# Presentation: 033973

## OSHA 1915.81 Comments

- Presented by Doug Dixon, P.E.
- General manager
-  Pacific Fishermen Shipyard

## Overview

- Existing standards
- Proposed standards with examples

## Existing Standards

- 29 CFR 1910.141 (a) (3) Housekeeping
- (i) Must be kept as clean as work will allow
- (ii) Floor maintained in dry condition, as practicable, water  proof foot wear and drainage provided for wet processes
- (iii) To facilitate cleaning, every floor, working place, and passageway shall be kept free from protruding nails, splinters, loose boards, and unnecessary holes and openings.

## Existing standards

- 1915.91 (a)
- Good housekeeping conditions at all times
- Areas kept clear of tools, materials and equipment not in use
- Areas kept clear of debris
- Hose and electric conductors elevated overhead or covered on ground

## Existing standards

- 1915.91 (b)
- Areas kept clear of debris and materials stacked so high  as to create a hazard
- 1915.91 (c)
- Slippery conditions eliminated as they occur

## Existing standards

- 1915.91 (d)
- Free access to exits, fire extinguishers and emergency alarms
- 1915.91 (e)
- flammable substances kept in fire resistant containers when not in use

## Proposed standards1915.81 (paragraph a through  f) 

- Retain and combine the housekeeping requirements applicable to shipyards (Sec.  1910.141(a)(3) and Sec.  1915.91)
- reorganize and simplify the provisions to make them easier to understand
- OSHA intends that the term ``debris'' continue to include bolts, nuts, and welding rod tips as well as other objects and material that could create a safety or health hazard to employees, such as scrap metal, broken equipment, liquid wastes, tools, and empty containers

## Proposed standards1915.81 (paragraph a through  f) 

- OSHA defines ``walking and working surfaces'‘ to mean any surface on which employees gain access or perform their job duties or upon which employees are required or allowed to walk or work in the workplace
- The proposal, by using the term ``walking and working surfaces'', attempts to ensure that all areas in the shipyard are kept clear

## 1915.81 (a)

- The employer shall maintain good housekeeping conditions to ensure that walking and working surfaces do not create a hazard for employees. The employer shall ensure that these conditions are maintained at all times
*Retains existing requirements thought to prevent slips, trips and falls*

## A clear working and walking surface

- May be deceptive
- Deck is surfaced with Apitong, a hard and slick wood that allows fishing gear (and workers) to slide easily

## A semi clear deck

- Deck is staging for many allied processes that are performed simultaneously

## Another common working and walking surface condition

- Most boats in the shipyard are working boats with equipment and gear for the boat and equipment, tools and materials  for repair operations

## A complex environment

- The presence of allied processes and a chaotic work organization  combine to create the conditions in this photo. Often a workers overhead work surface is another workers walking or working surface

## Ship board passageways

## New construction has similar challenges

## 1915.81 (b)

- The employer shall ensure that walking and working surfaces provide adequate space for work and passage
*Retains the existing requirement with minor editorial revisions*

## Adequate space for work and passage

- The physical layout of space aboard boats and ships often create conditions that do not fulfill this requirement

## Adequate space for work and passage

## Adequate space for work and passage

- Often work is in enclosed or confined space limiting the amount of space for work or passage

## Adequate space for work and passage

- Often shipyard work occurs at height, necessitating elaborate scaffolding

## Adequate space for work and passage

## 1915.81 (c)

- The employer shall ensure that only tools, materials, and equipment necessary to perform the job in progress are kept on walking and working surfaces.
-  All other tools, materials, and equipment shall be stored or located in an area that does not interfere with walking and working surfaces
*the proposal requires that equipment not necessary to perform the job in progress not be stored or located in an area that could interfere with walking and working surfaces*

## Required tools

- Repairs often involve changing schedules and  demands, and  the involvement of allied processes

## Tools and equipment from allied processes

## Rare event: One task

## New construction

## Required tools

- Often ship-board equipment is present, along with ships crew and workers performing allied processes

## 1915.81 (d)

- The employer shall ensure that the floor or deck of every work area shall be maintained, so far as practicable, in a dry condition.
- Where wet processes are used, drainage shall be maintained and the employer shall provide false floors, platforms, mats or other dry standing places.
- Where this is not practicable, the employer shall provide appropriate waterproof footgear, such as rubber overboots, in accordance with Sec.  1915.152
*Retains the existing requirements*

## Maintain dry conditions

- In shipyards, water is ubiquitous, unavoidable and often difficult to control or eliminate

## Maintain dry conditions

## 1915.81 (e)

- The employer shall ensure that walking and working surfaces are kept clear of debris, including solid and liquid wastes, and other objects that may create a safety or health hazard to employees, such as protruding nails, splinters, loose boards, and unnecessary holes and openings
*Combines and simplifies four existing requirements to keep walking and working clear of debris, including solid or liquid wastes, and other objects that may create a safety or health hazard for employees*

## 1915.81 (e) Continued

- All sweepings, solid or liquid wastes, refuse, and garbage shall be removed in such a manner as to avoid creating a menace to health and as often as necessary or appropriate to maintain the place of employment in a sanitary condition
- to facilitate cleaning, every floor, working place, and passageway shall be kept free from protruding nails, splinters, loose boards, and unnecessary holes and openings

## Repairs to infrastructure

## Scrap and debris from allied processes

## 1915.81 (f)

- The employer shall ensure that free access is maintained to exits, fire-alarm boxes, fire call stations, and firefighting equipment
*Retains existing requirements, and adds fire call stations*

## 1915.81 (g)

- The employer shall ensure that slippery conditions, such as snow and ice, on walking and working surfaces are eliminated as they occur
*Retains existing requirements, and clarifies that  snow and Ice are included as conditions *

## A clear working and walking surface

- May be deceptive
- Deck is surfaced with Apitong, a hard and slick wood that allows fishing gear to slide easily

## 1915.81 (h)

- The employer shall ensure that construction materials are stacked in a manner that does not create a hazard to employees
*Retains existing requirements and includes only non-substantive editorial changes*

## Stacking materials (pipe)

## 1915.81 (i)

- The employer shall ensure that hoses and electrical service cords are hung over or placed under walking and working surfaces or covered by crossovers to prevent injury to employees and damage to the hoses and cords
*Retains existing requirements*

## Trees provide scaffolding for overhead hoses, cords and welding leads

## Overhead handling of cords and hoses introduces a new hazard 

## 1915.81 (j)

- The employer shall ensure that flammable substances, such as paint thinners, solvents, rags and waste, are stored in covered fire-resistant containers when not in use
*Retains existing requirements*

## 1915.81 (k)

- The employer shall ensure that combustible scrap is removed from work areas as soon as possible
*Proposal adds a requirement that combustible scrap be removed from the work area as soon as possible to reduce fire hazards*

## Scrap and debris from allied processes