Safe Work Practices

for Shipbreaking

OSHA 3375-03 2010
Occupational Safety and Health Act of 1970

“To assure safe and healthful working conditions

for working men and women; by authorizing enforcement of the standards developed under

the Act; by assisting and encouraging the States in

their efforts to assure safe and healthful working

conditions; by providing for research, information,

education, and training in the field of occupational

safety and health.”

This publication provides a general overview of a

particular standards-related topic. This publication

does not alter or determine compliance responsibilities

which are set forth in OSHA standards, and the Occupational Safety and Health Act of 1970. Moreover, because interpretations and enforcement policy

may change over time, for additional guidance on

OSHA compliance requirements, the reader should

consult current administrative interpretations and

decisions by the Occupational Safety and Health

Review Commission and the courts.

Material contained in this publication is in the public

domain and may be reproduced, fully or partially,

without permission. Source credit is requested

but not required.

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impaired individuals upon request. Voice phone:

(202) 693-1999; teletypewriter (TTY) number: 1-877-

889-5627.
Safe Work Practices

for Shipbreaking

Occupational Safety and Health Administration

U.S. Department of Labor

OSHA 3375-03

2010

Cover photo courtesy of H. Reid, Metro Machine Incorporated.
This guidance document is not a standard or regulation, and it creates no new legal obligations.

It contains recommendations as well as descriptions of mandatory safety and health standards.

The recommendations are advisory in nature, informational in content, and are intended to assist

employers in providing a safe and healthful workplace. The Occupational Safety and Health Act

requires employers to comply with safety and health standards and regulations promulgated by

OSHA or by a state with an OSHA-approved state plan. In addition, the Act’s General Duty

Clause, Section 5(a)(1), requires employers to provide their employees with a workplace free

from recognized hazards likely to cause death or serious physical harm.

Start to Finish

Photos courtesy of Metro Machine Incorporated

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Occupational Safety and

Health Administration
S A F E W O R K P R A C T I C E S F O R S H I P B R E A K I N G

Contents

Introduction 4

Interagency Work Group 4

Steps in Shipbreaking Process 4

Initial Visit to Vessel to Determine

Suitability for Scrapping 6

Towing the Vessel 7

Mooring the Vessel 7

Hauling the Vessel 8

Planning 9

Breaking the Vessel 9

Burning Equipment 10

Cold Cutting 11

Mobile Hydraulic Shear Cutters 11

Shoreside Processing of Metals 11

Fall Protection 11

Fire Prevention and Protection 12

Emergency Response 13

Drills 13

Rescue 14

Lifesaving Materials 14

Hazardous Material Spills 14

Energy Control 14

Medical 15

Worker Medical Qualifications 16

Sanitation 16

Shipboard Rigging 16

Materials Handling 16

Crane Services 17

ForkTrucks 18

Trucks 18

Training 18

Communication 19

Maintenance Shops 19

References 20

Additional Resources 22

OSHA Assistance 23

OSHA Regional Offices 25

3
Introduction

Shipbreaking is a unique part of the maritime industry, primarily involving the dismantling and disposal

of obsolete U.S. Navy and Maritime Administration

ships, as well as commercial barges and mobile offshore drilling units. For many years, much of this

work was contracted to overseas companies. However, in recent years the exporting of ships from the

United States to foreign countries for scrapping has

come under criticism due to concerns over worker

safety and health, and adverse environmental impacts. As a result, the exporting of ships for scrapping was stopped by the Navy in December 1997

and by the Maritime Administration (MARAD) in

January 1998.1 Consequently, shipbreaking by domestic companies is rapidly growing, and there is a

need to improve shipbreaking (e.g., dismantling,

ship recycling, or scrapping) processes to ensure the

safety and health of these workers.

Dismantling of vessels is usually conducted at a

pier, drydock, or dismantling slip and includes a

wide range of activities, from removing all gear and

equipment to cutting down and recycling the ship's

structure. The structural complexity of ships makes

shipbreaking a challenging process. It involves

many safety, health and environmental issues, including exposure to asbestos, toxic fumes, hazardous materials, noise, falling objects, lead and

electrical shock, as well as dangers associated with

heat stress, falls, heavy materials handling and

fires.2 In light of the need to improve and manage

the hazards associated with shipbreaking, this document is to be used as a basic guide for employers

involved in shipbreaking activities. The hyperlinks to

OSHA, international, and other documentation provided throughout this publication give more detailed

information and recommendations.

This document does not cover all of the regulations governing the occupational safety and health

aspects of shipbreaking. However, it highlights important information through references and hyperlinks to OSHA regulations that can be used to help

employers develop a comprehensive Safety and

Health Management System (SHMS), encompassing

all aspects of a facility’s shipbreaking procedures and

processes. The appropriate Code of Federal Regulations (CFR) provisions must be incorporated in all

safety and health plans, and the safety processes

and programs must be managed to reduce risk and

provide a safe and healthful worksite for all workers.

In addition, employers must be aware of and comply

with all local and state regulations, which may be

more stringent than federal requirements.

Interagency Work Group

In December 1996, the Department of the Navy, the

Defense Logistics Agency (DLA), the U.S. Maritime

Administration (MARAD), and the U.S. Coast Guard

(USCG), along with other involved agencies, began

meeting quarterly to discuss shipbreaking program

improvements and to share evaluation procedures

and oversight information. In February 1998, the

group was formally chartered as the Interagency

Panel on Ship Scrapping. The work of the group

resulted in a set of recommendations that were

presented in the April 20, 1998, Report of the Interagency Panel on Ship Scrapping. The recommendations covered many aspects of the shipbreaking

industry, including contracting improvements, performance bonds, data gathering and pilot projects,

polychlorinated biphenyls (PCBs) guidance, regulatory oversight and international issues.

Under the category of regulatory oversight, the

panel recommended that the Environmental Protection Agency (EPA) and OSHA, in conjunction with

DLA, the U.S. Navy, and MARAD, develop a comprehensive compliance guide. This guide, entitled A

Guide for Ship Scrappers,

3 outlines the relevant environmental and occupational safety and health requirements applicable to shipbreaking. The guide

contains recommendations for completing shipbreaking operations in a safe and environmentally

compliant manner.

Steps in Shipbreaking

Process

After removal from the fleet site, the vessel is towed

or self-propelled to the site where scrapping will

occur. The vessel is then scrapped while being

moored to a pier, anchored, beached, or dry-docked

(including graving docks). Most scrapping is performed pier-side in slips, which are typically

dredged openings that are adjacent to a shipping

channel. Slips are approximately 400 to 1,000 feet

long and 100 to 140 feet wide at the entrance. Shipbreaking is generally performed by cutting away

large sections, which are then moved to shore for

further dismantling. A large winch at the head of the

slip is used to drag the hull farther out of the water

as work progresses. Throughout the scrapping

process, it is important for the appropriate safety

precautions to be determined and followed to effectively protect personnel. The scrapping process4

usually occurs in a series of steps:

4

Occupational Safety and

Health Administration
• Conduct a vessel survey.

5 Diagrams of all compartments, tanks and storage areas are used (or

prepared, if not available) to identify areas that

may contain hazardous materials such as fuels,

oils, asbestos, PCBs, lead and other hazardous

wastes. Sampling is conducted using a systematic approach, usually starting in the compartment that will be cut first. In many cases, a

facility will presume that certain items contain

hazardous materials and dispose of them as

such, in lieu of sampling. In such cases, the employer must use proper engineering controls and

work practices to ensure that workers, involved

with and in the vicinity of the removal, are properly protected from exposure (e.g., through the

use of wet methods, or wetting agents, and vacuums with HEPA filters).

• Remove fuels, oils, other liquids and combustible

materials. The removal of fuels, oils and other

liquids (e.g., bilge and ballast water) from the

ship generally occurs throughout the shipbreaking process. Bilge water is sampled and disposed

of appropriately. In addition, during the vessel

scrapping process, water may accumulate due to

rain, firefighting activity, or use of hot work cooling water, and will have to be properly removed.

The U.S. Coast Guard requires booms to be

placed around the vessel to help contain any

spills (See OSHA publication 3172 (2001), Training Marine Oil Spill Response Workers Under

OSHA’s Hazardous Waste Operations and Emergency Response Standard ). Following removal

activities, a marine chemist6 certifies that the vessel is safe for entry and safe for hot work. A

competent person must continually monitor

these areas to ensure that they are still in compliance with the marine chemist’s certificate.

• Remove equipment. Fixtures, anchors, chains

and small equipment are removed first. Large

reusable components (e.g., engine parts) are removed as they become accessible. Propellers

also may have to be removed so that the hull can

be pulled into shallow water.

• Remove and dispose of asbestos and PCBs.

Both asbestos-containing materials (ACMs) and

PCBs are usually removed in two stages. Prior to

cutting away a section of the vessel, ACM is removed from areas that are to be cut and PCBs

are removed from areas that are readily accessible. After the vessel section has been moved to

shore, the remaining ACMs and PCBs are removed as they become accessible during the dismantling of the vessel section. The engine rooms

usually contain the most asbestos and, therefore,

take the longest for asbestos removal to be conducted.

• Prepare surfaces for cutting. Following the removal of combustible materials, asbestos and

PCBs, paint or preservative coatings must be

stripped from surfaces to be cut (29 CFR 1915.53).

Hard-to-remove materials on surfaces may require specific cut-line preparation, such as grit

blasting or flame removal of paint,7 which can

expose workers to toxic metals and volatile components of paint. Appropriate precautions must

be taken (e.g., the use of airline respirators) to effectively protect personnel performing the removal, as well as those workers in the immediate

area (see 29 CFR 1910.134).

• Cut metal. During the cutting phase, the upper

decks, superstructure and systems are cut first,

followed by the main deck and lower decks.

Metal cutting is usually done manually using

oxygen-fuel cutting torches, but may be done

with shears or saws for nonferrous metals. Typically, as large parts of the vessel are cut away,

they are lifted by crane to the ground where they

are then cut into specific shapes and sizes required by the foundry or smelter to which the

scrap is shipped. As cutting continues and the

weight of the structure is reduced, the remaining

hull floats higher, exposing lower regions of the

hull. Ultimately, the remaining portion of the hull

is pulled ashore and cut.

• Recycle or dispose of materials. Scrap metals,

including steel, aluminum, copper, copper nickel

alloy and lesser amounts of other metals are

sorted by grade and composition, and sold to

remelting firms or to scrap metal-brokers. Valuable metals such as copper in electric cable that

are mixed with nonmetal materials may be recovered using shredders and separators. The

shredders produce a gravel-like mixture of recyclable metal particles and nonmetal “fluff,”

which is not recyclable and needs to be sampled

for hazardous materials and disposed of according to state and federal regulations. The metals

are then separated from the fluff using magnetic

separators, air flotation separator columns, or

shaker tables.

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Initial Visit to Vessel to

Determine Suitability

for Scrapping

Before any work is conducted, an initial visit to the

vessel is required to determine its condition. During

this visit, the following must be identified: the hazardous materials (e.g., lead, asbestos, PCBs) that

must be removed from the ship, the hazards that

workers could be exposed to during the scrapping

operations, and the condition of the ship, including

its suitability for towing and seaworthiness. From

the information obtained, a sampling plan8 must be

developed to address environmental remediation

and the health hazards9 identified, including the special tools and equipment that will be required to ensure worker safety. When workers are aboard the

ship for this assessment, those who are required to

work alone must be checked on frequently, as required by 29 CFR 1915.94. To comply with this requirement, employers should make arrangements

with the ship’s custodian for worker escorts during

this visit. The custodian should be consulted with to

identify unknown hazards such as missing decking,

open holes, or areas that may need to be gas-free.

Navy vessel pier-side for shipbreaking, Ex-USS Forrestal.

The Hazard Communication standard, 29 CFR

1915.1200, requires that employers communicate information about health hazards to workers and that

they have material safety data sheets (MSDSs) available for all hazardous materials handled or used in

the shipbreaking process. OSHA standards for specific substances are generally performance based

and require the protection of personnel from hazards through compliance with permissible exposure

limits, exposure monitoring, medical surveillance,

use of respirators and protective clothing, and other

requirements (see 29 CFR 1915, subpart Z). Some

specific hazards of shipbreaking include:

• Freon10 commonly found in refrigeration systems

that, if released, could evaporate rapidly to create

atmospheres immediately dangerous to life or

health (IDLH).

• Halon11 and carbon dioxide12 in fire suppression

systems that can create IDLH atmospheres if they

are released into spaces. Manual and free-flood

automatic fire-suppression systems must be

physically isolated or employ other positive

means to prevent discharge before any hot work

is permitted in spaces protected by such systems

(29 CFR 1915.506).

• Hydrogen sulfide13, a colorless, toxic and flammable gas that can result from the decomposition of microscopic marine life killed by Aqueous

Film Forming Foam (AFFF) mixed with seawater

in AFFF wet firefighting systems.

• Carbon monoxide (CO)14, a colorless and odorless gas that is produced by the combustion

process such as welding, spontaneous combustion, and internal combustion engines. Prolonged exposure may result in headaches,

nausea, dizziness and ataxia.

• Metals of concern may include:

■ Lead15 in paints and some greases, or possibly as tetraethyl lead16 for use as an additive

in fuels;

■ Mercury17 in gauges, tank-level indicators, or

fluorescent light tubes;

■ Tributyltin oxide18 on underwater hull plates;

■ Chromates19 in paints and varnishes;

■ Cadmium in electrical and electronic equipment; and

■ Arsenic paints.

• Oxygen deficiency20due to rusting in tanks that

have been sealed for long periods of time.

• Toxic contamination due to hazardous cargoes

that may have been carried in tanks.

• Asbestos exposure for workers removing asbestos-containing thermal insulation; handling

circuit breakers, cables, and cable penetrations;

and removing floor tiles (from asbestos in the

mastic and in tile). Additional concerns can arise

from handling and removing gaskets from piping

systems and from electrical systems. Asbestos

may also be found in some molded plastic parts.

All asbestos must be identified, removed and

handled in accordance with 29 CFR 1915.1001.

Asbestos removal is also regulated by the EPA

under the asbestos National Emissions Stan6

Occupational Safety and

Health Administration Occupational Safety and Health Administration
dards for Hazardous Air Pollutants (NESHAP),

40 CFR 61 Subpart M. Many states require, and

OSHA recommends, that an AHERA-qualified

(Asbestos Hazard Emergency Response Act of

1986) asbestos inspector identify all asbestoscontaining materials prior to beginning shipbreaking oerations. Some states also require that

employers notify their environmental regulatory

agencies prior to conducting asbestos removal

operations.

• Polychlorinated biphenyls (PCBs) in rubber products such as hoses, plastic foam insulation, cables, silver paint, habitability paint, felt under

septum plates, plates on top of the hull bottom,

and primary paint on hull steel.

Additional information on health hazards associated with shipbreaking can be found in the OSHA

Shipbreaking Fact Sheet.21

.

The Roger Stahl towing the Saginaw from Duluth on 10/24/99.

Towing the Vessel

Dead-vessel tows are regulated by the U.S. Coast

Guard at 33 CFR 165 et seq. Administrative procedures for towing vessels are established by local

Coast Guard Sectors, so employers should contact

their respective Captain of the Port (COTP) to determine local policy; see Port Directory. Usually, a request for a dead-ship tow is required to be submitted

at least 48 hours in advance, if the tow is within the

port, and seven days in advance, if the tow is outside the port. Typically, this task is handled by the

contracted towing company.

Generally, the request must contain the following

information about the towed vessel: name, call sign,

flag, length, draft, sail height, and the type, amount,

and locations of oil and other hazardous materials

onboard. However, the required information may

vary depending on the port. Tank diagrams are recommended to detail the location of oil and other

hazardous materials. The request must also contain

the total number of tugs and their horsepower, place

of departure and destination, the date and time of

departure, the duration of the tow, and the name

and 24-hour telephone number of the responsible

party. Indicate if an unusual tow configuration will

be used or if the request is for more than one towed

vessel.

Depending on the particulars of the vessel being

towed (e.g., age, extended lay-up status, vessel condition, etc.), the COTP may require that additional

safety precautions be established before the tow is

authorized. This may include requirements such as

obtaining a marine surveyor’s report, verifying the

vessel’s seaworthiness, or allowing a representative

from the Coast Guard to examine the vessel to verify seaworthiness, pollution potential, and the adequacy of the towing arrangement. Such a report will

include the recommended towing configuration, a

condition inspection to evaluate seaworthiness, a

determination of which personnel will be allowed on

board during the tow, and any other special instructions to allow for a safe tow.

In certain circumstances an International Load

Line Exemption Certificate or a Coastwise Single

Voyage Load Line Certificate may be required in accordance with 46 CFR 42 Subchapter E (Load Lines).

To make this determination and schedule an examination, requests for tows offshore (e.g., beyond the

boundary line) must be submitted seven days in advance.

Mooring the Vessel

Vessels that are intended for pier-side scrapping

need to be properly secured using approved mooring lines and a mooring plan reviewed by a qualified

professional, such as a naval architect or marine engineer. The facility should have a Heavy Weather

Plan, which includes additional mooring requirements for high and low tides, hurricanes, and other

adverse weather conditions. Mooring bits should be

engineered to have sufficient strength to withstand

forces imparted by all weather conditions. It is recommended that ships not be moved during winds

exceeding 25 knots.

Personnel assigned to assist in line handling

should be experienced in line handling and must

wear personal flotation devices22 (PFDs) when there

is a potential for falling into the water, as required by

29 CFR 1915.152(a). Personnel must be kept clear of

Photo: Al Miller

S A F E W O R K P R A C T I C E S F O R S H I P B R E A K I N G

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the lines and never stand in the bight of a line.

Nylon lines, primarily used on older ships, are subject to atmospheric damage (e.g., sunlight, weathering, etc.) and may break without warning, releasing

large amounts of energy capable of killing or maiming workers.

Spill-containment booms must be placed around

all vessels, and personnel should be trained in the

procedures for opening and closing the booms.

Care should be taken to keep small boats, located

between booms, from being crushed due to unanticipated vessel movement. Fenders or other breasting

devices should be used to prevent such an incident.

Operators of small boats must wear U.S. Coast

Guard-approved PFDs and have on board a life ring

with 90 feet of line.

Workers must be denied access to the vessel

until a gangway, ladder, or ramp meeting the requirements of 29 CFR 1915.74(a) and (b) and 29 CFR

1915.75(a) thru (d) is provided. Particular attention

should be paid to the trim of the gangway, ladder, or

ramp, where the fall or rise of tides may cause the

angle to become unsafe, or pull away from its support. Means should be provided to deny access to

the vessel by unauthorized personnel during nonwork hours.

Vessel in dry dock for scrapping.

If work is conducted at night, adequate lighting23

must be provided and maintained at all times as required by 29 CFR 1915.92(a). In shipbreaking operations, the ship’s lighting may be difficult to maintain

and, therefore, should be considered unreliable. If

ship’s lighting is used, a secondary means of lighting (e.g., temporary lighting or personal flashlights)

must be provided as required by 29 CFR 1915.92(e).

Personal flashlights must be intrinsically safe or explosion-proof as required by 29 CFR 1915.13(b)(9).

Light-emitting diode (LED) flashlights are recommended for use in gas-free spaces due to their small

size, durability and dependability.

Example of temporary lighting.

Hauling the Vessel

It is important, before hauling a vessel24 out of the

water, that an evaluation of the stability of the vessel

be conducted. Forces can develop that could make

the vessel unstable and cause it to tip over. Personnel must not be aboard a vessel while it is being

pulled ashore, since it is possible for the vessel to

topple over or for sections to break, creating severe

hazards for workers onboard. A naval architect or

marine engineer who has extensive experience

docking ships should evaluate the ship for stability

prior to hauling the vessel to ensure a safe operation.

Hauling machines and chains or wire ropes are

used in the hauling process to move vessels in the

water and on shore. This equipment is affected by

the weight of the vessel, the incline of the slope, the

friction between the hull and the slope, and any

change in the rate at which the vessel is hauled.

When more than one chain or wire rope is used, the

loading must be equalized among the chains or wire

ropes to ensure that no single leg is overstressed. It

is imperative that the equipment operators are

aware of the hazards associated with the hauling

process and have the ability to quickly compensate

for torque or variation in pitch.

Hauling machines usually consist of a train of

gears, operated by electric motors turning one or

more toothed chain wheels driving the hauling

chain. The moving parts of hauling equipment must

be guarded as required by 29 CFR 1915.115(b).

Steel hauling chains with appropriate pitch and

uniform link dimensions should be used for hauling

the ship. Because of their high tensile strength and

the ease with which they can be connected with

Courtesy H. Reid, Metro Machine Incorporated

Courtesy of Metro Machine Incorporated

8

Occupational Safety and

Health Administration
special hauling shackles, which are as strong as or

stronger than the chain itself, most scrappers find

chains more durable and economical than the best

wire rope. The ability to measure the strength of

chains is a major advantage that chains have over

wire ropes. These chains, fitted over alloy steel

wheels, have a small pitch diameter that permits

hauling heavy loads with relatively small hauling

machines. A chain swivel is recommended to prevent excessive twist, which could cause an overload

of one section of chain.

It is particularly important to protect chains from

abrasion caused by sliding through sand, gravel, or

silt. In some installations, a means for washing the

sand off the incoming chain should be provided.

Chains should be inspected frequently for wear and

removed from service when they become excessively worn or do not meet the manufacturer’s recommendations. Caliper measurements can be used

to determine the strength and corresponding safe

live load of chains at any stage of wear.

Rivers are often subject to wide ranges of water

level, with periods of low water lasting several

months, interchanged with shorter periods of high

water. The vessels traveling such rivers are, of necessity, shallow-draft, flat-bottomed craft of light

construction. A side-hauling method may be used

when dealing with such vessels in rivers, but would

not be appropriate for hauling ocean-going vessels.

This method should be chosen only after careful

study by a qualified naval architect or marine engineer to determine if it is a suitable method.

The principal technical disadvantage of the usual

side-haul arrangement, handled by several parts of

chain or wire rope, is that the load on any component cannot be accurately determined. Therefore, it

is impossible to use an equalizing system. Consequently, it is necessary to use oversized chains or

wire ropes to avoid possible overload.

Some employers use all-terrain forklifts or bulldozers to pull vessels ashore. When this practice is

used, it should be done only in accordance with the

manufacturer’s recommendations. This system

should be evaluated and approved by a naval architect or marine engineer before being used. No modifications or additions may be made to a forklift to

allow hauling of vessels without the manufacturer’s

prior written approval as required by 29 CFR

1910.178(a)(4). Any equipment used for this purpose

should be protected with a rollover protective structure, and operators should wear seat belts. Additionally, workers should be kept clear of the line of pull

of the chains or wire rope used, and a suitable guard

may need to be installed to protect the operator of

the hauling machine from being struck by a breaking chain or wire rope.

Planning

It is important for employers to have a safety and

health management system (SHMS) in place that

encompasses all aspects of the facility’s shipbreaking procedures and processes. The SHMS should

consist of a technical plan, safety and health plan,

and an environmental technical plan, which can be

altered for each specific job. A written technical plan

should outline the scrapping process, schedule, cut

lines, and other engineering factors specific to each

project, to ensure that the vessel is scrapped in a

systematic manner to protect property and personnel. Drawings of the vessel should be obtained and

broken down by work areas to allow a naval architect or marine engineer to develop a cut plan so that

the weight and stability of each vessel section can

be assessed at each stage to ensure a safe operation. A safety and health plan or manual should

cover all aspects of the shipbreaking process and

specify actions to be taken in the event that an emergency occurs. An environmental technical plan

should address remediation of all hazardous materials. Each plan must be developed in accordance

with federal, state and local laws. Daily production

meetings should take place to discuss the day’s

events, upcoming critical processes and procedures,

and any safety considerations or special instructions

needed to complete the day’s tasks safely. A morning safety talk should be scheduled to discuss safety

and health issues that will be faced on that day, or

other topics for educational and special emphasis

purposes.

Breaking the Vessel

One of the first steps in breaking the vessel is the removal of hazardous and flammable materials, which

is often called the drilling and draining phase (or

pumping phase). Drilling refers to the act of drilling

holes in systems to allow the release and capture of

fluids in the systems. It may also involve opening

drain ports already installed in the system. Holes

are drilled at the lowest possible points in the system to ensure that the system is completely drained

of fluids. Draining involves removing all hazardous

fluids and materials from the ship’s systems including hydraulic, cooling, high-pressure air, steam condensate, preservatives in rudders and skegs, and

fire-suppressant materials such as AFFF (aqueous

film-forming foam), halon and carbon dioxide. It is

important to consider the hazards that this process

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9
creates, and they should be treated accordingly.

Personal protective equipment (PPE) must be provided to personnel to prevent them from coming

into contact with liquids, oils, greases and materials

that could cause skin and eye irritation (29 CFR

1915.152(a)). All PPE should be selected by appropriately trained personnel and examined for proper fit.

Further, atmospheric testing by a competent person

is required while these systems are being drained

(29 CFR 1915.12(a)). Testing must be performed in

each space or area that workers are required to

enter or conduct work. This testing must occur in

the following sequence: oxygen content, flammability and toxicity.

No hot work is allowed in spaces that contain active fixed fire-extinguishing systems that have not

been isolated to prevent discharge. If this precautionary step is not followed, the system could release its contents into the space, producing a

dangerous atmosphere.

As hazardous materials are drained from systems, the materials should be segregated by substance and kept separate. Mixing hazardous

materials may cause uncontrolled chemical reactions between materials, resulting in exothermic reactions (excessive heat or fire), release of toxic

gases, or other reactions that could injure personnel

or cause an environmental spill.

Several procedures/processes may occur simultaneously during the drilling and draining phase, including hazardous materials remediation, removing

recyclable items, and extracting easily removed interior components. This process helps remove as

many components as possible from the interior of

the vessel, creating a tunnel effect, to allow cutting

to begin from the top down. Cutting then proceeds

from each end of the vessel, working towards the

center of the vessel (see the diagram below – Module Cut Plan).

A sample Module Cut Plan.

This multifaceted approach requires excellent

planning and constant safety oversight so that workers are aware of what operations are ongoing and

where they are occurring aboard the vessel. The

daily safety talk can be a valuable tool for informing

workers of planned operations for the day.

As the work progresses, good housekeeping

must be maintained to reduce hazards and provide

safe work surfaces and areas for workers. Solid

wastes should be promptly removed and properly

disposed of to aid in maintaining a safe work area.

Worker torch-cutting scrap metal from vessel.

Burning Equipment

Burning equipment used in cutting metals must be

provided with regulators and flashback arrestors

should be installed. Lighter-than-air gases (e.g.,

acetylene, natural gas) are recommended because

they do not pool in low areas as heavier-than-air

gases (e.g., argon, propane, carbon dioxide) tend to

do. Lines should be inspected frequently for damage

and should be routed to avoid damage and to avoid

tripping hazards for workers. Lines must not be left

in enclosed spaces while unattended for longer than

15 minutes (29 CFR 1915.503(b)(2)(ii)). Pressure-drop

tests or other positive measures should be conducted on the lines each time that they are connected to a manifold to ensure their integrity, so that

there are no leaks within the burning system (29

CFR 1915.503(b)(2)(iv)). At the end of each shift the

torch lines should be rolled back to the manifold.

Fittings for gas lines must be incompatible with respiratory equipment to avoid mixing toxic gases with

breathing air.

Compressed-gas cylinders must not be taken into

confined spaces. During storage, oxygen cylinders

must be separated from fuel-gas cylinders by a minimum of 20 feet or by a 5-foot high barrier with a

minimum half-hour fire resistance rating. When

Courtesy of Metro Machine Incorporated

Photo by Chris Tyree, The Virginian Pilot

1 0

Occupational Safety and

Health Administration
cylinders are not in use, they must be disconnected

and have valve protection caps in place. Cylinders

should be stored in an upright and secured position

away from high traffic areas.

Cold Cutting

Cold cutting of vessels presents numerous hazards

to workers. Therefore, it is imperative that reciprocating saw blades are kept sharp to prevent malfunctions that can lead to possible injuries. This

practice will speed production as well. Since saws

create noise sufficient to cause hearing loss, hearing

protection must be provided to and be used by

workers operating or working in close proximity to

the saws (see 29 CFR 1910.95). Additionally, ergonomically-designed gloves should be used to minimize vibration exposure to workers. The employer

must ensure that the power supply to reciprocating

saws is provided with ground-fault circuit interrupters

(see 29 CFR 1910 Subpart S). Electrical cords must be

maintained in sound condition and routed or protected so as to prevent damage to the cords and

avoid creating a tripping hazard for workers.

Mobile Hydraulic Shear Cutters

Mobile shear cutting is prevalent in shipbreaking

and presents several hazards to personnel. Workers

must not place any part of their bodies in the danger

zone of the equipment (e.g., the shear area). When

this type of machine is mounted as an attachment

on a backhoe or excavator-type machinery, the

swing radius should be barricaded to prevent workers from coming into the pinch-point area between

the rotating structure of the machine and its drive

carriage or other fixed objects, such as the part of

the ship being scrapped. Care should be taken to cut

materials to prevent recoil and to keep large pieces

from striking or falling on workers.

Mobile hydraulic shear cutters used in shipbreaking.

Shoreside Processing of Metals

Scrap metals, including steel, aluminum, copper,

copper nickel alloy, and lesser amounts of other

metals, are sorted by grade and composition and

sold to remelting firms or to scrap metal brokers.

Valuable metals, such as copper in electric cable,

that are mixed with nonmetal material may be recovered using shredders and separators. The shredders produce a gravel-like mixture of recyclable

metal particles and non-metal “fluff” that is not recyclable and needs to be sampled for hazardous

materials and disposed of according to state and

federal regulations. The metals are then separated

from the fluff using magnetic separators, air-flotation separator columns, or shaker tables. Machine

guarding must be provided in accordance with 29

CFR 1910.212 and 29 CFR 1910.219. Guards should

be interlocked to shut down the equipment in the

event that the guard is opened. Noise exposure

must be controlled in accordance with 29 CFR

1910.95. An industrial hygiene assessment of metals

exposure must be conducted and controls implemented to maintain worker exposures within acceptable limits. Asbestos must be removed in

accordance with 29 CFR 1915.1001 before processing scrap metal. Measures must be taken to prevent

skin contact with polychlorinated biphenyls (PCBs).

Additionally, PCBs must be cleaned from cut lines of

materials that are to be cut by burning (see 29 CFR

1915.53(d)(1)).

Care must be taken to ensure that workers do not

position themselves beside or below a section being

cut, where falling pieces of scrap or the section

might strike them. Pieces being cut often become

unstable, shift, fall or slide. Therefore, workers must

be positioned so that they are not subject to being

struck by shifting materials (see 29 CFR 1915.116(j)

and (k)). Several fatalities have been recorded where

scrap metal pieces or sections crushed workers

walking through cutting areas.

Fall Protection

Falls are a major hazard in shipbreaking due to the

ever-changing work environment. Continuous cutting of the vessel weakens the structures or sections

and creates new openings and deck edges, making

fall protection a necessity. Workers need to wear

safety harnesses and be tied off when near open

holes and deck edges. Anchorage points for each

positioning device system must be capable of supporting at least double the potential impact load of a

worker’s fall (29 CFR 1915.160(a)(3)). In addition, lifelines must be kept clear from sharp edges to avoid

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Occupational Safety and Health Administration
the lines from being cut or damaged (see 29 CFR

1915.159(c)(4)). Although the requirement in 29 CFR

1915.73 (“Guarding of deck openings and edges”)

does not apply to shipbreaking, it is recommended

that barriers be placed around or near deck edges

and openings whenever feasible.

Examples of fall protection.

The lack of a requirement to guard deck edges

and openings does not remove the employer’s responsibility to protect workers from fall hazards

through the use of appropriate fall protection systems. In certain circumstances, during the shipbreaking process, workers are required to work from

aerial lifts and man lifts that are suspended by

cranes to reach elevated areas for cutting. In these

situations, it is also important for appropriate fall

protection to be used.

Side shell cuts are made, leaving 42-inch high bulkhead at

the deck level for fall protection.

Fire Prevention and

Protection

Subpart P - Fire Protection in Shipyard Employment,

29 CFR 1915, requires employers to have an overall

fire suppression program that establishes the location, type and capacity of firefighting equipment

such as extinguishers, fire hoses and standpipes,

smoke detectors, automatic sprinklers and other

fixed firefighting systems in accordance with applicable fire codes. Employers must have a written

plan in place that provides for the routine inspection, maintenance and replacement of this equipment and must require training for new workers and

refresher training for all shipyard workers. The written plan must include procedures for the control of

fire hazards, such as flammable and non-flammable

compressed gases, ignition sources, combustible

All photos courtesy of Metro Machine Incorporated

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Occupational Safety and

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materials, welding and hotwork operations and

must include procedures for evacuation. The employer’s evacuation plan must include the following:

emergency escape procedures; procedures to be followed by workers who may remain longer in the

worksite to perform critical shipyard operations before they evacuate; procedures to account for all

workers after an emergency evacuation is completed; preferred means for reporting fires and other

emergencies; and the names or job titles of the

workers or departments who may be contacted for

further information or explanation of duties.

The hazards associated with the use of fixed fireextinguishing systems on vessels and vessel sections have long been recognized by the U.S. Coast

Guard as evidenced by Coast Guard Commandant

Notices and Instructions that date from 1978. The International Maritime Organization (the United Nations’ specialized agency responsible for improving

maritime safety and preventing pollution from

ships) has also addressed these hazards by issuing

regulations that are part of the International Convention for the Safety of Life at Sea. 29 CFR 1915.506(b)

requires employers to protect their workers who

may be exposed to a dangerous atmosphere caused

by a fixed fire-extinguishing system by either physically isolating the system, disconnecting or blanking, or using other positive means to prevent the

system’s discharge. In shipbreaking operations,

OSHA recommends that the system be physically

disabled. In general, there should be no work conducted with the system activated. However, should

such a situation occur, the employer must ensure

that workers are trained to recognize the system’s

discharge and evacuation alarms, appropriate evacuation routes and hazards associated with components of the system.

Employers must have a written fire watch policy

that specifies the necessary training of workers, their

duties and personal protective equipment (PPE) to

be used. This policy may be part of the overall fire

safety plan or separate, but must be effective in protecting workers from injury. A firewatch must be

posted while hot work is being performed when any

of the following conditions are present: slag, weld

splatter, or sparks; unprotected combustible materials or insulation; and heat radiation or conduction

on insulated pipes, bulkheads, decks, overheads and

partitions (see 29 CFR 1915.504). It is important that

workers assigned to firewatch duty are not tasked

with any additional duties while hot work is in

progress. In addition, the firewatch must be able to

communicate with the workers performing the hot

work, as well as any personnel that may be affected.

Method used for emergency response and fire-prevention

planning.

Emergency Response

In addition to compliance with 29 CFR 1915.502,

which includes a fire safety plan, OSHA requires

compliance with 29 CFR 1910.38 and 29 CFR 1910.39

for emergency response and fire prevention planning. Employers do not need to have separate emergency response plans as long as the plan covers the

applicable general industry worker emergency plan

and fire prevention plan provisions, as well as the

shipyard employment fire safety plan. A mustering

plan for each jobsite should be incorporated in the

emergency response plan to account for all workers

in the event of an emergency where evacuation is

required. Each plan or combination of emergency

response plans must be in writing, kept in the workplace and be available to workers for review.

Drills

A fire response organization, as defined in 29 CFR

1915.509, may include (1) fire brigades, (2) shipyard

fire departments, (3) private or contractual fire departments, or (4) municipal fire departments.

While larger shipyards may have their own fire

responders, smaller shipyards often use an outside

source, typically the local fire department. These

municipal or other fire departments may have little

experience in fighting fires in shipyards, especially

on vessels. Fighting vessel fires can be more complicated than traditional firefighting because outside firefighters seldom have the opportunity to

learn the layout of the vessels. Additionally, vessels

being scrapped have constantly changing structures. Therefore, proper coordination, familiarization, training and drills are necessary to ensure the

safety of outside firefighters who respond to shipyard fires. See 29 CFR 1915.505 for OSHA safety requirements. Courtesy of Metro Machine Incorporated

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If an outside fire response organization is used,

OSHA requires employers to communicate with that

organization about facility layout and familiarization,

and coordination protocols (29 CFR 1915.505). OSHA

believes that any fire response organization that expects to respond to shipyard fires will benefit from

this coordination. They will be able to respond to

fires quickly and effectively, thus enhancing safety

for the shipyard workers and their own fire response

team members.

In coordinating drills and other communications

with an outside fire department, employers must

discuss the types of fire suppression incidents to

which the fire response organization is expected to

respond to and procedures for obtaining help from

other fire response organizations. Additionally,

methods of familiarizing the external fire response

organization with the layout of the facility or worksite, including access routes to controlled areas and

site-specific operations, occupancies, vessels or vessel sections and hazards should be discussed. The

employer must ensure the standardization of all firehose couplings and connection threads throughout

the shipyard and on vessels or vessel sections by

providing the same type of hose coupling and connection threads for hoses of the same or similar diameter. See 29 CFR 1915.505 (f)(2)(ii).

Responders to shipyard fires encounter a complex set of hazards involving buildings, as well as

vessels in drydocks, wet slips, or pier-side. Fire responders need to be prepared to safely and successfully handle a wide range of fires from flammable

liquids in a storage room of a shipyard building, to

oil-soaked rags in the engine room of a ship. The

fires could include: combustible materials (such as

wood, paper, or cloth); flammable or combustible

liquids (such as oil, fuels, paints, or chemicals); insulation and other materials that may give off toxic

gases and smoke during a fire; electrical components (such as energized motors, circuit controls,

transformers, or wiring); or even combustible metals (such as magnesium or titanium).

Rescue

A rescue team must be established to respond

promptly to rescues required in confined and enclosed spaces or other areas where dangerous atmospheres may be present. The rescue team can be

composed of workers, or it can be an outside team

that meets all the applicable requirements of 29 CFR

1915.12(e)(1). When an outside rescue team is used,

they should be given a tour of the employer’s facility

to ensure familiarity with the operations and to identify any special concerns for rescue. They must be

given an opportunity to conduct drills on board a

vessel being scrapped in accordance with 29 CFR

1915.12(e)(1)(iii).

Lifesaving Materials

At least one ladder25 meeting the requirements of 29

CFR 1915.158(b)(5) must be available near each

floating vessel on which scrapping work is being

conducted. Depending upon vessel length, one or

more liferings26 meeting the requirements of 29 CFR

1915.158(b)(1) thru (4) must also be provided. Although they are not required for shipbreaking operations, OSHA recommends that at least one

lifesaving skiff be immediately available at locations

where workers are working over or adjacent to

water.

Hazardous Material Spills

Spill kits should be provided that contain an adequate quantity of suitable materials for spill containment and cleanup. The contents of these kits should

be restored after each use to ensure that adequate

materials are available to allow workers to respond

safely to future spills. All applicable environmental

regulations should be consulted to ensure that response and reporting requirements are met. Only

fully qualified and properly equipped personnel are

allowed to respond to hazardous material spills.27

Energy Control

Every effort should be made to take all mechanical

and electrical systems to a zero energy state during

the drill and drain phase of breaking the vessel.

However, to provide adequate lighting for workers,

the ship’s lighting system28 is often maintained. It

may also be desirable to maintain the electrical distribution system, which can be more dependable,

rather than using shore-based temporary services to

provide power to electrical equipment and tools.

When this is done, the employer must ensure that

the integrity of electrical systems is maintained in a

safe manner, including guarding of live parts and

grounding by implementing electrical energy control procedures in accordance with 29 CFR 1910

Subpart S to ensure the safety of workers.

Mechanical systems should be isolated from

their energy source and rendered inoperative,

drained and depressurized prior to working on

them. Each isolation device, controlling the energy

to a mechanical system, should be physically located and disabled. In addition, workers must not be

allowed to work in or on a lifeboat until the boat is

secured in accord with 29 CFR 1915.96(a). Cradles or

carriages on marine railways in a hauled position

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Occupational Safety and

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must be secured in accord with 29 CFR

1915.115(e)(1).

Before hot work is permitted in areas where freeflooding, automatically activated fire-suppression

systems are installed, the system must be physically

isolated or other positive means used to prevent an

accidental discharge. For additional information on

the hazards of fixed extinguishing systems, see 29

CFR 1915.506.

Medical

The employer must provide a first-aid room in close

proximity to workers or a first-aid kit for each vessel

on which work is being performed. In either case, a

qualified person must be close at hand to render

first aid to workers. Employers must take the necessary precautions to protect persons administering

first aid, as well as nearby workers who may come

into contact with blood and other potentially infectious materials (see 29 CFR 1910.1030 and OSHA

Bloodborne Pathogens Fact Sheets). When work is

being performed on more than one small vessel at a

pier, only one first-aid kit is required to be kept in

close proximity to the work (see 29 CFR 1915.98).

However, it is recommended that employers provide

additional first-aid kits where needed. A facility may

consult with a physician or licensed healthcare professional who is knowledgeable in occupational

medicine, regarding specific first-aid needs. One

person qualified to render first aid may serve several vessels as long as he/she is conveniently located near the vessels. Emergency contact numbers

should be posted where the first-aid kit is maintained. On vessels in which ten or more workers are

working, at least one, but not more than two, Stokes

basket stretchers, or equivalent, are required to be

located at each job location. Stretchers must be permanently equipped with bridles for attaching to the

hoisting gear. A blanket or other liner suitable for

transferring an injured worker to and from the

stretcher must also be provided (see 29 CFR

1915.98(d)).

In addition to first-aid treatment, workers might

be exposed to harmful substances such as lead, asbestos and cadmium. Any workers exposed to these

substances, in particular, require appropriate medical surveillance. All medical exams and procedures

must be performed by or under the supervision of a

licensed physician, at no cost to workers and at a

reasonable time and place.

Lead – An employer must institute a medical surveillance program for all workers who are or may be

exposed at or above the action level (30 μg/m3 of air,

averaged over an 8-hour period) for more than 30

days a year. In addition to a detailed work and medical history, blood sampling and analysis must be

made available at least every six months. If a worker’s blood lead levels are at or above 40 μg/100 g of

whole blood during the last sampling period, then

the frequency must be increased to every two

months until two consecutive blood lead levels are

below 40 μg/100 g of whole blood in accord with 29

CFR 1910.1025(j)(2)(i)(B). See 29 CFR 1910.1025(j) for

additional medical surveillance requirements.

Asbestos – When dealing with asbestos, the employer must institute a medical surveillance program for all workers who, for a combined total of 30

or more days per year, are engaged in Class I, II and

III work or are exposed at or above a permissible exposure limit (PEL), 29 CFR 1915.1001(m)(1)(i). However, for purposes of the 30-day threshold, the

employer need not count any day in which a worker

engages in Class II or Class III operations on intact

material for one hour or less (taking into account the

entire time spent on the removal operation, including cleanup) and, while doing so, adheres fully to

the work practices specified in 29 CFR 1915.1001(g).

The employer must make medical examinations

and consultations available to each worker covered

under paragraph 1915.1001(m)(1)(i) on the following

schedules: (1) before the worker is assigned to an

area where negative pressure respirators are worn;

(2) within 10 working days following the thirtieth day

of exposure when the worker is assigned to an area

where exposure to asbestos may be at or above the

PEL for 30 or more days per year, or engages in

Class I, II, or III work for a combined total of 30 or

more days per year; and (3) annually thereafter (see

29 CFR 1915.1001(m)(2)(i)). No worker is to be exposed to an airborne concentration of asbestos in

excess of 0.1 fiber per cubic centimeter (f/сc) of air

as an eight-hour time-weighted average. See 29 CFR

1915.1001(m) for additional medical surveillance requirements. Additionally, no worker is to be exposed to an airborne concentration exceeding 1.0

f/сc in a thirty-minute sampling period. See 29 CFR

1915.1001(c).

Cadmium – Under 29 CFR 1910.1027(l), an employer must institute a medical surveillance program for all workers who are or may be exposed at

or above the action level (2.5 μg/m3), unless the employer can demonstrate that the worker is not, and

will not be, exposed at or above the action level 30

days or more a year (twelve consecutive months).

The employer must provide an initial (preplacement)

examination to all workers receiving medical surveillance within 30 days after initial job assignment.

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See 29 CFR 1910.1027(l)(1)(i) and (2)(i). In addition

to a detailed work and medical history, biological

monitoring must include: (1) cadmium in urine

(CdU); (2) cadmium in blood; and (3) beta-2-microglobulin in urine (β2-M). See 29 CFR 1910.

1027(l)(2)(ii).

Worker Medical Qualifications

All workers should be physically capable of performing their tasks in a safe manner. Workers with a history of chronic back injuries should not be assigned

to tasks that require manual material handling. Additionally, the employer must identify a physician or

other licensed healthcare provider to perform a

medical evaluation to determine a worker’s ability to

use a respirator. The medical evaluation can be performed either by administering a medical questionnaire or by conducting an initial medical examination

that obtains the same information as the medical

questionnaire (29 CFR 1910.134(e)(2)). Any abnormalities indicated on medical questionnaires may

need to be evaluated by a physician specialist.

As required by 29 CFR 1915.117(c), workers with

known uncorrected impaired eyesight or hearing, or

who suffer from heart disease, epilepsy, or similar

ailments which may suddenly incapacitate them, are

prohibited from operating a crane, winch, or other

power-operated hoisting apparatus.

Sanitation

Washing facilities must be provided for all workers

in accordance with 29 CFR 1915.97(b). Workers must

not be allowed to consume food or beverages, or to

smoke in areas where they are exposed to contaminants. Workers must be instructed to wash before

consuming food or beverages and smoking (see 29

CFR 1915.97(c)). Separate toilet facilities must be

provided for men and women, or the facilities must

be lockable (see 29 CFR 1910.141(c)).

Shipboard Rigging

Personnel assigned to perform rigging should be

trained in good rigging practices. Rigging gear must

be of adequate capacity to safely handle the largest

anticipated load with a safety factor of no less than 5

(see 29 CFR 1915.112 and 29 CFR 1915.113). While

the use of tag lines is not required in shipbreaking,

care must be taken to ensure that loads are not carried over the heads of workers and that workers do

not place themselves between a suspended load

and a fixed object where they could be crushed (see

29 CFR 1915.116(j) and (q)). When slings attached to

eye-bolts are used, the pull must be within 20 degrees of the axis of the bolt as required by 29 CFR

1915.116(e). Only shouldered eye-bolts should be

used. Wood, canvas, or other suitable materials

must be used as chafing gear or softeners to prevent damage to wire rope slings29 where they run

over the edges of materials being handled (see 29

CFR 1915.116(f)). Slings should not be covered with

padding that prevents them from being inspected

before each use. Kinked slings, which do not

straighten out when placed under load, should immediately be removed from service. Additional information regarding sling safety can be found in

OSHA Publication 3072 (1996), Sling Safety.

30

Workers must never be allowed to ride the load

or hook (see 29 CFR 1915.116(i)). When cranes are

operated “in the blind,” a signalman must be assigned who is familiar with the signal codes to be

used (see 29 CFR 1915.116(l)). Only this signalman

must give signals to the crane operator. Hatch covers must be completely opened or removed before

moving materials or equipment through them (see

29 CFR 1915.116(n)). It is recommended that the

hatch beams also be removed; if not removed, the

beams must be sufficiently lashed, locked, or otherwise secured to prevent them from being displaced

by accident (see 29 CFR 1915.116(n)). Hatches must

not be opened or closed while workers are in the

square of the hatch below (see 29 CFR 1915.116(o)).

Swing and travel alarms must be sounded to warn

workers of movement before loads are raised, lowered, or swung (see 29 CFR 1915.116(p)). Alarms

must be capable of being heard or seen above ambient noise or light levels to appropriately warn

workers of potential danger (see 29 CFR 1910.

165(b)(2)).

Materials Handling

During the shipbreaking process, workers handle

large sections of steel and other heavy or awkward

materials, resulting in unique materials handling issues that may cause injury. To the extent feasible,

manual materials handling should be avoided when

weights are unknown or excessive, or because of

other conditions such as uneven walking surfaces,

falling hazards and irregular or sharp edges of a cut

plate. Mechanical materials handling methods

should be used whenever possible (e.g., cranes);

however, when manual materials handling is performed, gloves should be provided to protect

against cuts. Walking paths31 should be kept free

from obstructions and tripping hazards. Shoes32

should be maintained in a dry, oil-free condition,

with soles and heels evenly worn.

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Occupational Safety and

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Workers should be trained on ergonomic hazards

in the workplace and about ways to minimize the

risk of injury from these hazards. Some of the training topics should include: the proper use of equipment, tools and machine controls; proper lifting

techniques; awareness of work tasks that may lead

to pain or injury; and procedures for reporting workrelated injuries and illnesses. In addition, workers

should be encouraged to warm up or stretch prior to

engaging in heavy lifting.32

Crane Services

One of the more hazardous operations in shipbreaking is handling materials with cranes.33 Crane operations involve a complex relationship between the

machine, the operator, the material being handled,

the rigging and rigging gear that secures the material to the crane hook, the workers and obstructions

in the area, and the ground surface or foundation of

the crane. Failure, inadequate planning, or improper

operation can have disastrous consequences. In

2005 alone, crane accidents.com34 reported 127 fatalities related to crane accidents.

Only workers who are properly trained and qualified may be assigned to operate cranes in support of

shipbreaking operations. Crane operators must

know and understand signals used to control the

crane and must be familiar with the operation of the

specific machine to which they are assigned (see 29

CFR 1915.117(b) and (c)). Riggers should also be

trained to safely carry out their assigned tasks.

The swing radius of the counterweight and superstructure must be established and guarded to

prevent workers from being struck. Special attention

should be given when cranes are operating near

buildings or other structures (see 29 CFR 1915.115(d)).

Loads must not be swung over the heads of workers

(see 29 CFR 1915.116(j)). Both swing and travel

alarms should be used to warn workers of machine

movement. When lifting “in the blind,” a signalman

who is visible to the operator must be placed to assist the operator in safely moving the load (see 29

CFR 1915.116(l)).

Cranes used for removing materials from the

ship must be certified in accord with 29 CFR

1915.115(a). A crane of sufficient capacity to safely

handle the largest expected load must be used (see

29 CFR 1915.115(c)(2)). It is particularly important in

selecting cut lines to consider the weight of the total

load to be handled. A qualified naval architect or

marine engineer should be consulted to ensure that

sections cut are within the safe lifting capacity of

the machine to be used. Industry practice often involves attaching the load to the crane before the

final cut frees the load to avoid shock loading of the

crane. The use of an electric load-indicating device

is recommended to ensure that the crane or rigging

is not overloaded beyond the structural safe load

rating. If any recognized over-load or shock load occurs, then the crane should be removed from service until the crane and rigging are inspected in

accord with the crane manufacturer’s or certified

agent’s instructions. The crane must be maintained

in accord with the manufacturer’s recommendations and must be inspected in accord with applicable standards for the type of crane used. See 29

CFR 1915.111.

Crane being used to lift cut section from vessel undergoing

scrapping.

Safe working loads for cranes are based on both

the structural integrity of the machine and the stability of the machine on its foundation surface. Safe

loading normally requires a crane to be placed on a

surface with a grade of no more than 1 degree. In

addition, the manufacturer’s designated safe working load must not be exceeded (29 CFR

1915.115(c)(2)). Load rating charts provide no value

in determining stability once the grade limitation is

exceeded, thus the operation of the crane is considered unsafe beyond that point. Additionally, surfaces should be capable of safely supporting the

weight of the machine and its total load. Cribbing or

pads may be necessary to level the crane or to create a sufficiently stable footing. The area to be used

for crane setup should be carefully selected by a

person well qualified in crane operations to ensure

that adequate footing is provided. The use of an engineer qualified in soil structure and stability is recommended (e.g., civil or geotechnical engineer).

Rigging must be selected to handle the largest

anticipated load. Good rigging practices are required and rigging personnel should be trained in

safe rigging techniques. Chafing gear should be

used to protect rigging gear35 from abrasion caused Courtesy of Metro Machine Incorporated
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Occupational Safety and

Health Administration

by rough edges of cut materials. Rigging gear must

be inspected36 frequently as required by 29 CFR

1915.111. Knots are not permitted in wire rope or

chains.

Crane being used to lift cut section from vessel undergoing

scrapping.

ForkTrucks

If fork trucks are used to move materials, only rough

terrain fork trucks are recommended. Operators

must be trained and must not have any condition

that could cause them to become incapacitated (e.g.,

uncontrolled diabetes, epilepsy or heart disease) (29

CFR 1915.117(c)). Fork trucks should be of sufficient

capacity for the intended load. Loads should not extend beyond the forks in a manner that could cause

the fork truck to tip over. If frontend attachments are

used, other than factory installed attachments, the

employer must have the truck marked to identify the

attachments and the appropriate weight of the truck

and attachment combination (29 CFR 1910.178(a)

(2)(5)). Fork trucks should be properly maintained

with consideration given to the effects of the marine

environment on the truck. Gasoline or diesel fork

trucks should not be placed in vessel holds due to

the potential for buildup of toxic gases (e.g., exhaust

fumes). Fork trucks should not be driven up to workers where they might be crushed by the truck or

load. Where the operator’s view could be obstructed

by a load, the truck should be operated with the load

trailing. In situations when loads must be carried uphill they should only be driven in a forward motion

and with a designated spotter. The truck path should

be twice the width of the load being carried to avoid

inadvertent contact with objects. An inspection must

be performed on all trucks in service before each

shift and at necessary intervals during its use, in accordance with 29 CFR 1915.111(a). If any item that

affects the safe operation of the truck is found to be

defective, the truck should be removed from service

until it is repaired. For additional information see 29

CFR 1910.178 and 29 CFR 1915.117.

Trucks

Trucks may be used to haul scrap both over the road

and in the yard. Trucks used over the road should be

maintained in a road-worthy condition and inspected

in accordance with federal and state safety regulations. The truck should be inspected daily by the

driver and any condition that affects the safe use of

the truck should be corrected before it is used.

Trucks used in the yard should never be backed or

driven up to workers standing between the truck

and a fixed object. Additionally, backup alarms

should be provided on these trucks when they are

used in the yard to haul scrap. A spotter should be

used to assist the driver when the view to the rear is

obstructed. Over-the-road drivers must have a

proper Commercial Driver’s License. Scrap should

be loaded within the safe capacity of the truck and

evenly distributed over all axles, ensuring compliance with state and federal axle weight requirements. It should be loaded so as to prevent

materials from shifting in or falling from the truck.

While on the road, the load should be covered to

prevent loose pieces from falling out. Drivers should

have no condition that could cause them to become

incapacitated (e.g., uncontrolled diabetes, epilepsy,

or heart disease).

For More Information About Over-the-Road

Truck Requirements

Federal Motor Carrier Safety Administration:

Rules and Regulations www.fmcsa.dot.gov/

rules-regulations/rules-regulations.htm.

Federal Motor Carrier Safety Administration:

Registration and Licensing www.fmcsa.dot. gov/

registration-licensing/registration-licensing.htm.

Powered Industrial Trucks (Forklifts) eTool, OSHA

www.osha.gov/dcsp/products/etools/pit/index.html

Training

All workers engaged in shipbreaking operations

must be trained in the hazards of the work to which

they are exposed (e.g., persons assigned to burn

materials should be trained in burning safety; riggers in rigging safety). General hazard recognition

and safety precautions should be included in worker

orientations, as well as training provided on the personal protective equipment (PPE) to be used at the

worksite. PPE37 training must include use of hard

Courtesy of Metro Machine Incorporated
S A F E W O R K P R A C T I C E S F O R S H I P B R E A K I N G

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hats, eye protection, footwear, hearing protection,

work gloves, and other PPE as appropriate (see 29

CFR 1915.152(e)). Workers should be instructed to

avoid the use of synthetic clothing that melts or

burns rapidly such as nylon, rayon, or Corfam®, in

areas where burning operations are conducted. A

daily “tool-box safety talk” to review work progress,

planned work for the day and anticipated hazards

associated with that work is recommended.

Daily safety talk.

A hazard assessment38 of work activities, as described in 29 CFR 1915.152(b), must be conducted to

determine hazards. Hazard communication39 training must be provided to the workers and must cover

the hazardous materials used in work procedures, as

well as how to protect themselves from exposure to

those hazards. This includes hazardous materials introduced by other employers at the worksite to

which workers may be exposed. Fulfilling this requirement is the responsibility of the employer who

has control over the workers performing the work.

Copies of material safety data sheets (MSDSs) for

hazardous materials used must be available at the

worksite (29 CFR 1915.1200).

Communication

Increasingly, non-English-speaking workers are

being employed in the shipbreaking industry. As a

result, it has become difficult for employers and

workers to communicate effectively. Despite the

language barrier, signage and instructions must be

understood by all workers (29 CFR 1915.16(a)).

Therefore, employers may need to provide required

postings and warnings in more than one language

(e.g., English, Spanish, Vietnamese) at the worksite.

It is important for workers to understand the hazards

to which they might be exposed and the precautions

necessary to avoid injury from those hazards. If

workers are unable to read MSDSs or other hazard

communication information themselves, then the

employer should provide an interpreter to pass the

information on to them.

Maintenance Shops

Maintenance shops at shipbreaking facilities have

similar safety and health hazards normally encountered in other maintenance shops. As in other

shops, particular attention should be paid to housekeeping, electrical safety, machine guarding and

storage, and the use and disposal of hazardous materials.

Courtesy of Metro Machine Incorporated
S A F E W O R K P R A C T I C E S F O R S H I P B R E A K I N G

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References

1 http://www.epa.gov/Compliance/resources/

publications/civil/federal/shipscrap guide.pdf, A

Guide for Ship Scrappers. Tips for Regulatory

Compliance, EPA, Summer 2000.

2 http://www.basel.int/ships/techguid.html, Technical Guidelines for the Environmentally Sound

Management of Full and Partial Dismantling of

Ships, Basel Convention, August 8, 2002.

3 See note 1, above.

4 http://www.osha.gov/SLTC/etools/shipyard/ship_

breaking/index.html, eTool, Shipyard EmploymentShipbreaking, OSHA.

5 See note 4, above.

6 http://www.osha.gov/pls/oshaweb/owadisp.show_

document?p_table=STAND ARDS&p_id=10330,

Regulations, Compliance Assistance Guidelines

for Confined and Enclosed Spaces and Other Dangerous Atmospheres, 29 CFR 1915 Subpart B, App

A, OSHA.

7 http://www.osha.gov/pls/oshaweb/owadisp.show_

document?p_table=STAND ARDS&p_id=10231,

Regulations, Welding, Cutting and Heating in Way

of Preservative Coating, 29 CFR 1915.53, OSHA.

8 See note 4, above.

9 http://www.osha.gov/SLTC/etools/shipyard/

standard/health_hazards.html, eTool, Shipyard

Employment-General Requirements-Inventory of

Hazardous Materials, OSHA.

10 http://msds.dupont.com/msds/pdfs/EN/PEN_

09004a2f80007210.pdf, Material Safety Data Sheet

for “Freon” 22, Dupont, revised April 28, 2004.

11 http://www.ask.com/bar?q=MSDS+Halon&page=

1&qsrc=2417&ab=0&u=http%3A%2F%2Fwww.

wfrfire.com%2Fmsds%2Fhalon.htm, MSDS for

Halon 1211, WFR Wholesale Fire and Rescue Ltd.,

September 2006.

12 http://www.vngas.com/pdf/g8.pdf, MSDS, BOC

Gases, reviewed June 7, 1996.

13 http://www.marsulex.com/customers/pdfs/msds_

HydrogenSulfide.pdf, MSDS for Hydrogen

Sulfide, Marsulex, validation date November 13,

2004.

14 http://www.osha.gov/SLTC/healthguidelines/

carbonmonoxide, Carbon Monoxide,

NIOSH/OSHA Health Guidelines.

15 http://www.atsdr.cdc.gov/substances/toxsubstance.

asp?toxid=22, Lead Toxic Substances Portal,

Agency for Toxic Substances and Disease

Registry (ATSDR) or http://www.osha.gov/pls/

oshaweb/owadisp.show_document?p_table=

STANDARDS&p_id=10030, Toxic and Hazardous

Substances, 29 CFR 1910.1025, OSHA.

16 http://www.osha.gov/dts/chemicalsampling/data/

CH_270900.html, Chemical Sampling Information

for Tetraethyl Lead (as Pb), January 15, 1999,

OSHA.

17 https://www.osha.gov/SLTC/mercury/index.html,

Safety and Health Topics for Mercury, OSHA.

18 http://www.cdc.gov/niosh/ipcsneng/neng1282.

html, International Chemical Safety Cards, Tributyltin Oxide, validated March 26, 1998, NIOSH.

19 http://www.osha.gov/SLTC/healthguidelines/

zincchromate/recognition.html, Occupational

Safety and Health Guideline for Zinc Chromate,

OSHA.

20 https://www.osha.gov/SLTC/etools/shipyard/

shiprepair/confinedspace/oxygendeficient.html,

Shipyard Employment eTool, Confined or Enclosed Spaces, Oxygen-Deficient or -Enriched Atmospheres, OSHA.

21 http://www.osha.gov/OshDoc/data_MaritimeFacts/

shipbreaking-factsheet.pdf, OSHA Fact SheetShipbreaking, OSHA, 2001.

22 http://www.osha.gov/SLTC/etools/shipyard/ship_

breaking/ppe/general_ppe/life saving_equipment.

html, eTool, Shipyard Employment-PPE SelectionShipbreaking-Lifesaving Equipment, OSHA.

23 http://www.osha.gov/SLTC/etools/shipyard/ship_

breaking/working_conditions/illumination.html,

eTool, Shipyard Employment-Shipbreaking-Working Conditions-Illumination, OSHA.

24 http://www.osha.gov/SLTC/etools/shipyard/ship_

breaking/access/drydock_marinerailways.html,

eTool, Shipyard Employment-Shipbreaking-Access-Access to and Guarding of Dry Docks and

Marine Railways, OSHA.

25 See note 22, above.

26 See note 22, above.

27 http://www.epa.gov/oswer/cleanup, Cleaning Up

Our Land, Water, and Air, EPA, last updated July

13, 2009.
28 http://www.osha.gov/SLTC/etools/shipyard/ship_

breaking/working_conditions/ housekeeping.html,

eTool, Shipyard Employment-Shipbreaking-Working Conditions-Housekeeping, OSHA.

29 http://www.osha.gov/Publications/osha3072.pdf,

Sling Safety, OSHA, 1996.

30 See note 28, above.

31 http://www.osha.gov/SLTC/etools/shipyard/ship_

breaking/ppe/general_ppe/foot_protection.html,

eTool, Shipyard Employment-Shipbreaking-PPE

Selection-Foot Protection, OSHA.

32 http://www.osha.gov/dsg/guidance/shipyard

guidelines.html, Guidelines for Shipyards,

Ergonomics for the Prevention of Musculoskeletal

Disorders.

33 http://www.osha.gov/SLTC/etools/shipyard/ship_

breaking/material_handling/gear.html, eTool,

Shipyard Employment-Shipbreaking-Material

Handling-Use of Gear, OSHA.

34 http://craneaccidents.com/stats.htm, Crane Accident Statistics, CraneAccidents.com.

35 http://www.osha.gov/SLTC/etools/shipyard/ship_

breaking/material_handling/ropes.html, eTool,

Shipyard Employment-Shipbreaking-Material

Handling-Ropes, Chains, and Slings, OSHA.

36 http://www.osha.gov/SLTC/etools/shipyard/ship_

breaking/material_handling/inspection.html,

eTool, Shipyard Employment-ShipbreakingMaterial handling-Inspection, OSHA.

37 http://www.osha.gov/SLTC/etools/shipyard/

standard/ppe/ppe_selection.html, eTool, Shipyard Employment-PPE-PPE Selection, OSHA.

38 http://www.osha.gov/SLTC/etools/shipyard/

standard/ppe/hazard_assessment.html, eTool,

Shipyard Employment-Hazard Assessment,

OSHA.

39 http://www.osha.gov/pls/oshaweb/owadisp.show_

document?p_table=STANDARDS&p_id=10099,

Regulations, Hazard Communication, 1910.1200,

OSHA.

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Health Administration
S A F E W O R K P R A C T I C E S F O R S H I P B R E A K I N G

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Additional Resources

http://www.imo.org/includes/blastDataOnly.asp/data

_id%3D11404/ResShiprecycling962.pdf, International

Maritime Organization (IMO) Guidelines on Ship

Recycling, IMO, March 4, 2004.

http://www.ilo.org/public/english/protection/safework/

sectors/ships/shpbreak.htm, Safe Work, Ship breaking, last updated April 2000, International Labor

Office (ILO).

https://www.osha.gov/Publications/OSHA3348-

metal-scrap-recycling.pdf, Guidance for the Identification and Control of Safety and Health Hazards in

Metal Scrap Recycling, OSHA, 2008.

http://www.osha.gov/pls/oshaweb/owadisp.show_

document?p_table=DIRECTIVES&p_ id=3224,

OSHA’s National Emphasis Program (NEP) on Shipbreaking, OSHA, 3/16/05.

http://www.osha.gov/dts/maritime/index.html, OSHA

Assistance for the Maritime Industry, OSHA.

https://voa.marad.dot.gov/programs/ship_disposal/

standing_quot/docs/TECHNICAL%20COMPLIANCE

%20PLAN%20(TCP).pdf, Requirements for Technical

Compliance Plan, Maritime Administration

(MARAD).

http://www.marad.dot.gov/Offices/index.html,

MARAD Home Page.

http://www.osha.gov/dcsp/osp/index.html, State

Occupational Safety and Health Plans, OSHA.

http://www.osha.gov/pls/oshaweb/owadisp.show_

document?p_table=DIRECTIVES&p_ id=3429, Directive, CPL-02-00-142, Shipyard Employment “Tool

Bag” Directive, effective date August 3, 2006, OSHA.

www.osha.gov, OSHA Home Page.
2 3

Occupational Safety and

Health Administration

OSHA Assistance

OSHA can provide extensive help through a variety of

programs, including technical assistance about effective safety and health programs, state plans, workplace

consultations, and training and education.

Safety and Health Management

System Guidelines

Effective management of worker safety and health protection is a decisive factor in reducing the extent and

severity of work-related injuries and illnesses and their

related costs. In fact, an effective safety and health

management system forms the basis of good worker

protection, can save time and money, increase productivity and reduce employee injuries, illnesses and related workers’ compensation costs.

To assist employers and workers in developing effective safety and health management systems, OSHA

published recommended Safety and Health Program

Management Guidelines (54 Federal Register (16):

3904-3916, January 26, 1989). These voluntary guidelines can be applied to all places of employment covered by OSHA.

The guidelines identify four general elements critical to the development of a successful safety and

health management system:

• Management leadership and worker involvement,

• Worksite analysis,

• Hazard prevention and control, and

• Safety and health training.

The guidelines recommend specific actions, under

each of these general elements, to achieve an effective

safety and health management system. The Federal

Register notice is available online at www.osha.gov.

State Programs

The Occupational Safety and Health Act of 1970 (OSH

Act) encourages states to develop and operate their

own job safety and health plans. OSHA approves and

monitors these plans. Twenty-five states, Puerto Rico

and the Virgin Islands currently operate approved state

plans: 22 cover both private and public (state and local

government) employment; Connecticut, Illinois, New

Jersey, New York and the Virgin Islands cover the public sector only. States and territories with their own

OSHA-approved occupational safety and health plans

must adopt standards identical to, or at least as effective as, the Federal OSHA standards.

Consultation Services

Consultation assistance is available on request to employers who want help in establishing and maintaining

a safe and healthful workplace. Largely funded by

OSHA, the service is provided at no cost to the employer. Primarily developed for smaller employers with

more hazardous operations, the consultation service is

delivered by state governments employing professional safety and health consultants. Comprehensive assistance includes an appraisal of all mechanical

systems, work practices, and occupational safety and

health hazards of the workplace and all aspects of the

employer’s present job safety and health program. In

addition, the service offers assistance to employers in

developing and implementing an effective safety and

health program. No penalties are proposed or citations

issued for hazards identified by the consultant. OSHA

provides consultation assistance to the employer with

the assurance that his or her name and firm and any

information about the workplace will not be routinely

reported to OSHA enforcement staff. For more information concerning consultation assistance, see OSHA’s

website at www.osha.gov.

Strategic Partnership Program

OSHA’s Strategic Partnership Program helps encourage, assist and recognize the efforts of partners to

eliminate serious workplace hazards and achieve a

high level of worker safety and health. Most strategic

partnerships seek to have a broad impact by building

cooperative relationships with groups of employers

and workers. These partnerships are voluntary relationships between OSHA, employers, worker representatives, and others (e.g., trade unions, trade and

professional associations, universities, and other government agencies).

For more information on this and other agency programs, contact your nearest OSHA office, or visit

OSHA’s website at www.osha.gov.

OSHATraining and Education

OSHA area offices offer a variety of information services, such as technical advice, publications, audiovisual

aids and speakers for special engagements. OSHA’s

Training Institute in Arlington Heights, IL, provides

basic and advanced courses in safety and health for

Federal and state compliance officers, state consultants, Federal agency personnel, and private sector employers, workers and their representatives.

The OSHA Training Institute also has established

OSHA Training Institute Education Centers to address

the increased demand for its courses from the private

sector and from other federal agencies. These centers

are colleges, universities, and nonprofit organizations

that have been selected after a competition for participation in the program.

OSHA also provides funds to nonprofit organizations, through grants, to conduct workplace training

and education in subjects where OSHA believes there
S A F E W O R K P R A C T I C E S F O R S H I P B R E A K I N G

2 4

is a lack of workplace training. Grants are awarded

annually.

For more information on grants, training and education, contact the OSHA Training Institute, Directorate

of Training and Education, 2020 South Arlington

Heights Road, Arlington Heights, IL 60005, (847) 297-

4810, or see Training on OSHA’s website at

www.osha.gov. For further information on any OSHA

program, contact your nearest OSHA regional office

listed at the end of this publication.

Information Available Electronically

OSHA has a variety of materials and tools available on

its website at www.osha.gov. These include electronic

tools, such as Safety and HealthTopics, eTools, Expert

Advisors; regulations, directives and publications;

videos and other information for employers and workers. OSHA’s software programs and eTools walk you

through challenging safety and health issues and common problems to find the best solutions for your workplace.

OSHA Publications

OSHA has an extensive publications program.

For a listing of free items, visit OSHA’s website at

www.osha.gov or contact the OSHA Publications Office, U.S. Department of Labor, 200 Constitution Avenue, NW, N-3101, Washington, DC 20210; telephone

(202) 693-1888 or fax to (202) 693-2498.

Contacting OSHA

To report an emergency, file a complaint, or seek OSHA

advice, assistance, or products, call (800) 321-OSHA or

contact your nearest OSHA Regional or Area office

listed at the end of this publication. The teletypewriter

(TTY) number is (877) 889-5627.

Written correspondence can be mailed to the nearest

OSHA Regional or Area Office listed at the end of this

publication or to OSHA’s national office at: U.S. Department of Labor, Occupational Safety and Health Administration, 200 Constitution Avenue, N.W., Washington,

DC 20210.

By visiting OSHA’s website at www.osha.gov, you

can also:

• File a complaint online,

• Submit general inquiries about workplace safety and

health electronically, and

• Find more information about OSHA and occupational safety and health.
OSHA Regional Offices

Region I

(CT*, ME, MA, NH, RI, VT*)

JFK Federal Building, Room E340

Boston, MA 02203

(617) 565-9860

Region II

(NJ*, NY*, PR*, VI*)

201 Varick Street, Room 670

New York, NY 10014

(212) 337-2378

Region III

(DE, DC, MD*, PA, VA*, WV)

The Curtis Center

170 S. Independence Mall West

Suite 740 West

Philadelphia, PA 19106-3309

(215) 861-4900

Region IV

(AL, FL, GA, KY*, MS, NC*, SC*, TN*)

61 Forsyth Street, SW, Room 6T50

Atlanta, GA 30303

(404) 562-2300

RegionV

(IL*, IN*, MI*, MN*, OH, WI)

230 South Dearborn Street

Room 3244

Chicago, IL 60604

(312) 353-2220

RegionVI

(AR, LA, NM*, OK, TX)

525 Griffin Street, Room 602

Dallas, TX 75202

(972) 850-4145

RegionVII

(IA*, KS, MO, NE)

Two Pershing Square

2300 Main Street, Suite 1010

Kansas City, MO 64108-2416

(816) 283-8745

RegionVIII

(CO, MT, ND, SD, UT*, WY*)

1999 Broadway, Suite 1690

PO Box 46550

Denver, CO 80202-5716

(720) 264-6550

Region IX

(AZ*, CA*, HI*, NV*, and American Samoa,

Guam and the Northern Mariana Islands)

90 7th Street, Suite 18-100

San Francisco, CA 94103

(415) 625-2547

Region X

(AK*, ID, OR*, WA*)

1111 Third Avenue, Suite 715

Seattle, WA 98101-3212

(206) 553-5930

*These states and territories operate their own

OSHA-approved job safety and health programs and

cover state and local government employees as

well as private sector employees. The Connecticut,

Illinois, New Jersey, New York and Virgin Islands

plans cover public employees only. States with approved programs must have standards that are

identical to, or at least as effective as, the Federal

OSHA standards.

Note: To get contact information for OSHA Area

Offices, OSHA-approved State Plans and OSHA

Consultation Projects, please visit us online at

www.osha.gov or call us at 1-800-321-OSHA.

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Occupational Safety and

Health Administration