Hot Work (including Welding, Cutting and Heating) » Testing and Certifying for Hot Work
In a shipyard, typically two types of individuals conduct tests and authorize spaces for hot work: The Marine Chemist certifies spaces and equipment containing  or that have previously contained flammable and combustible materials, as well as all adjacent spaces. The Shipyard Competent Person tests for and authorizes hot work locations that do not require a Marine Chemist (their specific areas of jurisdiction are listed below). When a Marine chemist is not available, a Coast Guard Authorized Person (CGAP) can also conduct tests and authorize spaces for hot work.

Note: During shipbuilding operations, the need for testing by a SCP and CMC will depend on the progress of the vessel construction. Until there is a potential for a hazard, such as after the introduction of flammable liquids, testing may not be required.

Note: Confined space entry is one of the leading hazards associated with barge cleaning. Review the Shipbuilding: Confined or Enclosed Spaces and Other Dangerous Atmospheres chapter for information on how to protect workers from this hazard.


Certified Marine Chemist (CMC)
Figure 1: Marine Chemist
Figure 1: Marine Chemist.

Figure 2: Marine Chemist certificate
Figure 2: Marine Chemist certificate.
Certified Marine Chemists (CMC) are required to test for hot work in confined and enclosed spaces, adjacent spaces, and equipment (such as fuel tanks, cargo tanks, piping, pumps, etc.) containing, or that have previously contained, flammable or combustible liquids or gases. Tests to be performed include: A marine chemist issues a certificate for hot work, which must be posted. The Marine Chemist Certificate identifies condition of spaces, such as "Safe for Hot Work" or "Safe for Workers." Spaces that are designated "Not Safe for Workers" or "Not Safe for Hot Work" must be labeled. [29 CFR 1915.11, 29 CFR 1915.14(a) and 29 CFR 1915 Subpart P, and NFPA 306]
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Shipyard Competent Person (SCP)
Figure 3: Shipyard Competent Person, with PFD, testing tanks on a barge prior to authorizing entry. Note: Fall protection to be installed after testing for initial entry
Figure 3: Shipyard Competent Person, with PFD, testing tanks on a barge prior to authorizing entry. Note: Fall protection to be installed after testing for initial entry.

Figure 4: SCP testing equipment
Figure 4: SCP testing equipment.

Figure 5: Rudder being inspected for structural voids
Figure 5: Rudder being inspected for structural voids.

Figure 6: Testing and visual inspection to maintain Marine Chemist Certificate.
Figure 6: Testing and visual inspection to maintain Marine Chemist Certificate.

Figure 7: Sample Competent Person Record of Inspection
Figure 7: Sample Competent Person Record of Inspection.

A Shipyard Competent Person (SCP) is required to test for hot work in certain spaces that do not require a Marine Chemist. However, the employer may use a  Marine Chemist to conduct all the tests required by a Shipyard Competent Person. [29 CFR 1915.7(b)]

The Shipyard Competent Person's testing responsibilities include:
  • Calibrating and maintaining test equipment. [29 CFR 1915.7(c)(4)]
  • Testing and inspecting hollow structures including: [29 CFR 1915.54]
    • skegs,
    • pipe stanchions and handrails
    • booms,
    • masts, and
    • rudders.
  • Testing and inspecting spaces not requiring Marine Chemist certification including: [29 CFR 1915.14(b)(1)]
    • dry cargo holds,
    • bilges,
    • vessel modules,
    • tanks, and
    • and landside confined or enclosed spaces.
  • Conduct tests and visual inspections to maintain a Marine Chemist Certificate. [29 CFR 1915.7(c)]

Exception: On dry cargo, miscellaneous (such as tugs, barges, supply boats, etc.) and passenger vessels and in the landside operations within spaces which meet the standards for oxygen, flammability and toxicity in 1915.12, but are adjacent to spaces containing flammable gases or liquids, as long as the gases or liquids have a flash point below 150 deg. F (65.6 deg. C) and the distance between such spaces and the work is 25 feet (7.5m) or greater.

Note: For flammable liquids with flash points above 150 deg. F (65.6 deg. C), see paragraph (b) of this section. [29 CFR 1915.14(a)(1)(iv)]

The Shipyard Competent Person must complete the Inspection Record, which must be posted. This record identifies conditions of spaces, such as "Safe for Hot Work" or "Safe for Workers." Spaces that are designated "Not Safe for Workers" or "Not Safe for Hot Work," must have warning signs and labels posted at the entrance of the space. [29 CFR 1915.16] The shipyard must maintain and make available a roster of shipyard competent persons. [29 CFR 1915.7(b)(2)(i)]
 











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