Download - 3375 Ship Breaking

Safe Work Practicesfor Shipbreaking

OSHA 3375-03 2010

Occupational Safety and Health Act of 1970“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 the Oc-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 courts.

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Safe Work Practicesfor Shipbreaking

Occupational Safety and HealthAdministrationU.S. Department of Labor

OSHA 3375-032010

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 assistemployers in providing a safe and healthful workplace. The Occupational 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 harm.

Start to Finish

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Occupational Safety andHealth 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

ContentsIntroduction 4

Interagency Work Group 4

Steps in Shipbreaking Process 4

Initial Visit to Vessel to DetermineSuitability 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

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IntroductionShipbreaking is a unique part of the maritime indus-try, primarily involving the dismantling and disposalof obsolete U.S. 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 1998.1 Consequently, shipbreaking by do-mestic companies is rapidly growing, and there is aneed to improve shipbreaking (e.g., dismantling,ship recycling, or scrapping) processes to ensure thesafety and health of these workers.

Dismantling 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. 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 andfires.2 In 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 recommendations.

This 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. 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 workers.In addition, employers must be aware of and complywith all local and state regulations, which may bemore stringent than federal requirements.

Interagency Work GroupIn December 1996, the Department of the Navy, theDefense Logistics Agency (DLA), the U.S. MaritimeAdministration (MARAD), and the U.S. 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 issues.

Under the category of regulatory oversight, thepanel recommended that the Environmental Protec-tion Agency (EPA) and OSHA, in conjunction withDLA, the U.S. Navy, and MARAD, develop a compre-hensive compliance guide. This guide, entitled AGuide for Ship Scrappers,3 outlines 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 manner.

Steps 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. The scrapping process4

usually occurs in a series of steps:

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• Conduct a vessel survey.5 Diagrams 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 (e.g., 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 (e.g., bilge and ballast water) from theship generally occurs throughout the shipbreak-ing process. 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 removed.The U.S. 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 chemist6 certifies 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 (e.g., 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 PCBs.Both asbestos-containing materials (ACMs) andPCBs are usually removed in two stages. 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 to

shore, 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 1915.53).Hard-to-remove materials on surfaces may re-quire specific cut-line preparation, such as gritblasting or flame removal of paint,7 which canexpose workers to toxic metals and volatile com-ponents of paint. Appropriate precautions mustbe taken (e.g., 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 1910.134).

• Cut metal. During the cutting phase, the upperdecks, superstructure and systems are cut first,followed by the main deck and lower decks.Metal 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. Theshredders produce a gravel-like mixture of recy-clable metal particles and nonmetal “fluff,”which is not recyclable and needs to be sampledfor hazardous materials and disposed of accord-ing to state and federal regulations. The metalsare then separated from the fluff using magneticseparators, air flotation separator columns, orshaker tables.


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Initial Visit to Vessel toDetermine Suitabilityfor ScrappingBefore any work is conducted, an initial visit to thevessel is required to determine its condition. Duringthis visit, the following must be identified: the haz-ardous materials (e.g., lead, asbestos, PCBs) thatmust be removed from the ship, the hazards thatworkers could be exposed to during the scrappingoperations, and the condition of the ship, includingits suitability for towing and seaworthiness. Fromthe information obtained, a sampling plan8 must bedeveloped to address environmental remediationand the health hazards9 identified, including the spe-cial tools and equipment that will be required to en-sure worker safety. When workers are aboard theship for this assessment, those who are required towork alone must be checked on frequently, as re-quired by 29 CFR 1915.94. To comply with this re-quirement, employers should make arrangementswith the ship’s custodian for worker escorts duringthis visit. The custodian should be consulted with toidentify 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 CFR1915.1200, requires that employers communicate in-formation about health hazards to workers and thatthey have material safety data sheets (MSDSs) avail-able for all hazardous materials handled or used inthe shipbreaking process. OSHA standards for spe-cific substances are generally performance basedand require the protection of personnel from haz-ards through compliance with permissible exposurelimits, exposure monitoring, medical surveillance,use of respirators and protective clothing, and otherrequirements (see 29 CFR 1915, subpart Z). Somespecific hazards of shipbreaking include:

• Freon10 commonly found in refrigeration systemsthat, if released, could evaporate rapidly to createatmospheres immediately dangerous to life orhealth (IDLH).

• Halon11 and carbon dioxide12 in fire suppressionsystems that can create IDLH atmospheres if theyare released into spaces. Manual and free-floodautomatic fire-suppression systems must bephysically isolated or employ other positivemeans to prevent discharge before any hot workis permitted in spaces protected by such systems(29 CFR 1915.506).

• Hydrogen sulfide13, a colorless, toxic and flam-mable gas that can result from the decomposi-tion of microscopic marine life killed by AqueousFilm Forming Foam (AFFF) mixed with seawaterin AFFF wet firefighting systems.

• Carbon monoxide (CO)14, a colorless and odor-less gas that is produced by the combustionprocess such as welding, spontaneous combus-tion, and internal combustion engines. Pro-longed exposure may result in headaches,nausea, dizziness and ataxia.

• Metals of concern may include:

� Lead15 in paints and some greases, or possi-bly as tetraethyl lead16 for use as an additivein fuels;

� Mercury17 in gauges, tank-level indicators, orfluorescent light tubes;

� Tributyltin oxide18 on underwater hull plates;

� Chromates19 in paints and varnishes;

� Cadmium in electrical and electronic equip-ment; and

� Arsenic paints.

• Oxygen deficiency20 due to rusting in tanks thathave been sealed for long periods of time.

• Toxic contamination due to hazardous cargoesthat may have been carried in tanks.

• Asbestos exposure for workers removing as-bestos-containing thermal insulation; handlingcircuit breakers, cables, and cable penetrations;and removing floor tiles (from asbestos in themastic and in tile). Additional concerns can arisefrom handling and removing gaskets from pipingsystems and from electrical systems. Asbestosmay also be found in some molded plastic parts.All asbestos must be identified, removed andhandled in accordance with 29 CFR 1915.1001.Asbestos removal is also regulated by the EPAunder the asbestos National Emissions Stan-

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dards for Hazardous Air Pollutants (NESHAP),40 CFR 61 Subpart M. Many states require, andOSHA recommends, that an AHERA-qualified(Asbestos Hazard Emergency Response Act of1986) asbestos inspector identify all asbestos-containing materials prior to beginning ship-breaking oerations. Some states also require thatemployers notify their environmental regulatoryagencies prior to conducting asbestos removaloperations.

• Polychlorinated biphenyls (PCBs) in rubber prod-ucts such as hoses, plastic foam insulation, ca-bles, silver paint, habitability paint, felt underseptum plates, plates on top of the hull bottom,and primary paint on hull steel.

Additional information on health hazards associ-ated with shipbreaking can be found in the OSHAShipbreaking Fact Sheet.21

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

Towing the VesselDead-vessel tows are regulated by the U.S. CoastGuard at 33 CFR 165 et seq. Administrative proce-dures for towing vessels are established by localCoast Guard Sectors, so employers should contacttheir respective Captain of the Port (COTP) to deter-mine local policy; see Port Directory. Usually, a re-quest for a dead-ship tow is required to be submittedat least 48 hours in advance, if the tow is within theport, and seven days in advance, if the tow is out-side the port. Typically, this task is handled by thecontracted towing company.

Generally, the request must contain the followinginformation 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 mayvary depending on the port. Tank diagrams are rec-ommended to detail the location of oil and otherhazardous materials. The request must also containthe total number of tugs and their horsepower, placeof departure and destination, the date and time ofdeparture, the duration of the tow, and the nameand 24-hour telephone number of the responsibleparty. Indicate if an unusual tow configuration willbe used or if the request is for more than one towedvessel.

Depending on the particulars of the vessel beingtowed (e.g., age, extended lay-up status, vessel con-dition, etc.), the COTP may require that additionalsafety precautions be established before the tow isauthorized. This may include requirements such asobtaining a marine surveyor’s report, verifying thevessel’s seaworthiness, or allowing a representativefrom the Coast Guard to examine the vessel to ver-ify seaworthiness, pollution potential, and the ade-quacy of the towing arrangement. Such a report willinclude the recommended towing configuration, acondition inspection to evaluate seaworthiness, adetermination of which personnel will be allowed onboard during the tow, and any other special instruc-tions to allow for a safe tow.

In certain circumstances an International LoadLine Exemption Certificate or a Coastwise SingleVoyage Load Line Certificate may be required in ac-cordance with 46 CFR 42 Subchapter E (Load Lines).To make this determination and schedule an exami-nation, requests for tows offshore (e.g., beyond theboundary line) must be submitted seven days in ad-vance.

Mooring the VesselVessels that are intended for pier-side scrappingneed to be properly secured using approved moor-ing lines and a mooring plan reviewed by a qualifiedprofessional, such as a naval architect or marine en-gineer. The facility should have a Heavy WeatherPlan, which includes additional mooring require-ments for high and low tides, hurricanes, and otheradverse weather conditions. Mooring bits should beengineered to have sufficient strength to withstandforces imparted by all weather conditions. It is rec-ommended that ships not be moved during windsexceeding 25 knots.

Personnel assigned to assist in line handlingshould be experienced in line handling and mustwear personal flotation devices22 (PFDs) when thereis a potential for falling into the water, as required by29 CFR 1915.152(a). Personnel must be kept clear of

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the lines and never stand in the bight of a line.Nylon lines, primarily used on older ships, are sub-ject to atmospheric damage (e.g., sunlight, weather-ing, etc.) and may break without warning, releasinglarge amounts of energy capable of killing or maim-ing workers.

Spill-containment booms must be placed aroundall vessels, and personnel should be trained in theprocedures for opening and closing the booms.Care should be taken to keep small boats, locatedbetween booms, from being crushed due to unantic-ipated vessel movement. Fenders or other breastingdevices should be used to prevent such an incident.Operators of small boats must wear U.S. CoastGuard-approved PFDs and have on board a life ringwith 90 feet of line.

Workers must be denied access to the vesseluntil a gangway, ladder, or ramp meeting the re-quirements of 29 CFR 1915.74(a) and (b) and 29 CFR1915.75(a) thru (d) is provided. Particular attentionshould be paid to the trim of the gangway, ladder, orramp, where the fall or rise of tides may cause theangle to become unsafe, or pull away from its sup-port. Means should be provided to deny access tothe vessel by unauthorized personnel during non-work hours.

Vessel in dry dock for scrapping.

If work is conducted at night, adequate lighting23

must be provided and maintained at all times as re-quired by 29 CFR 1915.92(a). In shipbreaking opera-tions, the ship’s lighting may be difficult to maintainand, therefore, should be considered unreliable. Ifship’s lighting is used, a secondary means of light-ing (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 ex-plosion-proof as required by 29 CFR 1915.13(b)(9).Light-emitting diode (LED) flashlights are recom-

mended for use in gas-free spaces due to their smallsize, durability and dependability.

Example of temporary lighting.

Hauling the VesselIt is important, before hauling a vessel24 out of thewater, that an evaluation of the stability of the vesselbe conducted. Forces can develop that could makethe vessel unstable and cause it to tip over. Person-nel must not be aboard a vessel while it is beingpulled ashore, since it is possible for the vessel totopple over or for sections to break, creating severehazards for workers onboard. A naval architect ormarine engineer who has extensive experiencedocking ships should evaluate the ship for stabilityprior to hauling the vessel to ensure a safe opera-tion.

Hauling machines and chains or wire ropes areused in the hauling process to move vessels in thewater and on shore. This equipment is affected bythe weight of the vessel, the incline of the slope, thefriction between the hull and the slope, and anychange in the rate at which the vessel is hauled.When more than one chain or wire rope is used, theloading must be equalized among the chains or wireropes to ensure that no single leg is overstressed. Itis imperative that the equipment operators areaware of the hazards associated with the haulingprocess and have the ability to quickly compensatefor torque or variation in pitch.

Hauling machines usually consist of a train ofgears, operated by electric motors turning one ormore toothed chain wheels driving the haulingchain. The moving parts of hauling equipment mustbe guarded as required by 29 CFR 1915.115(b).

Steel hauling chains with appropriate pitch anduniform link dimensions should be used for haulingthe ship. Because of their high tensile strength andthe ease with which they can be connected with

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special hauling shackles, which are as strong as orstronger than the chain itself, most scrappers findchains more durable and economical than the bestwire rope. The ability to measure the strength ofchains is a major advantage that chains have overwire ropes. These chains, fitted over alloy steelwheels, have a small pitch diameter that permitshauling heavy loads with relatively small haulingmachines. A chain swivel is recommended to pre-vent excessive twist, which could cause an overloadof one section of chain.

It is particularly important to protect chains fromabrasion caused by sliding through sand, gravel, orsilt. In some installations, a means for washing thesand off the incoming chain should be provided.Chains should be inspected frequently for wear andremoved from service when they become exces-sively worn or do not meet the manufacturer’s rec-ommendations. Caliper measurements can be usedto determine the strength and corresponding safelive load of chains at any stage of wear.

Rivers are often subject to wide ranges of waterlevel, with periods of low water lasting severalmonths, interchanged with shorter periods of highwater. The vessels traveling such rivers are, of ne-cessity, shallow-draft, flat-bottomed craft of lightconstruction. A side-hauling method may be usedwhen dealing with such vessels in rivers, but wouldnot be appropriate for hauling ocean-going vessels.This method should be chosen only after carefulstudy by a qualified naval architect or marine engi-neer to determine if it is a suitable method.

The principal technical disadvantage of the usualside-haul arrangement, handled by several parts ofchain or wire rope, is that the load on any compo-nent cannot be accurately determined. Therefore, itis impossible to use an equalizing system. Conse-quently, it is necessary to use oversized chains orwire ropes to avoid possible overload.

Some employers use all-terrain forklifts or bull-dozers to pull vessels ashore. When this practice isused, it should be done only in accordance with themanufacturer’s recommendations. This systemshould be evaluated and approved by a naval archi-tect or marine engineer before being used. No mod-ifications or additions may be made to a forklift toallow hauling of vessels without the manufacturer’sprior written approval as required by 29 CFR1910.178(a)(4). Any equipment used for this purposeshould be protected with a rollover protective struc-ture, and operators should wear seat belts. Addition-ally, workers should be kept clear of the line of pullof the chains or wire rope used, and a suitable guardmay need to be installed to protect the operator of

the hauling machine from being struck by a break-ing chain or wire rope.

PlanningIt is important for employers to have a safety andhealth management system (SHMS) in place thatencompasses all aspects of the facility’s shipbreak-ing procedures and processes. The SHMS shouldconsist of a technical plan, safety and health plan,and an environmental technical plan, which can bealtered for each specific job. A written technical planshould outline the scrapping process, schedule, cutlines, and other engineering factors specific to eachproject, to ensure that the vessel is scrapped in asystematic manner to protect property and person-nel. Drawings of the vessel should be obtained andbroken down by work areas to allow a naval archi-tect or marine engineer to develop a cut plan so thatthe weight and stability of each vessel section canbe assessed at each stage to ensure a safe opera-tion. A safety and health plan or manual shouldcover all aspects of the shipbreaking process andspecify actions to be taken in the event that an emer-gency occurs. An environmental technical planshould address remediation of all hazardous materi-als. Each plan must be developed in accordancewith federal, state and local laws. Daily productionmeetings should take place to discuss the day’sevents, upcoming critical processes and procedures,and any safety considerations or special instructionsneeded to complete the day’s tasks safely. A morn-ing safety talk should be scheduled to discuss safetyand health issues that will be faced on that day, orother topics for educational and special emphasispurposes.

Breaking the VesselOne of the first steps in breaking the vessel is the re-moval of hazardous and flammable materials, whichis often called the drilling and draining phase (orpumping phase). Drilling refers to the act of drillingholes in systems to allow the release and capture offluids in the systems. It may also involve openingdrain ports already installed in the system. Holesare drilled at the lowest possible points in the sys-tem to ensure that the system is completely drainedof fluids. Draining involves removing all hazardousfluids and materials from the ship’s systems includ-ing hydraulic, cooling, high-pressure air, steam con-densate, preservatives in rudders and skegs, andfire-suppressant materials such as AFFF (aqueousfilm-forming foam), halon and carbon dioxide. It isimportant to consider the hazards that this process


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creates, and they should be treated accordingly.Personal protective equipment (PPE) must be pro-vided to personnel to prevent them from cominginto contact with liquids, oils, greases and materialsthat could cause skin and eye irritation (29 CFR1915.152(a)). All PPE should be selected by appropri-ately trained personnel and examined for proper fit.Further, atmospheric testing by a competent personis required while these systems are being drained(29 CFR 1915.12(a)). Testing must be performed ineach space or area that workers are required toenter or conduct work. This testing must occur inthe following sequence: oxygen content, flammabil-ity and toxicity.

No hot work is allowed in spaces that contain ac-tive fixed fire-extinguishing systems that have notbeen isolated to prevent discharge. If this precau-tionary step is not followed, the system could re-lease its contents into the space, producing adangerous atmosphere.

As hazardous materials are drained from sys-tems, the materials should be segregated by sub-stance and kept separate. Mixing hazardousmaterials may cause uncontrolled chemical reac-tions between materials, resulting in exothermic re-actions (excessive heat or fire), release of toxicgases, or other reactions that could injure personnelor cause an environmental spill.

Several procedures/processes may occur simul-taneously during the drilling and draining phase, in-cluding hazardous materials remediation, removingrecyclable items, and extracting easily removed inte-rior components. This process helps remove asmany components as possible from the interior ofthe vessel, creating a tunnel effect, to allow cuttingto begin from the top down. Cutting then proceedsfrom each end of the vessel, working towards thecenter of the vessel (see the diagram below – Mod-ule Cut Plan).

A sample Module Cut Plan.

This multifaceted approach requires excellentplanning and constant safety oversight so that work-ers are aware of what operations are ongoing andwhere they are occurring aboard the vessel. Thedaily safety talk can be a valuable tool for informingworkers of planned operations for the day.

As the work progresses, good housekeepingmust be maintained to reduce hazards and providesafe work surfaces and areas for workers. Solidwastes should be promptly removed and properlydisposed of to aid in maintaining a safe work area.

Worker torch-cutting scrap metal from vessel.

Burning EquipmentBurning equipment used in cutting metals must beprovided with regulators and flashback arrestorsshould be installed. Lighter-than-air gases (e.g.,acetylene, natural gas) are recommended becausethey do not pool in low areas as heavier-than-airgases (e.g., argon, propane, carbon dioxide) tend todo. Lines should be inspected frequently for damageand should be routed to avoid damage and to avoidtripping hazards for workers. Lines must not be leftin enclosed spaces while unattended for longer than15 minutes (29 CFR 1915.503(b)(2)(ii)). Pressure-droptests or other positive measures should be con-ducted on the lines each time that they are con-nected to a manifold to ensure their integrity, so thatthere are no leaks within the burning system (29CFR 1915.503(b)(2)(iv)). At the end of each shift thetorch lines should be rolled back to the manifold.Fittings for gas lines must be incompatible with res-piratory equipment to avoid mixing toxic gases withbreathing air.

Compressed-gas cylinders must not be taken intoconfined spaces. During storage, oxygen cylindersmust be separated from fuel-gas cylinders by a min-imum of 20 feet or by a 5-foot high barrier with aminimum half-hour fire resistance rating. When

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cylinders are not in use, they must be disconnectedand have valve protection caps in place. Cylindersshould be stored in an upright and secured positionaway from high traffic areas.

Cold CuttingCold cutting of vessels presents numerous hazardsto workers. Therefore, it is imperative that recipro-cating saw blades are kept sharp to prevent mal-functions that can lead to possible injuries. Thispractice will speed production as well. Since sawscreate noise sufficient to cause hearing loss, hearingprotection must be provided to and be used byworkers operating or working in close proximity tothe saws (see 29 CFR 1910.95). Additionally, er-gonomically-designed gloves should be used to mini-mize vibration exposure to workers. The employermust ensure that the power supply to reciprocatingsaws is provided with ground-fault circuit interrupters(see 29 CFR 1910 Subpart S). Electrical cords must bemaintained in sound condition and routed or pro-tected so as to prevent damage to the cords andavoid creating a tripping hazard for workers.

Mobile Hydraulic Shear CuttersMobile shear cutting is prevalent in shipbreakingand presents several hazards to personnel. Workersmust not place any part of their bodies in the dangerzone of the equipment (e.g., the shear area). Whenthis type of machine is mounted as an attachmenton a backhoe or excavator-type machinery, theswing radius should be barricaded to prevent work-ers from coming into the pinch-point area betweenthe rotating structure of the machine and its drivecarriage or other fixed objects, such as the part ofthe ship being scrapped. Care should be taken to cutmaterials to prevent recoil and to keep large piecesfrom striking or falling on workers.

Mobile hydraulic shear cutters used in shipbreaking.

Shoreside Processing of MetalsScrap metals, including steel, aluminum, copper,copper nickel alloy, and lesser amounts of othermetals, are sorted by grade and composition andsold to remelting firms or to scrap metal brokers.Valuable metals, such as copper in electric cable,that are mixed with nonmetal material may be re-covered using shredders and separators. The shred-ders produce a gravel-like mixture of recyclablemetal particles and non-metal “fluff” that is not re-cyclable and needs to be sampled for hazardousmaterials and disposed of according to state andfederal regulations. The metals are then separatedfrom the fluff using magnetic separators, air-flota-tion separator columns, or shaker tables. Machineguarding must be provided in accordance with 29CFR 1910.212 and 29 CFR 1910.219. Guards shouldbe interlocked to shut down the equipment in theevent that the guard is opened. Noise exposuremust be controlled in accordance with 29 CFR1910.95. An industrial hygiene assessment of metalsexposure must be conducted and controls imple-mented to maintain worker exposures within ac-ceptable limits. Asbestos must be removed inaccordance with 29 CFR 1915.1001 before process-ing scrap metal. Measures must be taken to preventskin contact with polychlorinated biphenyls (PCBs).Additionally, PCBs must be cleaned from cut lines ofmaterials that are to be cut by burning (see 29 CFR1915.53(d)(1)).

Care must be taken to ensure that workers do notposition themselves beside or below a section beingcut, where falling pieces of scrap or the sectionmight strike them. Pieces being cut often becomeunstable, shift, fall or slide. Therefore, workers mustbe positioned so that they are not subject to beingstruck by shifting materials (see 29 CFR 1915.116(j)and (k)). Several fatalities have been recorded wherescrap metal pieces or sections crushed workerswalking through cutting areas.

Fall ProtectionFalls are a major hazard in shipbreaking due to theever-changing work environment. Continuous cut-ting of the vessel weakens the structures or sectionsand creates new openings and deck edges, makingfall protection a necessity. Workers need to wearsafety harnesses and be tied off when near openholes and deck edges. Anchorage points for eachpositioning device system must be capable of sup-porting at least double the potential impact load of aworker’s fall (29 CFR 1915.160(a)(3)). In addition, life-lines must be kept clear from sharp edges to avoid


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the lines from being cut or damaged (see 29 CFR1915.159(c)(4)). Although the requirement in 29 CFR1915.73 (“Guarding of deck openings and edges”)does not apply to shipbreaking, it is recommendedthat barriers be placed around or near deck edgesand openings whenever feasible.

Examples of fall protection.

The lack of a requirement to guard deck edgesand openings does not remove the employer’s re-sponsibility to protect workers from fall hazardsthrough the use of appropriate fall protection sys-tems. In certain circumstances, during the ship-breaking process, workers are required to work fromaerial lifts and man lifts that are suspended bycranes to reach elevated areas for cutting. In thesesituations, it is also important for appropriate fallprotection to be used.

Side shell cuts are made, leaving 42-inch high bulkhead atthe deck level for fall protection.

Fire Prevention andProtectionSubpart P - Fire Protection in Shipyard Employment,29 CFR 1915, requires employers to have an overallfire suppression program that establishes the loca-tion, type and capacity of firefighting equipmentsuch as extinguishers, fire hoses and standpipes,smoke detectors, automatic sprinklers and otherfixed firefighting systems in accordance with appli-cable fire codes. Employers must have a writtenplan in place that provides for the routine inspec-tion, maintenance and replacement of this equip-ment and must require training for new workers andrefresher training for all shipyard workers. The writ-ten plan must include procedures for the control offire hazards, such as flammable and non-flammablecompressed gases, ignition sources, combustible

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materials, welding and hotwork operations andmust include procedures for evacuation. The em-ployer’s evacuation plan must include the following:emergency escape procedures; procedures to be fol-lowed by workers who may remain longer in theworksite to perform critical shipyard operations be-fore they evacuate; procedures to account for allworkers after an emergency evacuation is com-pleted; preferred means for reporting fires and otheremergencies; and the names or job titles of theworkers or departments who may be contacted forfurther information or explanation of duties.

The hazards associated with the use of fixed fire-extinguishing systems on vessels and vessel sec-tions have long been recognized by the U.S. CoastGuard as evidenced by Coast Guard CommandantNotices and Instructions that date from 1978. The In-ternational Maritime Organization (the United Na-tions’ specialized agency responsible for improvingmaritime safety and preventing pollution fromships) has also addressed these hazards by issuingregulations that are part of the International Conven-tion for the Safety of Life at Sea. 29 CFR 1915.506(b)requires employers to protect their workers whomay be exposed to a dangerous atmosphere causedby a fixed fire-extinguishing system by either physi-cally isolating the system, disconnecting or blank-ing, or using other positive means to prevent thesystem’s discharge. In shipbreaking operations,OSHA recommends that the system be physicallydisabled. In general, there should be no work con-ducted with the system activated. However, shouldsuch a situation occur, the employer must ensurethat workers are trained to recognize the system’sdischarge and evacuation alarms, appropriate evac-uation routes and hazards associated with compo-nents of the system.

Employers must have a written fire watch policythat specifies the necessary training of workers, theirduties and personal protective equipment (PPE) tobe used. This policy may be part of the overall firesafety plan or separate, but must be effective in pro-tecting workers from injury. A firewatch must beposted while hot work is being performed when anyof the following conditions are present: slag, weldsplatter, or sparks; unprotected combustible materi-als or insulation; and heat radiation or conductionon insulated pipes, bulkheads, decks, overheads andpartitions (see 29 CFR 1915.504). It is important thatworkers assigned to firewatch duty are not taskedwith any additional duties while hot work is inprogress. In addition, the firewatch must be able tocommunicate with the workers performing the hotwork, as well as any personnel that may be affected.

Method used for emergency response and fire-preventionplanning.

Emergency ResponseIn addition to compliance with 29 CFR 1915.502,which includes a fire safety plan, OSHA requirescompliance with 29 CFR 1910.38 and 29 CFR 1910.39for emergency response and fire prevention plan-ning. Employers do not need to have separate emer-gency response plans as long as the plan covers theapplicable general industry worker emergency planand fire prevention plan provisions, as well as theshipyard employment fire safety plan. A musteringplan for each jobsite should be incorporated in theemergency response plan to account for all workersin the event of an emergency where evacuation isrequired. Each plan or combination of emergencyresponse plans must be in writing, kept in the work-place and be available to workers for review.

DrillsA fire response organization, as defined in 29 CFR1915.509, may include (1) fire brigades, (2) shipyardfire departments, (3) private or contractual fire de-partments, or (4) municipal fire departments.

While larger shipyards may have their own fireresponders, smaller shipyards often use an outsidesource, typically the local fire department. Thesemunicipal or other fire departments may have littleexperience in fighting fires in shipyards, especiallyon vessels. Fighting vessel fires can be more com-plicated than traditional firefighting because out-side firefighters seldom have the opportunity tolearn the layout of the vessels. Additionally, vesselsbeing scrapped have constantly changing struc-tures. Therefore, proper coordination, familiariza-tion, training and drills are necessary to ensure thesafety of outside firefighters who respond to ship-yard fires. See 29 CFR 1915.505 for OSHA safety re-quirements.

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If an outside fire response organization is used,OSHA requires employers to communicate with thatorganization about facility layout and familiarization,and coordination protocols (29 CFR 1915.505). OSHAbelieves that any fire response organization that ex-pects to respond to shipyard fires will benefit fromthis coordination. They will be able to respond tofires quickly and effectively, thus enhancing safetyfor the shipyard workers and their own fire responseteam members.

In coordinating drills and other communicationswith an outside fire department, employers mustdiscuss the types of fire suppression incidents towhich the fire response organization is expected torespond to and procedures for obtaining help fromother fire response organizations. Additionally,methods of familiarizing the external fire responseorganization with the layout of the facility or work-site, including access routes to controlled areas andsite-specific operations, occupancies, vessels or ves-sel sections and hazards should be discussed. Theemployer must ensure the standardization of all fire-hose couplings and connection threads throughoutthe shipyard and on vessels or vessel sections byproviding the same type of hose coupling and con-nection threads for hoses of the same or similar di-ameter. See 29 CFR 1915.505 (f)(2)(ii).

Responders to shipyard fires encounter a com-plex set of hazards involving buildings, as well asvessels in drydocks, wet slips, or pier-side. Fire re-sponders need to be prepared to safely and success-fully handle a wide range of fires from flammableliquids in a storage room of a shipyard building, tooil-soaked rags in the engine room of a ship. Thefires could include: combustible materials (such aswood, paper, or cloth); flammable or combustibleliquids (such as oil, fuels, paints, or chemicals); insu-lation and other materials that may give off toxicgases and smoke during a fire; electrical compo-nents (such as energized motors, circuit controls,transformers, or wiring); or even combustible met-als (such as magnesium or titanium).

RescueA rescue team must be established to respondpromptly to rescues required in confined and en-closed spaces or other areas where dangerous at-mospheres may be present. The rescue team can becomposed of workers, or it can be an outside teamthat meets all the applicable requirements of 29 CFR1915.12(e)(1). When an outside rescue team is used,they should be given a tour of the employer’s facilityto ensure familiarity with the operations and to iden-tify any special concerns for rescue. They must be

given an opportunity to conduct drills on board avessel being scrapped in accordance with 29 CFR1915.12(e)(1)(iii).

Lifesaving MaterialsAt least one ladder25 meeting the requirements of 29CFR 1915.158(b)(5) must be available near eachfloating vessel on which scrapping work is beingconducted. Depending upon vessel length, one ormore liferings26 meeting the requirements of 29 CFR1915.158(b)(1) thru (4) must also be provided. Al-though they are not required for shipbreaking oper-ations, OSHA recommends that at least onelifesaving skiff be immediately available at locationswhere workers are working over or adjacent towater.

Hazardous Material SpillsSpill kits should be provided that contain an ade-quate quantity of suitable materials for spill contain-ment and cleanup. The contents of these kits shouldbe restored after each use to ensure that adequatematerials are available to allow workers to respondsafely to future spills. All applicable environmentalregulations should be consulted to ensure that re-sponse and reporting requirements are met. Onlyfully qualified and properly equipped personnel areallowed to respond to hazardous material spills.27

Energy ControlEvery effort should be made to take all mechanicaland electrical systems to a zero energy state duringthe drill and drain phase of breaking the vessel.However, to provide adequate lighting for workers,the ship’s lighting system28 is often maintained. Itmay also be desirable to maintain the electrical dis-tribution system, which can be more dependable,rather than using shore-based temporary services toprovide power to electrical equipment and tools.When this is done, the employer must ensure thatthe integrity of electrical systems is maintained in asafe manner, including guarding of live parts andgrounding by implementing electrical energy con-trol procedures in accordance with 29 CFR 1910Subpart S to ensure the safety of workers.

Mechanical systems should be isolated fromtheir energy source and rendered inoperative,drained and depressurized prior to working onthem. Each isolation device, controlling the energyto a mechanical system, should be physically lo-cated and disabled. In addition, workers must not beallowed to work in or on a lifeboat until the boat issecured in accord with 29 CFR 1915.96(a). Cradles orcarriages on marine railways in a hauled position

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must be secured in accord with 29 CFR1915.115(e)(1).

Before hot work is permitted in areas where free-flooding, automatically activated fire-suppressionsystems are installed, the system must be physicallyisolated or other positive means used to prevent anaccidental discharge. For additional information onthe hazards of fixed extinguishing systems, see 29CFR 1915.506.

MedicalThe employer must provide a first-aid room in closeproximity to workers or a first-aid kit for each vesselon which work is being performed. In either case, aqualified person must be close at hand to renderfirst aid to workers. Employers must take the neces-sary precautions to protect persons administeringfirst aid, as well as nearby workers who may comeinto contact with blood and other potentially infec-tious materials (see 29 CFR 1910.1030 and OSHABloodborne Pathogens Fact Sheets). When work isbeing performed on more than one small vessel at apier, only one first-aid kit is required to be kept inclose proximity to the work (see 29 CFR 1915.98).However, it is recommended that employers provideadditional first-aid kits where needed. A facility mayconsult with a physician or licensed healthcare pro-fessional who is knowledgeable in occupationalmedicine, regarding specific first-aid needs. Oneperson qualified to render first aid may serve sev-eral vessels as long as he/she is conveniently lo-cated near the vessels. Emergency contact numbersshould be posted where the first-aid kit is main-tained. On vessels in which ten or more workers areworking, at least one, but not more than two, Stokesbasket stretchers, or equivalent, are required to belocated at each job location. Stretchers must be per-manently equipped with bridles for attaching to thehoisting gear. A blanket or other liner suitable fortransferring an injured worker to and from thestretcher must also be provided (see 29 CFR1915.98(d)).

In addition to first-aid treatment, workers mightbe exposed to harmful substances such as lead, as-bestos and cadmium. Any workers exposed to thesesubstances, in particular, require appropriate med-ical surveillance. All medical exams and proceduresmust be performed by or under the supervision of alicensed physician, at no cost to workers and at areasonable time and place.

Lead – An employer must institute a medical sur-veillance program for all workers who are or may beexposed at or above the action level (30 µg/m3 of air,

averaged over an 8-hour period) for more than 30days a year. In addition to a detailed work and med-ical history, blood sampling and analysis must bemade available at least every six months. If a work-er’s blood lead levels are at or above 40 µg/100 g ofwhole blood during the last sampling period, thenthe frequency must be increased to every twomonths until two consecutive blood lead levels arebelow 40 µg/100 g of whole blood in accord with 29CFR 1910.1025(j)(2)(i)(B). See 29 CFR 1910.1025(j) foradditional medical surveillance requirements.

Asbestos – When dealing with asbestos, the em-ployer must institute a medical surveillance pro-gram for all workers who, for a combined total of 30or more days per year, are engaged in Class I, II andIII work or are exposed at or above a permissible ex-posure limit (PEL), 29 CFR 1915.1001(m)(1)(i). How-ever, for purposes of the 30-day threshold, theemployer need not count any day in which a workerengages in Class II or Class III operations on intactmaterial for one hour or less (taking into account theentire time spent on the removal operation, includ-ing cleanup) and, while doing so, adheres fully tothe work practices specified in 29 CFR 1915.1001(g).

The employer must make medical examinationsand consultations available to each worker coveredunder paragraph 1915.1001(m)(1)(i) on the followingschedules: (1) before the worker is assigned to anarea where negative pressure respirators are worn;(2) within 10 working days following the thirtieth dayof exposure when the worker is assigned to an areawhere exposure to asbestos may be at or above thePEL for 30 or more days per year, or engages inClass I, II, or III work for a combined total of 30 ormore days per year; and (3) annually thereafter (see29 CFR 1915.1001(m)(2)(i)). No worker is to be ex-posed to an airborne concentration of asbestos inexcess of 0.1 fiber per cubic centimeter (f/сc) of airas an eight-hour time-weighted average. See 29 CFR1915.1001(m) for additional medical surveillance re-quirements. Additionally, no worker is to be ex-posed to an airborne concentration exceeding 1.0f/сc in a thirty-minute sampling period. See 29 CFR1915.1001(c).

Cadmium – Under 29 CFR 1910.1027(l), an em-ployer must institute a medical surveillance pro-gram for all workers who are or may be exposed ator above the action level (2.5 µg/m3), unless the em-ployer can demonstrate that the worker is not, andwill not be, exposed at or above the action level 30days or more a year (twelve consecutive months).The employer must provide an initial (preplacement)examination to all workers receiving medical sur-veillance within 30 days after initial job assignment.


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See 29 CFR 1910.1027(l)(1)(i) and (2)(i). In additionto a detailed work and medical history, biologicalmonitoring must include: (1) cadmium in urine(CdU); (2) cadmium in blood; and (3) beta-2-micro-globulin in urine (β2-M). See 29 CFR 1910.1027(l)(2)(ii).

Worker Medical QualificationsAll workers should be physically capable of perform-ing their tasks in a safe manner. Workers with a his-tory of chronic back injuries should not be assignedto tasks that require manual material handling. Ad-ditionally, the employer must identify a physician orother licensed healthcare provider to perform amedical evaluation to determine a worker’s ability touse a respirator. The medical evaluation can be per-formed either by administering a medical question-naire or by conducting an initial medical examinationthat obtains the same information as the medicalquestionnaire (29 CFR 1910.134(e)(2)). Any abnor-malities indicated on medical questionnaires mayneed to be evaluated by a physician specialist.

As required by 29 CFR 1915.117(c), workers withknown uncorrected impaired eyesight or hearing, orwho suffer from heart disease, epilepsy, or similarailments which may suddenly incapacitate them, areprohibited from operating a crane, winch, or otherpower-operated hoisting apparatus.

SanitationWashing facilities must be provided for all workersin accordance with 29 CFR 1915.97(b). Workers mustnot be allowed to consume food or beverages, or tosmoke in areas where they are exposed to contami-nants. Workers must be instructed to wash beforeconsuming food or beverages and smoking (see 29CFR 1915.97(c)). Separate toilet facilities must beprovided for men and women, or the facilities mustbe lockable (see 29 CFR 1910.141(c)).

Shipboard RiggingPersonnel assigned to perform rigging should betrained in good rigging practices. Rigging gear mustbe of adequate capacity to safely handle the largestanticipated load with a safety factor of no less than 5(see 29 CFR 1915.112 and 29 CFR 1915.113). Whilethe use of tag lines is not required in shipbreaking,care must be taken to ensure that loads are not car-ried over the heads of workers and that workers donot place themselves between a suspended loadand a fixed object where they could be crushed (see29 CFR 1915.116(j) and (q)). When slings attached toeye-bolts are used, the pull must be within 20 de-

grees of the axis of the bolt as required by 29 CFR1915.116(e). Only shouldered eye-bolts should beused. Wood, canvas, or other suitable materialsmust be used as chafing gear or softeners to pre-vent damage to wire rope slings29 where they runover the edges of materials being handled (see 29CFR 1915.116(f)). Slings should not be covered withpadding that prevents them from being inspectedbefore each use. Kinked slings, which do notstraighten out when placed under load, should im-mediately be removed from service. Additional in-formation regarding sling safety can be found inOSHA Publication 3072 (1996), Sling Safety.30

Workers must never be allowed to ride the loador hook (see 29 CFR 1915.116(i)). When cranes areoperated “in the blind,” a signalman must be as-signed who is familiar with the signal codes to beused (see 29 CFR 1915.116(l)). Only this signalmanmust give signals to the crane operator. Hatch cov-ers must be completely opened or removed beforemoving materials or equipment through them (see29 CFR 1915.116(n)). It is recommended that thehatch beams also be removed; if not removed, thebeams must be sufficiently lashed, locked, or other-wise secured to prevent them from being displacedby accident (see 29 CFR 1915.116(n)). Hatches mustnot be opened or closed while workers are in thesquare of the hatch below (see 29 CFR 1915.116(o)).Swing and travel alarms must be sounded to warnworkers of movement before loads are raised, low-ered, or swung (see 29 CFR 1915.116(p)). Alarmsmust be capable of being heard or seen above am-bient noise or light levels to appropriately warnworkers of potential danger (see 29 CFR 1910.165(b)(2)).

Materials HandlingDuring the shipbreaking process, workers handlelarge sections of steel and other heavy or awkwardmaterials, resulting in unique materials handling is-sues that may cause injury. To the extent feasible,manual materials handling should be avoided whenweights are unknown or excessive, or because ofother conditions such as uneven walking surfaces,falling hazards and irregular or sharp edges of a cutplate. Mechanical materials handling methodsshould be used whenever possible (e.g., cranes);however, when manual materials handling is per-formed, gloves should be provided to protectagainst cuts. Walking paths31 should be kept freefrom obstructions and tripping hazards. Shoes32

should be maintained in a dry, oil-free condition,with soles and heels evenly worn.

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Workers should be trained on ergonomic hazardsin the workplace and about ways to minimize therisk of injury from these hazards. Some of the train-ing topics should include: the proper use of equip-ment, tools and machine controls; proper liftingtechniques; awareness of work tasks that may leadto pain or injury; and procedures for reporting work-related injuries and illnesses. In addition, workersshould be encouraged to warm up or stretch prior toengaging in heavy lifting.32

Crane ServicesOne of the more hazardous operations in shipbreak-ing is handling materials with cranes.33 Crane opera-tions involve a complex relationship between themachine, the operator, the material being handled,the rigging and rigging gear that secures the mate-rial to the crane hook, the workers and obstructionsin the area, and the ground surface or foundation ofthe crane. Failure, inadequate planning, or improperoperation can have disastrous consequences. In2005 alone, crane accidents.com34 reported 127 fa-talities related to crane accidents.

Only workers who are properly trained and quali-fied may be assigned to operate cranes in support ofshipbreaking operations. Crane operators mustknow and understand signals used to control thecrane and must be familiar with the operation of thespecific machine to which they are assigned (see 29CFR 1915.117(b) and (c)). Riggers should also betrained to safely carry out their assigned tasks.

The swing radius of the counterweight and su-perstructure must be established and guarded toprevent workers from being struck. Special attentionshould be given when cranes are operating nearbuildings 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 travelalarms should be used to warn workers of machinemovement. When lifting “in the blind,” a signalmanwho is visible to the operator must be placed to as-sist the operator in safely moving the load (see 29CFR 1915.116(l)).

Cranes used for removing materials from theship must be certified in accord with 29 CFR1915.115(a). A crane of sufficient capacity to safelyhandle the largest expected load must be used (see29 CFR 1915.115(c)(2)). It is particularly important inselecting cut lines to consider the weight of the totalload to be handled. A qualified naval architect ormarine engineer should be consulted to ensure thatsections cut are within the safe lifting capacity ofthe machine to be used. Industry practice often in-volves attaching the load to the crane before the

final cut frees the load to avoid shock loading of thecrane. The use of an electric load-indicating deviceis recommended to ensure that the crane or riggingis not overloaded beyond the structural safe loadrating. If any recognized over-load or shock load oc-curs, then the crane should be removed from serv-ice until the crane and rigging are inspected inaccord with the crane manufacturer’s or certifiedagent’s instructions. The crane must be maintainedin accord with the manufacturer’s recommenda-tions and must be inspected in accord with applica-ble standards for the type of crane used. See 29CFR 1915.111.

Crane being used to lift cut section from vessel undergoingscrapping.

Safe working loads for cranes are based on boththe structural integrity of the machine and the stabil-ity of the machine on its foundation surface. Safeloading normally requires a crane to be placed on asurface with a grade of no more than 1 degree. Inaddition, the manufacturer’s designated safe work-ing load must not be exceeded (29 CFR1915.115(c)(2)). Load rating charts provide no valuein determining stability once the grade limitation isexceeded, thus the operation of the crane is consid-ered unsafe beyond that point. Additionally, sur-faces should be capable of safely supporting theweight of the machine and its total load. Cribbing orpads may be necessary to level the crane or to cre-ate a sufficiently stable footing. The area to be usedfor crane setup should be carefully selected by aperson well qualified in crane operations to ensurethat adequate footing is provided. The use of an en-gineer qualified in soil structure and stability is rec-ommended (e.g., civil or geotechnical engineer).

Rigging must be selected to handle the largestanticipated load. Good rigging practices are re-quired and rigging personnel should be trained insafe rigging techniques. Chafing gear should beused to protect rigging gear35 from abrasion caused

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by rough edges of cut materials. Rigging gear mustbe inspected36 frequently as required by 29 CFR1915.111. Knots are not permitted in wire rope orchains.

Crane being used to lift cut section from vessel undergoingscrapping.

ForkTrucksIf fork trucks are used to move materials, only roughterrain fork trucks are recommended. Operatorsmust be trained and must not have any conditionthat could cause them to become incapacitated (e.g.,uncontrolled diabetes, epilepsy or heart disease) (29CFR 1915.117(c)). Fork trucks should be of sufficientcapacity for the intended load. Loads should not ex-tend beyond the forks in a manner that could causethe fork truck to tip over. If frontend attachments areused, other than factory installed attachments, theemployer must have the truck marked to identify theattachments and the appropriate weight of the truckand attachment combination (29 CFR 1910.178(a)(2)(5)). Fork trucks should be properly maintainedwith consideration given to the effects of the marineenvironment on the truck. Gasoline or diesel forktrucks should not be placed in vessel holds due tothe potential for buildup of toxic gases (e.g., exhaustfumes). Fork trucks should not be driven up to work-ers where they might be crushed by the truck orload. Where the operator’s view could be obstructedby a load, the truck should be operated with the loadtrailing. In situations when loads must be carried up-hill they should only be driven in a forward motionand with a designated spotter. The truck path shouldbe twice the width of the load being carried to avoidinadvertent contact with objects. An inspection mustbe performed on all trucks in service before eachshift and at necessary intervals during its use, in ac-cordance with 29 CFR 1915.111(a). If any item that

affects the safe operation of the truck is found to bedefective, the truck should be removed from serviceuntil it is repaired. For additional information see 29CFR 1910.178 and 29 CFR 1915.117.

TrucksTrucks may be used to haul scrap both over the roadand in the yard. Trucks used over the road should bemaintained in a road-worthy condition and inspectedin accordance with federal and state safety regula-tions. The truck should be inspected daily by thedriver and any condition that affects the safe use ofthe truck should be corrected before it is used.Trucks used in the yard should never be backed ordriven up to workers standing between the truckand a fixed object. Additionally, backup alarmsshould be provided on these trucks when they areused in the yard to haul scrap. A spotter should beused to assist the driver when the view to the rear isobstructed. Over-the-road drivers must have aproper Commercial Driver’s License. Scrap shouldbe loaded within the safe capacity of the truck andevenly distributed over all axles, ensuring compli-ance with state and federal axle weight require-ments. It should be loaded so as to preventmaterials from shifting in or falling from the truck.While on the road, the load should be covered toprevent loose pieces from falling out. Drivers shouldhave no condition that could cause them to becomeincapacitated (e.g., uncontrolled diabetes, epilepsy,or heart disease).

For More InformationAbout Over-the-RoadTruck 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, OSHAwww.osha.gov/dcsp/products/etools/pit/index.html

TrainingAll workers engaged in shipbreaking operationsmust be trained in the hazards of the work to whichthey are exposed (e.g., persons assigned to burnmaterials should be trained in burning safety; rig-gers in rigging safety). General hazard recognitionand safety precautions should be included in workerorientations, as well as training provided on the per-sonal protective equipment (PPE) to be used at theworksite. PPE37 training must include use of hard

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hats, eye protection, footwear, hearing protection,work gloves, and other PPE as appropriate (see 29CFR 1915.152(e)). Workers should be instructed toavoid the use of synthetic clothing that melts orburns rapidly such as nylon, rayon, or Corfam®, inareas where burning operations are conducted. Adaily “tool-box safety talk” to review work progress,planned work for the day and anticipated hazardsassociated with that work is recommended.

Daily safety talk.

A hazard assessment38 of work activities, as de-scribed in 29 CFR 1915.152(b), must be conducted todetermine hazards. Hazard communication39 train-ing must be provided to the workers and must coverthe hazardous materials used in work procedures, aswell as how to protect themselves from exposure tothose hazards. This includes hazardous materials in-troduced by other employers at the worksite to

which workers may be exposed. Fulfilling this re-quirement is the responsibility of the employer whohas control over the workers performing the work.Copies of material safety data sheets (MSDSs) forhazardous materials used must be available at theworksite (29 CFR 1915.1200).

CommunicationIncreasingly, non-English-speaking workers arebeing employed in the shipbreaking industry. As aresult, it has become difficult for employers andworkers to communicate effectively. Despite thelanguage barrier, signage and instructions must beunderstood by all workers (29 CFR 1915.16(a)).Therefore, employers may need to provide requiredpostings and warnings in more than one language(e.g., English, Spanish, Vietnamese) at the worksite.It is important for workers to understand the hazardsto which they might be exposed and the precautionsnecessary to avoid injury from those hazards. Ifworkers are unable to read MSDSs or other hazardcommunication information themselves, then theemployer should provide an interpreter to pass theinformation on to them.

Maintenance ShopsMaintenance shops at shipbreaking facilities havesimilar safety and health hazards normally encoun-tered in other maintenance shops. As in othershops, particular attention should be paid to house-keeping, electrical safety, machine guarding andstorage, and the use and disposal of hazardous ma-terials.

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References1 http://www.epa.gov/Compliance/resources/

publications/civil/federal/shipscrap guide.pdf, AGuide for Ship Scrappers. Tips for RegulatoryCompliance, EPA, Summer 2000.

2 http://www.basel.int/ships/techguid.html, Techni-cal Guidelines for the Environmentally SoundManagement of Full and Partial Dismantling ofShips, Basel Convention, August 8, 2002.

3 See note 1, above.4 http://www.osha.gov/SLTC/etools/shipyard/ship_

breaking/index.html, eTool, Shipyard Employ-mentShipbreaking, 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 Guidelinesfor Confined and Enclosed Spaces and Other Dan-gerous Atmospheres, 29 CFR 1915 Subpart B, AppA, OSHA.

7 http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STAND ARDS&p_id=10231,Regulations, Welding, Cutting and Heating in Wayof 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, ShipyardEmployment-General Requirements-Inventory ofHazardous Materials, OSHA.

10 http://msds.dupont.com/msds/pdfs/EN/PEN_09004a2f80007210.pdf, Material Safety Data Sheetfor “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 forHalon 1211, WFR Wholesale Fire and Rescue Ltd.,September 2006.

12 http://www.vngas.com/pdf/g8.pdf, MSDS, BOCGases, reviewed June 7, 1996.

13 http://www.marsulex.com/customers/pdfs/msds_HydrogenSulfide.pdf, MSDS for HydrogenSulfide, 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 DiseaseRegistry (ATSDR) or http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=10030, Toxic and HazardousSubstances, 29 CFR 1910.1025, OSHA.

16 http://www.osha.gov/dts/chemicalsampling/data/CH_270900.html, Chemical Sampling Informationfor 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, Tri-butyltin Oxide, validated March 26, 1998, NIOSH.

19 http://www.osha.gov/SLTC/healthguidelines/zincchromate/recognition.html, OccupationalSafety and Health Guideline for Zinc Chromate,OSHA.

20 https://www.osha.gov/SLTC/etools/shipyard/shiprepair/confinedspace/oxygendeficient.html,Shipyard Employment eTool, Confined or En-closed Spaces, Oxygen-Deficient or -Enriched At-mospheres, OSHA.

21 http://www.osha.gov/OshDoc/data_MaritimeFacts/shipbreaking-factsheet.pdf, OSHA Fact Sheet-Shipbreaking, OSHA, 2001.

22 http://www.osha.gov/SLTC/etools/shipyard/ship_breaking/ppe/general_ppe/life saving_equipment.html, eTool, Shipyard Employment-PPE Selection-Shipbreaking-Lifesaving Equipment, OSHA.

23 http://www.osha.gov/SLTC/etools/shipyard/ship_breaking/working_conditions/illumination.html,eTool, Shipyard Employment-Shipbreaking-Work-ing Conditions-Illumination, OSHA.

24 http://www.osha.gov/SLTC/etools/shipyard/ship_breaking/access/drydock_marinerailways.html,eTool, Shipyard Employment-Shipbreaking-Ac-cess-Access to and Guarding of Dry Docks andMarine 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 July13, 2009.

28 http://www.osha.gov/SLTC/etools/shipyard/ship_breaking/working_conditions/ housekeeping.html,eTool, Shipyard Employment-Shipbreaking-Work-ing 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-PPESelection-Foot Protection, OSHA.

32 http://www.osha.gov/dsg/guidance/shipyardguidelines.html, Guidelines for Shipyards,Ergonomics for the Prevention of MusculoskeletalDisorders.

33 http://www.osha.gov/SLTC/etools/shipyard/ship_breaking/material_handling/gear.html, eTool,Shipyard Employment-Shipbreaking-MaterialHandling-Use of Gear, OSHA.

34 http://craneaccidents.com/stats.htm, Crane Acci-dent Statistics, CraneAccidents.com.

35 http://www.osha.gov/SLTC/etools/shipyard/ship_breaking/material_handling/ropes.html, eTool,Shipyard Employment-Shipbreaking-MaterialHandling-Ropes, Chains, and Slings, OSHA.

36 http://www.osha.gov/SLTC/etools/shipyard/ship_breaking/material_handling/inspection.html,eTool, Shipyard Employment-Shipbreaking-Material handling-Inspection, OSHA.

37 http://www.osha.gov/SLTC/etools/shipyard/standard/ppe/ppe_selection.html, eTool, Ship-yard 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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Additional Resourceshttp://www.imo.org/includes/blastDataOnly.asp/data_id%3D11404/ResShiprecycling962.pdf, InternationalMaritime Organization (IMO) Guidelines on ShipRecycling, IMO, March 4, 2004.

http://www.ilo.org/public/english/protection/safework/sectors/ships/shpbreak.htm, Safe Work, Ship break-ing, last updated April 2000, International LaborOffice (ILO).

https://www.osha.gov/Publications/OSHA3348-metal-scrap-recycling.pdf, Guidance for the Identifi-cation and Control of Safety and Health Hazards inMetal 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 Ship-breaking, OSHA, 3/16/05.

http://www.osha.gov/dts/maritime/index.html, OSHAAssistance for the Maritime Industry, OSHA.

https://voa.marad.dot.gov/programs/ship_disposal/standing_quot/docs/TECHNICAL%20COMPLIANCE%20PLAN%20(TCP).pdf, Requirements for TechnicalCompliance Plan, Maritime Administration(MARAD).

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

http://www.osha.gov/dcsp/osp/index.html, StateOccupational Safety and Health Plans, OSHA.

http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=DIRECTIVES&p_ id=3429, Direc-tive, CPL-02-00-142, Shipyard Employment “ToolBag” Directive, effective date August 3, 2006, OSHA.

www.osha.gov, OSHA Home Page.

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OSHA AssistanceOSHA can provide extensive help through a variety ofprograms, including technical assistance about effec-tive safety and health programs, state plans, workplaceconsultations, and training and education.

Safety and Health ManagementSystem GuidelinesEffective management of worker safety and health pro-tection is a decisive factor in reducing the extent andseverity of work-related injuries and illnesses and theirrelated costs. In fact, an effective safety and healthmanagement system forms the basis of good workerprotection, can save time and money, increase produc-tivity and reduce employee injuries, illnesses and re-lated workers’ compensation costs.

To assist employers and workers in developing ef-fective safety and health management systems, OSHApublished recommended Safety and Health ProgramManagement Guidelines (54 Federal Register (16):3904-3916, January 26, 1989). These voluntary guide-lines can be applied to all places of employment cov-ered by OSHA.

The guidelines identify four general elements criti-cal to the development of a successful safety andhealth management system:• Management leadership and worker involvement,• Worksite analysis,• Hazard prevention and control, and• Safety and health training.

The guidelines recommend specific actions, undereach of these general elements, to achieve an effectivesafety and health management system. The FederalRegister notice is available online at www.osha.gov.

State ProgramsThe Occupational Safety and Health Act of 1970 (OSHAct) encourages states to develop and operate theirown job safety and health plans. OSHA approves andmonitors these plans. Twenty-five states, Puerto Ricoand the Virgin Islands currently operate approved stateplans: 22 cover both private and public (state and localgovernment) employment; Connecticut, Illinois, NewJersey, New York and the Virgin Islands cover the pub-lic sector only. States and territories with their ownOSHA-approved occupational safety and health plansmust adopt standards identical to, or at least as effec-tive as, the Federal OSHA standards.

Consultation ServicesConsultation assistance is available on request to em-ployers who want help in establishing and maintaininga safe and healthful workplace. Largely funded by

OSHA, the service is provided at no cost to the em-ployer. Primarily developed for smaller employers withmore hazardous operations, the consultation service isdelivered by state governments employing profes-sional safety and health consultants. Comprehensive as-sistance includes an appraisal of all mechanicalsystems, work practices, and occupational safety andhealth hazards of the workplace and all aspects of theemployer’s present job safety and health program. Inaddition, the service offers assistance to employers indeveloping and implementing an effective safety andhealth program. No penalties are proposed or citationsissued for hazards identified by the consultant. OSHAprovides consultation assistance to the employer withthe assurance that his or her name and firm and anyinformation about the workplace will not be routinelyreported to OSHA enforcement staff. For more infor-mation concerning consultation assistance, see OSHA’swebsite at www.osha.gov.

Strategic Partnership ProgramOSHA’s Strategic Partnership Program helps encour-age, assist and recognize the efforts of partners toeliminate serious workplace hazards and achieve ahigh level of worker safety and health. Most strategicpartnerships seek to have a broad impact by buildingcooperative relationships with groups of employersand workers. These partnerships are voluntary rela-tionships between OSHA, employers, worker represen-tatives, and others (e.g., trade unions, trade andprofessional associations, universities, and other gov-ernment agencies).

For more information on this and other agency pro-grams, contact your nearest OSHA office, or visitOSHA’s website at www.osha.gov.

OSHATraining and EducationOSHA area offices offer a variety of information serv-ices, such as technical advice, publications, audiovisualaids and speakers for special engagements. OSHA’sTraining Institute in Arlington Heights, IL, providesbasic and advanced courses in safety and health forFederal and state compliance officers, state consult-ants, Federal agency personnel, and private sector em-ployers, workers and their representatives.

The OSHA Training Institute also has establishedOSHA Training Institute Education Centers to addressthe increased demand for its courses from the privatesector and from other federal agencies. These centersare colleges, universities, and nonprofit organizationsthat have been selected after a competition for partici-pation in the program.

OSHA also provides funds to nonprofit organiza-tions, through grants, to conduct workplace trainingand education in subjects where OSHA believes there


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is a lack of workplace training. Grants are awardedannually.

For more information on grants, training and edu-cation, contact the OSHA Training Institute, Directorateof Training and Education, 2020 South ArlingtonHeights Road, Arlington Heights, IL 60005, (847) 297-4810, or see Training on OSHA’s website atwww.osha.gov. For further information on any OSHAprogram, contact your nearest OSHA regional officelisted at the end of this publication.

InformationAvailable ElectronicallyOSHA has a variety of materials and tools available onits website at www.osha.gov. These include electronictools, such as Safety and HealthTopics, eTools, ExpertAdvisors; regulations, directives and publications;videos and other information for employers and work-ers. OSHA’s software programs and eTools walk youthrough challenging safety and health issues and com-mon problems to find the best solutions for your work-place.

OSHA PublicationsOSHA has an extensive publications program.For a listing of free items, visit OSHA’s website atwww.osha.gov or contact the OSHA Publications Of-fice, U.S. Department of Labor, 200 Constitution Ave-nue, NW, N-3101, Washington, DC 20210; telephone(202) 693-1888 or fax to (202) 693-2498.

Contacting OSHATo report an emergency, file a complaint, or seek OSHAadvice, assistance, or products, call (800) 321-OSHA orcontact your nearest OSHA Regional or Area officelisted at the end of this publication. The teletypewriter(TTY) number is (877) 889-5627.

Written correspondence can be mailed to the nearestOSHA Regional or Area Office listed at the end of thispublication or to OSHA’s national office at: U.S. Depart-ment of Labor, Occupational Safety and Health Admin-istration, 200 Constitution Avenue, N.W., Washington,DC 20210.

By visiting OSHA’s website at www.osha.gov, youcan also:• File a complaint online,• Submit general inquiries about workplace safety and

health electronically, and• Find more information about OSHA and occupa-

tional safety and health.

OSHA Regional Offices

Region I(CT*, ME, MA, NH, RI, VT*)JFK Federal Building, Room E340Boston, MA 02203(617) 565-9860

Region II(NJ*, NY*, PR*, VI*)201 Varick Street, Room 670New York, NY 10014(212) 337-2378

Region III(DE, DC, MD*, PA, VA*, WV)The Curtis Center170 S. Independence Mall WestSuite 740 WestPhiladelphia, PA 19106-3309(215) 861-4900

Region IV(AL, FL, GA, KY*, MS, NC*, SC*, TN*)61 Forsyth Street, SW, Room 6T50Atlanta, GA 30303(404) 562-2300

RegionV(IL*, IN*, MI*, MN*, OH, WI)230 South Dearborn StreetRoom 3244Chicago, IL 60604(312) 353-2220

RegionVI(AR, LA, NM*, OK, TX)525 Griffin Street, Room 602Dallas, TX 75202(972) 850-4145

RegionVII(IA*, KS, MO, NE)Two Pershing Square2300 Main Street, Suite 1010Kansas City, MO 64108-2416(816) 283-8745

RegionVIII(CO, MT, ND, SD, UT*, WY*)1999 Broadway, Suite 1690PO Box 46550Denver, 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 18-100San Francisco, CA 94103(415) 625-2547

Region X(AK*, ID, OR*, WA*)1111 Third Avenue, Suite 715Seattle, WA 98101-3212(206) 553-5930

*These states and territories operate their ownOSHA-approved job safety and health programs andcover state and local government employees aswell as private sector employees. The Connecticut,Illinois, New Jersey, New York and Virgin Islandsplans cover public employees only. States with ap-proved programs must have standards that areidentical to, or at least as effective as, the FederalOSHA standards.

Note: To get contact information for OSHA AreaOffices, OSHA-approved State Plans and OSHAConsultation Projects, please visit us online atwww.osha.gov or call us at 1-800-321-OSHA.

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