SafeWork Practices for Shipbreaking

1 Safe Work Practicesfor ShipbreakingOSHA 3375-03 2010 OccupationalSafetyandHealthActof1970 To assure safe and healthful working conditionsfor working men and women; by authorizing en-forcement of the standards developed underthe Act; by assisting and encouraging the States intheir efforts to assure safe and healthful workingconditions; by providing for research, information,education, and training in the field of occupationalsafety and health. This publication provides a general overview of aparticular standards-related topic. This publicationdoes not alter or determine compliance responsibilitieswhich are set forth in OSHA standards, and theOc-cupational Safety and Health Act of 1970. More-over, because interpretations and enforcement policymay change over time, for additional guidance onOSHA compliance requirements, the reader shouldconsult current administrative interpretations anddecisions by the Occupational Safety and HealthReview Commission and the contained in this publication is in the publicdomain and may be reproduced, fully or partially,without permission.

2 Source credit is requestedbut not information will be made available to sensoryimpaired individuals upon request. Voice phone:(202) 693-1999; teletypewriter (TTY) number: Work Practicesfor ShipbreakingOccupational Safety and Department of LaborOSHA 3375-032010 Cover photo courtesy of H. Reid, Metro Machine guidance document is not a standard or regulation, and it creates no new legal contains recommendations as well as descriptions of mandatory safety and health recommendations are advisory in nature, informational in content, and are intended to assistemployers in providing a safe and healthful workplace. TheOccupational Safety and Health Actrequires employers to comply with safety and health standards and regulations promulgated byOSHA or by a state with an OSHA-approved state plan. In addition, the Act s General DutyClause, Section 5(a)(1), requires employers to provide their employees with a workplace freefrom recognized hazards likely to cause death or serious physical to FinishPhotos courtesy of Metro Machine Incorporated2 Occupational Safety andHealth AdministrationS 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 GContentsIntroduction4 Interagency Work Group4 Steps in Shipbreaking Process4 Initial Visit to Vessel to DetermineSuitability for Scrapping6 Towing the Vessel7 Mooring the Vessel7 Hauling the Vessel8 Planning9 breaking the Vessel9 Burning Equipment10 Cold Cutting11 Mobile Hydraulic Shear Cutters11 Shoreside Processing of Metals11 Fall Protection11 Fire Prevention and Protection12 Emergency Response13 Drills13 Rescue14 Lifesaving Materials14 Hazardous Material Spills14 Energy Control14 Medical15 Worker Medical Qualifications16 Sanitation16 Shipboard Rigging16 Materials Handling16 Crane Services17 Fork Trucks18 Trucks18 Training18 Communication19 Maintenance Shops19 References20

3 Additional Resources22 OSHA Assistance23 OSHA Regional Offices253 IntroductionShipbreaking is a unique part of the maritime indus-try, primarily involving the dismantling and disposalof obsolete Navy and Maritime Administrationships, as well as commercial barges and mobile off-shore drilling units. For many years, much of thiswork was contracted to overseas companies. How-ever, in recent years the exporting of ships from theUnited States to foreign countries for scrapping hascome under criticism due to concerns over workersafety and health, and adverse environmental im-pacts. As a result, the exporting of ships for scrap-ping was stopped by the Navy in December 1997and by the Maritime Administration (MARAD) inJanuary , Shipbreaking by do-mestic companies is rapidly growing, and there is aneed to improve Shipbreaking ( , dismantling,ship recycling, or scrapping) processes to ensure thesafety and health of these of vessels is usually conducted at apier, drydock, or dismantling slip and includes awide range of activities, from removing all gear andequipment to cutting down and recycling the ship'sstructure.

4 The structural complexity of ships makesshipbreaking a challenging process. It involvesmany safety, health and environmental issues, in-cluding exposure to asbestos, toxic fumes, haz-ardous materials, noise, falling objects, lead andelectrical shock, as well as dangers associated withheat stress, falls, heavy materials handling light of the need to improve and managethe hazards associated with Shipbreaking , this docu-ment is to be used as a basic guide for employersinvolved in Shipbreaking activities. The hyperlinks toOSHA, international, and other documentation pro-vided throughout this publication give more detailedinformation and document does not cover all of the regula-tions governing the occupational safety and healthaspects of Shipbreaking . However, it highlights im-portant information through references and hyper-links to OSHA regulations that can be used to helpemployers develop a comprehensive Safety andHealth Management System (SHMS), encompassingall aspects of a facility s Shipbreaking procedures andprocesses.

5 The appropriate Code of Federal Regula-tions (CFR) provisions must be incorporated in allsafety and health plans, and the safety processesand programs must be managed to reduce risk andprovide a safe and healthful worksite for all addition, employers must be aware of and complywith all local and state regulations, which may bemore stringent than federal Work GroupIn December 1996, the Department of the Navy, theDefense Logistics Agency (DLA), the MaritimeAdministration (MARAD), and the Coast Guard(USCG), along with other involved agencies, beganmeeting quarterly to discuss Shipbreaking programimprovements and to share evaluation proceduresand oversight information. In February 1998, thegroup was formally chartered as the InteragencyPanel on Ship Scrapping. The work of the groupresulted in a set of recommendations that werepresented in the April 20, 1998,Report of the Intera-gency Panel on Ship Scrapping. The recommenda-tions covered many aspects of the shipbreakingindustry, including contracting improvements, per-formance bonds, data gathering and pilot projects,polychlorinated biphenyls (PCBs) guidance, regula-tory oversight and international the category of regulatory oversight, thepanel recommended that the Environmental Protec-tion Agency (EPA) and OSHA, in conjunction withDLA, the Navy, and MARAD, develop a compre-hensive compliance guide.

6 This guide, entitledAGuide for Ship Scrappers,3outlines the relevant en-vironmental and occupational safety and health re-quirements applicable to Shipbreaking . The guidecontains recommendations for completing ship- breaking operations in a safe and environmentallycompliant in ShipbreakingProcessAfter removal from the fleet site, the vessel is towedor self-propelled to the site where scrapping willoccur. The vessel is then scrapped while beingmoored to a pier, anchored, beached, or dry-docked(including graving docks). Most scrapping is per-formed pier-side in slips, which are typicallydredged openings that are adjacent to a shippingchannel. Slips are approximately 400 to 1,000 feetlong and 100 to 140 feet wide at the entrance. Ship- breaking is generally performed by cutting awaylarge sections, which are then moved to shore forfurther dismantling. A large winch at the head of theslip is used to drag the hull farther out of the wateras work progresses. Throughout the scrappingprocess, it is important for the appropriate safetyprecautions to be determined and followed to effec-tively protect personnel.

7 The scrapping process4usually occurs in a series of steps:4 Occupational Safety andHealth Administration Conduct a vessel of all com-partments, tanks and storage areas are used (orprepared, if not available) to identify areas thatmay contain hazardous materials such as fuels,oils, asbestos, PCBs, lead and other hazardouswastes. Sampling is conducted using a system-atic approach, usually starting in the compart-ment that will be cut first. In many cases, afacility will presume that certain items containhazardous materials and dispose of them assuch, in lieu of sampling. In such cases, the em-ployer must use proper engineering controls andwork Practices to ensure that workers, involvedwith and in the vicinity of the removal, are prop-erly protected from exposure ( , through theuse of wet methods, or wetting agents, and vacu-ums with HEPA filters). Remove fuels, oils, other liquids and combustiblematerials. The removal of fuels, oils and otherliquids ( , bilge and ballast water) from theship generally occurs throughout the shipbreak-ing process.

8 Bilge water is sampled and disposedof appropriately. In addition, during the vesselscrapping process, water may accumulate due torain, firefighting activity, or use of hot work cool-ing water, and will have to be properly Coast Guard requires booms to beplaced around the vessel to help contain anyspills (See OSHA publication 3172 (2001),Train-ing Marine Oil Spill Response Workers UnderOSHA s Hazardous Waste Operations and Emer-gency Response Standard). Following removalactivities, a marine chemist6certifies that the ves-sel is safe for entry and safe for hot work. Acompetent person must continually monitorthese areas to ensure that they are still in compli-ance with the marine chemist s certificate. Remove equipment. Fixtures, anchors, chainsand small equipment are removed first. Largereusable components ( , engine parts) are re-moved as they become accessible. Propellersalso may have to be removed so that the hull canbe pulled into shallow water. Remove and dispose of asbestos and asbestos-containing materials (ACMs) andPCBs are usually removed in two stages.

9 Prior tocutting away a section of the vessel, ACM is re-moved from areas that are to be cut and PCBsare removed from areas that are readily accessi-ble. After the vessel section has been moved toshore, the remaining ACMs and PCBs are re-moved as they become accessible during the dis-mantling of the vessel section. The engine roomsusually contain the most asbestos and, therefore,take the longest for asbestos removal to be con-ducted. Prepare surfaces for cutting. Following the re-moval of combustible materials, asbestos andPCBs, paint or preservative coatings must bestripped from surfaces to be cut (29 CFR ).Hard-to-remove materials on surfaces may re-quire specific cut-line preparation, such as gritblasting or flame removal of paint,7which canexpose workers to toxic metals and volatile com-ponents of paint. Appropriate precautions mustbe taken ( , the use of airline respirators) to ef-fectively protect personnel performing the re-moval, as well as those workers in the immediatearea (see 29 CFR ).

10 Cut metal. During the cutting phase, the upperdecks, superstructure and systems are cut first,followed by the main deck and lower cutting is usually done manually usingoxygen-fuel cutting torches, but may be donewith shears or saws for nonferrous metals. Typi-cally, as large parts of the vessel are cut away,they are lifted by crane to the ground where theyare then cut into specific shapes and sizes re-quired by the foundry or smelter to which thescrap is shipped. As cutting continues and theweight of the structure is reduced, the remaininghull floats higher, exposing lower regions of thehull. Ultimately, the remaining portion of the hullis pulled ashore and cut. Recycle or dispose of materials. Scrap metals,including steel, aluminum, copper, copper nickelalloy and lesser amounts of other metals aresorted by grade and composition, and sold toremelting firms or to scrap metal-brokers. Valu-able metals such as copper in electric cable thatare mixed with nonmetal materials may be re-covered using shredders and separators.