national fire protection association · reorganizing nfpa 306 will allow all users of the standard...

National Fire Protection Association 1 Batterymarch Park, Quincy, MA 02169-7471 Phone: 617-770-3000 • Fax: 617-770-0700 • www.nfpa.org

M E M O R A N D U M

TO: NFPA Technical Committee on Gas Hazards FROM: Lawrence Russell, Staff Liaison

DATE: February 22, 2012 SUBJECT: NFPA 306 ROP TC Letter Ballot (A2013)

______________________________________________________________________ The ROP letter ballot for NFPA 306 is attached. The ballot is for formally voting on whether or not you concur with the committee’s actions on the proposals. Reasons must accompany all negative and abstention ballots. Please do not vote negatively because of editorial errors. However, please bring such errors to my attention for action. Please complete and return your ballot as soon as possible but no later than Friday, March 16, 2012. As noted on the ballot form, please return the ballot to Diane Matthews either via e-mail to [email protected] or via fax to 617-984-7110. You may also mail your ballot to the attention of Diane Matthews at NFPA, 1 Batterymarch Park, Quincy, MA 02169. The return of ballots is required by the Regulations Governing Committee Projects. Attachments: Proposals

Report on Proposals – June 2013 NFPA 306_______________________________________________________________________________________________306-1 Log #CP1

_______________________________________________________________________________________________Technical Committee on Gas Hazards,

Review entire document to: 1) Update any extracted material by preparing separate proposals todo so, and 2) review and update references to other organizations documents, by preparing proposal(s) as required.

To conform to the NFPA Regulations Governing Committee Projects.

1Printed on 2/21/2012



Reorganize NFPA 306-2009 as described below. Renumbering of sections within chapters shall bein accordance with NFPA Manual of Style.Chapter 1 - No reorganizationChapter 2 - No reorganizationChapter 3 - No reorganizationCurrent Chapter 6 is moved and re-numbered as Chapter 4 and add new Section 4.6:Chapter 6 4, Vessels Required to Have Marine Chemist's Certificate4.6 Obtaining the Marine Chemist’s Certificate. It is the responsibility of the Certificate requester to retain the services ofthe Marine Chemist, to secure copies of the Marine Chemist’s Certificate in accordance with the provisions of Section8.3.Chapter 5 - No reorganization, except add the following new section, 5.2.4, and renumber all sections in Chapter 5thereafter:5.2.4 Care shall be exercised in the selection of methods and materials used for cleaning or inerting to avoidnoncompatibility with previous cargoes.Create a new Chapter 6, Procedures for the Marine Chemist Prior to Issuance of a CertificateCurrent edition 4.2 becomes 6.1Current edition 4.2.1 and 4.2.1.1 are combined and become 6.1.1Current edition 4.2.1.2 becomes 6.1.2Current edition 4.1 becomes 6.2 with subsections are re-numberedCurrent edition 4.2.2 becomes 6.3Delete Current Chapter 7, Additional Requirements for Bulk Chemical Cargo Tanks and all sections therein; and createa new Chapter 7, Standard Safety Designations and Conditions Required with the following reorganization/renumberingof these sections:Current edition 4.3 becomes 7.1Current edition 4.3.1 Atmosphere Safe For Workers and subsections become 7.1.1 Atmosphere Safe For Workers withsubsections numbered thereafterCurrent edition 4.3.2 Not Safe For Workers becomes 7.1.2 Not Safe For WorkersCurrent edition 4.3.3 Enter With Restrictions and subsections become 7.1.3 Enter With Restrictions with subsectionsnumbered thereafterCurrent edition 4.3.4 Safe For Hot Work and subsections become 7.1.4 Safe For Hot Work with subsections numberedthereafterCurrent edition 4.3.5 Not Safe For Hot Work becomes 7.1.5 Not Safe For Hot WorkCurrent edition 4.3.6 Safe For Limited Hot Work and subsections become 7.1.6 Safe For Limited Hot Work withsubsections numbered thereafterCurrent edition 4.3.7 Safe For Shipbreaking and subsections become 7.1.7 Safe For Shipbreaking with subsectionsnumbered thereafterCurrent edition 4.3.8 Inerted and subsections become 7.1.8 Inerted with subsections numbered thereafterCurrent edition 4.3.9 Safe For Flammable Compressed Gas becomes 7.1.9 Safe For Flammable Compressed GasCurrent edition 4.3.10 Safe for Lay-up and subsections become 7.1.10 Safe For Lay-up with subsections numberedthereafterCreate a new Chapter 8, The Marine Chemist’s Certificate, with the following reorganization/renumbering of thesesections:Current edition 4.4 becomes 8.1 with subsections renumberedCurrent edition 4.4.1 becomes 8.1.2 with subsections renumberedCurrent edition 4.4.2 becomes 8.1.3 with subsections renumberedCurrent edition 4.4.3 becomes 8.1.4 with subsections renumberedCurrent edition 4.5 becomes 8.2 with subsections renumberedCurrent edition 4.6 becomes 8.3 Responsibility for Obtaining the Certificate and Maintaining ConditionsCurrent edition 4.6.1 becomes 8.3.1Current edition 4.6.2 becomes 8.4 Responsibility for Obtaining the Certificate and Maintaining ConditionsRenumber current Chapter 8 as Chapter 9, Additional Requirements for Flammable Cryogenic Liquid Carriers, with


Report on Proposals – June 2013 NFPA 306sections & subsections renumberedAnnex A Explanatory Material No reorganization except, renumbering of content as required by the above reorganization changes in other chapters.A.4.3.1 becomes A.7.1.1A.4.3.1(1) becomes A.7.1.1(1)A.4.3.1(2) becomes A.7.1.1(2)A.4.3.1(3) becomes A.7.1.1(3)A.4.3.1(4) becomes A.7.1.1(4)A.4.3.4(1) becomes A.7.1.4(1)A.4.3.4(2) becomes A.7.1.4(2)A.4.3.4(3) becomes A.7.1.4(3)A.4.3.4(4) becomes A.7.1.4(4)A.4.3.8(1) becomes A.7.1.8(1)A.4.4.1.1 becomes A.8.1.2.1A.4.4.3 becomes A.8.1.4A.4.6.2(3) becomes A.8.4(3)A.5.1.3(B) becomes A.5.1.3.5.2Annex B - No reorganizationAnnex C - No reorganizationAnnex D - No reorganizationAnnex F - No reorganization

The Committee believes that the current sequence of the Standard, NFPA 306, does not accuratelyreflect the actual work flow process and is confusing to users other than Marine Chemists. The Committee believesreorganizing NFPA 306 will allow all users of the standard to better understand the process of when a Marine Chemist isrequired, who is responsible for getting the Marine Chemist, how to clean the vessel in preparation for a MarineChemist's inspection and survey, what the Marine Chemist will ask for prior to his /her inspection and what will beexamined during the inspection, and finally, how to prepare, issue and maintain the Marine Chemist's Certificate. Thereorganization will reflect the actual work process as applicable during vessel construction, conversion, repair and othersimilar shipyard employment.


Report on Proposals – June 2013 NFPA 306_______________________________________________________________________________________________306-3 Log #69

_______________________________________________________________________________________________Tom D. Littlepage, Gulf Marine Chemists, Inc.

Revise text to read as follows:1.1.5 This standard applies specifically to those spaces on vessels that are subject to concentrations of combustible

gas, flammable and toxic liquids, vapors, gases, and chemicals as here-inafter described. This standard is alsoapplicable in those spaces on vessels that might not contain sufficient oxygen to permit safe entry. This standard mayalso be optionally applied to other spaces aboard vessels to ensure, and promote safe working conditions.

Broadening the scope of 306 to be optionally applicable to "other spaces" for enhanced safety isstandard procedure which we have always done. Impediments to this were resolved by 4.3.4(5)

Problem resolved.

The Committee separated the two pieces of the submitters proposal and removed unenforcable language as follows:1.1.5 This standard applies specifically to those spaces on vessels that are subject to concentrations of combustiblegas, flammable and toxic liquids, vapors, gases, and chemicals as here-inafter described. This standard is alsoapplicable in those spaces on vessels that might not contain sufficient oxygen to permit safe entry. This standard shallalso apply may also be applied other spaces aboard vessels to ensure, and promote safe working conditions.1.1.5.1 When requested the Marine Chemist shall apply this standard to other spaces to ensure and promote safeworking conditions.

As written the scope of the standard only applies to spaces that are subject to concentrations ofcombustible gas, flammable and toxic liquids, vapors, gases, and chemicals or are oxygen deficient environments.Marine Chemists are often requested to apply the standard to other types of spaces (such as spaces within theaccommodation block of a vessel) that may not be subject to concentrations of combustible gas, flammable and toxicliquids, vapors, gases, and chemicals or are oxygen deficient environments. The change made by the Committeereflects this reality.

_______________________________________________________________________________________________306-4 Log #104

_______________________________________________________________________________________________Phillip Dovinh, Sound Testing Inc.

Pleaser revise text to read as follows:This standard applies to land-side confined spaces, whether stationary or mobile, underground and aboveground

storage tanks, or other dangerous atmospheres located within the boundaries of a shipyard or ship repair facility.The existing language doen’t make any references to underground or aboveground storage tanks

located within the boundaries of a shipyard or ship repair facility. “Land-side confined spaces” are not necessarilyunderstood as underground or aboveground storage tanks. In fact, often times, they are associated with sumps, vaults,cisterns, reservoirs, receptacles, crawlspaces, tunnels, silos, storage bins, pressure vessels, etc…The proposed text willmake it unequivocally clear for the users and enhances safety.

The Committee made the following change to this proposal:This standard applies to land-side confined spaces, whether stationary or mobile, underground and abovegroundstorage tanks, or other hollow structures throughout a shipyard such as tank trucks, railroad tank cars, powerplant fueltanks, storage tanks, dip and laundry tanks, vaults, tunnels or other spaces that may contain dangerous atmosphereslocated within the boundaries of a shipyard or ship repair facility.

The Committee combined text from public proposals 306-4 (Log #104),306-19 (Log 96) and306-105 (Log #99) to provide clear examples of the various landside spaces that may be encountered within theshipyard.



_______________________________________________________________________________________________Donald Raffo, Marine Chemist Association 306 Committee

Revise text to read as follows:1.4* Governmental Regulations. Nothing in this standard shall be construed as superseding existing requirements of

any governmental or local authority. The intent of this standard is to assist those using it to meet minimum governmentalsafety objectives. Attention of owners, repairers, and Marine Chemists is directed to the rules and regulations for tankvessels in 46 CFR 35, "Operations," and other rules and regulations for vessel inspection of the United States CoastGuard and the Occupational Safety and Health Administration Standards (OSHA) of the United States Department ofLabor, which prescribe an inspection prior to making repairs involving hot work and prior to entering spaces whereoxygen deficiency can exist. Those standards provide, under the conditions stated therein, for inspection by a MarineChemist certificated by the National Fire Protection Association or, alternatively, for inspection by certain other persons.

A.1.4 All applicable regulations, requirements, and standards should be consulted. Some requirements in this standardmay differ from governmental requirements to better protect personnel and property.

The word supersede can be construed as misleading, causing confusion on the application of thestandard. The standard may in some cases supersede an existing regulation or governmental safety objective but willnot result with non compliance with any law or governmental authority.

Revise text to read as follows:1.4* Governmental Regulations. Nothing in this standard shall be construed as superseding existing requirements of anygovernmental or local authority. The intent of this standard is to assist those using it to meet minimum governmentalsafety objectives. Attention of owners, repairers, and Marine Chemists is directed to the rules and regulations for tankvessels in 46 CFR 35, "Operations," and other rules and regulations for vessel inspection of the United States CoastGuard and the Occupational Safety and Health Administration Standards (OSHA) of the United States Department ofLabor, in 29 CFR 1915, which prescribe an inspection prior to making repairs involving hot work and prior to enteringspaces where oxygen deficiency can exist. Those standards provide, under the conditions stated therein, for inspectionby a Marine Chemist certificated by the National Fire Protection Association or, alternatively, for inspection by certainother persons.A.1.4 All applicable regulations, requirements, and standards should be consulted. Some of the requirements in thisstandard might exceed differ from minimum governmental regulations to better protect personnel and property.

The Committee deleted the second sentence in 1.4 of the proposed text because it did not addanything to the intent of the proposed change. The addition of the changed text in the Annex in A.1.4 identifies thatsome requirements and recommended practices in the standard might exceed the requirements set forth ingovernmental regulations.




Revise text to read as follows:The documents or portions thereof listed in this chapter are referenced within this code and shall be

considered part of the requirements of this document.National Fire Protection Association, 1 Batterymarch Park, Quincy, MA 02169-7471.

NFPA 312, 2006 2011 Edition“Rules for the Certification and Recertification of Marine Chemists,” current edition.

U.S. Government Printing Office, Washington, DC 20402.Title 29, Code of Federal Regulations, Part 1915.7.Title 29, Code of Federal Regulations, Part 1915.11Title 29, Code of Federal Regulations, Part 1915.15Title 46, Code of Federal Regulations, Chapter I, Part 35, “Operations,” Subpart 35.01

11th edition, Springfield, MA, 2003 2009.NFPA 55,

2005 2010edition.

To conform to the NFPA Regulations Governing Committee Projects the Committee updated extractedmaterial references to other organizations documents.

_______________________________________________________________________________________________306-7 Log #105


Please delete the current and replace it with:…NFPA 312, Standard for Five Protection of Vessels During Construction, Conversion, Repair, and Lay-Up, 2006

2011 Edition.2011 is the current edition of NFPA-312.

The changes recommended in this proposal have been incorporated in the Committee's Proposal 306-6 (Log #CP2).See 306-6 (Log #CP2) for the Committee's action regarding update of edition dates of

referenced publications in Chapter 2.



_______________________________________________________________________________________________John Doran, OSG Ship Management,Inc.

Revise text to read as follows:It is proposed that the references noted throughout the NFPA 306 Standard be updated to reflect most recent Edition

as follows:Chapter 2.2 - NFPA 312 should be revised to 2011 EditionChapter 2.4 - NFPA 55 should be revised to 2010 EditionAnnex E Tables E.1 (a) (b) and (c) Notes:NFPA 69 should be revised to 2008 Edition

Annex F.1.1 NFPA Publications:NFPA 30 should be revised to 2012 Edition.NFPA 69 should be revised to 2008 Edition.NFPA 312 should be revised to 2011 EditionFire Protection Guide to Hazardous Materials, 1997 Edition should be revised to 2010 Edition

Self explanatory

The changes recommended in this proposal have been incorporated in the Committee's Proposals 306-6 (Log #CP2)and 306-119 (Log # CP3).

See 306-6 (Log #CP2) for the Committee's action regarding update of edition dates ofreferenced publications in Chapter 2.See 306-119 (Log #CP3) for the Committee's action regarding update of edition dates of referenced publications inAnnex F.




Revise text to read as follows:3.3.1 Adjacent Spaces - Consideration should be given to include "piping systems" within the scope of this definition as

follows: .... .including all points of contact, piping systems. corners, .....3.3.19 Toxic - Consideration should be given to adding the words "health hazard" to the definition as follows: .... that

has the capacity to create a health hazard or to produce an injury to workers .....3.3.20.1 Ship - Consideration should be given to simply state that a ship is "Any vessel that is self-propelled."3.3.20.3 Coiled Vessel - Question - should this definition be expanded to also include the use of steam as a heating

medium?3.3.20.4 Tank Vessel- Typo the word "especially" should simply state "specially".3.4.2 Hot Work - Consider adding the following language to the last sentence to ensure consistency with 4.3.4, 4.3.8

and 5.2.5 or providing a separate definition for Grinding, etc: .... of a flammable or combustible substance or theatmosphere in adjacent spaces has been inerted as per 4.3.4, 4.3.8 and 5.2.5.

It is also recommended that definitions to the following terms / acronyms be added to the list of definitions:1) Permissible Exposure Levels (PEL) - The concentration of an airborne substance to which an average person can

be repeatedly exposed without adverse effects. as defined by OSHA.2) Threshold Limit Value (TLV) - The concentration of an airborne substance to which an average person can be

repeatedly exposed without adverse effects. These values are considered recommendations by ACGIH. are based onaccumulated data on the health effects of the various substances and are an expression of scientific opinion. Althoughcompliance to ACGIH Threshold Limit Values (TLV) recommendations is not mandatory, a Marine Chemist has theauthority to recommend a TLV if such a value offers a higher degree of protection. TLVs may be expressed in threeways:

a. TLV-TWA--Time weighted average, based on an allowable exposure averaged over a normal 8-hour workday or40- hour work week:

b. TLV-STEL--Short-term exposure limit or maximum concentration for a brief specified period of time, depending ona specific chemical (TWA must still be met); and

c. TL V-C--Ceiling Exposure Limit or maximum exposure concentration not to be exceeded under any circumstances.(TWA must still be met.)

3) Short Term Exposure Limit (STEL) - STEL is a TWA defined over a short time period of 15 minutes. According toACGIH, it should not be exceeded during any part of a workday, even if the 8-Hour TWA is within its limit.

3.3.1 Adjacent Spaces - This proposal is intended to ensure piping systems connected to a particularenclosed space such as Inert Gas, Vapor or Cargo piping are not over looked when evaluating spaces safe for Workersor Safe for Hot Work. This also helps ensure the term "adjacent spaces" in 4.2.2 is correctly interpteted.

3.3.19 Toxic - This proposal is intended to clarify the fact that a toxic chemical also has the capacity to produce a shortor long term health hazard.

3.3.20.1 Ship - Self explanatory.3.3.20.3 Coiled Vessel - Intended to clarify that steam used as a heating medium are also considered coiled vessels.3.3.20.4 Tank Vessel- Self explanatory.3.4.2 Hot Work - There is some confusion with regard to spark producing operations such as grinding, chipping, grit

blasting, etc.on tank vessels as NFPA and ISGOTT are not totally consistent with regard to definitions andrecommended preparations for conducting this frequently performed task.New definitions are intended to clarify to third parties the difference between OSHA and ACGIH.

The Committee rejected this proposal.Submitter failed to present a proposal in format required by the Document Proposal Form.

Proposed changes should be limited to a single requirement or single subject. Some of the items listed within thesubmitter's proposal have been addressed by the Committee in other public proposals.




Please incorporate the term “Gas-Free” in 3.3 General Definition to read as follows:“Gas-Free” means the conditions of 4.3.1 “Atmosphere Safe For Workers” have been met or being maintained.

The terms “gas-free”, “gas-freed” and “gas-freeing” are not defined in NFPA 306 but they are beingused loosely in 1.3, 5.7.1, Annex A.8.1.1(1), Annex D.1 in reference to meeting some or all of the requirements of NFPA306 4.3.1 and 4.3.4.

Because these terms are not defined in NFPA 306, the users are often lost as to their exact meaning. MerriamWebster, 11th Edition does not definitions for these terms either.

Currently, the USCG defines “Gas Free” in 46 CFR 30.10-29 as “free from dangerous concentrations of flammable ortoxic gases.”

The Committee rejected the proposal.Gas-freeing is a process used to make a space safe for entry and/or work. The term is well

understood in the industry therefore a definition is not necessary in this standard.

_______________________________________________________________________________________________306-11 Log #31

_______________________________________________________________________________________________Robert H. Walker, III, Marine Chemist Service, Inc.

Revise text to read as follows:Those spaces in all directions from the subject space, including all points of contact, corners,

diagonals, decks, tank tops, and bulkheads, and including areas affected by hot work, where slag, products ofcombustion, and sparks would be expected to fall or accumulate, but not produce a temperature reaching or exceeding400°F (204°C) on the opposite side. If the opposite surface temperature reaches or exceeds 400°F (204°C), then thespace in question is no longer considered an Adjacent Space but, instead, is now an additional space needinginspection for hot work just like the original, subject space in which the hot work operator is located.

1. The 400°F (204°C) portion of the new hot work definition (2009 revision) most likely came from theUSN's TM that was published in 2006. In their regulation, the numerical temperature requirement is explained in thecontext of the "opposite surface temperature." The current text in Section 3.3.1 is lacking this explanation, andconfusing: is it referring to the surface temperature where hot work is being administered/applied, or to the temperatureon the opposite side? Note 1: In any event, the USN's guidance in their TM should be followed regarding how thetemperature determination is assessed: through "documented processes," "objective evidence (e.g. mockup testing bythe welding engineer, etc.)," or other definitive means to exclude guessing. Note 2: Though this intended correctioncould be made in the actual definition of Hot Work, the revised wording here in Section 3.3.1 has the added benefit ofNo. 2 Substantiation.

2. For many years there has been a general misconception by a few in industry that an Adjacent Space is always thenext space over, under, or above a subject (e.g. hot work) space. Though this is often true, there are occasions whenthe next space over, under, or above exceeds the intended meaning of Adjacent Space; such as, for example, when it isbeing welded on from the opposite side. The added wording will help draw attention to the necessity of having twospaces certified for hot work, not just one (i.e. where the welder is standing) when bulkheads, decks, and overheads arebeing welded.

The Committee rejected the proposal.It is the intent of the Committee that the standard will not define an adjacent space solely by the

temperature that the space may reach. Using 204o C (400o F) does not address the following issues:a) metal inconsistencies that would affect heat transfer, andb) auto-ignition temperatures of substances that are less than 204o C (400o F).




Revise text to read as follows:3.3.1 Adjacent Spaces. Those spaces in all directions from subject space, including all points of contact, corners,

diagonals, decks, tank tops, and bulkheads. and including This also includes areas affected by hot work, where slag,products of combustion, where sources of ignition from hot work, such as sparks and/or slag would be expected to fallor accumulate. Pipelines are not adjacent spaces and are considered as Not Safe for Hot Work unless noted on themarine chemist certificate.

The words products of combustion have been changed to sources or ignition to exclude the chemistfrom considering a space as adjacent if it is affected by smoke from combustion. The current language also does notspecifically define that a pipeline is not an adjacent space. The addition clarifies that pipelines should be considered asNot Safe for Hot Work unless it is specifically addressed on the certificate. It also mirrors the language on the existingcertificate.

Revise text to read as follows:3.3.1* Adjacent Spaces. Those spaces in all directions from subject space, including all points of contact, corners,diagonals, decks, tank tops, and bulkheads includingThis also includes areas affected by hot work where slag, heat conduction, heat radiation and/or sparks from hot workcould fall and/or accumulate and act as a source of ignition.A.3.3.1 Pipelines are not adjacent spaces and are considered as to be "Not Safe for Hot Work" unless noted on theMarine Chemist's Certificate.

The Committee changed the definition for adjacent space to include areas affected by ignitionsources and clarified that a pipeline is considered to be not safe for hot work unless the pipeline has been tested,inspected and noted safe for hot work by the Marine Chemist on the Certificate. The NFPA Manual of Style requiresdefinitions to be in single sentences and not to contain requirements. The sentence concerning pipelines is informationthat should be placed in Annex A.



_______________________________________________________________________________________________Michael Arnold, Marine Chemist Qualification Board

Revise text to read as follows:3.3.1 Adjacent Spaces. Those spaces in all directions from subject space, including all points of contact, corners,

diagonals, decks, tank tops, and bulkheads, and including areas affected by hot work, where slag, products ofcombustion acting as sources of ignition, and sparks would be expected to fall or accumulate.

“Products of combustion” are substances and components being given off, generated or scattered inan area during hot work. The quantities and types are dependent on the magnitude and intensity of the hot workoperation as well as the kind of materials being burned, heated or decomposed.

NOT all products of combustion are capable of acting as sources of combustion (e.g. nitrogen (N2), water vapor (H2O),carbon dioxide (CO2), carbon monoxide (CO), hydrocarbons (HCs), nitrogen oxides (NOx), sulfur oxides (SOx), metaloxides, Ozone (O3), particulate matter (soot), welding fumes, smoke, and free radicals.)

During hot work, many of these components may rise, fall, scatter or accumulate throughout the vessel makingadditional spaces unnecessarily considered or classified as “Adjacent Spaces” according to the existing definition.

The proposed change brings attention only to products of combustion that are capable of acting as sources of ignition(e.g. embers, sparks, slag, molten materials, arcs, heat, etc.). It makes sense that the accumulation, scattering orspreading of these products into any other spaces would make them “Adjacent Spaces”.

The action that the Committee took in 306-12 (Log #73) addresses the content of this proposal.The Committee agreed with the proposal in principle to address sources of ignition resulting

from hot work when considering adjacent spaces.

_______________________________________________________________________________________________306-14 Log #90

_______________________________________________________________________________________________Marcelo M. Hirschler, GBH International

Revise text to read as follows:Material made of or surfaced with wood, compressed paper, plant fibers, plastics,

liquids, or other material that will ignite and burn, whether flameproofed or not, or whether plastered or unplastered. Amaterial that, in the form in which it is used and under the conditions anticipated, will ignite and burn; a material thatdoes not meet the definition of noncombustible or limited-combustible [101].

The proposed definition comes from NFPA 101 and from NFPA 5000 and is the preferred NFPAdefinition for combustible (material). The use of the term flameproofed is deprecated.

The Committee rejected the proposal.The current definition in the standard is unique to conditions, materials and operations common

in shipyard employment.



_______________________________________________________________________________________________Marcelo M. Hirschler, GBH International

Revise text to read as follows:The holder of a valid Certificate issued by the National Fire Protection Association in

accordance with the “Rules for the Certification and Recertification of Marine Chemists,” establishing the person’squalifications to determine whether construction, alteration, repair, or ship-breaking of vessels can be undertaken withsafety. Activities of a Marine Chemist, as defined in this section, are limited to the inspection and certification proceduresdescribed in this standard and consulting services connected therewith.

Activities of a Marine Chemist, as defined in this standard, are limited to the inspection and certificationprocedures described in this standard and consulting services connected therewith.

The NFPA Manual of Style requires definitions to be in single sentences and not to containrequirements. The second sentence of this definition is information that should be placed in an annex or elsewhere inthe standard.

_______________________________________________________________________________________________306-16 Log #41


Revise text to read as follows:A written statement document issued by a Marine Chemist...

—OR—A written, statement legal document issued by a Marine Chemist...

Statements (standard safety designations, qualifications, etc.) are actually what are written on theMarine Chemist's Certificate. Further, Annex C contains a sample of a Marine Chemist's Certificate, a legal document,not a statement. Finally, the referenced (Chapter 2) defines "statement" as "theact of stating in speech, writing, etc." and "document" as "an official paper, a certificate."

The Committee made the following change to the proposed text:3.3.14 Marine Chemist's Certificate (Certificate). A written document statement issued by a Marine Chemist on a formauthorized by the National Fire Protection Association, stating the conditions that the Marine Chemist found at the timeof the inspection. (see annex C for an example).

Committee acted on the proposals in 306-16 (Log #41), 306-17 (Log #74) as a single proposalsince the subject matter was similar. See additional explanation in 306-17 (Log #74).




Revise text to read as follows:3.3.14 Marine Chemist's Certificate (Certificate). A written statement issued by a Marine Chemist on a form authorized

by the National Fire Protection Association, stating the conditions that the Marine Chemist found at the time ofinspection. (see annex C for an example).

The mandatory section of 306 does not specifically require that Marine Chemists use a form providedby NFPA. The new wording now requires all Marine Chemists to use a form approved by NFPA in their inspections. Thiscan be either a paper certificate or the new electronic certificate.

The Committee modified the proposed text as follows:3.3.14 Marine Chemist's Certificate (Certificate). A written document statement issued by a Marine Chemist on a formauthorized by the National Fire Protection Association, stating the conditions that the Marine Chemist found at the timeof the inspection. (see annex C for an example).

Committee acted on the proposals in 306-16 (Log #41), and 306-17 (Log #74) as a singleproposal since the subject matter was similar.The committee preferred the term "document" when referring to the Marine Chemist's Certificate. The requirementspecifies that the only acceptable Marine Chemist's Certificate form is a form authorized by the NFPA.

_______________________________________________________________________________________________306-18 Log #58


Add new text to read as follows:A space affected by work; whether cold work (including entry), hot work, or both.

The term "subject space" is found in both NFPA's 306 and OSHA's 1915 definitions of "adjacentspaces." However, neither has a definition for "subject space." Understanding of the term "subject space" is necessaryto determine whether or not a space is alternatively an "adjacent space." There are occasions when a space, in physicalcontact with another space, is not an "adjacent space" but, instead, is a space "subject" to the effects of hot work.Though any space can be either a "subject space" or an "adjacent space," it cannot be both at the same time.

Misunderstandings do not appear to be as great of a problem when, for example, fire and molten metal from cutting anaccess in one space penetrates into an adjoining space. Most everyone knows that two spaces are affected by hot workin this type of scenario. The same cannot be said for welding operations, for example, conducted against a bulkhead,overhead, or deck, and the adjoining space beside, above, or underneath is "subject" to the affects of heat transfercoming from the opposite side (i.e. the space in which the worker is physically located). One plausible reason is theeffects of hot work in this scenario (e.g. blistering paint, "cherry-red" metal) are sometimes not readily apparent. This isespecially true when the backside surface in the adjoining space is covered with insulation, cabinets, etc. Thus, thesecond scenario has a greater potential for an accident, and it appears at least one fire has been attributed to thismisunderstanding. Adding the definition will focus attention and promote better understanding of the inferred meaning ofthe word "subject" (As in, "subject" to what? The effects of nearby cold work or hot work).

The Committee rejected the proposal.The term subject space is any space that is not an adjacent space. The addition of a definition

of subject space doesn't add any additional clarification to the standard and may create more confusion.



_______________________________________________________________________________________________Edward J. Willwerth, Atlantic Environmental & Marine Services, Inc. / Rep. Marine Chemist Association 306

CommitteeAdd new text to read as follows:

Vessel. Every description of watercraft or other artificial contrivance used or capable of being used as a meansof transportation on water including special purpose floating structures not primarily designed for or used as a means oftransportation on water, or other hollow vessels throughout a shipyard.

Since 1994, the scope of 29CFR1915 has included such shipyard hollow vessels other than ships,barges, etc., including tank trucks, railroad tank cars, powerplant fuel tanks, storage tanks, dip and laundry tanks, vaults,tunnels etc. in its scope. The proposed change makes it clear to the reader that these spaces are also included as partof the definition of vessel in this standard.

The Committee rejected the proposal.The change made to the requirement in 1.1.6 of the standard (306-4 (Log #104)) addresses

hollow structures that are not part of marine vessels within the shipyard. The Committee chose to keep the term"vessel" reserved for marine vessels as defined in 3.3.20 rather than confuse it with the term hollow structures in 3.3.10of the standard. The submitter's intent was incorporated in the Committee's action in 306-4 (Log #104).

_______________________________________________________________________________________________306-20 Log #45

_______________________________________________________________________________________________David J. Capen, Sr., Upper Chesapeake Chemist Co., Inc.

Revise text to read as follows:Any vessel not equipped with a stern driven means of self-propulsion.

There's currently being used large barges >100,000 barrel capacity with 2-drive bow thrustersdesigned to move the barge forward or aft in the mooring to piers or in the event of tug failures.

The Committee rejected the proposal.Bow thruster units are controllable pitch or reversible impeller devices fitted in an athwartship

watertight tunnel. Bow thruster units are for lateral movement and positioning rather than forward/aft propulsion of avessel through the water. No change to the definition in the standard is necessary.



_______________________________________________________________________________________________Tom D. Littlepage, Gulf Marine Chemists, Inc.

Revise text to read as follows:3.4.2 Hot Work . . . .raises the temperature of the work piece to 204 C (400 F) 212 F (100C) . . .

400 F approximates the autoignition temperature of diesel (~410F) and exceeds the autoignitiontemperature of several industrial chemicals. A more modest safety factor seem to be in order.

3.4.2 Hot Work: My problem arises with NFPA 306 defining hot work as exceeding 400F degrees. 400F meets orapproaches the auto-ignition of some hydrocarbons, as documented by the attached tables. Coupled with the possibilityof inaccurate temperature measurements in an maritime industrial environment, it may be plausible to produce a fire orexplosion and still be apparently within the “safe for hot work” parameters described by NFPA-306.Though I wished that the Committee would select an appropriate lower temperature, I would like to suggest 212F

(100C), as a lower and more readily determined benchmark with a wider safety factor as a definition of hot work.Reference: http://www.engineeringtoolbox.com/fuels-ignition-temperatures-d_171.html.

Note: Supporting material is available for review at NFPA Headquarters.

The Committee rejected the proposal.The reference to temperature in the definition of hot work applies to the temperature of the

metal or work piece and not the flashpoint of combustible and flammable liquids.




CommitteeRevise text to read as follows:

Any activity involving riveting, welding, burning, the use of powder actuated tools or similar fireproducing operations as well as grinding, drilling, abrasive blasting, or similar operations not isolated physically from anyatmosphere containing more than 10 percent of the lower explosive limit of a flammable or combustible substance anyof the following:

(A) Riveting, welding, burning, the use of powder actuated tools or similar fire producing operations, or,(B) Any operation that raises the temperature of the work piece to 204°C (400°F), or,(C) The activation of non-explosion proof or non-intrinsically safe electrical equipment in the presence of flammable

gases or vapors of flammable liquids when in confined or enclosed spaces, or,(D) Grinding, drilling, abrasive blasting, or similar operations in the presence of accumulations of readily combustible

materials or flammable or combustible liquids or their vapors.The proposed language increases the scope of hot work for those responsible for seeking and those

responsible for issuing hot work permits to include consideration of flammable liquid hazards when used in confined andenclosed space vessel work, hopefully eliminating a repeat of a serious accident that occurred in the standard's lastcycle (Sept 2007)

The Committee revised the proposal as follows:Any activity involving riveting, welding, burning, the use of powder actuated tools or similar fire

producing operations as well as grinding, drilling, abrasive blasting, or similar operations not isolated physically from anyatmosphere containing more than 10 percent of the lower explosive limit of a flammable or combustible substance anyof the following:

(A) Riveting, welding, burning, the use of powder actuated tools or similar fire producing operations, or,(B) Any operation that raises the temperature of the work piece to 204°C (400°F), or higher,

(C) The activation of non-explosion proof or non-intrinsically safe electrical equipment in the presence of flammablegases or vapors of flammable liquids when in confined or enclosed spaces.(C) (D) Grinding, drilling, abrasive blasting, the activation of non-intrinsically or non-explosion-proof equipment or similaroperations in the presence of or against accumulations of readily combustible materials or flammable or combustibleliquids or their vapors when the atmosphere exceeds 10 percent of the LEL.

Part (C) of the submitter's proposal was deleted by the Committee. Addressing the activation ofnon-explosion proof or non-intrinsically safe electrical equipment as proposed was deemed impractical. A reference tothese devices was added to the Committee's revised Part (C). The Committee also added a reference to atmospheresexceeding 10% LEL in its revised Part (C) to clarify when such operations or use of certain equipment is to beconsidered hot work.





Any activity involving riveting, welding, burning, the use of powder actuated tools or similar fireproducing operations as well as grinding, drilling, abrasive blasting, or similar operations not isolated physically from anyatmosphere containing more than 10 percent of the lower explosive limit of a flammable or combtistible substance.

The current language allows considering grinding over rags or paper soaked in diesel fuel at roomtemperature in the same space, since, although they would take place in the same space, a test of the area might notgive a reading of more than 10 percent of the lower explosive limit of a flammable or combustible substance, i.e., thecurrent language is ambiguous regarding readily combustible materials near applied sources of ignition.

The Committee rejected the proposal.The Committee wanted to keep the reference to operations such as grinding, drilling, abrasive

blasting in the definition. The Committee's revision to the definition of hot work is addressed 306-22 (Log #102).

_______________________________________________________________________________________________306-24 Log #44

_______________________________________________________________________________________________John E. Ramos, Bayonne, NJ

Revise text to read as follows:4.1 Determination of Conditions: The Marine Chemist shall, whenever possible, physically enter each compartment or

space and conduct a visual inspection to the extent necessary to determine the atmosphere or fire hazards that exist.Problem: "To the extent necessary" is very subjective. A 22 year-old Marine Inspector has my bet 99

times out of 100 to be able to get further and into smaller spaces than a 40 year old Marine Chemist. By eliminating tothe extent necessary it requires a Marine Chemist to do visual inspections in each compartment and space. So if he/shecan't, another Marine Chemist who can must be brought in to do the job.

The Committee rejected the proposal.The Committee believes the existing language adequately addresses the requirement for the

Marine Chemist to visually inspect spaces.




Revise text to read as follows:4.2.1.1* The accuracy and sampling integrity of all instruments used by the Marine Chemist shall be verified before

each day's use. by using with a known concentration of test gases in a manner consistent with the manufacturer'srecommendations. Calibration of sensors shall be verified using a known concentration of test gas. in a mannerconsistent with the manufacturer's recommendations.

A.4.2.1.1 It is recognized that in limited circumstances the marine chemist may not be able to transport compressedcalibration gas. In these limited cases the chemist shall make every attempt to verify the accuracy of their instrumentsprior to use.

Current wording requires a Marine Chemist to use a specific calibration gas even though a differentgas may provide a more accurate result when testing for a specific gas. The new wording will permit the Marine Chemistto verify the accuracy of their instruments using a test gas which most closely represents the gasses they will be testingfor. The addition of the annex statement allows the chemist to verify their instruments when specific calibration gas isnot available.

Revise text to read as follows:4.2.1.1* The accuracy and sampling integrity of all instruments used by the Marine Chemist shall be verified before eachday's use. by using with a known concentration of test gases in a manner consistent with the manufacturer'srecommendations.4.2.1.2 Calibration of sensors shall be verified using a known concentration of test gas. in a manner consistent with themanufacturer's recommendations.4.2.1.2 3 This record of calibration shall be maintained for at least 3 months.A.4.2.1.1 It is recognized that in limited circumstances the marine chemist may not be able to transport compressedcalibration gas by air. In these limited cases the chemist shall should make every attempt to verify the accuracy of theirinstruments prior to use.

The Committee amended the requirement as follows:Renumbered to comply with NFPA Manual of StyleIn the Annex note the Committee inserted "by air" to specify that air transportation requirements may prohibit thecarriage of calibration test gas by the Marine Chemist to job locations and also removed the word, "shall", sincemandatory language can not be used in the Annex.

_______________________________________________________________________________________________306-26 Log #76


Revise text to read as follows:4.2.1.2 A record of the This record of calibration verification of accuracy or calibration shall be maintained for at least

3 months.This will make this section consistent with the new proposal for section 4.2.1.1 and A.4.2.1.1.



_______________________________________________________________________________________________Don Sly, Sound Testing Inc

Revise text to read as follows:The Marine Chemist's determinations shall include a visual an inspection and tests of the spaces to be certified.

and f For repair or alterations involving hot work, all spaces adjacent to hot work cargo tanks, spaces adjacent to cargotanks, and other adjacent spaces containing or having contained flammable or combustible cargo, fuels, or oils shall betreated in accordance with 4.3.4(4) or 4.3.4(5) as applicable. the Determinations also shall include...

1. "Visual" is one of OSHA's least-defined terms. For instance, OSHA (subpart B, "Precautions beforeentry") has the competent person detecting "toxic" contaminants using a visual test. I don't think it adds anything toNFPA 306. Also, please note that 4.1 already tells the chemist to enter spaces when possible.

2. The deleted sections are redundant, in that the same material is in 4.3.4.

The Committee combined and acted upon proposals: 306-27 (Log #54), 306-28 (Log #55), 30629- (Log #77), 306-30(Log #95),306-31 (Log #35), 306-32 (Log #38), 306-33 (Log #1), 306-34 (Log #47) and 306-35 (Log #94) since theseproposals address the same section within the Standard. See 306- 29(Log #77) for the Committee's action on thissection, 4.2.2.

The Committee did not accept the deletion of "a visual". Visual inspection is defined in 3.3.21of the standard. Otherwise the intent of this proposal is addressed in the Committee's Action in 306-29 (Log #77). Therevised text is shown in the Committee's Action in 306-29 (Log #77).

_______________________________________________________________________________________________306-28 Log #55


Revise text to read as follows:The Marine Chemist's determinations shall include a visual inspection and tests of the spaces to be certified.,

and fFor repair or alterations involving hot work, all adjacent spaces cargo tanks, spaces adjacent to cargo tanks, andother adjacent spaces containing of having contained flammable or combustible cargo, fuels, or oils shall be treated inaccordance with 4.3.4(4) or (5), as applicable.

Note: highlights added for clarification of Statement of Problem and Substantiation (below).The first clause containing "spaces to be certified" implies all spaces, whether for entry (SFW) and/or

hot work. The second clause (after the semi-colon, containing three subsections, separated by commas; and furtherhighlighted) is specific for only spaces requiring hot work. "Adjacent spaces" or "spaces adjacent" is mentioned in eachsubsection. The current wording of the second clause is confusing: A) ["spaces adjacent to cargo tanks" in which cargotanks could themselves be adjacent spaces to "spaces to be certified;" as well as the redundancy of "all adjacent cargotanks" and "other adjacent spaces containing ... cargo"]. B) The second clause might even be inaccurate [other adjacentspaces" should refer to 4.3.4(5) "All other spaces adjacent ...", not 4.3.4(4)]. C) Since the second clause, thirdsubsection, already refers to 4.3.4(4), that is, is a precedent which is also written better, truncating the entire clause andreferencing 4.3.4(5) make everything more clear.

The Committee combined and acted upon proposals: 306-27 (Log #54) ,306-28 (Log #55), 306-29 (Log #77), 306-30(Log #95), 306-31 (Log #35), 306-32 (Log #38), 306-33 (Log #1) , 306-34 (Log #47) and 306-35 (Log #94) since theseproposals address the same section within the Standard. See 306-29 (Log #77) for the Committee's action on thissection, 4.2.2.

The intent of this proposal is addressed in the Committee's Action in 306-29 (Log #77). Therevised text is shown in the Committee's Action in 306-29 (Log #77).




Revise text to read as follows:4.2.2 The Marine Chemist's determinations shall include a visual inspection and tests of the spaces to be certified; and

for repair or alterations involving hot work, all adjacent cargo tanks, spaces adjacent to cargo tanks, and other adjacentspaces containing or having contained flammable or combustible cargo, fuels, or oils spaces are treated in accordancewith 4.3.4(4) and 4.3.4(5). The determinations also shall include the following:

(1) The three previous cargo loadings(2) Nature and extent of the work(3) Starting time and duration of the work(4) Tests of cargo and vent lines at manifolds and accessible openings associated with the scope of work on or in the

compartments concerned(5) Verification that pipelines that could release hazardous materials into spaces that will be certified ATMOSPHERE

SAFE FOR WORKERS or SAFE FOR HOT WORK are either disconnected, blanked off, or otherwise blocked by apositive method, or the valves are positioned and tagged in such a manner to prevent, or by written notice restrict,operation

(6) Tests of cargo heating coilsThese changes modify two sets of directions. Wording in the initial paragraph clarifies the intent that all

adjacent spaces to hot work must be inspected to meet 4.3.4 (4) and (5). Secondly, only cargo and vent lines associatedwith the scope of work must be inspected, not all cargo and vent lines. This change is consistent with the new proposalto revise section 4.3.4.

The Committee combined and acted upon proposals: 306-27 (Log #54) ,306-28 (Log #55), 306-29 (Log #77), 306-30(Log #95), 306-31 (Log #35), 306-32 (Log #38), 306-33 (Log #1) , 306-34 (Log #47) and 306-35 (Log #94) since theseproposals address the same section within the Standard. See 30629- (Log #77) (below) for the Committee's action onthis section, 4.2.2.4.2.2 The Marine Chemist's determinations shall include a visual inspection and tests of the spaces to be certified; andfor repair or alterations involving hot work, all adjacent cargo tanks, spaces adjacent to cargo tanks, and other adjacentspaces containing or having contained flammable or combustible cargo, fuels, or oils spaces are treated in accordancewith 4.3.4(4) and 4.3.4(5). The determinations also shall include the following:

(1) The three previous cargo loadings(2) Nature and extent of the work(3) Starting time and duration of the work(4) Tests of cargo and vent lines at manifolds and accessible openings associated with the scope of work on or in the

compartments concerned(5) Verification that pipelines that could release hazardous materials into spaces that will be certified ATMOSPHERE

SAFE FOR WORKERS or SAFE FOR HOT WORK are either disconnected, blanked off, or otherwise blocked by apositive method, or the valves are positioned and tagged in such a manner to prevent, or by written notice restrict,operation

(6) Tests of cargo heating coils(7) In spaces which are not cargo tanks or are not adjacent to cargo tanks the Marine Chemist shall carry out tests to

determine the atmospheric or fire hazards that may exist within each affected compartment or space, and any adjacentspaces which may be affected by hot work, ensuring compliance with the minimum applicable requirements prior toissuing a Certificate.

The Committee accepted the change to the main part of the requirement 4.2.2. and 4.2.2(4).The Committee deleted "cargo" from 4.2.2(1) since many spaces that are inspected by the Marine Chemist and coveredby the Standard are not cargo spaces. This action is consistent with its action on 306-32 (Log #38).The Committee deleted text in 4.2.2(5) consistent with action taken in 306- (Log #1).The Committee added a requirement for spaces that are not cargo tanks (4.2.2(7)).




Delete text as follows:The Marine Chemist's determinations shall include a visual inspection and tests of the spaces to be certified, and

for repair or alterations involving hot work, all adjacent cargo tanks spaces adjacent to cargo tanks, and other adjacentspaces containing or having contained flammable or combustible cargo, fuel, or oils in accordance with 4.3.4(4). Thedeterminations also shall include...

"...and other adjacent spaces" should be deleted because it makes this paragraph unworkable.Chemists commonly certify for hot work engine rooms, passageways, and other structures which have dozens of"adjacent spaces." So many adjacent spaces are, in fact, impossible to visually inspect or test.

"containing or having....fuel or oils..." should be deleted because adjacent cargo tanks, cofferdams and pumproomsshould be inspected regardless of what they last contained.

"in accordance with 4.3.4(4)" should be deleted because it weakens the whole paragraph, since 4.3.4(4) doesn'tmention spaces adjacent to cargo tanks.

The sentence should read simply, " The Marine Chemist's determinations shall include a visual inspection and tests ofthe spaces to be certified, and for repair or alterations involving hot work, all adjacent cargo tanks and spaces adjacentto cargo tanks,

The Committee combined and acted upon proposals:306-27 (Log #54) ,306-28 (Log #55), 306-29 (Log #77), 306-30(Log #95), 306-31 (Log #35), 306-32 (Log #38), 306-33 (Log #1) , 306-34 (Log #47) and 306-35 (Log #94) since theseproposals address the same section within the Standard. See 306-29 (Log #77) for the Committee's action on thissection, 4.2.2.


_______________________________________________________________________________________________306-31 Log #35

_______________________________________________________________________________________________Donald V. Raffo, Stonington, CT

Revise text to read as follows:The Marine Chemist's determinations shall include a visual inspection and tests of the spaces to be certified; and

for repair or alterations involving hot work, all adjacent cargo tanks, spaces adjacent to cargo tanks, and other adjacentspaces containing or having contained flammable or combustible cargo, fuels, or oils in accordance with 4.3A(4). Thedeterminations also shall include the following:

(1) The three previous cargo loadings or most recent product if the space inspected is not a cargo tank.Adding the suggested wording will require the chemist list the contents of a tank even if it is not a

cargo tank being inspected. With the current wording if a chemist is inspecting a fuel tank then the contents are notrequired to be listed. This will also help to ensure that the necessary tests are carried out during the course of theinspection and an audit.






Revise text to read as follows:(1) The three previous cargo loadings

The Marine Chemist Certificate has a blank area in the upper left corner in which a Marine Chemist isto fill in the "Last Three (3) Loadings." This proposed change will maintain consistency between NFPA 306 and theMarine Chemist Certificate, and maintain the previous intention behind deleting the word "cargo" from said Certificate.



_______________________________________________________________________________________________306-33 Log #1


Revise text to read as follows:Suggest deleting section 4.2.2(5) in its present location and including it in sections 4.3.1, 4.3.4 and 4.3.6. and modify

the wording as follows:(5) Verification that pipelines that could release hazardous materials into spaces that will be certified ATMOSPHERESAFE FOR WORKERS or SAFE FOR HOT WORK are either disconnected, blanked off, or otherwise blocked by apositive method, or the valves are positioned and tagged in such a manner to prevent, or by written notice restrict,operation.

This inspection is an important part of making a space Safe for Hot Work or Safe for Limited Hot Workor Atmosphere Safe for Workers. It should be included in these sections to make it clear what must be done to anypipelines that may be associated with the space being inspected.

The Committee combined and acted upon proposals 306-27 (Log #54) ,306-28 (Log #55), 306-29 (Log #77), 306-30(Log #95), 306-31 (Log #35), 306-32 (Log #38), 306-33 (Log #1) , 306-34 (Log #47) and 306-35 (Log #94) since theseproposals address the same section within the Standard. See 306-29 (Log #77) for the Committee's action on thissection, 4.2.2.

The Committee accepted this proposal. The change is shown in the Committee's action in306-29 (Log #77). The revised text is shown in the Committee's action in 306-29 (Log #77).




Delete text to read as follows:(6) Tests of Cargo Heating Coils

Sub-paragraph (6) is just repeating what is stated in sub-paragraph (5) for verification that pipelinesthat could release hazardous materials. There is no need to specifically single out cargo heating coils.

The Committee combined and acted upon proposals: 306-27 (Log #54) ,306-28 (Log #55), 306-29 (Log #77), 306-30(Log #95), 306-31 (Log #35), 306-32 (Log #38), 306-33 (Log #1) , 306-34 (Log #47) and 306-35 (Log #94)) since theseproposals address the same section within the Standard. See 306-29 (Log #77) for the Committee's Action on thissection, 4.2.2.

Cargo heating coils are not pipelines and therefore a separate consideration of cargo heatingcoils in the Standard is appropriate and necessary. The revised text is shown in the Committee's Action in 306-29 (Log#77).

_______________________________________________________________________________________________306-35 Log #94

_______________________________________________________________________________________________James P. Bruff, Atlantic Coast Marine Chemist, LLC

Add text to read as follows:(7) The presence of and/or any test results about potential toxic hard (paint) coatings. The customers plan for dealing

with such coatings in the event they may have toxic characteristics.As, with other customers responsibilities pertaining to compliance with OSHA regulations in protecting

their own employees when performing any type of work that also could change the conditions of a Marine ChemistCertificate, this would seem appropriate for the Marine Chemist to inquire as a standard practice.

The Customer does not need a Marine Chemist Certificate to enter the confined / enclosed space for the removal ofsuch coatings. However, if such coating has not been removed at the time of the Marine Chemist Inspection, testingmay have determined it to be non toxic.

The Committee combined and acted upon proposals: 306-27 (Log #54) ,306-28 (Log #55), 306-29 (Log #77), 306-30(Log #95), 306-31 (Log #35), 306-32 (Log #38), 306-33 (Log #1) , 306-34 (Log #47) and 306-35 (Log #94)) since theseproposals address the same section within the Standard. See 306-29 (Log #77) for the Committee's action on thissection, 4.2.2.

The shipyard's responsibility under 29 CFR 1915 to address any toxic hazards associated withhard paint coatings. The revised text is shown in the Committee's Action in 306-29 (Log #77).

_______________________________________________________________________________________________306-36 Log #2


Add text to read as follows:Suggest that the Standard Safety Designations section 4.3 to 4.3.10.2 should be a chapter onto itself and not have the

other sections ( 4.1, 4.2, 4.4, 4.5 and 4.6) included.The Standard Safety Designations are one of the most important parts of NFPA 306 To make them

stand out they should have their own chapter.

The Committee proposed a reorganization of the Standard that includes the creation of a separate chapter for theStandard Safety Designations. See Committee Action on 306-2 (Log #CP9).

The intent of this proposal is addressed in the Committee's Action in 306-2 (Log #CP9).




Revise text to read as follows:The following standard safety designations shall be used where applicable in preparing Certificates, cargo tank labels,

and other references.This section lists the standard safety designations used to prepare Marine Chemist Certificates only.

While the safety designations may be used on other documents, the intention of 306 is for vessels to prepare for MarineChemist inspections and issuing a certificate to allow work to safely proceed and the intention should be limited to thisarea.

_______________________________________________________________________________________________306-38 Log #63


Revise text to read as follows:4.3.3 - Insert the following language at the end of this section: ..... or for emergency rescue with proper respiratory

protection.4.3.4(4)(5) - It is recommended that section 4.3.4(5) be eliminated and that section 4.3.4(4) be reworded as follows: All

spaces adjacent to cargo tanks the space certified "SAFE FOR HOT WORK" have been cleaned sufficiently of residues,scale, or preservative coatings to prevent the spread of fire, or are inerted and treated in accordance with MarineChemist requirements and acknowledged on the Certificate.

4.3.6 - Consideration should be given to having the word "limitations" noted in large cap letters "LIMITATIONS".4.3.10 - This section should be reviewed to ensure it is consistent with the latest edition of NFPA 312 as well as

Classification Society and Insurance company guidelines. Consideration should be given to defining requirements forboth short term and hard layup.

4.6.1 and 4.6.2 - The word "owner" should be modified to say "owner/operator".4.6.2(4) - This section should be relocated after 4.3.2(6) as existing section 4.3.2(6) should also be one of the

requirements for maintaining a Certificate.4.3.3 - Self explanatory

4.3.4(4)(5) - The proposal is intended to consolidate language and clarify that that it is not just spaces adjacent to a"cargo tank" that need to be sufficiently cleaned.

4.3.6 - Self explanatory to emphasize the fact that limitations are noted.4.3.10 - There have been significant enhancements to layup guidelines within the past couple of years that should be

taken into consideration, especially those associated with hard layup (long term).4.6.1 and 4.6.2 - This is intended to clarify the fact that it is often the vessel operator, not the actual owner that is

involved in obtaining a Certificate.4.6.2(4) - Follows a logical sequence and also includes existing section 4.3.2(6) as a requirement.

The Committee rejected the proposal.Submitter failed to present proposed in format required by the Document Proposal Form. The

proposed changes should be limited to a single requirement or single subject. Some of the items listed in thesubmitter's proposal have been addressed by the Committee in other public proposals. The Submitter may submit acomment on this action or action on other subjects covered within this proposal.




Revise text to read as follows:4.3.1.1* If any of the conditions of 4.3.1 (1), (2), (3),or (4) do not exist, then the designation NOT SAFE FOR

WORKERS or ENTER WITH RESTRICTIONS shall be used. If the atmosphere of the space is inert and is too small fora person to physically enter, then the NOT SAFE FOR WORKERS designation is not required to be used in conjunctionwith the INERT designation.

A.4.3.4.1. The NOT SAFE FOR WORKERS designation does not have to be used in conjunction with the INERTdesignation for spaces which are inerted and are too small to physically enter such as skegs, piping, stanchions andsimilar structures. This does not apply to tanks which are inerted and closed, but large enough to physically enter.

Spaces which have been intentionally inerted in accordance with section 4.3.8 and cannot bephysically entered by workers do not require the NOT SAFE FOR WORKERS designation be used in conjunction withthe INERTED designation. The use of these two designations for spaces which cannot be entered by workers can beconfusing and one could infer that the chemist may not have an understanding of the operation when they list a spacewhich cannot be entered as NOT SAFE FOR WORKERS. The intention of this suggestion would only apply to structuressuch as piping, skegs, keels, stanchions and similar structures.

The Committee rejected the proposal.The Committee determined that the change as proposed does not enhance worker safety.



_______________________________________________________________________________________________Thomas Beacham, Marine Chemist & Environmental Consultants, Inc.

Revise text to read as follows:Any toxic chemicals in the atmosphere associated with cargo, fuel, tank coatings, inerting mediums, adjacent spaces,

or fumigants are within permissible concentrations exposure limits (PELs) as listed in 29 CFR 1915 at the time ofinspection.

By specifying the information source for the Marine Chemist to use in testing and determining toxiclevels this proposal eliminates the confusion of what is required to comply with the minimal requirements of thestandard. This minimum and proposal reflects the actual exposure limits that the maritime community is required byOSHA to meet. Acceptance of this proposal will not negate or prevent the Marine Chemist from using otherrecommendations of exposure that are not regulations should the customer, other federal agencies or the MarineChemist feel those recommendations are appropriate at the time of inspection.

Accept the proposal and revise the Annex note for this requirement as follows:A.4.3.1(3) OSHA Permissible Exposure Limit Values (PELs) are found Permissible concentrations can be found in thelatest version of Threshold Limit Values for Chemical Substances and Physical Agents, published by the AmericanConference of Governmental Industrial Hygienists, in Subpart Z of 29 CFR 1915.1000,. “Permissible Exposure LimitValue,” or the value listed in the Manufacturers’ Safety Data Sheet (MSDS).In addition to or in the absence of an When determining "permissible concentrations" according to 4.3.1(3), the MarineChemist should use the lower value of the published ACGIH’s Threshold Limit Values (TLVs) or OSHA PermissibleExposure Limit (PEL) as the primary source for compliance with this requirement. Only in the absence of a publishedTLV and PEL for a substance should the Marine Chemist should refer to the Threshold Limit Values for ChemicalSubstances and Physical Agents, published by the American Conference of Governmental Industrial Hygienists,National Institute of Occupational Safety and Health (NIOSH) Recommended Exposure Limits (REL's), or MaterialSafety Data Sheets (MSDSs) to determine if any alternate value exists.

The Committee agrees with the proposal that the minimum requirement for assessing potentialworker exposure to toxic chemicals in the atmosphere associated with cargo, fuel, tank coatings, inerting mediums, orfumigants are the OSHA Permissible Exposure Limits (PEL's). However, the Committee believes that is also necessaryto provide guidance to the Marine Chemist regarding best practice when making such assessments particularly in theabsence of an OSHA PEL or in situations where a PEL may not provide sufficient protection. Therefore the Committeerevised the Annex note (A.4.3.1(3)) for this requirement and included that change with its action on this proposal. Therevised Annex note directs the Marine Chemist to other reference documents for occupational exposure limits whenappropriate.




Revise text to read as follows:(3) Any toxic chemicals in the atmosphere associated with cargo, fuel, tank coatings, inerting mediums, adjacent

spaces, or fumigants are within permissible concentrations at the time of the inspection.The change I recommend would much simplify the section.

Also, the present list of sources of toxic materials excludes common toxic problems. For instance, the Chemist neednot consider an ammonia leak because the present text does not include refrigerants. Similarly, the Chemist can ignoreexcessive weld fume or carbon monoxide because the text excludes them.

Also, the mention of "cargo" is a throwback to an age when the standard was understood to apply exclusively to cargotanks. This paragraph should apply as well to toxic problems in any enclosed workplace, such as an engine room orcompressor room.

It should read simply, "Toxic chemicals in the atmosphere are within permissible concentrations at the time of theinspection."

See the Committee's Action on 306-40 (Log #37).The requirement does not prohibit the Marine Chemist from testing for any toxic chemical

substance in the atmosphere. The Committee determined the reference to cargo, fuel, tank coatings, inerting mediums,adjacent spaces, or fumigants should remain in the requirement.

_______________________________________________________________________________________________306-42 Log #78


Revise text to read as follows:4.3.1* ATMOSPHERE SAFE FOR WORKERS requires that in the compartment or space so designated the following

criteria shall be met at the time the Certificate is issued:(1) *The oxygen content of the atmosphere is at least 19.5 percent and not greater than 22 percent by volume.(2)*The concentration of flammable materials is below 10 percent of the lower explosive limit (LEL).(3) *Any toxic chemicals in the atmosphere associated with cargo, fuel, tank coatings, inerting mediums, adjacent

spaces, or fumigants are within permissible concentrations at the time of the inspection.

M

(4) *The residues or chemicals remaining in a certified space associated with the work authorized by the Certificate arenot capable of producing unacceptable chemicals concentrations of toxic materials under existing atmosphericconditions while maintained as directed on the certificate.

Current wording is unclear. This clarifies that a chemist is ensuring that any remaining residues havebeen addressed.

The only change to the requirement is in 4.3.1(4) as noted in the proposal.




Add text to read as follows:(1) the Certificate shall include a statement describing the specific conditions of proper protection equipment, clothing,

or time, or any or all of the aforementioned. These areas shall be listed on the Certificate under the heading"restrictions."

Just as in paragraph, 4.3.6 SAFE FOR LIMITED HOT WORK, sub-paragraph. (2) which states "Theseareas shall be listed on the certificate under the heading "limitations," paragraph 4.3.3 ENTER WITH RESTRICTIONSsuggests there is something unique about a designated space. The respective headings, with words "limitations" and"restrictions," thus reinforces this uniqueness and, more importantly, prompts workers to read further what the special"limitations" and "restrictions" are, before entering and/or working in a space. In addition, only requiring conditions ofPPE, etc. to be "specified," without mentioning anything about "in writing' or the Marine Chemist Certificate, and infurther consideration of 1915.7(c)(1) in which a Competent Person shall have the "ability to understand and carry outwritten or oral information or instructions left by a Marine Chemist," these conditions should not be left to verbaltransference.

Revise text to read as follows:(1) The Certificate shall include a statement describing the specific conditions of personal protection equipment,

clothing, or time, or any, or all of the aforementioned. These areas shall be listed on the Certificate under the heading"rRestrictions."

Committee changed "proper protection equipment" to personal protection equipment andcapitalized the heading notation to draw emphasis to the restrictions that are mandated by the Marine Chemist on theCertificate.




Revise text to read as follows:4.3.4 SAFE FOR HOT WORK requires that in the compartment or space so designated, the following criteria shall be

met at the time the Certificate is issued:(1) *The oxygen content of the atmosphere is not greater than 22 percent by volume.(2)*The concentration of flammable materials in the atmosphere is less than 10 percent of the LEL.(3)* The residues scale, or preservative coatings in the entire space are cleaned sufficiently to prevent the spread of

fire and are not capable of producing a higher concentration than permitted by 4.3.4(1) or (2) under existing atmosphericconditions in the presence of hot work and while maintained as directed on the Certificate.; or, in the case of the engineroom or fire room bilges, or other machinery spaces, or spaces that have not contained flammable or combustible cargo,fuels, or coils are treated in accordance with the Marine Chemist's requirements.

(4)* All cargo tanks adjacent to cargo tanks certified “SAFE FOR HOT WORK “have been entirely cleaned sufficientlyof residues, scale or preservative coatings to prevent the spread of fire, and meet the requirements of 4.3.4 (1), (2), (3),or are inerted The adjacent cargo tanks can be partially cleaned to prevent the spread of fire from the hot work space inaccordance with section 5.1.3 provided the residues or coatings and meet the requirements of 5.1.3.(A). The adjacentspaces partially cleaned shall have hot work limitations listed in accordance with 4.3.6(3)(c)

(5) Non-cargo tank spaces adjacent to cargo spaces certified “SAFE FOR HOT WORK” must be treated in accordancewith Marine Chemist requirements and acknowledged on the Certificate.

(6) Spaces such as passage ways, living spaces or store rooms which are not adjacent to cargo tanks, and areundergoing hot work, must meet the requirements of section 4.3.4 (1) and (2). These spaces along with any adjacentspaces shall be treated in accordance with the Marine Chemists instructions and be free of material which could igniteunder conditions of work or be protected with barriers to prevent the spread of fire.

This is a new proposal for the definition of Safe for Hot Work. It clarifies the requirement that the spacebe entirely cleaned unless it meets certain criteria. It also provides additional information on how adjacent spaces mustbe treated to prevent the spread of fire. This information was not clear in the previous definition.

The Committee combined and acted upon proposals 306-44 (Log #4), 306-45 (Log #57), 306-46 (Log #5), 306-47 (Log#52), 306-48 (Log #6), 306-49 (Log #53), 306-50 (Log #79), 306-51 (Log #7) and 306-52 (Log #8) as one proposal sincethe content of these proposals affect or are intended to affect 4.3.4 Safe For Hot Work.

The Committee addressed parts of this proposal in other items related to this section of thestandard.The proposed change to 4.3.4(3) was rejected, consistent with the Committee's action in 306-46 (Log #5).The proposed change to 4.3.4(4) was rejected, consistent with the Committee's action in 306-48 (Log #6).The proposed change to 4.3.4(5) was rejected, consistent with the Committee's action in 306-51 (Log 7).The proposed change to 4.3.4(6) was rejected, consistent with the Committee's action in 306-52 (Log #8).




Revise text to read as follows:

Since the word "atmosphere" was added to "safe for workers" several revisions ago, it has causedsome confusion. When a Chemist inspects a space and writes "Atmosphere Safe for Workers and Safe for Hot Work" acursory reading implies "Safe for Hot Work" applies to the atmosphere when, in fact the Chemist wants "safe for hotwork" to apply to the space. Adding the word "space" to "Safe for Hot Work" is more direct and less ambiguous.

In my experience twice shipyard competent people have mistakenly thought that the "safe for hot work" applied to theatmosphere, not directly to the space. Their confusion was entirely understandable.

The Committee combined and acted upon proposal 306-44 (Log #4), 306-45 (Log #57), 306-46 (Log #5), 306-47 (Log#52), 306-48 (Log #6), 306-49 (Log #53), 306-50 (Log #79), 306-51 (Log #7) and 306-52 (Log #8) as one proposal sincethe content of these proposals affect or are intended to affect 4.3.4 Safe For Hot Work.

Adding the word "space" to the designation does not improve the Standard Safety Designationand furthermore changing the Standard Safety Designation as proposed is contrary to the designation that similarlyappears in the OSHA Shipyard Employment Standard in 29 CFR 1915.11 and 29 CFR 1915.14(a).

_______________________________________________________________________________________________306-46 Log #5


Revise text to read as follows:The residues scale, or preservative coatings in the entire space are cleaned sufficiently to prevent the spread of fire

and are not capable of producing a higher concentration than permitted by 4.3.4(1) or (2) under existing atmosphericconditions in the presence of hot work and while maintained as directed on the Certificate. or, in the case of the engineroom or fire room bilges, or other machinery spaces, or spaces that have not contained flammable or combustible cargo,fuels, or coils are treated in accordance with the Marine Chemist's requirements.

Some confusion has existed on whether this section will permit partial cleaning of a space. Theinsertion of the word entire clarifies this section informing the user that the entire space must be cleaned. This proposalalso removes the last sentence of this section and suggests that it be added as a stand alone section under 4.3.4 and islisted in another proposal.

The Committee combined and acted upon proposals 306- (Log #4), 306- (Log #57), 306- (Log #5), 306- (Log #52), 306-(Log #6), 306- (Log #53), 306- (Log #79), 306- (Log #7) and 306- (Log #8) as one proposal since the content of theseproposals affect or are intended to affect 4.3.4 Safe For Hot Work. The Committee used the submitter's proposal for4.3.4(3) and took the submitter's deleted material to create a new listed item (7).(3) The residues scale, or preservative coatings in the entire space are cleaned sufficiently to prevent the spread of fireand are not capable of producing a higher concentration than permitted by 4.3.4(1) or (2) under existing atmosphericconditions in the presence of hot work and while maintained as directed on the Certificate. or, in the case of the engineroom or fire room bilges, or other machinery spaces, or spaces that have not contained flammable or combustible cargo,fuels, or coils are treated in accordance with the Marine Chemist's requirements.(7) The residues scale, or preservative coatings in the entire space are cleaned sufficiently to prevent the spread of fireand are not capable of producing a higher concentration than permitted by 4.3.4(1) or (2) under existing atmosphericconditions in the presence of hot work and while maintained as directed on the Certificate. or, in In the case of theengine room or fire room bilges, or other machinery spaces, or spaces that have not contained flammable orcombustible cargo, fuels, or oils are treated in accordance with the Marine Chemist's requirements.

The Committee didn't want to leave the requirement for engine rooms or fire room bilges,machinery spaces or spaces that did not have combustible or flammable materials out of 4.3.4.and created a new listitem (7) under 4.3.4.



_______________________________________________________________________________________________Don Sly, Marine Chemist Assn. / Rep. Sound Testing Inc


met at the time the Certificate is issued:...(3)*The residues, scale, or preservative coatings are cleaned sufficiently to prevent the spread of fire and are not

capable of producing a higher concentration than permitted by 4.3.4(1) or (2) under existing atmospheric conditions inthe presence of hot work and while maintained as directed on the Certificate; or, in the case of the engine room or fireroom bilges, or other machinery spaces, or spaces that have not contained flammable or combustible cargo, fuels, orcoils are treated in accordance with the Marine Chemist's requirements.

(3) Combustible materials have been cleaned sufficiently to prevent uncontrolled ignition while maintained as directedon the Certificate.

It is difficult to say enough bad things about existing Section 4.3.4(3). But, here goes:1) "residues, scale, or preservative coatings..." is terminology left over from tank vessel context of the last century.

Today the most common shipyard fires come from rags, furnishings, debris or insulation; not from "residues, scale, orpreservative coatings." Why have a list of ignitable materials which excludes the most common and worrisome firedangers?

2) "...cleaned sufficiently to prevent the spread of fire..." is language from the "adjacent spaces" section and is notstrong enough to describe the safety needed in the actual hot work site. We want to prevent not the "spread" of fire, butto prevent any fire at all.

3) "not capable of producing higher concentration than permitted by...in the presence of hot work..." is an unworkablestab at relating fire danger to meter readings. No Chemist tries to test the LEL of anything "in the presence of hot work."Moreover, the preceding sentence (Section 4.3.4) expressly demands that our certificate reflect conditions "at the timethe certificate is issued". This is incompatible with "in the presence of hot work," which is different than at the time ofinspection. Thus, current Section 4.3.4(3) language literally demands we foretell the future, which is a certificate ofconvenience. The point of Section 4.3.4(3) is to prevent fires. But is so difficult to read that the meaning cannot betaught to Competent Persons. Better to directly say "prevent ignition" than to refer to impossible testing for LEL's "in thepresence of hot work." .

4) "Or in the case of ... fire room bilges..." For most Chemists a fire room bilge turns up once or twice a decade. Anymore, there aren't very many steam-driven vessels. Why include "fire room bilges" in our most-used standarddesignation? And even when there is a boiler, it is probably in a mid-level space and has no "bilge." In any case,"treated in accordance with the Marine Chemist's requirements is redundant because we already have "...whilemaintained as directed on the Certificate" in the paragraph

5) "Residues, scale, or preservative coatings" is best replaced by: "combustible materials" which is (Section 3.3.5)defined within the Standard.

The Committee combined and acted upon proposals 306-44 (Log #4), 306-45 (Log #57), 306-46 (Log #5), 306-47 (Log#52), 306-48 (Log #6), 306-49 (Log #53), 306-50 (Log #79), 306-51 (Log #7) and 306-52 (Log #8) as one proposal sincethe content of these proposals affect or are intended to affect 4.3.4 Safe For Hot Work.The Committee rejected this Proposal.

The proposal eliminates references to residues, scale and preservative coatings that may beflammable or combustible and is therefore unacceptable to the Committee.




Revise text to read as follows:All cargo tanks adjacent to cargo tanks certified “SAFE FOR HOT WORK “have been entirely cleaned sufficiently of

residues, scale or preservative coatings to prevent the spread of fire, and meet the requirements of 4.3.4 (1), (2), (3), orare inerted The adjacent cargo tanks can be partially cleaned to prevent the spread of fire from the hot work space inaccordance with section 5.1.3 provided the residues or coatings meet the requirements of 5.1.3.(A). The adjacentspaces partially cleaned shall have hot work limitations listed in accordance with 4.3.6(3)(c).

This proposal will clarify that any space adjacent to cargo tanks certified SFHW must be entirelycleaned unless it meets the requirements of 5.1.3. If the adjacent space meets the requirements of 5.1.3 then it can bepartially cleaned and the space certified as SFLHW. If this proposal is accepted then the diagrams in section Annex Bmust be amended or expanded.

The Committee combined and acted upon proposals 306- (Log #4), 306- (Log #57), 306- (Log #5), 306- (Log #52), 306-(Log #6), 306- (Log #53), 306- (Log #79), 306- (Log #7) and 306- (Log #8) as one proposal since the content of theseproposals affect or are intended to affect 4.3.4 Safe For Hot Work.

The use of words "entirely" and "partially" in the proposed requirement are conflicting.

_______________________________________________________________________________________________306-49 Log #53


All spaces adjacent to cargo tanks to be certified "Safe for Hot Work", as well as any cargo tankadjacent to a hot work site, have combustible gas readings less than 10% LEL, have been cleaned sufficiently ofresidues, scale or preservative coatings to prevent the spread of fire, or are have been inerted.

Add "to be" because if the spaces are already certified "Safe for Hot Work" the referenced conditionsare already in effect and don't need to be evaluated. (A point of logic.)

Add "as well as any cargo tank adjacent to a hot work site" because existing text does not cover cargo tanks unlessthey are adjacent to hot work in other cargo tanks; cargo tanks adjacent to non-cargo tank hot work sites are notcovered by existing text, and by default go to paragraph 4.3.4(5), which allows cargo tanks to be treated "according tothe Chemist's requirements."

Add "have combustible gas readings less than 10% LEL" because this section was inadvertently deleted in the lastrevision.

Delete "are" and add "have been" to keep the tense consistent.

The Committee combined and acted upon proposals 306-44 (Log #4), 306-45 (Log #57), 306-46 (Log #5), 306-47 (Log#52), 306-48 (Log #6), 306-49 (Log #53), 306-50 (Log #79), 306-51 (Log #7) and 306-52 (Log #8) as one proposal sincethe content of these proposals affect or are intended to affect 4.3.4 Safe For Hot Work.Committee made the following editorial changes deleted, "to be" from the proposal and deleted "are" and added "havebeen"(4) All spaces adjacent to cargo tanks to be certified "Safe for Hot Work", as well as any cargo tank adjacent to a hotwork site, have combustible gas readings less than 10 percent of the LEL, have been cleaned sufficiently of residues,scale or preservative coatings to prevent the spread of fire, or are have been inerted.

The phrase, "to be", implies future action which is in conflict with the requirements for certifyingspaces Safe for Hot Work. Deleting "are" and inserting "have been" is an editorial change.





met at the time the Certificate is issued:(1) *The oxygen content of the atmosphere is not greater than 22 percent by volume.(2)*The concentration of flammable materials in the atmosphere is less than 10 percent of the LEL.(3)*The residues, scale, or preservative coatings are cleaned sufficiently to prevent the spread of fire and are not

capable of producing a higher concentration than permitted by 4.3.4(1) or (2) under existing atmospheric conditions inthe presence of hot work and while maintained as directed on the Certificate; or, in the case of the engine room or fireroom bilges, or other machinery spaces, or spaces that have not contained flammable or combustible cargo, fuels, orcoils are treated in accordance with the Marine Chemist's requirements.

(4)*All spaces adjacent to cargo tanks adjacent to hot work certified "SAFE FOR HOT WORK" have been cleanedsufficiently of residues, scale, or preservative coatings to prevent the spread of fire, and flammable concentrations in theatmosphere are less than 10 percent of the LEL, or are have been inerted.

(5) All other non-cargo spaces adjacent to spaces to be certified "SAFE FOR HOT WORK’' are treated in accordancewith Marine Chemist requirements and acknowledged on the Certificate.

Currently, it is permissible to permit an adjacent cargo space to be certified for hot work with an LELreading above 10%. This new wording will not permit hot work if an adjacent space has greater than 10% LEL.Additionally, changes to sections (4) and (5) address spaces adjacent to hot work by separating them into cargo andnon-cargo spaces and treating them differently.

The Committee combined and acted upon proposals 306-44 (Log #4), 306-45 (Log #57), 306-46 (Log #5), 306-47 (Log#52), 306-48 (Log #6), 306-49 (Log #53), 306-50 (Log #79), 306-51 (Log #7) and 306-52 (Log #8) as one proposal sincethe content of these proposals affect or are intended to affect 4.3.4 Safe For Hot Work.Below is the revised text for 4.3.4 from the actions taken on the above proposals:4.3.4 SAFE FOR HOT WORK requires that in the compartment or space so designated, the following criteria shall bemet at the time the Certificate is issued:(1) *The oxygen content of the atmosphere is not greater than 22 percent by volume.(2)*The concentration of flammable materials in the atmosphere is less than 10 percent of the LEL.(3)* The residues scale, or preservative coatings in the entire space are cleaned sufficiently to prevent the spread of fireand are not capable of producing a higher concentration than permitted by 4.3.4(1) or (2) under existing atmosphericconditions in the presence of hot work and while maintained as directed on the Certificate. ; or, in the case of the engineroom or fire room bilges, or other machinery spaces, or spaces that have not contained flammable or combustible cargo,fuels, or coils are treated in accordance with the Marine Chemist's requirements. ( from Log 5)(4) All spaces adjacent to cargo tanks to be certified "Safe for Hot Work", as well as any cargo tank adjacent to a hotwork site, have combustible gas readings less than 10 percent of the LEL, have been cleaned sufficiently of residues,scale or preservative coatings to prevent the spread of fire, or are have been inerted. (from 306- Log #53)).(5) Non-cargo tank spaces adjacent to cargo spaces certified “SAFE FOR HOT WORK” must be treated in accordancewith Marine Chemist requirements and acknowledged on the Certificate. (from 306- ( Log #7)).(6) Spaces such as passage ways, living spaces or store rooms which are not adjacent to cargo tanks, and areundergoing hot work, must meet the requirements of section 4.3.4 (1) and (2). These spaces along with any adjacentspaces shall be treated in accordance with the Marine Chemists instructions and be free of material which could igniteunder conditions of work or be protected with barriers to prevent the spread of fire. (from 306- (Log #8)).(7) In the case of the engine room or fire room bilges, or other machinery spaces, or spaces that have not containedflammable or combustible cargo, fuels, or oils are treated in accordance with the Marine Chemist's requirements. (from306- Log #5)).

The intent of this specific proposal is addressed in the Committee Action in 306-49 (Log #53)and 306-51 (Log #7). The revised requirement based on the Committee's meeting action on proposals 306-44 (Log #4),306-45 (Log #57), 306-46 (Log #5), 306-47 (Log #52), 306-48 (Log #6), 306-49 (Log #53), 306-50 (Log #79), 306-51(Log #7) and 306-52 (Log #8)) is shown above.


Report on Proposals – June 2013 NFPA 306

_______________________________________________________________________________________________306-51 Log #7


Add text to read as follows:Non-cargo tank spaces adjacent to cargo spaces certified “SAFE FOR HOT WORK” must be treated in accordance

with Marine Chemist requirements and acknowledged on the Certificate.Section 4.3.4(5) is poorly worded. This proposed wording would clarify how non-cargo spaces

adjacent to cargo spaces (SFHW) must be treated.

_______________________________________________________________________________________________306-52 Log #8


Add text to read as follows:Spaces such as passage ways, living spaces or store rooms which are not adjacent to cargo tanks, and are

undergoing hot work, must meet the requirements of section 4.3.4 (1) and (2). These spaces along with any adjacentspaces shall be treated in accordance with the Marine Chemists instructions and be free of material which could igniteunder conditions of work or be protected with barriers to prevent the spread of fire.

This new proposed section outlines how a Marine Chemist must address spaces which are notadjacent to cargo. It clearly states how a Chemist must address hot work in living, storage or miscellaneous areasshipboard. It also requires the chemist to address any adjacent spaces as they deem necessary.

_______________________________________________________________________________________________306-53 Log #71

_______________________________________________________________________________________________Thomas T. Govey, Govey Enterprises, LLC

Revise text to read as follows:4.3.5 Not safe for hot work indicates that in, or on, the compartment or space so designated, hot work shall not be

permitted.By adding "or on" the designation will be reflective of the potential danger of doing H/W on or against

the exterior of the compartment/space.By adding "or space" the designation will become consistent with the other SSDs.




Revise text to read as follows:4.3.5 NOT SAFE FOR HOT WORK indicates that in or on the compartment so designated, hot work shall not be

permitted.The addition of the words “or on” makes it clear that when a space is certified Not Safe for Hot Work

that hot work cannot be conducted either on or in the space.

This proposal is nearly identical to the proposed change in 306-53 (Log #71). The intent of thisproposal was addressed by the Committee in its action in 306-53 (Log #71).

_______________________________________________________________________________________________306-55 Log #66

_______________________________________________________________________________________________Gregory G. Grondin, Downeast Laboratories, Inc,

Add new text to read as follows:In compartments/spaces on vessels, that are not considered cargo or fuel spaces and have not contained

and are not subject to concentrations of combustible, flammable or toxic liquids, vapors, or gases, the Marine Chemistshall survey the spaces and adjacent spaces in accordance with Section 4.2.2 (revised). The certificate shall include astatement under the heading "limitations" describing the locations and type of Hot Work along any directions for theCompetent Person to ensure safe work conditions.

Marine Chemists frequently perform inspections in areas not covered by the scope of 306. Theemployer is utilizing the experience of the chemist to prescribe safe precautions for completing the work. Many of thesespaces will contain ordinary combustible materials that are covered by OSHA 29 CFR 1915 Subpart P. Subpart Ppermits protection of the combustible materials and/or the use of firewatches when combustible materials cannot easilybe removed or protected. However, paragraph 5.1.3 of NFPA 306 does not permit the use of firewatches in lieu ofcleaning, therefore, the Marine Chemist must mandate that the combustible materials are removed to issue a certificate.Having a client remove a rug, glued to the deck in a berthing space, seems extreme when other protective methods areavailable.

Revise text to read as follows:In compartments/spaces on vessels, that are not considered cargo or fuel spaces and have not contained

and are not subject to concentrations of combustible, flammable or toxic liquids, vapors, or gases, the Marine Chemistshall survey the spaces and adjacent spaces in accordance with Section 4.2.2 (revised). The Certificate shall include astatement under the heading "Limitations" describing the locations and type of Hot Work along with any directions forthe Competent Person to ensure safe work conditions.

Committee made editorial changes. Deleted "(revised)" in the first sentence and added "with"in the second sentence.




Revise text to read as follows:4.3.6 SAFE FOR LIMITED HOT WORK indicates that all of the following criteria shall be met at the time the Certificate

is issued:(1) Any compartment or space so designated meets the requirements of 4.3.4(1) and 4.3.4(2) (unless inerted in

accordance with 4.3.8).(2) The Certificate shall include a statement describing the specific location and type of the hot work. The

Marine Chemist shall also be permitted to list any areas to be excluded from hot work. These areas shall be listed on theCertificate under the heading "limitations."

(3) The space meets one of the following conditions:(a) The space or compartment is inerted in accordance with 4.3.8, adjacent spaces shall be treated in

accordance with 4.3.4( 4), and the hot work shall be limited to the specific location or locations described in the"limitations" in 4.3.6(2). The marine chemist shall ensure that the atmospheres of adjacent space(s) meet therequirements of sections below in accordance with 4.3.4 (4) or (5), or are inerted.

(b) The space or compartment meets the requirements of 4.3.4 (1), (2), (3) and (4); and adjacent spaces meet4.3.4 (4) or (5) and the hot work shall not be allowed on adjacent spaces or pipelines. or both as applicable; and Thehot work limitations restrictions shall be described in the listed under "limitations" in accordance with 4.3.6(2). Themarine chemist shall ensure that the atmospheres of adjacent space(s) are maintained below 10%, of the lowerexplosive level or are inerted.

(c) Portions of the space or compartment meet the requirements of 4.3.4(3) and (4) or (5), as well as theapplicable portions of 5.1.3, and the hot work shall be limited to the location or locations described in the "limitations" in4.3.6(2)

Currently, it is permissible to permit an adjacent space to be certified for hot work with an LEL readingabove 10%. This new wording will not permit hot work if an adjacent space has greater than 10% LEL. Additionally, thechanges it compatible with proposed changes to Safe for Hot Work.

The Committee made changes to text in 3a and 3b as shown below:(a) The space or compartment is inerted in accordance with 4.3.8, adjacent spaces shall be treated in accordance with4.3.4( 4), and the hot work shall be limited to the specific location or locations described in the "limitations" in 4.3.6(2).The marine chemist shall ensure At the time of the inspection the Marine Chemist shall verifythat the atmospheres of adjacent space(s) meet the requirements of sections below in accordance with 4.3.4 (4) or (5),or are inerted.(b) The space or compartment meets the requirements of 4.3.4 (1), (2), (3) and (4); and adjacent spaces meet 4.3.4 (4)or (5) and the hot work shall not be allowed on adjacent spaces or pipelines. or both as applicable; and The hot worklimitations restrictions shall be described in the listed under "limitations" in accordance with 4.3.6(2). The marine chemistshall ensure that the atmospheres of adjacent space(s) are maintained below 10%, of the lower explosive levelconcentration of flammable materials in the atmosphere is less than 10 percent of the LEL or are inerted.

In list item 3(a) the Committee deleted, "The Marine Chemist shall ensure", and added text: "Atthe time of the inspection the Marine Chemist shall verify", which better explains when this action is required.In list item 3(b) the Committee deleted, "The marine chemist shall ensure that the atmospheres of adjacent space(s) aremaintained below 10%, of the lower explosive level or are inerted.", and added text, "The Marine Chemist shall ensurethat the concentration of flammable materials in the atmosphere is less than 10 percent of the LEL or are inerted.", sothat this requirement is consistent with language in 4.3.4(2) of the standard.




Revise text to read as follows:The space or compartment meets the requirements of 4.3.4(1), (2), (3), and (4); the hot work shall not be allowed on

adjacent spaces or pipelines, or both as applicable; but the proposed hot work has a higher degree of potential hazardand must be limited in accordance with Marine Chemist's requirements; and the hot work limitations shall be describedin the limitations" in 4.3.6(2).

This wording implies there may be instances in which Hot Work is "allowed on adjacent spaces," if, forexample, condition (a) or (c), instead of (b), has been met (only one of the three conditions is required by this section).Though this should never be the case, there have been several incidents in which Hot Work in a "subject space" (3.3.1)was conducted against decks and, especially, bulkheads. When Hot Work is against a common boundary, both spacesneed to be inspected/certified (regardless of where the Hot Work worker is located) and the remaining spaces, aroundboth subject spaces, are then adjacent spaces. Similarly, hot work is never allowed on pipelines unless they arespecifically inspected/certified (according to the Marine Chemist Certificate, undesignated pipelines are to be considered"not safe"). In the context of condition (b)'s current working, conditions (a) and (c) imply Hot Work can be conducted onany uninspected/uncertified pipeline as long as the pipeline is physically located within a specific location." Therefore,there is no added value in retaining the proposed deleted phrase because it 1) causes confusion between subjectspaces and adjacent spaces 2) implies Hot Work is acceptable where none has been authorized, and 3) specificallyprohibits Hot Work on pipelines, which is often a common application of this designation. Conversely, the insertedwording 1) removes the context promoting the aforementioned confusion and implications, and 2) allows for Hot Work,for example, on a small section of pipeline that has been isolated and cleaned, while the remaining (majority) length ofthe same pipeline is still contaminated.

The Committee rejected the proposal.The proposed language is confusing. The standard does not allow hot work in or on adjacent

spaces.

_______________________________________________________________________________________________306-58 Log #50


Revise text to read as follows:4.3.8(1) INERTED requires that one of the following procedures shall have been completed in the compartment or

space so designated:(1)* Carbon dioxide or other nonflammable gas acceptable to the Marine Chemist shall have been introduced into the

space in sufficient volume to maintain the oxygen content of the atmosphere of the enclosed space at or below 6percent or 50 percent of the amount require to support combustion, whichever is less.

Delete "enclosed" space because (5.2.3 All spaces to be inerted shall be sufficiently intact to retainthe inerting medium) demands a vapor-tight condition which only exists in confined, not enclosed, spaces. Please notethat "enclosed" spaces (29CFR1915, Subpart B) merely have deck, overhead, and bulkhead enclosure...for example,spaces such as pantries, staterooms, passageways, etc. However, "confined spaces" should not be substituted for"enclosed" spaces because "confined spaces" implies possible entry, whereas often the Chemist inerts spaces (rudders,bilge-keels, etc.) which are hollow or inaccessible. Best to simply reference "spaces".




Revise text to read as follows:The space has been filled to overflow with water and the water level shall be maintained throughout the intended work.

Valves shall be tagged or by written notice positioned to restrict operation to maintain the water level. If any headspaceremains in the tank, it shall meet the requirements of 4.3.4(2). Any such procedure shall be approved by the MarineChemist.

The current 4.3.8.2 section instructs you to flood the space but then contradicts itself by allowing hotwork below three feet of the surface of the water and permits headspace. This section along with another proposal willclarify the inerting by water practice by splitting it into two sections. One will allow flooding the space and the other willpermit hot work 3 feet below the water level.

Change the proposed text as follows:The space Spaces other than cargo tanks, fuel tanks have has been filled to overflow with water and the water levelshall be maintained throughout the intended work. Valves shall be tagged or by written notice positioned to restrictoperation to maintain the water level. If any headspace remains in the tank, it shall meet the requirements of 4.3.4(2).Any such procedure shall be approved by the Marine Chemist.

Overflowing cargo tanks or fuel tanks with water may result in a pollution incident. TheCommittee modified the proposed text to exclude cargo tanks and fuel tanks from the practice of overflowing with water.

_______________________________________________________________________________________________306-60 Log #10


Add text to read as follows:The space has been filled with water so that the water level is a minimum of 0.9 m (3 feet) above the intended exterior

hot work and the atmosphere of the headspace meets the requirements of 4.3.4(2). The water level shall be maintainedthroughout the intended work by tagging valves in a position to maintain the water level. Any procedure shall beapproved by the Marine Chemist.

This proposed new section clarifies and separates the two methods of inerting with water, filling tooverflow and partial filling with water. It also requires that any valves are positioned and tagged to maintain the waterlevel. The previous method required the valves to be closed and this may not always be the case.




Add text to read as follows:All valves to the inerted spaces shall be tagged and positioned in such a manner as to prevent or, by written notice,

restrict operation.Suggest a new section to the inerted safety designation requiring valves to be tagged or by written

notice restricted to prevent changing valve position.

Revised the proposed text as follows:All valves, vent lines and other openings to the inerted spaces shall be positioned in such a manner and tagged andpositioned in such a manner as to prevent or, by written notice, restrict operation.Add to Annex:A.4.3.8(4) Valves may be opened, closed or blanked as necessary to maintain the inert condition of the space.

The Committee did not want to limit the requirement to just valves and added an annex note toaddress the valves used to control the inert medium that is used.

_______________________________________________________________________________________________306-62 Log #33


Revise text to read as follows:4.4 Preparation of Certificates. When the Marine Chemist is satisfied that the related requirements necessary for the

safe conduct of the work have or have not been met, a Certificate shall be prepared in accordance with this standardand in the format of the most recent Certificate of Style published by the Marine Chemist Qualification Board inconjunction with the Marine Chemist Association. The Certificate shall be written legibly. If ink stamps are used, allcopies of the Certificate shall be stamped and legible.

The Marine Chemist Qualification Board and the Marine Chemist Association have published arecommended format for Marine Chemist Certificates. The benefit of following one format is that employees andcompetent persons in all areas of the country will see a unified style for Marine Chemist Certificates, which should beuniversally understandable. When different Chemists work in the same shipyard, having a similar certificate format is abenefit to workers and competent persons understanding of the requirements. Incorporating this requirement into 306will make this format mandatory for Chemists to follow.




Revise text to read as follows:Limits of detection (LOD) for toxic tests shall be indicated on the Certificate for all test results in which the display or

reading is 0, below the lowest division or marking, or otherwise "None Detected."In Annex A, paragraph A.4.4.1.1 (notice the "A" in this paragraph number, contrasted to the proposed

change in para. 4.4.1.1), gives explanatory material on the importance of Limits of Detection and how to record a testresult of 0) or otherwise "none detected." Paragraph 4.4.1.1 (without an "A"; the subject of this proposal) does not makethis same distinction between detectable test results (numbers greater than zero, greater than a manufacturer'spublished LOD; readings above the lowest division or marking) and undetectable test results (zero, less than amanufacturer's published LOD; readings below the lowest division or marking). Instead, 4.4.1.1 states "Limits ofDetection (LOD) for toxic test results shall be indicated on the Certificate." The preceding paragraph, 4.4.1, furtherstates that this is to be done "for all spaces tested including adjacent spaces." When interpreted literally, recordingLODs with detectable/recordable test results 1) clutters the Certificate with added text, 2) does not offer any added value(e.g. 52.7 ppm JP-5 with a LOD = 0.3 ppm is still 52.7 ppm), and 3) tends to circumvent the intent and most importantpoint of the Annex to make sure each instrument is capable of detecting toxic concentrations below their establishedexposure limits. Thus, considering paragraph 4.4.1.1 is the mandatory section of the Standard (not A.4.4.1.1), andfurther considering A.4.4.1.1 contains good examples of explanatory material, paragraph 4.4.1.1 should be revised asproposed.

The Committee rejected this proposal.The use of the less than symbol (<) is a common practice used by Marine Chemists to display

toxicity test results obtained during the quantitative survey and is acceptable to the Committee.

_______________________________________________________________________________________________306-64 Log #107


Revise text to read as follows:Such qualifications and requirements shall include precautions, including protective equipment and devices,

necessary to eliminate or minimize hazards that could be present from protective coatings or residues from cargoes.These qualifications also shall include limitations or restrictions, if any, on the areas where work is to be done.Qualifications may also include references to requirements established in current regulations and standards.

This language permits the Marine Chemists to include qualifications as applicable, includingreferences and requirements of established regulations and standards, such as those from OSHA, USCG, US Navy,ANSI, etc. For example, reference topics may include the requirements for paints, coatings, static electicity,lockout/tagout, house-keeping, dust explosion, fall protection, biological or radiological factors, etc…

The Committee rejected this proposal.The term, "may", is unenforceable language. The standard does not prohibit the Marine

Chemist from making references to appropriate regulations, the requester's safety procedures or other documented bestpractices.




Revise text to read as follows:4.4.3* Such qualifications and requirements shall include precautions, including protective equipment and devices,

necessary to eliminate or minimize hazards that could be present from common combustibles, protective coatings orresidues from cargoes and combustible liquids. These qualifications shall include limitations or restrictions, if any, on theareas where work is to be done and shall be listed on the certificate.

A.4.4.3 If there is no additional statement regarding the scope of the work on the Certificate, any hot work or cold workcan proceed as indicated by the standard safety designation. If all types of work cannot be conducted safely under astandard safety designation, then the authorized work or prohibited work should be listed on the Certificate.

The new wording allows the chemist to address common combustibles and fuel residues. The annexshould be dropped due to changes in the standard no longer make this explanation necessary.

The Committee modified the proposed text as follows:4.4.3* Such qualifications and requirements shall include precautions, including protective equipment and devices,

necessary to eliminate or minimize hazards that could be present from common combustibles, protective coatings orresidues from cargoes and combustible liquids. These qualifications shall include limitations or restrictions, if any, on theareas where work is to be done and shall be listed on the certificate.

A.4.4.3 If there is no additional statement regarding the scope of the work on the Certificate, any hot work or cold workcan proceed as indicated by the standard safety designation. If all types of work cannot be conducted safely under astandard safety designation, then the authorized work or prohibited work should be listed on the Certificate.

The Committee deleted the word, "common", since it is unclear what the submitter meant by"common combustibles" .




Delete text to read as follows:4.6.1(D) Only one requester will be listed on the certificate. The requester is responsible for providing a complete

statement of the scope of the work. The requester listed...Present NFPA 306-2009 sentence imposes an unrealistic burden on both the requestor and the

Chemist. It is the nature of ship repair projects to be temporary, demand-driven workplaces. When a vessel enters ashipyard everyone involved realizes that the scope of the work will change as each repair item is dealt with in detail. Forinstance, when one subcontractor accidentally contaminates a space and cleaners need be called, this changes thescope of a repair job in ways that could not have been predicted.

The chemist routinely inquires as to the scope of the work. But everyone knows the answer, like the conditionsaboard the vessel, applies only to the time of the inspecton.

And that's why we routinely protect ourselves by forbidding repairs beyond spaces listed on the certificate.Moreover, for certain jobs, such as repairs to a deck cargo barge, from the chemist's point of view no one cares what

the scope of the work is, as the vessel is safe for almost all eventualities.It seems over-reaching for a regulation to demand "total" information when all parties know the info is temporary and

limited.

The Committee rejected this proposal.The standard's requirement for the requester to provide a complete scope of work to the Marine

Chemist is neither unrealistic or over-burdensome. The need for the Certificate requester to communicate the scope ofwork to the Marine Chemist is essential. The requirement in 4.6.1(D) is consistent with the procedures prior to issuanceof a Certificate that are found in 4.2.2 of the standard. Section 4.6.1(D) of the standard is an instruction for the users ofthe standard to communicate the scope of work as it applies to the spaces that will be the subject of the MarineChemist's Certificate. Without this information the Marine Chemist cannot perform his or her tasks related to thepreparation of the Certificate.

_______________________________________________________________________________________________306-67 Log #67


Delete text as follows:4.6.2(1) Conditions documented on the Certificate shall be inspected by the shipyard competent person within one

day..."Deleted this paragraph because:

1. This paragraph violates OSHA's "as-often-as-necessary" approach to maintaining the Chemist's certificate.2. It is redundant. The same material is covered just below in 4.6.2 (3), where it is related to "in support of work."3. Generally, NFPA use of "daily" is harmful because it causes certain regulatory bodies to demand useless SCP

inspections on weekends and holidays. The fact that unsafe conditions will be easily detected Monday morning even ifthe SCP sleeps in on Saturday and Sunday does not seem to occur.

The Committee rejected this proposal.The requirement in 4.6.2(1) is intended to verify that the conditions found by the Marine

Chemist at the time of his or her inspection and survey and issuance of the Certificate have not changed within one day(24 hours). It is essential that a competent person rechecks the spaces that are subject to the Certificate at least oncein the first 24 hours that the Certificate is valid. Thereafter maintaining the Certificate is addressed in Section 4.6.2(3) ofthe Standard.



_______________________________________________________________________________________________Martin H. Finkel, Kerikeri

Revise text to read as follows:Unless otherwise stated on the certificate, all spaces documented on the Marine Chemist Certificate shall be

reinspected daily, or more often as necessary, by the shipyard competent person in support of work prior to entry orrecommencement of work.

The deleted phrase "in support of work" is not defined anywhere in NFPA-306 and introduces into anotherwise clear requirement for daily reinspection by the SCP an ambiguity. By deleting this phrase it is clear that tomaintain the certificate, a daily SCP reinspection on all spaces must be performed, at a minimum.

The Committee addressed 306-68 (Log #28), 306-69 (Log #97) and 306-70 (Log #83) as a single proposal. TheCommittee's action is found in 306-70 (Log #83).

The submitter's intended change is addressed by the Committee's Action on 306-70 (Log #83).

_______________________________________________________________________________________________306-69 Log #97



4.6.2(3) * Unless otherwise stated on the Certificate, all spaces including adjacent spaces documented on the MarineChemist Certificate shall be reinspected daily, or more often as necessary, by the shipyard competent person in supportof' vvork prior to entry or recommencement of work. shall be re-inspected by the shipyard competent person prior tore-entry or re-commencement of work in or on them, and thereafter as often as necessary, to ensure safe conditionsstated on the Certificate have been maintained.

The proposed language clarifies ambiguous meaning and interpretation of the current language in thissection.

The Committee addressed in proposals 306-68 (Log #28), 306-69 (Log #97) and 306- (Log #83) as a single proposal.The Committee's action is found in 306-70 (Log #83).

The submitter's intended change is addressed by the Committee's Action on 306-70 (Log #83).




Revise text to read as follows:4.6.2(3)*Unless otherwise stated on the Certificate, all spaces including adjacent spaces documented on the .Marine

Chemist Certificate shall be reinspected daily, or more often as necessary, by the shipyard competent person in supportof work prior to entry or recommencement of work.

4.6.2(3)* Unless otherwise stated on the Certificate, certified spaces including spaces adjacent to hot work, where workis being done shall be re-inspected daily, or more often as necessary, by the shipyard competent person, prior to entryor external hot work.

A.4.6.2(3) The intent of this wording is to clarify that spaces listed on the Marine Chemist Certificate do not need to betested by the competent person unless work is being done on or in a space. For example, spaces on a certificate do notneed to be tested and inspected on a weekend if no work or entry is taking place. However, nothing shall prevent acompetent person from testing more frequently than the minimum,

The current wording is confusing and this new wording helps clarify when a competent personre-inspection is needed. An addition to the annex provides the intent of the mandatory section.




Revise text to read as follows:(6) (4) Certificates not maintained according to the requirements in Sections 4.6.2(1) through (5) shall be void.

a

(6) (5), (5)1. From a totally safety perspective, a Competent Person should always use a calibrated instrument.

Though Competent Person tests/inspections fall under the domain of OSHA 29CFR1915, NFPA 306 should be able toexercise control over how "its own" Marine Chemist Certificate is maintained, according to its own (NFPA) document. Ifa Competent Person maintaining a Certificate uses an improperly functioning or calibrated instrument, or no instrumentat all, the Certificate should be voided. This is a dangerous situation. As it is currently written, there are noconsequences to encourage a Competent Person use a calibrated instrument.

2. From an editorial perspective, positioning paragraph (4) in the middle of the "4.6.2(1) through (5)" requirement is anexample of awkward grammatical construction; an infinite loop (i.e. "(4) Certificates are not maintained according to therequirements in (4)," which states, "(4) Certificates are not maintained . . .")

As proposed the listed items affected by this proposal shall appear as follows:(4) Certificates not maintained according to the requirements in 4.6.2(1) through (5) shall be void.(5) (4) It is the responsibility of the Certificate requester, vessel owner, or their representative to ensure that theprescribed work is carried out at the original location within the facility for which the Certificate was issued, unlessmovement is authorized within that facility by the Marine Chemist on the Certificate. If movement is authorized within thefacility, a reinspection shall be performed by a competent person. The Marine Chemist shall include on the Certificatethe nature of any tests to be performed after the move is complete and prior to beginning work. (6) (5) The calibration of all instruments used by a competent person to maintain a Marine Chemist’s Certificate shall beverified by either the competent person, another qualified individual, or metrology laboratory, before each day’s use byusing a known concentration of test gas in a manner consistent with the manufacturer’s recommendations. A recordshall be maintained for at least 3 months.(4) (6) Certificates not maintained according to the requirements in 4.6.2(1) through (5) shall be void.

Committee Statement: in accepting this proposal the Committee has shown the affected listeditems under the requirement.

_______________________________________________________________________________________________306-72 Log #12


Preparing Tank Vessels for Issuance of a Marine Chemist’s Certificate Involving Hot Work.There has been confusion on whether this section only applies to tank vessels or to all vessels.

Section 6.2 and 6.3 (all) refer you back to specific sections of Chapter 5 but do the other sections of chapter 5 apply tothese vessels? Adding the word Tank will clarify that this chapter only fully applies to tank vessels. If this is not the caseand this section applies to all vessels then sections 6.2 and 6.3 should be removed or clarified.

Committee did not want to limit this chapter to only tank vessels. There are requirements inthis chapter that are applicable to other vessel types such as offshore supply vessels that also carry bulk liquid cargo (e.g. methanol).





This proposed change will clarify the separation of responsibilities of vessel preparation by the vesselowner, operator or repairer from the conditions inspected for by the Marine Chemist needed for approval of thecommencement of hot work.

_______________________________________________________________________________________________306-74 Log #49


Revise text to read as follows:5.1 Where a Safe Condition Is to Be Obtained Entirely by Cleaning (

Since figure B.1 explicitly refers to a tank vessel, referring to it for this section means that all non-tankvessels are funnelled into "Vessels Other Than Tank Vessels" and thus written outside the rules for partial cleaning(such as the minimum 180°F flash point, or the absence of free-flowing liquids.) They are no longer subject to objectiveprocesses and rules, but (Paragraph 6.2) are left "as directed by the Marine Chemist." Therefore, it is better in thissection not to refer to the tank-ship drawing. Perhaps the Committee should design a sketch which does not referexplicitly to tank vessels. The existing figure is left over from a time when tank vessels were the overwhelming focus ofthe standard, and that is no longer the case.

The Committee's Action on 306-113 (Log #CP4) addresses the intent of this proposal.The Committee added an Annex A note to sections 5.1, 5.2, 5.3, 5.4, 5.5 and 5.8 to advise

users of the Standard that the requirements in Chapter 5 can be used for spaces other than cargo tanks such as fueltanks, landside spaces and hollow structures as covered by the Standard as appropriate. See the Committee's Actionon 306-113 (Log #CP4).

_______________________________________________________________________________________________306-75 Log #CP6


Revise text to read as follows:5.1.1 All cargo pumps, cargo lines, inert gas lines, crude oil wash lines, piped cargo fire-extinguishing lines, vaporcontrol and recovery lines and vent lines to the spaces involved in the scope of work shall have been flushed with water,blown with air or inerted.

The proposed change limits the requirement to piping systems for the subject space that are within thescope of the work.




Revise text to read as follows:5.1.2 Compartments concerned shall be cleaned so that the atmosphere in all cargo compartments and adjacent

spaces, including those diagonally adjacent to the cargo compartments, is in accordance with 4.3.1, 4.3.4, or 4.3.6, orwith both 4.3.1 and 4.3.4, or with both 4.3.1 and 4.3.6, as applicable.

4.3.1 is "Atmosphere Safe for Workers." But because the title of section 5.1.2 refers to a "Chemist'sCertificate Involving Hot Work", the paragraphs relating to Atmosphere Safe for Workers are out of place. Spaces,especially adjacent spaces, may have been cleaned and be perfectly safe for a hot work operation, even though theycontain, for instance, oxygen at 18%, or diesel at 50ppm, both of which would violate any reference to 4.3.1. In fact, anyunventilated adjacent diesel tank, even though cleaned, would probably violate any 4.3.1 reference.

If an adjacent space need be entered, 4.3.1 may be separately applied; but its safety as a space adjacent to hot workshould not be tied up with a few ppm contaminant or a slight oxygen deficiency. Also, please note there is no 4.3.1requirement for the hot work space itself. Why impose it on all the adjacent spaces?

The Committee rejected this proposal.In order for the the Marine Chemist and then subsequently the competent person to enter the

subject space and adjacent spaces the atmosphere of those spaces must meet the requirements of 4.3.1 of theStandard. An exception would be adjacent spaces that are inerted or are tanks pressed up with ballast water or fuel aspermitted by the Standard.

_______________________________________________________________________________________________306-77 Log #13


Add text to read as follows:Spaces adjacent to spaces cleaned to meet 5.1.3 (A) and (B) shall be permitted to be cleaned to meet the

requirements of 5.1.3(A) and (B) provided the residues or preservative coatings meet the requirements of 5.1.3(A).This addition will permit spaces adjacent to partially cleaned spaces to meet the same requirement.

This would apply if the work is on the common bulkhead.

Revised by the Committee as follows:Spaces adjacent to spaces When subject spaces are cleaned to meet 5.1.3(A) and 5.1.3(B) then, adjacent spaces shallbe permitted to be cleaned to meet the requirements of 5.1.3(A) and (B) provided the residues or preservative coatingsmeet the requirements of 5.1.3(A).

The Committee made editorial changes to the proposal to make it clear that the requirementapplies to subject spaces and adjacent spaces.




Revise text to read as follows:5.2.2.1 All valves to the inerted spaces shall be tagged and positioned in such a manner as to prevent or, by written

notice, restrict opening or operation.Valves are not always required to be closed during an inerting process and this will allow them to be

tagged out in any position.

The Committee modified the proposed text as follows:5.2.2.1 All valves to the inerted spaces shall be positioned in such a manner and tagged and positioned in such amanner as to prevent or, by written notice, restrict opening or operation.

The Committee switched position of positioned and tagged requirement since it is logical thatthe valves would be positioned before being tagged.

_______________________________________________________________________________________________306-79 Log #64


Add new text to read as follows:5.2.2.1, 5.3.2.1, 5.4.1.1 Requires "All valves to the inerted spaces shall be tagged and secured .... ", It is recommended

to add another section as follows:Any valve connecting the approved space to a common header to other spaces that have not been certified SAFE

FOR WORKERS and/or SAFE FOR HOT WORK, such as a vapor return line or inert gas line, shall be tagged andsecured in such a manner as to prevent or, by written notice. restrict opening or operation. Furthermore. the inert gasgenerator shall be tagged and secured in the same manner to prevent inadvertent operation of the inert gas generator.

There is no mention of isolating the space that has been deemed safe from the common vapor headeror IG line.

The Committee rejected this proposal.The Committee made a change to 5.2.2.1 that addresses valves to inerted spaces in its action

on 306-78 (Log #14).5.3.2..1 does not involve inerting spaces and therefore should be deleted - See the Committee's action on 306-84 (Log#17).The Committee created an Annex A note for 5.4.1.1 which states the valves to the inerted compartments referenced inthe requirement do not include those valves that are part of a fixed inert gas system used to in controlling theintroduction of the inerting medium into the subject space. See the Committee's Action on 306-114 (Log #CP5).




Delete text as follows:All vent lines (unless they are inerted) shall be inspected to ensure they are free of gas, vapor, and product.

This paragraph is superfluous. The vent lines have already "been flushed with water, blown with steamor air, or inerted," according to paragraph 5.2.2 above. (5.2.2 itself is a burdensome requirement with questionableapplication to isolated, minor repairs on tank vessels.)

Also, the terms "gas" and "vapor" are redundant, and only visual inspections will detect "product." It is extremelyunlikely that a chemist would perform visual inspections of "all vent lines" before allowing workers to, say, repair afracture in a tank barge's forward rake. It seems this has so many deficiencies that it is best deleted.

These same comments apply to the language of which is identical to

The Committee rejected the proposal.The proposed change goes against common practice. Vent lines on tank vessels such as

those associated with fixed inert gas systems and vapor recovery systems may contain vapor and/or product andtherefore need to be inspected by the Marine Chemist as appropriate and consistent with the scope of work.

_______________________________________________________________________________________________306-81 Log #15


Revise text to read as follows:Compartments of spaces on which external repairs or alterations are to be undertaken on the external boundaries

(deck or shell) shall be permitted to be inerted by gas instead of being cleaned as described in...This section appears to prohibit the use of water as an inerting medium in accordance with section

4.3.8. Water is a permitted inerting medium in accordance with 4.3.8. Removal of the words by gas will allow all inertingpractices.

_______________________________________________________________________________________________306-82 Log #84


Revise text to read as follows:5.3.2 All Cargo pumps and cargo lines, inert gas lines, and crude oil wash lines to the spaces involved in the scope of

work shall have been flushed with water, blown with steam or air, or inerted.Current wording requires all lines on the vessel to be cleaned/inerted. This is not necessary for limited

work. This additional wording corrects this issue.

The Committee modified the proposed text as follows:5.3.2 All Cargo pumps and cargo lines, inert gas lines, and crude oil wash lines to the spaces involved in the scope ofwork shall have been flushed with water, or blown with steam or air, or inerted.

The Committee also deleted references to the inert gas system since this section does notapply to inerting tanks.




Revise text to read as follows:5.3.2.1 All valves to the inerted spaces shall be tagged and positioned in such a manner as to prevent or, by written

notice, restrict opening or operation.Section 5.3.2.1 is under the 5.3 heading for obtaining a safe condition by cleaning and securing. This

section does not detail inerting and the inerting description should be deleted as described in another proposal.However, if the committee chooses to keep this section it should be re-worded. Requiring valves to be closed may notbe appropriate in all cases; the new wording allows valves to be tagged in any position.

The Committee modified the proposed text as follows:5.2.2.1 All valves to the inerted spaces shall be positioned in such a manner and tagged and positioned in such amanner as to prevent or, by written notice, restrict opening or operation.

The Committee switched position of positioned and tagged requirement since it is logical thatthe valves would be positioned before being tagged.

_______________________________________________________________________________________________306-84 Log #17


Delete the following text:5.2.2.1 All valves to the inerted spaces shall be tagged and secured in such a manner as to prevent or, by written

notice, restrict opening or operation.Section 5.3.2.1 is under the 5.3 heading for obtaining a safe condition by cleaning and securing. This

section does not detail inerting and the inerting description should be deleted.

_______________________________________________________________________________________________306-85 Log #85


Revise text to read as follows:5.3.2.2 All Vent lines (unless they are inerted) to the spaces involved in the scope of work shall be inspected to ensure

they are free of gas, vapor, and product.Current wording requires all lines on the vessel to be cleaned/inerted. This is not necessary for limited

work. This additional wording corrects this issue.

The Committee modified the text as follows:5.3.2.2 All Vent lines unless they are (inerted) to the spaces involved in the scope of work shall be inspected to ensurethey are free of gas, vapor, and product.

The Committee made an editorial change to the proposed text by removing the parentheses.




Revise text to read as follows:5.4.1 All Cargo pumps and cargo lines, inert gas lines, and crude oil wash lines to the spaces involved in the scope of

work shall have been flushed with water, blown with steam or air, or inerted.Current wording requires all lines on the vessel to be cleaned/inerted. This is not necessary for limited

work. This new wording corrects this issue.

_______________________________________________________________________________________________306-87 Log #87


Revise text to read as follows:5.4.1.2 All Vent lines (unless they are inerted) to the spaces involved in the scope of work shall be inspected to ensure

they are free of gas, vapor, and product.Current wording requires all lines on the vessel to be cleaned/inerted. This is not necessary for limited

work. This new wording corrects this issue.

_______________________________________________________________________________________________306-88 Log #18


Revise text to read as follows:5.8 Vessel Fuel Oil Tanks. No hot work shall be permitted within 25 feet any vessel's fuel oil tanks whose contents

have a flashpoint of less than 150°F unless the work has been authorized by the Marine Chemist.This change reflects the OSHA requirement under 29CFR Section 1915.14(iv). If adjacent hot work

does not meet this requirement a competent person may approve it. The new wording clarifies this requirement. This isalso a requirement under USGC regulations.

The Committee rejected this proposal.The Committee decided that this issue is better addressed as an Annex A note. The content of

this proposal is better addressed in 306-89 (Log #88) which was authored by the same submitter. See the Committee'saction on 306-89 (Log #88).




Revise text to read as follows:5.8* Vessel Fuel Oil Tanks. No hot work shall be permitted immediately adjacent to any vessel's fuel oil tanks unless

the work has been authorized by the Marine Chemist.A.5.8 Vessel or other Fuel Oil Tanks. On dry cargo vessels, miscellaneous vessels, passenger vessels, and shipyard

employment land-side operations no hot work shall be permitted adjacent to any vessel's or other fuel oil tanks unlessthe work has been authorized by the Marine Chemist. When the adjacent space contains flammableliquids with a flash point at or below 150 degrees-Fahrenheit, or flammable gasses and the distance between suchspaces and the hot work is greater than 25 feet, then a competent person can visually inspect and test the space (if thehot work is 25 feet or closer to the adjacent space containing such flammables, then a Marine Chemist must certify thehot work.)

Adding information in the annex clarifies the intention of this statement. The annex wording is a directquote from the OSHA compliance directive. (CPL-02-01-051) with clarification.

_______________________________________________________________________________________________306-90 Log #19


Revise text to read as follows:6.2 Vessels Other Than Tank Vessels.On any vessels that have carried flammable or combustible liquid in bulk as fuel or cargo, or that have carried cargoes

that can produce hazardous atmospheres (including, but not limited to, those caused by decomposition or reaction withoxygen from the atmosphere), no repairs involving hot work shall be made in or on the external boundaries (shell, tanktop, or deck) of cargo tanks, fuel tanks, oil pipelines, heating coils or hollow structures, and machinery spaces, unlesssuch compartments and pipelines, as deemed necessary by the Marine Chemist, have been inerted or cleaned to meetthe appropriate designation requirements of 4.3.4, or 4.3.6 or 4.3.8 and for spaces that will be entered 4.3.1. Repairsand alterations shall not be undertaken until a Certificate is obtained.

If a vessel carries a flammable or combustible liquid in bulk as cargo it would be a tank vessel and thissection would not apply. (suggestion is to delete, or cargo) Additionally, it should be permitted that a space can meet therequirements of 4.3.6 to safely carry out hot work. Also, if a space must be entered it must meet the requirements of4.3.1. With the current wording it would appear to allow entry with an oxygen concentration at any level below 22percent.

Revise text to read as follows:6.2 Vessels Other Than Tank Vessels.On any vessels that have carried flammable or combustible liquid in bulk as fuel or cargo, or that have carried cargoesthat can produce hazardous atmospheres (including, but not limited to, those caused by decomposition or reaction withoxygen from the atmosphere), no repairs involving hot work shall be made in or on the external boundaries (shell, tanktop, or deck) of cargo tanks, fuel tanks, oil pipelines, heating coils or hollow structures, and machinery spaces, unlesssuch compartments and pipelines, as deemed necessary by the Marine Chemist, have been inerted or cleaned to meetthe appropriate designation requirements of 4.3.4, or 4.3.6 or 4.3.8 and for spaces that will be entered 4.3.1. Repairsand alterations shall not be undertaken until a Certificate is obtained.

There are vessels such as offshore supply vessels that carry combustible and flammableliquids in bulk as cargo not fuel and these vessels are not tank vessels therefore the Committee left the reference tocargo in the requirement.




Revise text to read as follows:6.3.2 All ammunition shall be removed from any space requiring hot work. Adjacent spaces containing ammunition

shall be treated in accordance with the Marine Chemist's requirements. Adjacent spaces containing flammable orcombustible liquids shall be treated in accordance with the Marine Chemist’s directions.

If you are doing hot work in a passage way 15 feet from a fuel tank, the existing paragraph requiresthe fuel tank be cleaned and made Safe for Hot Work. This proposal would allow it to be treated in accordance with theChemist’s instructions.

The Committee modified the text as follows:6.3.2 All ammunition shall be removed from any space requiring hot work. Adjacent spaces containing ammunition shallbe treated in accordance with the Marine Chemist's requirements. Adjacent spaces containing flammable or combustibleliquids shall be treated in accordance with the Marine Chemist’s directions requirements and acknowledged on theCertificate.

The Committee deleted "directions" and replaced it with text that is consistent with therequirement in 4.3.4(5) of the standard.

_______________________________________________________________________________________________306-92 Log #21


Revise text to read as follows:6.3.2 All ammunition shall be removed from any space requiring hot work. Adjacent spaces containing ammunition

shall be treated in accordance with the Marine Chemist's requirements. Adjacent spaces containing flammable orcombustible liquids shall be treated in accordance with 4.3.4 or secured.

If you are doing hot work in a passage way 15 feet from a fuel tank, this paragraph requires the fueltank be cleaned and made Safe for Hot Work.

The Committee rejected this proposal.The Committee's action on a similar proposal from the same submitter for this requirement

make this proposal obsolete. See the Committee's Action on 306-91 (Log #20).




Revise text to read as follows:6.3.4 All tanks, confined spaces, and machinery compartments in which internal repairs or alterations are to be

undertaken shall be cleaned to comply with the requirements of either 4.3.1 or 4.3.3. For repair or alteration involvinghot work, these spaces shall meet the requirements of 4.3.4 or 4.3.6 or 5.1.3 and adjacent compartments shall becleaned to meet the requirements of 4.3.4 or 4.3.6 or 5.1.3 or shall be permitted to be inerted to meet the requirementsof 4.3.8. The adjacent spaces may also be permitted to be secured in accordance with the Marine Chemist’sinstructions.

5.1.3, 5.8,Current wording requires an adjacent space to be cleaner than the hot work space, by adding 4.3.6 it

permits the same safety designation as the hot work space. Also, the sentence added permits adjacent spaces to besecured. In cases where hot work is done in an engine room with adjacent fuel tanks the tanks can be secured and notcleaned. With this inclusion the exception is no longer necessary.

The Committee modified the text as follows:6.3.4 All tanks, confined spaces, and machinery compartments in which internal repairs or alterations are to beundertaken shall be cleaned to comply with the requirements of either 4.3.1 or 4.3.3. For repair or alteration involvinghot work, these spaces shall meet the requirements of 4.3.4 or 4.3.6 or 5.1.3 and adjacent compartments shall becleaned to meet the requirements of 4.3.4 or 4.3.6 or 5.1.3 or shall be permitted to be inerted to meet the requirementsof 4.3.8. The adjacent spaces may shall also be permitted to be secured in accordance with the Marine Chemist’sinstructions. requirements and acknowledged on the Certificate.

5.1.3, 5.8,The Marine Chemist needs to include a statement concerning the requirements for securing the

adjacent space on the Certificate. The Committee included language consistent with 4.3.4(5) of the Standard.

_______________________________________________________________________________________________306-94 Log #23


Revise text to read as follows:6.3.5 All tanks, confined spaces, and machinery compartments in which external repairs or alterations are to be

undertaken shall be either cleaned to comply with the requirements of 4.3.4 or 4.3.6, or shall be inerted to comply withthe requirements of 4.3.8. All adjacent compartments shall be cleaned to meet the requirements of 4.3.4 or 4.3.6 or5.1.3 or shall be permitted to be inerted to meet the requirements of 4.3.8. The adjacent spaces may also be permittedto be secured in accordance with the Marine Chemist’s instructions.

5.1.3, 5.8,Current wording requires an adjacent space to be cleaner than the hot work space, by adding 4.3.6 it

permits the same safety designation as the hot work space. Also, the sentence added permits adjacent spaces to besecured when cleaning in not necessary. Also, with this wording the exception is no longer needed.

The Committee modified the text as follows:6.3.5 All tanks, confined spaces, and machinery compartments in which external repairs or alterations are to beundertaken shall be either cleaned to comply with the requirements of 4.3.4 or 4.3.6, or shall be inerted to comply withthe requirements of 4.3.8. All adjacent compartments shall be cleaned to meet the requirements of 4.3.4 or 4.3.6 or5.1.3 or shall be permitted to be inerted to meet the requirements of 4.3.8.The adjacent spaces may shall also be permitted to be secured in accordance with the Marine Chemist’s instructions.requirements and acknowledged on the Certificate.

5.1.3, 5.8,The Marine Chemist needs to include a statement concerning the requirements for securing the

adjacent space on the Certificate. The Committee included language consistent with 4.3.4(5) of the Standard.




Revise text to read as follows:6.4 - A tank ship vessel in lay-up shall be treated in accordance with Section 6.1 and NFPA 312

Intended to ensure consistency with definition 3.3.20.4 and hazards associated with all tank vessels inlay-up, not just tank ships.

_______________________________________________________________________________________________306-96 Log #CP7


Delete the entire Chapter 7, Additional Requirements for Bulk Chemical Cargo Tanks, except thesecond sentence of 7.3.2 which is moved to Chapter 5 (see 306- (Log #CP8)); and hold Chapter 7 as a "reserved" in thestandard for future use except, if 306- (Log #CP9) is approved, then Chapter 7 will become a new chapter for StandardSafety Designations.

Chapter 7 provides no unique requirements for tank vessels that carry chemicals in bulk andunnecessary except for the requirement in 7.3.2 which is proposed to be moved to Chapter 5.

_______________________________________________________________________________________________306-97 Log #24


Revise text to read as follows:7.1.1 This section describes the conditions required before repairs can be made in spaces that have carried or have

been exposed to chemicals in bulk. The remaining spaces in the vessel shall comply with the applicable provisions inChapter 6. This section does not apply to petroleum products such as diesel, lubricating, bunker or crude oil.

The 306 definition of chemical would include many petroleum products which have a toxicity level. Thiswould clarify that this section does not apply to these products carried as cargo.

The Committee rejected this proposal.It is the opinion of the Committee that Chapter 7 of the standard has no unique requirements

for chemical tank ships. The Committee therefore created a proposal to delete the Chapter. See the Committee'sAction on 306-96 (Log #CP7).




Delete the following text:7.2.3 Results of any chemical hazard tests shall be permitted to be noted on the Certificate.

This section is not needed. Any test result or cautions can be placed on the certificate in accordancewith section 4.4.1.



_______________________________________________________________________________________________306-99 Log #CP8


Move the text from 7.3.2 to Chapter 5 as new requirement 5.2.4 ( and renumber Section 5.2thereafter)5.2.4 7.3.2 All pipelines, including heating coils, fire-extinguishing systems, and vents, together with the cargo pumpsand cargo lines serving the chemical-carrying spaces, shall be initially dealt with to the satisfaction of the MarineChemist. Care shall be exercised in the selection of methods and materials used for cleaning or inerting to avoidnoncompatibility with previous cargoes.5.2.5 5.2.4 Compartments or spaces in which internal repairs or alterations are to be undertaken shall be cleaned tocomply with the requirements of Section 5.3, and all other spaces (with the exception of tanks described in 5.1.3) shallbe inerted in accordance with the requirements of 4.3.8 or 4.3.9, as applicable. 5.2.6 5.2.5 Compartments or spaces on which external repairs or alterations are to be undertaken on the externalboundaries (deck or shell) shall be permitted to be inerted by gas instead of being cleaned as described in Section 5.2,and all other spaces (with the exception of tanks described in 5.1.3) shall be inerted in accordance with therequirements of 4.3.8 or 4.3.9, as applicable.

The Committee has preserved the requirement concerning special cargoes and inerting media fromChapter 7.




Revise text to read as follows:7.3.3 Compartments that have carried chemicals in bulk and that are to be cleaned shall be cleaned so that the

atmosphere in those compartments is in accordance with 4.3.1 and 4.3.4 or 4.3.6 as applicable. Adjacent spaces shallbe treated in accordance with 4.3.4 or 4.3.6 as applicable.

The compartment is cleaned to meet applicable sections of 306. This new wording clarifies theintention of the document to have the compartment to meet the full requirements of each section of 306. This wordingbetter states the intention of the section. Additionally, this new wording addresses adjacent spaces. (depending on ifanother submitted proposal is accepted then it may be possible to specify what sections of 4.3.4 or 4.3.6 apply toadjacent spaces).



_______________________________________________________________________________________________306-101 Log #27


Revise text to read as follows:7.3.4 The residues in the compartments concerned shall be such that the conditions of 4.3.1 and 4.3.4 or 4.3.6 as

applicable, will be met. Adjacent spaces shall be treated in accordance with 4.3.4 or 4.3.6 sections as applicable.The new wording permits the SFLHW designation to be used and addresses adjacent spaces next to

the compartment undergoing hot work.



_______________________________________________________________________________________________306-102 Log #60


Add new text to read as follows:Confined and enclosed spaces unaffected by work being conducted in another space, to

which they are in contact, are adjacent spaces. Pipelines unaffected by work in spaces through which they pass are notadjacent spaces.

There are some who consider pipelines as meeting the literal definition of an adjacent space. Addingthis explanatory material to Annex A helps corrects this.

The Committee rejected this proposal.The content of this proposal is incorporated in the Committee's Action in 306-12 (Log #73).




Add text to read as follows:...Furthermore, a "Requester" can be either a "Host Employer" or a "Contract Employer." A Host Employer and a

Contract Employer are two separate entities, who have a relationship to one another via a formal contract (as perdefinition). What additionally distinguishes one from the other is the Host Employer's ability to "coordinate" all work intheir shipyard or workplace with other employers. The Contract Employer does not have this ability. Thus, whenexercised (not all shipyards want the associated liability), a Host Employer is in a better position to maintain a MCCertificate for themselves and all other employers, A Contract Employer can only coordinate work and maintain a MCCertificate for their own employees. They have limited authority and/or understanding to "tell" other contractors(including the Host Employer) what to do. Full knowledge of the scope of everyone's work, authority to coordinate thework packages of all(sub)contractors, and maintenance of the Certificate for all employers is in the Host Employer'sdomain.

The "Certificate requester" is responsible for "understanding [4.6.1(A)] and "signing [(B)] theCertificate. The "Certificate requester" is also responsible for "providing a complete statement of the scope of work" tothe MC and "maintaining the Certificate" [(D)]. The Host Employer can be "responsible for maintaining the Certificate forall contract employers [(D)], but not the other way around. The Host Employer "is in charge of coordinating work or whohires other employers to perform work at a multi-employer workplace" [3.3.11], but not the Contract Employer. Inaddition, a "subcontractor" can be a Contract Employer who is "under contract to the host employer or to anotheremployer under contract to the host employer" [3.3.7]. Other times, a subcontractor has no direct, or even indirect,contractual relationship with the Host Employer. They are simply working in the Host Employer's shipyard due toavailability, etc. In any event, whether contractually related or not, it is doubtful all subcontractors will know the complete"scope of work" that the Host Employer and other Contract Employers are involved. Thus, it is not feasible for ContractEmployers to adequately "maintain their Certificate" for other employers when they do not completely understand thenature and scope of the work of others.

The proposal is confusing and doesn't add to the definition or enhance understanding of thedefinition.




Add new text to read as follows:Referring to the illustrations found in Annex B Examples of Safe Conditions, hot work (i.e. the

circled “W”) in the middle of Tank 5 Center would necessitate this tank be certified Safe for Hot Work. In this example,Tank 5 Center is the "subject space." Furthermore, there are eight "adjacent spaces" to Tank 5 Center (i.e, 4P, 4C, 4S,5P, 5S, 6P, 6C, and 6S). These "adjacent spaces" are not the same as the "subject space" affected by hot work. Inanother example, if hot work in Tank 5 Center is against its forward bulkhead (i.e. the same steel plate that comprisesthe after bulkhead of Tank 4 Center), then there will be two "subject spaces" affected by hot work (i.e. 4C and 5C, eventhough the welder may be still physically located in Tank 5 Center). Both tanks, then, will have to be certified Safe forHot Work. Also, there is now a total of ten "adjacent spaces" to the hot work being conducted on the common bulkheadbetween Tanks 4 Center and 5 Center (i.e. 3P, 3C, 3S, 4P, 4S, 5P, 5S, 6P, 6C, and 6S).

The statements found in Annex A (A.4.4.3) and the illustrations found on the same page in Annex B(Examples of Safe Conditions), when considered together, have promoted confusion regarding the understanding of"subject spaces" vs. "adjacent spaces." First, since an Annex "is not a part of the requirements of this NFPA document",the two clauses "If there is no additional statement regarding the scope of work on the Certificate" and "authorized workor prohibited work should be listed on the Certificate" are not mandatory. Second, when the middle clause of A.4.4.3,"any hot work or cold work can proceed as indicated by the standard safety designation," is further considered, somehave interpreted this to mean that any hot work in Tank 5 Center can commence (including hot work against any of thefour bulkheads of 5C) provided Tank 5 Center is designated Safe for Hot Work and there are no additional statements,etc. to the contrary (the validity of this interpretation is not the focus of this Substantiation). Third, this helps explain whysome workers have welded against bulkheads, overheads, and decks when the opposite side was never inspected.Their only concern was whether the space in which they were physically located was certified Safe for Hot Work. Thisought not to be the case, and this added "explanatory material" will give a visual example that cannot be presented inthe body of the Standard's requirements.

The Committee rejected the proposal.The term subject space is any space that is not an adjacent space. The addition of a definition

of subject space or an Annex A note doesn't add any additional clarification to the standard and may create moreconfusion.

_______________________________________________________________________________________________306-105 Log #99



A.3.3.20 Vessel. Offshore drilling, production and/or storage vessels can be included in this definition. In addition,hollow vessels throughout the shipyard, including tank trucks, railroad tank cars, powerplant fuel tanks, storage tanks,dip and laundry tanks, vaults, tunnels, etc., also are considered vessels.

Since 1994, the scope of 29CFR1915 has included such shipyard hollow vessels other than ships,barges, etc., including tank trucks, railroad tank cars, powerplant fuel tanks, storage tanks, dip and laundry tanks, vaults,tunnels etc. in its scope. The proposed change makes it clear to the reader that these spaces are also included as partof the definition of vessel in this standard.

The Committee moved text from this proposal into 1.1.6 of the Standard.The change made to the requirement in 1.1.6 of the standard (306- (Log #104)) addresses

hollow structures that are not part of marine vessels within the shipyard. The Committee chose to keep the term"vessel" reserved for marine vessels as defined in 3.3.20 rather than confuse it with the term hollow structures in 3.3.10of the standard. The submitter's intent was incorporated in the Committee's Action in 306-4 (Log #104).




CommitteeRevise text to read as follows:Grinding, drilling, abrasive blasting, or similar spark-producing operations are considered hot work

unless deemed otherwise by a Marine Chemist and stated in writing on a Marine Chemist's Certificates should alwaysconsidered hot work when conducted in the presence of accumulations of flammable gases, flammable or combustibleliquids, their vapors or accumulations of other common combustible materials.

The proposed language sufficiently clarifies the meaning of hot work conducted in the presence ofreadily ignitable materials near applied sources of ignition, making the current language unnecessary.

From the Committee's Action on 306- (Log #102). The asterisk was added to the listed item C.(C)* (D) Grinding, drilling, abrasive blasting, the activation of non-intrinsically or non-explosion-proof equipment orsimilar operations in the presence of or against accumulations of readily combustible materials or flammable orcombustible liquids or their vapors when the atmosphere exceeds 10% LEL.

Grinding, drilling, abrasive blasting, or similar spark-producing operations are considered hot workunless deemed otherwise by a Marine Chemist and stated in writing on a Marine Chemist's Certificates should alwaysconsidered hot work when conducted in the presence of accumulations of flammable gases, flammable or combustibleliquids, their vapors or accumulations of other common combustible materials.

Based upon the Committee's Action on 306-22 (Log #102) it was determined that the bestplacement for the proposed text was in listed item (C).



_______________________________________________________________________________________________Thomas Beacham, Marine Chemist & Environmental Consultants, Inc.

Delete the following text:When determining “permissible concentrations” according to 4.3.1(3), the Marine Chemist should use the lower value

of the published ACHIH’s Threshold Limit Values (TLVs) or OSHA Permissible Exposure Limit (PEL) as the primarysource for compliance with this requirement. Only in the absence of a published TLV and PEL for a substance shouldthe Marine Chemist refer to Manufacturer's MSDSs to determine if any alternate value exists.

The responsibility of determining worker exposure (PELs) in the maritime industry is the responsibilityof OSHA. Requiring the Marine Chemist to use a “non regulation”, such as those published by ACGIH, puts the MarineChemist in a position of imposing a non-OSHA requirement on industry. This is the case with The ACHIH TLVs fordiesel, JP-5 and now the Hydrogen sulfide limit.

By accepting this proposal the Committee will assure the standard continues to be in compliance with 1.4 which states“Nothing in this standard shall be construed as superseding existing requirements of any governmental or localauthority.”

The Committee revised the Annex note in its action for 306- (Log #37) as follows:A.4.3.1(3) OSHA Permissible Exposure Limit Values (PELs) are found Permissible concentrations can be found in thelatest version of Threshold Limit Values for Chemical Substances and Physical Agents, published by the AmericanConference of Governmental Industrial Hygienists, in Subpart Z of 29 CFR 1915.1000,. “Permissible Exposure LimitValue,” or the value listed in the Manufacturers’ Safety Data Sheet (MSDS).In addition to or in the absence of an When determining "permissible concentrations" according to 4.3.1(3), the MarineChemist should use the lower value of the published ACGIH’s Threshold Limit Values (TLVs) or OSHA PermissibleExposure Limit (PEL) as the primary source for compliance with this requirement. Only in the absence of a publishedTLV and PEL for a substance should the Marine Chemist should refer to the Threshold Limit Values for ChemicalSubstances and Physical Agents, published by the American Conference of Governmental Industrial Hygienists,National Institute of Occupational Safety and Health (NIOSH) Recommended Exposure Limits (REL's), or MaterialSafety Data Sheets (MSDSs) to determine if any alternate value exists.

As stated in its action on 306-40 (Log #37) the Committee believes that is also necessary toprovide guidance to the Marine Chemist regarding best practice when making such assessments particularly in theabsence of an OSHA PEL or in situations where a PEL may not provide sufficient protection. Therefore the Committeerevised the Annex note (A.4.3.1(3)) for this requirement and included that change with its action on this proposal. Therevised Annex note directs the Marine Chemist to other reference documents for occupational exposure limits whenappropriate.




Revise text to read as follows:When determining "permissible concentrations" according to 4.3.1(3), the Marine Chemist should use the lower value

of the published ACGIH's Threshold Limit Values (TLVs) or OSHA's Permissible Exposure Limit (PEL) as the primarysource for compliance with this requirement. Only in the absence of published TLV and PEL for a substance should theMarine Chemist refer to the ACGIH's Threshold Limit Valves (TLVs) or Manufacturer's MSDSs to determine if anyalternate value exists.

Currently Marine Chemist must use the lowest published value (PEL or TLV). This is a problembecause ACGIH's TLVs are not concensus standards and not enforcable according to OSHA's standards. Furthermore,Section 1.4 says NFPA 306 "shall be construed as superseding...", this revised wording keeps the standard incompliance with OSHA. Also manufacturers of portable instruments are having difficulties making instruments to meetarbitrary values.

See the Committee's Action on 306-40 (Log #37).As stated in its action on 306-40 (Log #37) the Committee believes that is also necessary to

provide guidance to the Marine Chemist regarding best practice when making such assessments particularly in theabsence of an OSHA PEL or in situations where a PEL may not provide sufficient protection. Therefore the Committeerevised the Annex note (A.4.3.1(3)) for this requirement and included that change with its action on this proposal. Therevised Annex note directs the Marine Chemist to other reference documents for occupational exposure limits whenappropriate.

_______________________________________________________________________________________________306-109 Log #108


Please add the following text to read:The improper introduction of an inerting gas can generate sufficient static electricity for ignition. Refer to the current

NFPA 69, Standard on Explosion Prevention Systems for level of oxygen to support combustion and NFPA 77,Recommended Practice on Static Electricity.

Currently, there are no references listed in NFPA-306 for guidance on the control of static electricity,especially during inerting. NFPA-77, Recommended Practice on Static Electricity fills this void adequately.

The Committee modified the text as follows:The improper introduction of an inerting gas can generate sufficient static electricity for ignition. Refer to the currentNFPA 69, Standard on Explosion Prevention Systems for level of oxygen to support combustion and NFPA 77,Recommended Practice on Static Electricity and industry standards such as

(ISGOTT) and (Chemicals). The Committee added other industry reference sources.




Revise text to read as follows:If there is no additional statement regarding the scope of the work on the Certificate, any hot work or cold work can

proceed as indicated by the standard safety designation, with the exception of all lines, vents, heating coils, valves, andsimilar enclosed appurtenances, as well as all adjacent spaces, which shall be considered NOT SAFE FOR HOTWORK unless otherwise specifically designated. If all types of work cannot be conducted safely under a standard safetydesignation, then the authorized work or prohibited work should be listed on the Certificate.

The revised (underlined) wording is almost verbatim with a portion of the QUALIFICATIONS section onthe Certificate. However, 1) A.4.4.3 does not mention this qualification, and there is a perception that these areas areallowable; 2) the QUALIFICATIONS section is standard wording, instead of an "additional statement," and the literalimplication/expectation is additional authorized or prohibited writing in the body of the Certificate; and 3) few people readthe "small print" of any document and having this information, even in the Annex, helps shed additional light on certainareas in which hot work should not be conducted. Unchanged, A.4.4.3 conflicts with this portion of theQUALIFICATIONS section on the Certificate, and creates confusion.

The Committee rejected this proposal.The Committee addressed the content of this proposal in its action in 306-12 (Log #73).

_______________________________________________________________________________________________306-111 Log #89


Delete all of A.4.4.3A.4.4.3 If there is no additional statement regarding the scope of the work on the certificate, any hot work or cold work

can proceed as indicated by the standard safety designation. If all types of work cannot be conducted safely under astandard safety designation, then the authorized work or prohibited work should be listed on the Certificate

Due to additions of SAFE FOR LIMITED HOT WORK and other revisions to the standard thisstatement is no longer necessary. .





The Marine Chemist can recognize a facility's procedures and infrastructure used to minimize risk andhazards to people and equipment through engineering controls supplemented by administrative controls. As anexample, mechanical exhaust ventilation for the space has been installed and will operate continuously. OSHA, in 29CFR 1915.13, notes that the frequency of retesting the atmospheric conditions of a space should be a function ofseveral factors, including temperature, work in the tank, period of time elapsed, unattended tanks, work breaks, orballasting. This section allows the rotation of work away from spaces that have been certified and worked in or on, butwhere work has been suspended due to schedule requirements. It requires the shipyard competent person (if not theMarine Chemist) to reinspect and establish that safe conditions remain in certified spaces and applicable adjacentspaces before work resumes in or on such spaces. Vessel or shipyard management must always be aware however.that any suspension of work in or on a confined or enclosed space constitutes a time for significant potentialaccumulation of hazards. and careful and documented reinspection before reentry and resumption of work is a strictnecessity and requirement.

This language clarifies current ambiguous language currently in section 4.6.2(3).

The Committee modified the text as follows:The Marine Chemist can recognize a facility's procedures and infrastructure used to minimize risk and

hazards to people and equipment through engineering controls supplemented by administrative controls. As anexample, mechanical exhaust ventilation for the space has been installed and will operate continuously. OSHA, in 29CFR 1915.13, notes that the frequency of retesting the atmospheric conditions of a space should be a function ofseveral factors, including temperature, work in the tank, period of time elapsed, unattended tanks, work breaks, orballasting. This section allows the rotation of work away from spaces that have been certified and worked in or on, butwhere work has been suspended due to schedule requirements. It requires the shipyard competent person (if not theMarine Chemist) to reinspect and establish that safe conditions remain in certified spaces and applicable adjacentspaces before work resumes in or on such spaces. Vessel or shipyard management must always be aware however.that any suspension of work in or on a confined or enclosed space constitutes a time for significant potentialaccumulation of hazards. and careful and documented reinspection before reentry and resumption of work is a strictnecessity and requirement.The intent of this wording is to clarify that spaces listed on the Marine Chemist Certificate do not need to be tested bythe competent person unless work is being done on or in a space. For example, spaces on a certificate do not need tobe tested and inspected on a weekend if no work or entry is taking place. However, nothing shall prevent a competentperson from testing more frequently than the minimum.

The Committee added the accepted Annex A text from Log 83 to the end of the proposed newtext by this submitter.




Add an asterisk to the following sections of Chapter 5:5.1*5.2*5.3*5.4*5.5*5.8*Add the following to Annex A:A.5.1 The requirements of this section can be used in preparing other spaces such as fuel tanks, landside spaces orhollow structures covered by the standard as appropriate.A.5.2 The requirements of this section can be used in preparing other spaces such as fuel tanks, landside spaces orhollow structures covered by the standard as appropriate.A.5.3 The requirements of this section can be used in preparing other spaces such as fuel tanks, landside spaces orhollow structures covered by the standard as appropriate.A.5.4 The requirements of this section can be used in preparing other spaces such as fuel tanks, landside spaces orhollow structures covered by the standard as appropriate.A.5.5 The requirements of this section can be used in preparing other spaces such as fuel tanks, landside spaces orhollow structures covered by the standard as appropriate.A.5.8 The requirements of this section can be used in preparing other spaces such as fuel tanks, landside spaces orhollow structures covered by the standard as appropriate.

The requirements found in Chapter 5 can be used for preparing other types of vessels as covered bythe Standard (such as fuel tanks, landside structures and hollow structures) for the issuance of a Marine Chemist'sCertificate for hot work.

_______________________________________________________________________________________________306-114 Log #CP5


Add new Annex A note A.5.4.1.1 to read as follows:5.4.1.1*A.5.4.1.1 The valves to the inerted compartments referenced in this requirement do not include those valves that arepart of a fixed inert gas system used to in controlling the introduction of the inerting medium into the subject space.During the inerting process the valves on the inert gas line to a subject space are used by qualified individuals toregulate inert gas flow and/or pressure in the inerted space.

The Annex note recognizes the need for qualified individuals to be able to manage inert gas deliveredthrough fixed inert gas systems that is introduced into a compartment to maintain a safe condition.




Update Figure B.1, Illustrations of Safe Conditions, in Annex B to depict a modern double-hulledtank ship with an aft accommodation block.Change the text in Annex B as follows:Annex B Examples of Safe Conditions

The illustrations of a double-hulled tank ship in Figure B.1, parts (a) through (f), are examples of safe conditionsdiscussed in Chapter 5 of this standard. In this example hot work is planned for the deck area above the 4-starboardcargo tank. The conditions shown in the drawings correspond to Sections 5.1 through 5.4 of this standard. Although thesingle plane drawings show horizontal separations only, vertical compartmentation should be similarly treated.

(a) Side and cross-section view

(b) Section 5.1: Safe condition obtained by cleaning all cargo tanks, slop tanks and wing and double-bottomballast tanks

(c) Section 5.2: Safe condition obtained by cleaning the subject space and inerting the other cargo tanks and sloptanks. All wing and double-bottom ballast tanks are filled with water.

(d) Section 5.2: Safe condition obtained by inerting the subject space and other cargo tanks and slop tanks. Allwing and double-bottom ballast tanks are filled with water.

(e) Section 5.3: Safe condition obtained entirely by cleaning the subject space and adjacent cargo tanks andsecuring all other cargo tanks. All wing and double-bottom ballast tanks are filled with water.

(f) Section 5.4: Safe condition obtained by cleaning the subject space, inerting the adjacent cargo tanks andsecuring all other cargo tanks and slop tanks. All wing and double-bottom ballast tanks are filled with water.

The drawing in Annex B of the standard appears to be a drawing of a T-2 class tank ship, last built in1945. The drawing is also a single skin tanker. Single skin tank ships are obsolete, replaced by double-hulled tankvessels.


Annex B Examples of Safe Conditions This annex is not a part of the requirements of this NFPA document but is included for informational purposes only.

B.1 The illustrations of a double‐hulled tank ship in Figure B.1, parts (a) through (f), are examples of safe conditions discussed in Chapter 5 of this standard. In this example hot work is planned for the deck area above the 4‐starboard cargo tank. The conditions shown in the drawings correspond to Sections 5.1 through 5.4 of this standard. Although the single plane drawings show horizontal separations only, vertical compartmentation should be similarly treated.

(a) Side and cross‐section view

(b) Section 5.1: Safe condition obtained by cleaning all cargo tanks, slop tanks and wing and

double‐bottom ballast tanks

(c) Section 5.2: Safe condition obtained by cleaning the subject space and inerting the other

cargo tanks and slop tanks. All wing and double‐bottom ballast tanks are filled with

water.

(d) Section 5.2: Safe condition obtained by inerting the subject space and other cargo tanks

and slop tanks. All wing and double‐bottom ballast tanks are filled with water.

(e) Section 5.3: Safe condition obtained entirely by cleaning the subject space and adjacent

cargo tanks and securing all other cargo tanks. All wing and double‐bottom ballast tanks

are filled with water.

(f) Section 5.4: Safe condition obtained by cleaning the subject space, inerting the adjacent

cargo tanks and securing all other cargo tanks and slop tanks. All wing and double‐

bottom ballast tanks are filled with water.

Key:



Add new text to read as follows:Please add examples of both, the current 8.5x14” NFPA Marine Chemist paper Certificate and the new NFPA EMCC

(Electronic Marine Chemist Certificate) to this Annex.

Industry needs to see samples of offical NFPA Certificates for verification.

The Committee revised Annex C as follows (sample forms to be included in the Report on Proposals):Annex C Samples of Marine Chemist's Certificates

C.1 The Certificate shown in Figure C.1 is a sample of the paper form that is to be filled out manually by the MarineChemist at the completion of the inspection.Changes to Figure C.1:Delete MARINE CHEMIST'S CERTIFICATE from the top center of the figure.Caption for Figure C.1: FIGURE C.1 Sample of the Paper Form to be Filled Out After Inspection for Certification.C.2 The Certificate shown in Figure C.2 is a sample of the computer-generated form that is created by the MarineChemist at the completion of the inspection. The printed form can be produced on letter or legal size paper and can beprinted in color or black and white.Caption for Figure C.2: FIGURE C.2 Sample of the Computer-Generated Form to be Filled Out After Inspection forCertification.

****Insert Artwork Here****(Figures C.1 and C.2)

The Committee agreed with the submitter. The change to Figure C.1 is made since that textdoes not appear on the Certificate form that is in current use. The Committee revised text concerning Figure C.1 andadded new text for new Figure C.2.

_______________________________________________________________________________________________306-117 Log #110


Please add the following guidance document right below D.1(2):International Safety Guide for Inland Navigation Tank-barges and Terminals (ISGINTT)

The ISGINTT is a new publication. It’s a great guidance.

The following information should also be added to Annex F:Central Commission for the Navigation of the Rhine, 2 Place de la République, 67082

Strasbourg Cedex, France. (ISGINTT), first edition, 2010.

The Committee agrees with the submitter's proposal. This Guide provides safety (best)practices on the operation of tank barges and terminals utilizing a risk-based control philosophy. Referencing the Guidein the Standard is viewed by the committee as a proactive approach to enhancing risk awareness and managing gashazards associated with tank barge operations.




Update Annex E to the current edition of NFPA 69.Replace Table E.1(a) Limiting Oxidant Concentrations for Flammable Gases When Using Nitrogen or Carbon Dioxide asDiluents with Table C.1(a) Limiting Oxidant Concentrations for Flammable Gases When Using Nitrogen or CarbonDioxide as Diluents from NFPA 69, 2008 edition.Replace Table E.1(b) Limiting Oxidant Concentrations for Combustible Dust Suspensions When Using Nitrogen orCarbon Dioxide as Diluents with Table C.1(b) Limiting Oxidant Concentrations for Combustible Dust Suspensions WhenUsing Nitrogen as a Diluent from NFPA 69, 2008 edition.

****Insert Table E.1(a) Here****

****Insert Table E.1(b) Here****

Updates the information in Annex E with the most current data from NFPA 69,2008 edition.


1 NFPA 306 Log #CP10 Rec A2013 ROP

Table E.1(a) Limiting Oxidant Concentrations for Flammable Gases When Nitrogen or Carbon Dioxide Are Used as Diluents

Adjusted LOC (Volume % O2 Above Which

Deflagration Can Take Place) per 7.2.3

Original LOC (Volume % O2 Above Which

Deflagration Can Take Place)

Gas/Vapor N2–Air Mixture CO2–Air

Mixture

Reference* N2–Air Mixture CO2–Air

Mixture Methane 10.0 12.5 1 12.0 14.5 Ethane 9.0 11.5 1 11.0 13.5 Propane 9.5 12.5 1 11.5 14.5 n-Butane 10.0 12.5 1 12.0 14.5 n-Butyl acetate 9.0 — 9 9.0 — Isobutane 10.0 13.0 1 12.0 15.0 n-Pentane 10.0 12.5 1 12.0 14.5 Isopentane 10.0 12.5 2 12.0 14.5 n-Hexane 10.0 12.5 1 12.0 14.5 n-Heptane 9.5 12.5 2 11.5 14.5 Ethanol 8.7 — 9 8.7 — Ethylene 8.0 9.5 1 10.0 11.5 Propylene 9.5 12.0 1 11.5 14.0 1-Butene 9.5 12.0 1 11.5 14.0 Isobutylene 10.0 13.0 4 12.0 15.0 Butadiene 8.5 11.0 1 10.5 13.0 3-Methyl-1- butene

9.5 12.0 4 11.5 14.0

Benzene 10.1 12.0 1, 7 11.4 14.0 Toluene 9.5 — 7, 9 9.5 — Styrene 9.0 — 7 9.0 — Ethylbenzene 9.0 — 7 9.0 — Vinyltoluene 9.0 — 7 9.0 — Divinylbenzene 8.5 — 7 8.5 — Diethylbenzene 8.5 — 7 8.5 — Cyclopropane 9.5 12.0 1 11.5 14.0 Gasoline (73/100) 10.0 13.0 2 12.0 15.0 (100/130) 10.0 13.0 2 12.0 15.0 (115/145) 10.0 12.5 2 12.0 14.5 Kerosene 8.0 (150°C) 11.0 (150°C) 5 10.0 (150°C) 13.0 (150°C) JP-1 fuel 8.5 (150°C) 12.0 (150°C) 2 10.5 (150°C) 14.0 (150°C) JP-3 fuel 10.0 12.5 2 12.0 14.5 JP-4 fuel 9.5 12.5 2 11.5 14.5 Natural gas (Pittsburgh)

10.0 12.5 1 12.0 14.5

n-Butyl chloride 12.0 — 3 14.0 — 10.0 (100°C) — 3 12.0 (100°C) — Methylene chloride 17.0 (30°C)

15.0 (100°C) — —

3 3

19.0 (30°C) 17.0 (100°C)

— —

Ethylene dichloride 11.0 9.5 (100°C)

— —

3 3

13.0 11.5 (100°C)

— —


1,1,1-Trichloro- ethane

12.0 — 3 14.0 —

Trichloro- ethylene

7.0 (100°C) — 3 9.0 (100°C) —

Acetone 9.5 12.0 4 11.5 14.0 n-Butanol NA 14.5 (150°C) 4 NA 16.5 (150°C) Carbon disulfide 3.0 5.5 4 5.0 7.5 Carbon monoxide 3.5 3.5 4 5.5 5.5 Ethanol 8.5 11.0 4 10.5 13.0 2-Ethyl butanol 7.5 (150°C) — 4 9.5 (150°C) — Ethyl ether 8.5 11.0 4 10.5 13.0 Hydrogen 3.0 3.2 4 5.0 5.2 Hydrogen sulfide 5.5 9.5 4 7.5 11.5 Isobutyl acetate 9.1 — 9 9.1 — Isobutyl alcohol 9.1 — 9 9.1 — Isobutyl formate 10.5 13.0 4 12.5 15.0 Isopropyl acetate 8.8 — 9 8.8 — Isopropyl alcohol 9.5 — 10 9.5 — Methanol 8.0 10.0 4 10.0 12.0 Methyl acetate 9.0 11.5 4 11.0 13.5 Propylene oxide 5.8 — 8 7.8 — Methyl ether 8.5 11.0 4 10.5 13.0 Methyl formate 8.0 10.5 4 10.0 12.5 Methyl ethyl ketone 9.0 11.5 4 11.0 13.5 n-Propyl acetate 10.1 — 10 10.1 — n-Propyl alcohol 8.6 — 9 8.6 — UDMH (dimethyl- hydrazine)

5.0 — 6 7.0 —

Vinyl chloride 13.4 — 7 13.4 — Vinylidiene chloride 15.0 — 7 15.0 —

Notes: 1. See 7.7.2 for the required oxygen level in equipment. 2. Data were determined by laboratory experiment conducted at atmospheric temperature and pressure. Vapor–air–inert gas samples were placed in explosion tubes and ignited by electric spark or pilot flame. *References: 1. J. F. Coward and G. W. Jones (1952). 2. G. W. Jones, M. G. Zabetakis, J. K. Richmond, G. S. Scott, and A. L. Furno (1954). 3. J. M. Kuchta, A. L. Furno, A. Bartkowiak, and G. H. Martindill (1968). 4. M. G. Zabetakis (1965). 5. M. G. Zabetakis and B. H. Rosen (1957). 6. Unpublished data, U.S. Bureau of Mines. 7. Unpublished data, Dow Chemical Co. 8. U.S. Bureau of Mines. 9. L. G. Britton (2002). 10. Unpublished data, Dow Chemical Co., 2002.


Table E.1(b) Limiting Oxidant Concentrations for Combustible Dust Suspensions When Using Nitrogen as a Diluent

Dust

Median Particle Diameter by Mass

(µm)

LOC (Volume % O2

Above Which Deflagration Can Take

Place), N2–Air Mixture

Cellulosic Materials Cellulose 22 9 Cellulose 51 11 Wood flour 27 10 Food and Feed Pea flour 25 15 Corn starch 17 9 Waste from malted barley 25 11 Rye flour 29 13 Starch derivative 24 14 Wheat flour 60 11 Coals Brown coal 42 12 Brown coal 63 12 Brown coal 66 12 Brown coal briquette dust 51 15 Bituminous coal 17 14 Plastics, Resins, Rubber Resin <63 10 Rubber powder 95 11 Polyacrylonitrile 26 10 Polyethylene, h.p. 26 10 Pharmaceuticals, Pesticides Amino- phenazone

<10 9

Methionine <10 12 Intermediate Products, Additives Barium stearate <63 13 Benzoyl peroxide 59 10 Bisphenol A 34 9 Cadmium laurate <63 14 Cadmium stearate <63 12 Calcium stearate <63 12 Methyl cellulose 70 10 Dimethyl terephthalate 27 9 Ferrocene 95 7 Bistrimethyl- silyl-urea

65 9

Naphthalic acid anhydride 16 12 2-Naphthol <30 9


Paraform- aldehyde

23 6

Pentaerythritol <10 11 Metals, Alloys Aluminum 22 5 Calcium/ aluminum alloy

22 6

Ferrosilicon magnesium alloy 17 7 Ferrosilicon alloy 21 12 Magnesium alloy 21 3 Other Inorganic Products Soot <10 12 Soot 13 12 Soot 16 12 Others Bentonite derivative 43 12

Source: R. K. Eckhoff, Dust Explosions in the Process Industries, 2003.

Note: The data came from 1 m3 and 20 L chambers using strong chemical igniters.



Revise text to read as follows:F.1 Referenced Publications. The following documents or portions thereof are referenced within this standard forinformational purposes only and are thus not part of the requirements of this document unless also listed in Chapter 2.

National Fire Protection Association, 1 Batterymarch Park, P.O. Box 9101, Quincy, MA02169-7471.NFPA 30, , 2008 2012 edition.NFPA 69, , 1997 2008 edition.NFPA 312, , 2006 2011edition.NFPA 484, , 2009 2012 edition. , 19972010 edition.

American Conference of Governmental Industrial Hygienists, 1330 Kemper MeadowDrive, Cincinnati, OH 45240-1634. (latest edition).

American Petroleum Institute, 1220 L Street, NW, Washington, DC 20005-4070.API 1141,first edition, 1994.

ASTM International, 100 Barr Harbor Drive, P. O. Box C700, West Conshohocken, PA19428-2959.ASTM D 323, , 20062008.

International Chamber of Shipping, 12 Carthusian St. 38 St. Mary Axe, London, UK EC1M6EZ EC3A 8BH. (ISGOTT), fifth edition, 2006

Captain C. Baptist, eighth edition, 2000. (Chemicals), third edition,2002. (Liquefied Gas), second edition, 1995.

International Maritime Organization, 4 Albert Embankment, London, UK SE17SR. Marine Safety Committee Circular 744, June 14,1996.

U.S. Department of the Interior, Bureau of Mines Publications, National TechnicalInformation Service (NTIS), 5285 Port Royal Road, Springfield, VA 22161.U.S. Bureau of Mines Report of Investigation6543.U.S. Bureau of Mines Report of Investigation 6549.U.S. Bureau of Mines Report of Investigation 6561.U.S. Bureauof Mines Report of Investigation 6811.H. F. Coward and G. W. Jones, “Limits of Flammability of Gases and Vapors,”Bulletin 503, U. S. Bureau of Mines, 1952, 155 pp.M. G. Zabetakis, “Flammability Characteristics of Combustible Gasesand Vapors,” Bulletin 627, U.S. Bureau of Mines, 1965, 121 pp.Unpublished data, U.S. Bureau of Mines.Unpublisheddata, Dow Chemical Co.

U.S. Government Printing Office, Washington, DC 20402. Title 29, Code ofFederal Regulations, Part 1915, Subpart B.Title 29, Code of Federal Regulations, Part 1915, Subpart D.Title 29, Codeof Federal Regulations, Part 1915, Subpart I.Title 29, Code of Federal Regulations, Part 1915, Subpart P.Title 29, Codeof Federal Regulations, Part 1915, Subpart Z.Title 29, Code of Federal Regulations, Part 1915.7.Title 46, Code ofFederal Regulations, Chapter I, Part 35, Operations, Subpart 35.01.Title 46, Code of Federal Regulations, Chapter I,Part 71, Inspection & Certification, Subpart 71.60.Title 46, Code of Federal Regulations, Chapter I, Part 91, Inspection &Certification, Subpart 91.50.Title 46, Code of Federal Regulations, Chapter I, Part 109, Operations, Subpart G.Title 46,Code of Federal Regulations, Chapter I, Part 115, Inspection & Certification, Subpart G.Title 46, Code of FederalRegulations, Chapter I, Part 126, Inspection & Certification, Subpart A.Title 46, Code of Federal Regulations, Chapter I,Part 167, Public Nautical School Ships, Subpart 167.30.Title 46, Code of Federal Regulations, Chapter I, Part 176,Inspection & Certification, Subpart G.Title 46, Code of Federal Regulations, Chapter I, Part 189 Inspection &Certification, Subpart 189.50.

R. K. Eckhoff, , 1991, 586.G. W. Jones, M. G.Zabetakis, J. K. Richmond, G. S. Scott, and A. L. Furno, “Research on the Flammability Characteristics of AircraftFuels,” Wright Air Development Center, Wright-Patterson AFB, OH, Technical Report 52-35, Supplement I, 1954, 57pp.J. M. Kuchta, A. L. Furno, A. Bartkowiak, and G. H. Martindill, “Effect of Pressure and Temperature on FlammabilityLimits of Chlorinated Combustibles in Oxygen-Nitrogen and Nitrogen Tetroxide-Nitrogen Atmospheres,”

, Vol. 13, No. 3, July 1968, p. 421.F.2 Informational References. The followingdocuments or portions thereof are listed here as informational resources only. They are not a part of the requirements of


Report on Proposals – June 2013 NFPA 306this document.M. G. Zabetakis and B. H. Rosen, “Considerations Involved in Handling Kerosine,” , Vol.37, Sec. III, 1957, p. 296.F.3 References for Extracts in Informational Sections.NFPA 69,

, 1997 2008 edition.To conform to the NFPA Regulations Governing Committee Projects the Committee updated extracted

material references to other organizations documents.


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