        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.



HKnown 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. 

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 any combustible material is  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,
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.

