Current Status of Shipyard Competent Person Programs in Louisiana and Texas

1. Current Status of Shipyard Competent Person Programs in Louisiana and Texas Laura Hartline Weems United States Coast Guard Safety and Environmental Health Officer

2. What do you think of when you think of the South? Perhaps...

3. Fried Chicken POPEYES

4. Winn-Dixie Supermarket

5. Drive through Package Stores

6. Or maybe you think of the boats...

8. Objective of research • Evaluate Shipyard Competent Person programs and facility safety programs

9. Background- Marine Inspectors • Coast Guard has Marine Inspector program for commercial vessels • Inspectors often conduct inspections on vessels in shipyards • Principle hazard- confined space entry on vessels (fuel tanks, cargo tanks, voids)

10. Background- confined spaces • Confined space entry is serious hazard • CG definition: Limited openings, unfavorable ventilation, & not designed for continuous human occupancy • Ships have many confined spaces • Ships also carry many hazardous chemicals -cargoes, fuel, cleaners

11. Background- confined spaces • Confined space are normally first verified as “Safe for Workers” by Marine Chemist • OSHA allows Shipyard Competent Person to recheck spaces to maintain MC Certificate • Safety is rarely their primary duty

12. Background- SCPs • OSHA only requires that SCPs know how to do their job, does not require formal training • SCPs are usually the new employees at a facility. Receive little training on instruments & recognizing hazardous conditions • There is no formal audit program in place to evaluate SCPs

13. Background- CG’s position • Coast Guard safety policies are more stringent than OSHA’s • OSHA’s regulations -29 CFR 1915-Safety standards for shipyard employment • OSHA allows for: • Oxygen 19.5% - 22.0% • 10% of Lower Explosive Limit • Toxic vapors/gasses < PEL

14. Background- CG’s position • Coast Guard Marine Safety Offices usually add more restrictions to CG safety policies • Policies for each MSO may differ • Shipyards are expected to abide by all policies when CG inspectors are at their facility

15. Background- Why District 8?

16. Background- Why District 8?

17. Background- Why District 8?

18. Background- Why District 8?

19. Background continued • Examples of common shipyards in Louisiana and Texas...

22. Description of research • Survey tool was designed to gather info • shipyard competent persons • facilities policies and procedures • Planned visits to shipyards in Louisiana and Texas to conduct survey

23. Research Methods • Questionnaire used to survey SCPs and facilities • 3 main sections • Background Information (6 questions) • Basic Knowledge (15 questions) • Facility policies and procedures (17 questions)

24. Example Questions • 9. Define LEL (Lower Explosive Limit): _________________ • 16. What is the normal atmospheric level of oxygen? _______% • 20. What does it mean to visually inspect a space? _____________ • 30. How often do you zero your instrument(s)? ______________

25. Research Methods • Pilot administration in Rhode Island • 2 SCPs at 2 shipyards • Revisions made • Over 3 weeks, visited 46 SCPs in 24 shipyards in New Orleans, Morgan City and Houston

26. Research Methods Port No. No. SCPs Shipyards New Orleans 22 10 Morgan City 17 9 Houston 7 5

27. Research Results • 35 of the questions had point values of 0-4 pts for total possible score of 140 pts. • Lowest: 55 pts • Highest: 125 pts • Mean: 95 pts • Very broad distribution of scores

28. Comparison of zone scores

29. Project Results- Distribution • The distribution of scores was determined. Surprising results: • 40% knew term Lower Explosive Limit • 30% knew term Adjacent Space • 75% knew what normal atmospheric level of oxygen was • 65% knew what results constituted safe oxygen levels and Lower Explosive Limits

30. Project Results- Summed Score • Tests were performed to compare scores between different groups of SCPs • Chose the 95% confidence interval as significant

31. Project Results- Summed Score • Not significant: • High school graduate vs. not a high school graduate • More than 3 years on the job vs. less than 3 years • Significant: • NFPA 3-day course vs. other courses • Large (>200) shipyards vs. small (1-99) or medium (100-199)

32. Project Results- Summed Score • Significant: • NFPA 3-day vs. Marine Chemist course &/or in-house training programs • Not significant: • Marine Chemist course vs. in-house training

33. Conclusions • Questionnaire is good survey tool • SCPs & facilities are not up to regulatory standards • Average score for basic knowledge: 70% • For facility practices and procedures: 75% • The Coast Guard should continue to set stringent safety guidelines for its personnel

34. Conclusions • Inadequate evidence that CG inspectors can uniformly rely on SCPs & facilities • Training appears to have strong influence on SCP competency • Larger shipyards had better programs in place than the smaller ones

35. Recommendations • Surveys should be done of SCPs & facilities by CG units every 12-18 months • Coast Guard should make policies even more conservative to match needs of units

36. Recommendations • OSHA should require that SCPs be trained in a course similar to NFPA’s • “empowerment” education • 3 days versus 1 or 2 days • professional instructors • Biannual refresher training should also be required

37. With a little help, we can be like-

38. Thank you... • Any Questions?