                                  Fact Sheet
                  Hot Work on Hollow or Enclosed Structures 
                              in Marine Terminals

Hot work being performed on hollow structures located within a marine terminal can present a hazard to both the worker and facility.  OSHA defines hot work to mean riveting, welding, flame cutting, or other fire or spark producing operations (29 CFR 1917.152(a)).  

Hollow or enclosed structures include, but are not limited to; drums, inaccessible voids,  hatches, coamings, pipe stanchions, booms, lamp posts, crane pedestals, crane portal beams, doubler-plates, railings, mooring bitts, bollards, vents, container frames and bulkheads, sponsons, pontoons, floats, and buoys. Additional requirements for work on or in tanks or confined spaces, including the testing of confined spaces, can be found in 29 CFR 1917.152.  As a reminder any hot work being done in conjunction with ship repair falls under regulations found in 29 CFR 1915.

Hazards of hollow or enclosed structures:

  * May contain flammable or toxic gases, liquids, or residue;
  * Commonly filled with combustible preservatives;
  * Often contaminated with saltwater, fuel oils, solvents, degreasers, or cleaning chemicals;
  * May contain high pressure or vacuum effects due to fluctuations in temperatures; and 
  * Some hollow structures may contain polyurethane foam insulation and extreme caution must be taken when performing hot work against this material.
  
Recommended control measures prior to hot work on hollow or enclosed structures:
  
  * Always wear proper PPE, clothing, gloves, and eye protection during drilling, cutting and hot work operations (29 CFR 1917 Subpart E and 29 CFR 1918 Subpart J).
  * Inspect any adjacent areas which may be affected by the hot work to ensure all combustible materials are removed, covered or isolated.
  * Open all sampling ports to drain residual products and have a designated person test for the presence of flammable or combustible gases or liquids.
  * When a sampling port is not available, drill a small hole into the structure to facilitate air sampling and testing.  Use sharp bits and blades, and always lubricate the drilling bits and metal blades with cutting oil or soapy water to minimize the generation of heat and sparks.
  * Hollow structures that have contained flammable or combustible substances shall be made safe prior to hot work.  A designated person should be contacted to ensure that an appropriate method is used, (e.g. filled with water, cleaned, pressure-washed, degreased, steamed, and ventilated or inerted).
  * Before heat is applied to a hollow structure, an opening to release built-up pressure during heat application shall be provided (29 CFR 1917.152(c)(8)(ii)).
This is one in a series of informational fact sheets highlighting OSHA programs, policies or standards.  It does not impose any new compliance requirements.  For a comprehensive list of compliance requirements of OSHA standards or regulation, refer to Title 29 of the Code of Federal Regulations.  This information will be made available to sensory-impaired individuals upon request.  The voice phone is (202) 693-1999; teletypewriter (TTY) number: (877) 889-5627.
This is one in a series of informational fact sheets highlighting OSHA programs, policies or standards.  It does not impose any new compliance requirements.  For a comprehensive list of compliance requirements of OSHA standards or regulation, refer to Title 29 of the Code of Federal Regulations.  This information will be made available to sensory-impaired individuals upon request.  The voice phone is (202) 693-1999; teletypewriter (TTY) number: (877) 889-5627.

