LSWG Comments on SYWG document Confined Space Safety on Commercial
Fishing Vessels

1.  Our group had a long discussion about using the 29 CFR 1915 cites in
this document.  Some of the repair work will be done in the ship yard by
shipyard employees and some work will be done by shipboard employees at
the vessel’s pier.  There are 29 CFR 1910 citations which may apply. 
It is recommended that the citations be clarified.  It may be that the
fishing vessel crew is unaware that the 1915 standard applies if the
crew themselves are doing “shipyard like work”.  If the shipyard
cites do not apply at the vessel’s own dock then the 1910 cites should
be used.  

2.  In the Definitions section, the paragraphs explaining the Marine
Chemist duties and a competent persons duties are confusing.  It is
recommended that the document spell out when a competent person can
approve entry and when a Marine Chemist certificate is necessary.  It
also should be pointed out that safe hot work determination need only be
issued by a marine chemist in certain circumstances. See regulations 29
CFR 1915.12 and 1915.14 respectively; also see 46 CFR 35.01, 71.60,
91.50, 189.50, 109.573.  The way it currently reads would suggest that
only a marine chemist can permit entry and hot work as it does not
describe the conditions where a competent person is permitted to do so. 
It would be clearer to edit the brief definition of competent person to
show what that person is authorized by law to do, so that it might be
contrasted with the marine chemist. In the alternative, the definition
could better explain where the marine chemist is required per the CFR.

3.  In the section Safe Confined Space Entry Practices:

A. the second bullet beginning with “A qualified person who has
undergone…” our group questioned why the term “competent person”
was not used. 

B. in the seventh bullet the term “drop test” for welding hoses was
confusing at first to our group.  Once we realized it referred to
pressure drop test we understood the meaning but members of the group
also noted a soap test is also permissible.  We recommend use the words
“drop test or other positive means to ensure” the wording used in
1915.503(b)(2)(iv).

C. in the fourth bullet it might be useful to add a sentence explaining
who should be in charge of emergency response/rescue. 

D. in the sixth bullet regarding the emergency plan.  It is suggested
that this be made a separate section.  The cite 1915 Subpart P is
primarily for a fire plan.  It is very sketchy on rescuing a person from
a confined space.  Since this is primarily a confined space document
perhaps an outline for confined space rescue is appropriate. 

4. In paragraph Oxygen Levels: please consider the following changes:
Oxygen levels which are too low (<19.5%) can cause an initial loss of
awareness and can lead to suffocation resulting in death. Oxygen levels
greater than 22% can cause a fire or explosion hazard by allowing a fire
to burn at a faster than normal rate. 

5. In paragraph Toxic chemicals: please consider the following changes 
a chemical that can be harmful or lethal to a person if that person is
exposed to the chemical in sufficient quantities or concentrations or
for a prolonged duration

