
- Knowledge of the structure, location, and designation of spaces where work is done
- Ability to calibrate and use testing equipment and to interpret the test results
- Ability to perform all required tests and inspections which are or may be performed by a competent person as set forth in subparts B, C, D and H of this part
- Ability to inspect, test, and evaluate spaces to determine the need for further testing by a Marine Chemist or a Certified Industrial Hygienist
- Ability to maintain records required by this section
The NAVSEA Standard Items also require compliance with OSHA and this includes the aforementioned Competent Person training. Several additional requirements include:
- Initial and Annual Update Training must be provided by a National Fire Protection Association (NFPA) Certified Marine Chemist or NFPA Instructor
- The length of the Initial training class must be at least 24 hours and must be completed in person
- The length of the Annual update training must be at least 8 hours whereby Annual is further defined as “once a year, not-to-exceed 12 months.” The Annual update training can be either in person or a virtual live session.
- Certificates for completing the training are to be properly maintained like the OSHA requirement for rosters (RW: Marine Chemist Service also provides training ID cards which are more mconveniently carried on vessels in person, especailly if requested by the SUPERVISOR).
Level 2 Challenge
(a bit more involved, like inspecting two enclosed spaces in order to weld a stuffing tube through their shared bulkhead)
Competent Persons (as well as Marine Chemists and Industrial Hygienists) use many resources to Recognize, Evaluate, and Control different hazards found on various types of vessels. Where on a Safety Data Sheet (SDS) should Competent Persons look for the following information?
(Hint: if you are not familiar with SDS’s , just Google something like “diesel fuel Safety Data Sheet”).
- Common everyday name(s) of the toxic material, if any
- Whether it is a liquid and, if so, what does it look like
- Whether it is a gas and, if so, is it heavier than air
- Whether it is flammable, or not
- If flammable, how much so (another hint: flashpoint)
- Whether it has an 8-hr TWA PEL, or TLV, or both
- Type of gloves to protect a worker’s skin from contamination
Answer: (see below)
- Common everyday name(s) of the toxic material, if any Section 1
Whether it is a liquid and, if so, what does it look like Section 9 (and Section 2) - Whether it is a gas and, if so, is it heavier than air Section 9 (and Section 2)
- Whether it is flammable, or not Sections 2 and 9
- If flammable, how much so (another hint: flashpoint) Section 9 (and Section 5)
- Whether it has an 8-hr TWA PEL, or TLV, or both Section 8
- Type of gloves to protect a worker’s skin from contamination Section 8 (andSection 6)
Level 3 Challenge
(extreme, but not as difficult as crawling on hands and knees around a mogas cofferdam, and during a heatwave, in order to allow entry and hot work)
Which of the following are unsafe practices of using fire-retardant chemical gels (abbreviated FRG) and solutions?
- Applying FRG 360-degrees around a pipe to prevent heating the inside while brazing only a pinhole leak
- Saturating a fire-resistant blanket and wrapping greasy cables with it to prevent the ignition from incidental contact of a rosebud flame with the grease
- Troweling FRG near a deck weld to prevent heat transfer to the overhead of the backside (opposite side)
- Spraying a bulkhead that is only one-half inch from a sink’s hot water tubing in order to shield the adjacent space from the flame of a soldering torch
- Saturating “fire cloth” and placing it over a few boxes in a storeroom to prevent fire from nearby carbon arcing (gouging)
Answer: 1, 3, 4, 5 are all unsafe for varying reasons.
Quiz 2 – Answers
Level 1 Challenge
(easy as inspecting a weather deck, during the spring, for grinding metal in a portable vise)
Yes, or No: Do the requirements of 29 CFR 1915 to use Competent Persons and Marine Chemists for both entry and hot work apply to land-side spaces located in shipyards (such as above-ground storage tanks, crawlspaces, manholes, power plant boilers, tank trucks, etc.)?
Answer: Yes, according to 1915.11(a) Scope and application, “This subpart applies to work in confined and enclosed spaces and other dangerous atmospheres in shipyard employment, including vessels, vessel sections, and on land-side operations regardless of geographic location.” The National Fire Protection Association explains this further in NFPA 306 1.1.6. “This Standard applies to land-side confined spaces, located within the boundaries of a waterfront facility, shipyard, or ship repair facility, and related shipyard employment – regardless of geographic location, whether stationary or mobile – including, but not limited to, the following:
- Underground and aboveground storage tanks
- Other hollow structures such as tank trucks, railroad tank cars, power plant fuel tanks, storage tanks, dip and laundry tanks, vaults, and tunnels
- Other spaces that could contain dangerous atmospheres.”
Level 2 Challenge
(a bit more involved, like inspecting two enclosed spaces in order to weld a stuffing tube through their shared bulkhead)
Is a Competent Person required to test for the same toxic materials that were originally tested and recorded on a Marine Chemist Certificate? If so, can a Competent Person test for even more toxics than what a Marine Chemist originally tested? If the former is not always true, under what condition can an exception be used?
Answer: Yes, according to NFPA 306, one of the responsibilities for maintaining the conditions on a Marine Chemist Certificate (MCC) is found in 8.4.2: “Throughout the course of repairs or alterations, conditions on the Certificate shall be maintained on the vessel by testing and visually inspecting all certified spaces, including all adjacent spaces, accessory piping, valves, coils, and so on, that were part of the original inspection. In addition, for those CPs involved with inspections on USN vessels, the following wording is found in NSI 009-07 3.1.3.1 “A Competent Person must conduct the same atmospheric testing as required on the MCC” (Marine Chemist Certificate).
Regarding the second part of the question: Yes, a Competent Person is not limited to a maximum number of tests he/she can conduct. This might even be considered going “above and beyond” the call of duty, albeit not required. The only requirement is making sure the minimum number of tests are performed.
Lastly, in answer to the third part of the question, there is an exception in NFPA 306 under the ATMOSPHERE SAFE FOR WORKERS section. In section 7.1.1.4, “Further testing for toxic materials (RW: by the Competent Person) shall not be required if previous testing (RW: by the Marine Chemist) indicates that these materials have been eliminated or are not capable of regeneration to hazardous levels while maintained as directed on the Marine Chemist’s Certificate” (RW: maintaining continuous, low-point exhaust ventilation, for example, might be one of those directives; and there could be others that need to be explicitly followed).
Level 3 Challenge
(extreme, but not as difficult as crawling on hands and knees around a mogas cofferdam, and during a heatwave, in order to allow entry and hot work)
Which of the three regulations define a specific lower temperature that constitutes hot work: OSHA 29 CFR 1915, NFPA 306, USN Technical Manual S6470-AA-SAF-010 (“Safe Ten”). What is that (are those) temperature(s) and is it (are they) exactly the same?
Answer: This question was made Level 3 due to needing knowledge of other regulations besides OSHA. Other than that, the question is not difficult. Only two regulations, NFPA 306 and USN “Safe Ten,” have definitions associating heat with Hot Work. In both cases, temperatures of 400oF and above are considered Hot Work. In order for the back (or opposite) side temperature to rise to that kind of temperature via heat conduction, heat from the actual operation will have to be even hotter. Some welding arcs, for example, can exceed 10,000oF. OSHA specifically mentions welding, burning, and other activities, as well as similar flame- and spark-producing operations, in its definition of Hot Work; but it does not mention heat at all. OSHA does, however, combine Welding, Cutting and Heating in the title of Subpart D, but does not specify any temperature.
Two related and interesting edits occurred in the 2024 revision of NFPA 306. First, the phrase “does not involve heat” in the Cold Work definition was removed (RW: which eliminates the possible interpretation of someone rubbing their hands together to warm themselves as being other than Cold Work – that is, Hot Work). Second, the phrase “use of non-intrinsically safe tools” was added to the definition of Hot Work thereby expanding the use of sparking tools to include certain electric reciprocating saws (Sawzall), etc.
Quiz 1 – Answers
Level 1 Challenge
(easy as inspecting a weather deck, during the spring, for grinding metal in a portable vise)
What Standard Safety Designation(s) allow 22% Oxygen?
Answer: OSHA’s 29 CFR 1915 (Safe for Hot Work) and NFPA 306 (Safe for Hot Work, Safe for Limited Hot Work, and Atmosphere Safe for Workers) stipulate the oxygen content “does not exceed” and is “not greater than” 22% respectively. Hence, 22% oxygen is allowable for these Standard Safety Designations (However, according to Appendix A of Subpart B, “any oxygen level greater than 20.8 percent by volume should alert the competent person to look for the cause of the oxygen enriched atmosphere and correct it prior to entry” (RW: and/or hot work, as applicable). Interestingly, OSHA does not allow 22% oxygen for Safe for Workers. In this one case, the oxygen content must be “below 22%” (i.e. 21.9% to 19.5%).
Level 2 Challenge
(a bit more involved, like inspecting two enclosed spaces in order to weld a stuffing tube through their shared bulkhead)
Is 9% LEL on a Combustible Gas Indicator (CGI) the upper limit allowed for Safe for Workers and Safe for Hot Work?
Answer: Both 29 CFR 1915 and NFPA 306 stipulate the concentration of flammable vapors or materials respectively must be “below” or “less than” 10% LEL. Therefore, 9% LEL < 10% LEL; and, thus, 9% LEL is the allowable upper limit (Again, however, according to Appendix A of Subpart B, “when a space contains or produces measurable flammable vapors below the 10 percent LEL, it might indicate that flammable vapors are being released or introduced into the space and could present a hazard in time. Therefore, the cause of the vapors should be investigated and, if possible, eliminated prior to entry” (RW: and/or hot work, as applicable).
Level 3 Challenge
(extreme, but not as difficult as crawling on hands and knees around a mogas cofferdam, and during a heatwave, in order to allow entry and hot work)
According to NFFA 701, what happens to the fire-retardancy of poly when it is painted?
Answer: In Appendix D of NFPA 701 is the following statement: “It should be noted that painting or coating a treated or FR fabric or film could impair its flame-resistant qualities unless the coating itself is flame resistant.”