Ship Boat Manual

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ACHIEVING HEALTH AND SAFETY

IN THE BUILDING AND REPAIR


OF SHIPS AND BOATS

By the
Bureau of Labor Education
The University of Maine
Cover Drawing by Grigorios Magklis, Barcelona, Spain.
Used with permission of artist.
ACHIEVING HEALTH AND SAFETY
IN THE BUILDING AND REPAIR OF
SHIPS AND BOATS

Researched and Written by:


Bill Murphy, Jim Nicholson, Valerie Carter,
and Jane Crouch

Edited by
Bill Murphy and John Hanson

Published by the
Bureau of Labor Education
The University of Maine
and a grant funded in part by
OSHA, U.S. Department of Labor
2004

Copyright 2004
The University of Maine
Bureau of Labor Education
ii

“... to assure as far as possible every working man and


woman in the nation safe and healthful working conditions
and to preserve our human resources:

Each employer shall:


(1) furnish to each of [their] employees, employment
and a place of employment free from recognized haz-
ards that are causing or likely to cause death or seri-
ous physical harm;
(2) comply with occupational safety and health stan-
dards promulgated under this Act;
(3) provide proper safety and health training and edu-
cation to employees;

Each employee shall comply with occupational safety and


health standards and all rules, regulations, and orders pur-
suant to this Act which are applicable to [their] own actions
and conduct.”

— Public Law 91-596, Occupational Safety and


Health Act of 1970
iii

ACKNOWLEDGEMENTS

The Bureau recognizes and thanks the following individ-


uals and organizations whose assistance and resources were
very helpful in the development of this publication:
— University of Maine Printing Services Department;
— Mary Shannon and Allan Colena, Boston, OSHA;
— Labor Education and Research Service at Ohio State
University;
— National Institute for Occupational Safety and Health
(NIOSH).
This material was produced under grant number 46A3-
HT46 from the Occupational Safety and Health Administra-
tion, U.S. Department of Labor. It does not necessarily reflect
the views or policies of the U.S. Department of Labor, nor
does mention of trade names, commercial products, or organ-
izations imply endorsement by the U.S. Government.

In complying with the letter and spirit of applicable laws


and in pursuing its own goals of diversity, the University
of Maine System shall not discriminate on the grounds of
race, color, religion, sex, sexual orientation, national origin or
citizenship status, age, disability, or veterans status in
employment, education, and all other areas of the University.
The University provides reasonable accommodations to
qualified individuals with disabilities upon request.
Questions and complaints about discrimination in any
area of the University should be directed to Harry Payne,
Executive Director of Equal Opportunity, The University of
Maine, 5754 North Stevens Hall, Room 101, Orono, ME
04469-5754, telephone 581-1226 (voice and TDD).
iv

Table of Contents

Introduction v

Chapter I Identifying and Abating Hazards in


Ship/Boat Building and Repair 1

Chapter II Occupational Safety and Health Law 21

Chapter III Attaining Health and Safety in Ship


and Boat Yards 43

Appendix I Shipyard Trade Occupational Risk


Matrix (STORM) 66

Appendix II-A Some Key Elements in a Worksite


System 67

Appendix II-B How a Worksite Accident in a Shipyard


Develops Across Time 68

Appendix III OSHA’s Hazard Communication


Standard and Material Safety
Data Sheets 69

Index 75
v

Introduction

In 2002 there were over 5,500 fatalities reported by


industries in the United States.1 A total of 4.7 million injuries
and illnesses were reported in private sector workplaces in
2002, resulting in a rate of 5.3 cases per 100 equivalent full-
time workers.2 The Liberty Mutual 2002 Workplace Safety
Index estimates that direct costs for occupational injuries in
1999 rose to $40.1 billion, with indirect costs reaching over
$200 billion.3
Shipyard work is very hazardous, with an injury-illness
incidence rate of 16.6 that is more than twice that of con-
struction and general industry.4 While boatyard work is more
diverse, and usually smaller in scale, it also poses many seri-
ous risks to workers. Hazards in shipyards and boatyards
include exposure to toxic substances, ergonomic injuries, haz-
ardous atmospheres, electrocution, falls, fires, and explosions,
among others.5 Effective safety and health programs can help
to eliminate or minimize such hazards.6
Because of these high risks, OSHA (U.S. Occupational
Safety and Health Administration) has targeted shipyard and
boatyard work in its Strategic Management Plan to reduce
injuries and illnesses, and prevent fatalities.7 Also, OSHA is
working with the maritime industry to address these hazards
(e.g., see OSHA’s innovative new “Shipyard Employment
eTool”).8
These realities point out the great need for labor and
management in all areas, especially ship and boat yards, to
play an active role towards insuring that healthful and safe
working conditions exist on the worksite or in the workplace.
This publication contains important information for helping
labor and management in ship and boat yards to deal with
occupational health and safety challenges through the use of
the law, hazard identification and abatement, and joint labor-
management committee programs.
The approach and emphasis of this manual is its practical,
clear focus on hazard identification and abatement (Chapter I),
the use of employment law (Chapter II), and joint labor-
vi

management safety and health committee programs


(Chapter III). Chapter III also provides a listing of resources
and materials on occupational health and safety relevant to
ship/boat building and repair.
The ultimate effectiveness of any training will depend on
the presence of a number of elements, geared to the require-
ments of each workplace operation. However, training is
only one element of the challenge to maintain a safe and
healthful workplace. An effective workplace safety and health
program should have all of these components, according to
the U.S. Occupational Safety and Health Administration
(OSHA 2268, Shipyard Industry, p. 1):
 Management Commitment and Leadership
 Employee Participation
 Hazard Identification, Assessment and Control
 Accident and Incident Investigation
 Training
 Program Evaluation
 Record Keeping
 Procedures for Multi-Employer Workplaces

Source: http://siri.uvm.edu/graphics/Safety_Management/Safety_plan.gif
vii

This manual is not a comprehensive guide to all possible


kinds of hazards and risks. It supplements and complements
other sources of information on occupational safety and
health, but does not replace them. More detailed information
on OSHA provisions concerning safety and health in ship-
building and boat building can be obtained from OSHA; par-
ticularly in the OSHA publication Shipyard Industry, OSHA
2268 (1998 Revision).
Ultimately, it is the responsibility of everyone from top
management to individuals in the yard to ensure that work-
place safety and health is maintained to the highest degree
possible. Those most directly at risk, however, are workers,
supervisors, and worker/owners on the front lines who are
exposed to these hazards on a daily basis, and it is to these
individuals that this manual is dedicated.
viii

Endnotes
1
U.S. Department of Labor, Bureau of Labor Statistics:
http://www.bls.gov/news.release/pdf/cfoi.pdf
2
U.S. Department of Labor, Bureau of Labor Statistics:
http://www.bls.gov/iif/oshwc/osh/os/ostb1232.txt
3
U.S. Centers for Disease Control and Prevention, National
Institute of Occupational Safety and Health (NIOSH):
http://www.cdc.gov/niosh/about.html
4U.S. Department of Labor, Occupational Safety and Health
Administration (OSHA): “Safety and Health Topics: Ship
Building and Repair,” and U.S. Dept. of Labor, Bureau of
Labor Statistics, Injury and Illness Incident Rates, 2002, p. 1
(The incidence rate for private industry is 5.3).
http://www.osha.gov/SLTC/shipbuildingrepair/index.html#P
rocesses%20and%20Related%20Hazards
5
OSHA:http://www.osha.gov/SLTC/etools/shipyard/index.html
6
OSHA: http://www.osha.gov/SLTC/etools/shipyard/
shiprepair/sr_index.html
7OSHA: “OSHA Industry Concentrations for FY 2003 - FY 2004;”
http://www.osha.gov/StratPlanPublic/How_the_seven_
industries_were_chosen.html
8
http://www.osha.gov/SLTC/etools/shipyard/index.html.
The “Shipyard Employment eTool” is an interactive, “stand-
alone,” Internet-based training tool and highly visual source of
safety and health information which can be used by workers,
managers, and employers.
1

Chapter I:
Identifying and Abating Hazards in
Ship/Boat Building and Repair

The first critical step necessary for reducing accidents,


injuries, and occupational diseases in ship/boat building and
repair, involves establishing ongoing education on hazard
identification and abatement for employees and employers.
While there are many commonalities in hazards across the
ship/boat building and repair industries, there are also some
major differences, and also much diversity based on the size
and type of the operation. This chapter discusses approaches
for developing a program to identify and abate hazards in
these industries. Given the great diversity among individual
workplaces and the work processes within them, users of
this manual should view it as a flexible tool, to be applied as
needed.
OSHA has outlined several key components of work-
place safety and health programs (“SHPs”) in the shipyard
industry, describing the responsibilities of both employers
and employees. In addition to establishing a detailed and
systematic workplace safety and health program or SHP,
employers must take certain steps to identify workplace haz-
ards, and must periodically:
 Physically inspect the workplace;
 Review available safety and health information; and
 Evaluate the seriousness of identified hazards that are
not covered by OSHA standards.1
In addition, employees exposed to serious hazards need
to receive training, “so that they are able to assist in protecting
themselves and other employees.”2 Not all hazards are covered
in OSHA regulations, however. Both employees and employers
must have a vigilant and systematic approach towards hazard
recognition, identification and abatement, to deal with serious
hazards such as chemical, physical, biological and ergonomic
hazards which may cause death or serious harm, whether or
not they are specifically covered by OSHA standards.3
2

While OSHA regulatory language for most boatyards is


based on OSHA’s 1910 Standards for General Industry, rather
than 1915 Standards for the Shipyard Industry, these same
general principles for workplace safety and health programs
are certainly applicable to the boat building/repair industry
as well. Chapter II of this manual examines these legal stan-
dards in more detail.

Characteristics of the Ship/Boat Building and Repair


Industries Relevant to Hazard Abatement and
Recognition
Ship/boat building and repair have several characteristics
in common. Both industries involve the construction and
repair of vessels, often but not always next to or on the water.
There are many extremely hazardous conditions and job tasks
frequently associated with both industries. In general, the
larger the boatyard facility or operation, the more similar it
will be to a shipbuilding facility. While shipbuilding typically
involves working primarily with metals as the most funda-
mental material, boat building varies greatly, depending on
whether the operation builds boats of fiberglass, metal or
wood. In addition, while shipyards are typically quite large,
the size and nature of boat building operations ranges from
larger manufacturing plants where boats may be mass pro-
duced, to small boatyards with only a few employees, to
backyard boat building projects with only one individual or a
family involved in the construction of the boat. Finally, ship-
yards are more likely to be unionized facilities with collective
bargaining, while boatyards are less likely to be unionized,
and large shipyards are more likely to have a joint labor-
management safety and health committee.4 Unionization
however, is not a requirement for the creation of a joint labor-
management safety and health committee.

Types of Hazards and Their Impacts


It is useful to divide occupational illness and injury into
three major categories: accidents or injuries, chronic
ergonomic and noise injuries,5 and occupational illnesses, both
acute and chronic. Since accidents are typically discrete
3

events and are more easily observable and documented,


much training material tends to focus on accidents. However,
it is extremely important for workers to be aware of other
workplace hazards that may cause potentially debilitating
chronic injury and illnesses as well.
The topic of this chapter is on hazard recognition and
abatement, focusing on the Ohio State University (OSU)
“Hazard Recognition Program,”6 which categorizes work-
place hazards into five main types of hazards. This chapter
also will describe a creative “Worksite Systems Analysis”
(University of Maine/Bureau of Labor Education)7 that con-
centrates on the various elements contributing to hazardous
situations, and helps in understanding how accidents or haz-
ards may unfold over time. While the Hazard Recognition
Program and the Worksite Systems Analysis can be especially
useful in helping workers and supervisors avoid workplace
accidents, they can be utilized to deal with hazards leading to
chronic injury and workplace-related illnesses as well.

Hazard Identification and Recognition Program:


A Practical Approach
One useful approach to dealing with the somewhat over-
whelming challenge of recognizing and reducing workplace
hazards in ship/boat building and repair is to start from a
simple and straightforward system of types or categories of
workplace hazards. This is a much more usable method than
simply trying to draw up a comprehensive list of every
potential hazard or risk in these industries.
The Hazard Recognition Program used in this manual was
developed originally by the Labor Education and Research
Service at Ohio State University. These hazard categories can be
easily used by employees and employers in everyday work set-
tings to recognize, reduce and abate such hazards:

1) Falling Hazards
2) Struck By or Striking Against Hazards
3) Getting Caught Hazards
4) Contact Hazards
5) Inhalation and Swallowing Hazards
4

This five-category system of Hazard Recognition will be


helpful in identifying workplace risks and dangers in the
building and repair of both ships and boats. Here are some
examples from these industries, keeping in mind the special
hazards common to each industry — particularly heavy
metal exposure, explosions, and confined space hazards in
shipyards, and exposure to toxic chemicals such as styrene
and other toxics in boatyards.

Workplace Hazards in Ship/Boat Building and Repair,


With Selected Examples

1. Falling Hazards — There


are two types of falling haz-
ards: falls from a higher to
lower level, and falls on the
same level. Examples of
ship/boat building and repair
Source: http://siri.uvm.edu/graphics/
work where these hazards
Industrial_Operations/Welding.gif exist include:
a) work around unguarded areas and edges on a ship or
boat, including hatches;
b) surface preparation and descaling from staging,
decks, and end and wing walls of dry docks, where
falls are complicated by a drowning hazard;
c) falls from an overturning ship during dry-docking
and launching operations;
d) fabricating and repairing large structural components,
where falls can result in drowning; and
e) falls due to poor housekeeping practices, such as fail-
ure to remove debris, tools and equipment, or ice from
a work floor or surface.
2. Struck By or Striking Against Hazards — These hazards
occur in ship/boat building and repair work where employees
can be struck by objects, materials, equipment and/or vehicles.
Often such hazards result from unsafe work practices, poor
planning, and lack of training. Examples of hazards in ship/boat
building and repair that fall under this category involve:
5

a) injuries associated with moving equipment for boat/


ship building and repair (cranes, derricks, hoists, etc.);
b) injuries caused by objects falling from carrying
devices, similar to construction industry;
c) powered industrial truck operations in shipbreaking;
d) work where materials or equipment are improperly
stored or handled overhead; and
e) work where equipment, machinery, power tools or
instruments are not fitted with appropriate guards.
3. Getting Caught Hazards — The three common types of
hazards found in this category include caught in, caught on,
and caught between. Examples of ship/boat building and
repair work where these problems can occur encompass:
a) injuries, fatalities associated with an overturning ship
during dry-docking and launching operations;
b) traumatic injury among divers while using underwater
hull cleaning devices, where divers may get caught by
moving brushes or the current created by the impeller;
c) injuries from fire, asphyxiation, and toxic exposures
upon entry into confined spaces during fitting out
process;
d) spaces with limited openings for entry and exit with
unfavorable natural ventilation — not intended for
human occupancy — can readily aggravate a haz-
ardous exposure because of its design (e.g., double
bottom tank, wing tank, cofferdam); and
e) unexpected complications associated with a relatively
large confined space such as boat freezers, where explo-
sions can occur.
4. Contact Hazards — Hazards within this category are quite
varied. They include contact with: extreme temperatures
resulting from hot or cold working surfaces that are not covered
or shielded adequately; electrical current from improperly
grounded or maintained electrical equipment, machines, or
wiring; dangerous, toxic working materials, substances,
6

chemicals, and vapors; welding hazards, and exposure to


excessive noise without adequate hearing protection.
Employees and employers need to pay particularly close
attention to electrical hazards, which according to OSHA,
constitute the second highest cause of job-related fatalities in
the U.S. Also, ergonomic hazards are in this contact category,
such as unsafe work actions or procedures caused by aggra-
vated, repetitive motions; forced and strained exertions,
excessive vibration, and strained or awkward postures over
extended periods of time. (See “Appendix I, Shipyard Trade
Occupational Risk Matrix (STORM)” for further information
on ergonomic injuries in shipbuilding).
Examples of some ship/boat building and repair haz-
ards in this area include:
a) fitting out work exposes workers to electrocution haz-
ards from portable electric hand tools, or working on
a ship’s electrical circuits;
b) hearing loss from noise is pervasive in fitting out
work; engineering controls are difficult to implement
because workstations are not fixed;
c) fitting out work also may expose workers to frostbite,
hypothermia, heat exhaustion, heat cramps, dehydra-
tion, etc., from exposure to extreme weather;
d) underwater work on ships can cause decompression
sickness among divers while making temporary
underwater hull repairs;
e) fires and explosions from explosive atmospheres in
tanks during tank cleaning for ship repair; and
f) ionizing radiation not only on conventionally pow-
ered but also on nuclear powered vessels. [1915.57]
5. Inhalation and Swallowing Hazards — These hazards
result from toxic vapors and substances released into the
work environment. Such worksite toxics may not only con-
taminate water and food consumed by workers, but also may
be absorbed through the skin. Examples of these hazards
found in ship/boat building and repair are:
7

a) respiratory irritation and systemic poisoning from


exposure to toxic fumes and particles from welding
and painting operations;
b) respiratory damage and systemic poisoning from
exposure to toxic substances used in boat building and
repair;
c) lead poisoning during stripping and chipping opera-
tions involving lead paints;
d) respiratory damage or chronic disease from exposure
to asbestos;
e) damaging exposure to pigments, anti-fouling and anti-
rust paint components (e.g., organo-mercury com-
pounds, copper oxide, arsenic, organo-tin compounds,
cadmium, and chromium).
Many hazards fall into more than one category. For
example, a worker may be exposed to danger in a confined
space where there is a hazard from explosion or inhalation of
toxic fumes.

Hazards in Boat Building and Repair: Special


Considerations
At present, there is much more readily available specific
regulatory language and information on hazard recognition
and occupational health and safety for the shipyard industry
than for boatyards, in part because of the smaller scale and
greater diversity among boatyards and in boat construction.
Nonetheless, it is critical for workers, owners, and supervisors
in boatyards to be familiar with risks and hazards specific to
this industry.
Boat builders need to be especially mindful of a number
of different hazardous substances, depending on the materials
which they are coming in contact with at work. At a minimum,
sufficient ventilation and personal protective equipment,
including but not limited to safety glasses, hearing protec-
tion, gloves, protective footwear, and respirators, are among
the basic precautions that are critically important in a boat-
yard, in addition to complying with all applicable OSHA
standards.
8

Wood dust is one of the most commonly encountered


chemical hazards in boat building, particularly in the con-
struction of wooden boats.8 Methylene chloride (MC)9 and
styrene10 are also major concerns in boat building and repair,
and there are detailed guidelines for working with these
chemicals. Other chemical hazards in the boat building
industry include: epoxy resins, methyl ethyl ketone peroxide
(MEKP),11 sodium hydroxide, toluene, acetone, isocyanates,12
and even such natural materials as turpentine and pine tar.13
Manufacturers of aluminum boats may encounter hazards sim-
ilar to those found in shipbuilding, such as welding hazards.
Boat builders, whether at the commercial boatyard or in
the backyard boat shop, can protect themselves by keeping
their shops well ventilated and clean, and by following prod-
uct safety information. Boatyards that comply with OSHA
1910, General Industry Standards (CFR 29, Labor) should con-
sult Subpart Z, Toxic and Hazardous Substances, Parts
1915.1000 through 1915.1450. OSHA 1915, Shipyard Industry,
also covers hazardous substances under Subpart Z, and
under the same parts as the 1910 standards. See the
Resources section of this manual in Chapter III to find these
reference materials, as well as other references on hazardous
materials in boat building and shipbuilding.
Appendix III of this manual contains information
on Material Safety Data Sheets and OSHA’s Hazard
Communication Standard that boat builders and shipbuilders
must follow as well. Chapter II, particularly the section on
NIOSH, also contains important information on ways labor
and management can use the law for identifying and abating
hazardous chemicals.

Using a “Worksite Systems” Approach for Hazard


Recognition and Abatement in Ship/Boat Building and
Repair

The University of Maine/Bureau of Labor Education


“Worksite Systems” approach is based on an “organizational
systems” model or way of thinking. This approach looks at a
worksite or work situation as a system of interacting and
9

interdependent parts, within a larger environment or context.


This can be thought of as a worksite system.
Each part or element of the worksite system, and its envi-
ronment — such as the employer, employees, contractors, and
the physical environment (including weather or bodies of
water) — may potentially affect the functioning of the other
parts. The worksite system and its environment is not a single
snapshot or “still shot” at one point in time; rather, it is a con-
stantly changing, dynamic process that is not entirely pre-
dictable. And larger worksites, with more elements, will be
more complex.
Most workers and supervisors use such a dynamic “sys-
tems” approach intuitively, at least to some extent, in their
planning and thinking in daily life. Similarly, when dealing
with hazardous situations or machinery, an employee and/or
employer must be able to anticipate or project possible out-
comes based on his/her decisions, and also must take into
account the possible actions or behaviors of other workers
and supervisors, as well as the physical conditions. Of equal
importance, the employer must do a job hazard analysis dur-
ing each phase of the work, and each specific task assigned,
and communicate this important hazard information to all
employees and supervisors involved in the work.
Systems also involve inputs (e.g., labor, raw materials) and
outputs (e.g., a completed physical structure or service), as well
as some kind of work process which transforms the inputs into
outputs. A worksite system has certain goals as well, such as
completing a ship or boat structure within time deadlines,
keeping within cost limits, and maintaining high quality.
Within a system such as a shipyard or boatyard, each
part or element can be seen as playing a certain role or func-
tion within the system. When the parts mesh well together,
the worksite system as a whole will tend to work smoothly,
at least in theory — the project or tasks for each day or week
are completed, deadlines are met, quality is attained, goals
are fulfilled, morale is high, and workers leave at the end of
their work day without accidents or hazardous incidents.
Unpredictable occurrences are dealt with effectively.
10

On the other hand, if there is a problem with one or more


of the pieces or elements — a crucial part does not come in
when promised, bad housekeeping creates a hazard, com-
munications are unclear, a key worker gets sick, or a machine
malfunctions — the whole system may come to a grinding
halt. This worksite systems model also highlights the key
importance of appropriate, clear and complete information,
and of effective communications. In other words, it is not
only important to have the necessary labor, tools, materials,
and technical plans; it’s also critical to ensure that necessary
information gets communicated effectively to different players.
This organizational systems approach to worksites can
be very useful when applied to issues of health and safety in
boatyards and shipyards. Experienced workers, supervisors,
and others who analyze both the “big picture” (the work-
place system as a whole) AND the individual elements or
parts, often use this perspective intuitively, because it works.
Two major advantages of the worksite system model are
that: a) it can be applied to any situation, and b) it can be
used to analyze the potential for different possible outcomes
over time. For example, the combination of inexperienced
workers and/or managers, old or malfunctioning equipment,
poor communications and hazardous weather conditions may
greatly increase the probability of serious workplace accidents
occurring at a given workplace.
11

One last element of a worksite, considered as a kind of


organization, is that it tends to develop its own workplace
culture or set of beliefs, values, and norms over time. Even
identifiable occupational groups tend to develop their own
subcultures, such as an emphasis on “toughness” or bravado.
Whatever “rules” exist at any workplace, the informal culture
may or may not support responsible health and safety prac-
tices. Any perceptive person who begins work at a new site
quickly learns about the informal values and expectations of
behavior at the site. Is the habit of “cutting corners” usually
overlooked? Is a person’s maximum standard performance
typically at the minimum standard set for that job?
To summarize, workers, supervisors, owners and con-
tractors can apply this worksite systems approach to analyze
and abate specific hazards, as well as unsafe or unhealthy
conditions or practices in shipyards and boatyards. This
approach can help all the players at the worksite to work
jointly to identify and maximize those factors and resources
promoting safety and health within their work environment,
and to minimize and/or correct those factors and conditions
preventing the attainment of a safe and healthful worksite.
Appendix II-A lists some of the key factors promoting
or undermining worksite safety and health, and can be used
to help conduct a worksite systems analysis. In addition,
Appendix II-B provides illustrations of some of the key ele-
ments in a worksite system, and offers a worksite systems
analysis of an accident developing across time.
12

Chapter I:
Case Study Exercises

Instructions: For each of the following case study exer-


cises, select a team spokesperson who will be responsible for
summarizing and reporting on your group’s findings and
recommendations.
Case I
Discuss and identify the hazards you are exposed to
where you work.
1. Using the information and approaches cited previous-
ly in this chapter, develop strategies for abating these
hazards.
2. How can labor and management work effectively to
abate occupational safety and health hazards?
13

Case II
“A burner working in a confined space noticed that it
was five minutes past the start of lunch break. In hurrying to
get to the lunch area, he did not completely close the gas
valve on his torch. Neither did he take the time to disconnect
or shut off the gas supply to the torch at the manifold on
deck, as he was taught to do in training. The escaping gas
mixed with the air in the space until its explosive potential
was reached and an electrical spark from equipment in the
space ignited the mixture causing an explosion and fire.
Fortunately, all the workers had left the area for lunch and no
injuries occurred.”14
1. Identify the specific hazards in this case.
2. What preventive measures should be taken to avoid
this problem in the future?
3. Whose responsibility is it to make sure this problem
does not happen again?
14

Case III
An employee was working on a deck where a crane was
being used to transport materials. As the worker was directing
the crane, she started walking backwards, signaling as she
went. The worker experienced a major injury when she acci-
dentally stepped off the deck.
1. What were the hazards involved which caused this
injury?
2. What OSHA violations were committed?
3. What actions should have been taken to avoid the
injury?
15

Case IV
A worker went to see his doctor, and reported that he
had been having low back pain for some time. Until recently,
he had dismissed his symptoms as those associated with the
job, and with aging, and had been treating himself with
ibuprofen. As a burner and welder he would frequently per-
form his work while bent over at the waist for long periods
of time. Lately, he had been experiencing severe pain when
bending at the waist, and had developed a weakness in his
left leg that seemed to be getting worse. Finally, he decided
to seek medical treatment.15
1. What is the likely source of this worker’s pain?
2. What kinds of hazards are present in this situation?
3. Given the demands of this job, how might this kind of
situation be avoided?
4. What are the possible solutions or responses to this
situation? Is this problem only the worker’s responsi-
bility? If not, why not?
16

Case V
A new worker at a shipyard has been assigned to perform
welding and other hot work in an outside location on a metal
surface which has been coated with toxic coatings such as
epoxies and lead-based paints. She has done this type of work
before in enclosed spaces, but because this job is outside in
the open air, she believes that there will be sufficient ventila-
tion, and assumes that no protective equipment is needed.16
1. Is this worker correct in her assessment that she does
not need respiratory protection? Explain.
2. What kinds of hazards are present in this situation?
3. What steps or strategies should be followed in this
case, by both the employee and employer?
17

Case VI
“A worker performing hot work on a bulkhead stripped
back the paint four inches where the welding was to be done,
and began working. As the heat passed through the bulk-
head, the epoxy paint on the other side of the bulkhead in the
adjacent space began to smolder. Several employees working
in the adjacent space were quickly affected by the noxious
fumes and exited the space. Their eyes were burning and
their throats were already becoming sore. They were advised
to go to the medical department for treatment. One of the
employees was suffering considerably more than the others.
Her medical record revealed a preexisting sensitivity to
epoxies, due to past exposures.”17
1. What kinds of hazards are present in this case?
2. Discuss the actions that should be carried out by the
employer and employees in order to prevent this type
of accident in the future?
18

Endnotes

1
OSHA, Shipyard Industry: OSHA 2268, OSHA, U.S. Depart-
ment of Labor, 1998 (Revised).
2
Ibid., p. 9. The OSHA manual adds: “While many OSHA
standards do set forth training requirements, it is important
that employees who are exposed to serious hazards for
which there are no standards or no training requirements are
provided with training…. SHP training is meant to generally
educate employees about workplace hazard awareness and
prevention.”
3
Ibid., p. 6. OSHA points out: “The hazard assessment and con-
trol process should address at least ‘serious hazards,’ work-
place hazards that are causing or likely to cause death or seri-
ous physical harm to employees. This includes hazards cov-
ered by OSHA standards. This also includes all chemical,
physical, biological, and ergonomic hazards not covered by
OSHA standards that are causing or likely to cause death or
serious physical injury or impairment.”
4
Ibid., p. 4.
5
Noise injuries are included in this category along with repet-
itive motion and other ergonomic injuries. They are similar
in that they both tend to be long-term and cumulative in
nature, and may both result in nerve damage, although noise
would not typically result in musculo-skeletal injury.
6This approach was derived and adapted from: Labor
Education and Research Service, Hazard Recognition Slide-Tape
Training Program, Columbus, Ohio: Ohio State University. See
also the use of this approach in the construction industry, in:
William C. Murphy, Achieving Health & Safety in Construction,
edited by John R. Hanson and Valerie J. Carter, Bureau of
Labor Education, University of Maine, 1998, p. 26-35.
19

7
Ibid., p. 52-56 and 86-88. The Worksite Systems Analysis
approach was developed by Valerie J. Carter, in collaboration
with William C. Murphy and John R. Hanson.
8
See OSHA guidelines and information on wood dust at:
http://www.osha.gov/SLTC/wooddust/recognition.html
9
See OSHA guidelines on exposure to methylene chloride:
http://www.osha.gov/SLTC/methylenechloride/factsheets/
mcfsno1.html
10
See OSHA guidelines on styrene exposure:
http://www.osha.gov/SLTC/styrene/solutions.html
and NIOSH information:
http://www.cdc.gov/niosh/pel88/100-42.htm
11
See NIOSH information on methyl ethyl ketone peroxide
(MEKP): http://www.cdc.gov/niosh/pel88/1338-23.html
12
For NIOSH information on isocynates, see:
http://www.cdc.gov/niosh/topics/isocyanates/
13
The use of these chemicals is well documented from many
resources available to boat builders, although much of the
regulatory language governing their use is found in the
OSHA 1910 General Industry Standards, rather than being
specific to boat building. See, for example, David W. Carnell,
“Safe Boatbuilding,” http://www.messingaboutinboats.com/
archives/mbissuejanuary01.html
Note: For additional information on MSDS please see:
http://www.ilpi.com/msds/index.html under the OSHA,
NIOSH, and Other Government Resources Section located in
the Safety References Section of this manual. Electronic
Material Safety Data Sheets should be used as a reference only
due to the possibility of power failure or computer malfunc-
tion during emergencies.
14
Source: U.S. Department of Labor, OSHA, “Safety and Health
Injury Prevention Sheets: Working with the Shipyard Industry;”
http://www.osha.gov/dts/maritime/sltc/ships/ships_
combined.pdf (Process: Hot Work, p. A23)
20

15
Slightly adapted from U.S. Department of Labor, OSHA,
“Safety and Health Injury Prevention Sheets: Working with
the Shipyard Industry;” http://www.osha.gov/dts/maritime/
sltc/ships/ships_combined.pdf (Process: Hot Work, p. A7)
16
Based on information from U.S. Department of Labor,
OSHA, “Safety and Health Injury Prevention Sheets: Working
with the Shipyard Industry;” http://www.osha.gov/dts/
maritime/sltc/ships/ships_combined.pdf
(Process: Hot Work, p. A27)
17
U.S. Department of Labor, OSHA, “Safety and Health Injury
Prevention Sheets: Working with the Shipyard Industry;”
http://www.osha.gov/dts/maritime/sltc/ships/ships_
combined.pdf (Process: Hot Work, p. A 28)
21

Chapter II:
Occupational Safety and Health Law

When workers and supervisors confront safety and


health hazards in ship/boat building and repair, they have a
right to take one or all of the following actions:
• exercise their rights under the Occupational Safety
and Health Act (OSHA);
• request the National Institute for Occupational Safety
and Health (NIOSH) to conduct an occupational
health evaluation of their workplace;
• utilize OSHA standards and resources to identify as
well as abate hazards found in ship/boat building and
repair.
The following information will focus on how workers
and supervisors can exercise their rights and responsibilities
through these approaches.

OSHA

What Is the Purpose of OSHA?


The Occupational Safety and Health Act (OSHA) was
passed by Congress in 1970 to assure, so far as possible, safe
and healthy working conditions for American
workers. OSHA is responsible for
promulgating legally enforceable
standards. Under the act, the
Occupational Safety and Health
Administration (OSHA) was cre-
ated within the Department of
Labor to enforce this statute. This federal agency seeks to
implement this responsibility through:
• “strong, fair, and effective enforcement;
• outreach, education, and compliance assistance; and
• partnerships and other cooperative programs.”1
22

Who Is Covered by This Law?


Essentially, OSHA covers all employers and employees in
the private sector within the 50 states, as well as territories and
jurisdictions under U.S. authority. Some examples include
workers and supervisors employed in construction, manufac-
turing, business, ship/boat building and repair, agriculture,
law, private educational and health care facilities, charitable
organizations, labor organizations, and private relief agencies.

Who Is Not Covered By OSHA?


Those exempt from this law’s coverage include: immediate
family members employed on a farm that does not employ
other employees; employment sectors regulated by other
federal statute such as mining, certain truck and transporta-
tion sectors, and atomic energy; the self-employed; and public
employees on the state and local levels of government
including public education.

Do Employers Have a Duty to Provide a Safe and Healthful


Workplace?
Yes. The entire act rests on the duty of the employer to
provide safe and healthy working conditions. First, the
employer “shall furnish to each of his/her employees
employment and a place of employment which are free from
recognized hazards that are causing or are likely to cause
death or serious physical harm....” Second, employers “shall
comply with occupational safety and health standards prom-
ulgated under this act.” The standards are set by the
Secretary of Labor, after notice and public hearings.
Everything else in the act focuses on these two obligations.

What Do These Obligations Include?


The first obligation is the “general duty” clause,
designed to cover all hazards which don’t fall under a spe-
cific standard or regulation. OSHA may cite violations of this
employer duty directly from the language of the act, where
no published or promulgated standard exists. The “general
duty” clause, also known as section 5(a)(1), only can be
enforced when OSHA has determined: (1) that there is no
23

standard, (2) that it is a recognized industry hazard, (3) that


the employer has knowledge of the unsafe condition; or that
the condition is of a nature that could cause death or serious
physical harm.
The second obligation is compliance with existing federal
occupational safety and health standards. These standards are
detailed and technical, and cover nearly all aspects of the job
environment with special standards for selected industries.
Employers also have a number of other legal responsibilities.
Specifically they must:
• be familiar with OSHA standards, comply with all
applicable OSHA standards, rules, and regulations,
cooperate with OSHA compliance officers; and abate
any cited OSHA violations within the time required;
• provide OSHA-mandated training, keep employees
informed about OSHA as well as safety and health
matters concerning them; and, upon request, provide
employees with copies of OSHA standards;
• provide workers with tools and equipment that are
safe, along with personal protective equipment that is
adequate and used properly when needed;
• establish and maintain a system to warn employees of
potential hazards; this includes an evaluation of work-
place conditions, and abating potential hazards;
• maintain updated operating procedures and insure
effective communication of them to employees;
• establish and maintain records of work-related
injuries and illnesses; this includes keeping track of
these incidences through the OSHA Log of Workplace
Injuries and Ilnesses (OSHA 300), posting a copy of
the OSHA 300A form, which is a Summary of Work
Related Injury and Illnesses from February 1 to April
30 of the previous year; and providing current and
past employees, as well as their representatives with
access to the previously cited log.
• under law, provide required medical examinations,
and also provide employees and others with access to
medical and exposure records of employees;
24

• post the following: “OSHA, It’s the Law” poster


(OSHA 3165), and any OSHA citations and abatement
notices at or near the workplace or worksite involved;
• report to the nearest OSHA office within eight hours
any fatal accident or one that results in the hospital-
ization of three or more employees.2

What Are the Duties of Employees Under This Law?


Each employee also is required to comply with occupa-
tional safety and health standards and “all rules, regulations,
and orders issued pursuant to this act which are applicable to
his/her own actions and conduct,” such as wearing appro-
priate personal protective equipment, and following proper
procedures. Employees also have a responsibility to report
any of the following to their employer: hazardous conditions,
and any job-related injury, illness, or fatality. Employees also
must cooperate with OSHA compliance officers.

What Rights Do Employees Have Under OSHA?


In addition to the general right to a healthy and safe
workplace or worksite, other specific employee rights under
this law include the right to know about the hazards of their
jobs; the right to refuse to work under certain specific circum-
stances; and the right to complain to OSHA to have their
workplace or worksite inspected. The next three sections
describe these rights in more detail.

Right-to-Know
OSHA requires all employers to inform employees about
workplace or worksite hazards, on the necessary precautions
to be taken when working around these hazards, and emer-
gency procedures that must be followed relating to these
hazards. Employees also have the right to: (a) “observe any
monitoring or measuring of hazardous materials, and see
any related monitoring or medical records;” and (b) review
the log and summary of work-related injuries and illnesses
documented by their employer in OSHA forms 300 and
300A.3
25

Additional resources and approaches for enabling


employees to obtain practical, important information on
work hazards include:

Material Safety Data Sheets


Any company that manufactures, imports, or distributes
hazardous chemicals must provide a material safety data
sheet (MSDS) to the employer to which they ship those
chemicals. The MSDS must list the chemicals’ properties and
dangers, the proper means of handling them, appropriate
medical treatment in case of exposure, fire and explosion
limit information, dangerous chemical reactions, acute and
chronic health hazards, handling and labeling disposal proce-
dures in case of accidents, and how to avoid exposure.
Manufacturers, distributors, and importers of chemicals
have to label all hazardous containers. Labels must identify
the chemical, warn of potential dangers, and provide the
name and address of the manufacturer, distributor, or
importer. Appendix III provides more information on
Material Safety Data Sheets.

Training
OSHA requires employers to provide employees with
information and training on work hazards that is both adequate
and effective. Specifically, “employees who are exposed to
serious hazards must be trained so that they are able to assist
in protecting themselves and other employees.”4 In addition
to being relevant and applicable to the occupational health
and safety conditions of the workplace, according to OSHA,
basic topics that need to be
included in this training involve:
• “the nature of the hazards to
which the employee is expo-
sed and how to recognize
them;
• what the employer is doing
to control these hazards;
26

• protective measures that the employee needs to follow


to prevent or minimize exposure to these hazards;
• procedures to be followed in an emergency;
• the employer’s safety and health program and the
employee’s role in that program, including opportuni-
ties to participate in it.”5

Right to Refuse
The federal OSHA law stipulates that workers have a
right to refuse to do a job under certain specific circumstances
when they believe “a danger exists which could reasonably be
expected to cause death or serious physical harm immedi-
ately.” In other words, a hazard must be both serious and
imminent. For example, a boiler about to explode is clearly an
“imminent danger.” On the other hand, a long-term exposure
to toxic substances may not meet the “imminent danger”
classification because there would normally be sufficient
time to have such a hazard abated through regular OSHA
inspection procedures.
When an “imminent danger” condition is discovered by
an employee, he/she should act immediately by contacting a
supervisor, and union representative if a member of a union.
If the condition or act is not corrected, and the worker then
chooses to exercise the right to refuse in this imminent danger
situation, it is very important that they tell their supervisor,
preferably with another person present, that while they are
refusing to work at that location or function which places
their life in immediate imminent danger, they are willing to
continue to work at another location or function that does not
pose an imminent danger.
Also, if an “imminent danger” situation is not remedied,
the OSHA Area Office should be contacted. If the compliance
officer determines an “imminent danger” exists, the official
will attempt to have the employer abate the condition.
Failing to accomplish such action, the OSHA official can then
initiate legal action with the Secretary of Labor’s office.
27

Right to Complain
If a workplace or site is unsafe or unhealthful, a number
of corrective actions can be taken. First, where possible, the
most expedient and fastest way to abate a hazard or correct a
violation is to bring it to the attention of the employer. If this
is not possible or has not worked, employees have the right to
complain to OSHA, and request an inspection or investiga-
tion. Employees can do this via the phone, mail, fax, e-mail,
or online. A complaint can be initiated by calling this federal
agency at 1-800-321-OSHA(6742), or contacting the nearest
regional, area, or state office of OSHA, or through an OSHA
consultation office at www.osha.gov.6 Employees also have
the right to have their name withheld from their employer if
they file an OSHA complaint.

What About OSHA Investigations and Inspections?


Investigations
OSHA responds to complaints by conducting either on-site
inspections or off-site investigations. Generally, complaints
involving “low-priority” hazards that are filed by phone, fax,
e-mail, or online, are dealt with through OSHA’s off-site,
phone/fax investigation approach. The following summa-
rizes OSHA’s procedures when conducting this approach:
After receiving this type of a complaint, OSHA contacts
the employer by phone, describes the alleged hazard, and
confirms the contact with a follow-up letter or fax to the
employer. Within five days, the employer must provide a
written response that describes any problems and/or haz-
ards found to exist along with the corrective actions initiated
or planned. If OSHA finds the employer’s written response
to be adequate in addressing and correcting the hazard, an
inspection will not be conducted. OSHA also provides the
employee or employee representative who filed the complaint
with a copy of the employer’s written response. If this indi-
vidual does not find the employer’s response and corrective
actions to be satisfactory for correcting the hazard or problem,
they have the legal right to request that an on-site OSHA
inspection be conducted. According to OSHA, employees do
28

not give up this inspection right if they are not satisfied with
a phone/fax investigation.7
Inspections
Any of the following conditions will trigger an OSHA
inspection:
• a written, signed complaint, from an employee or
employee representative, claiming that an “imminent
danger” exists, or that an OSHA violation exists that
could cause serious harm or death;
• inadequate response from an employer to a previous
OSHA phone/fax investigation;
• “imminent danger” situation or condition (OSHA
places a top priority on taking immediate and correc-
tive actions in cases of “imminent danger”);
• accident resulting in the death of an employee or the
hospitalization of three or more workers;
• “planned or programmed inspections” in employment
sectors with statistically high incidences of occupa-
tional hazards and related injuries;
• follow-up or check-up inspections to OSHA inspec-
tions conducted previously.8

How Are OSHA Inspections Conducted?


An OSHA inspection consists of four parts. First, an
OSHA compliance officer arrives at the workplace or site, and
presents credentials to a designated employer representative.
Next, an opening conference is held to enable this official
to explain the purpose of the inspection and why it is being
conducted. Also, during this meeting the employer and
employees select their respective representatives to accom-
pany the compliance officer during the walkaround part of
the inspection. If one exists, a union designates this employee
representative.
The third part is the inspection itself, which may involve
only an inspection of a specific complaint or problem area, or
it may involve an inspection of the entire work establishment
or site. Work areas, processes and procedures, tools, equip-
29

ment, machinery, and any other relevant factors are inspected


for both hazards and violations. During this inspection, the
compliance officer may consult with the employer and
employee representatives, as well as other employees in both
labor and management. This official also checks and monitors
whether the employer has maintained records properly on
work-related injuries, deaths, and illnesses required by
OSHA (discussed previously). Records also are reviewed
regarding employee exposure to dangerous substances and
materials.
The fourth part consists of the closing conference where
the compliance officer meets with the employer and employee
representatives together or separately. At this conference or
conferences any unsafe or unhealthful conditions identified
during the inspection are discussed along with “all apparent
violations for which a citation may be recommended.”9 In
addition, both employers and employees are informed of their
respective rights and responsibilities after the inspection.10

What is an OSHA Citation?


A citation is issued when a violation of OSHA is found as
a result of an inspection. The citation serves to inform both
labor and management about the specific OSHA standards
and regulations that have been violated. Also, it identifies
any hazardous conditions that need to be abated that are
covered by the general duty clause of the law, the proposed
time allowed for the violations and hazard(s) to be abated,
and the proposed penalties to the employer.11

What Rights Do Employers Have After an OSHA


Inspection?
After an OSHA inspection has been conducted, employers
have the right to:
• contest an OSHA citation, abatement time, or proposed
penalty within 15 working days of its receipt;
• within this 15-working-day contest period, request an
informal conference with the OSHA area director, who
is authorized by OSHA “to reach settlement agreements
30

with employers that adjust citations, and penalties to


avoid prolonged legal disputes;”12
• the protection of the confidentiality of trade secrets
observed by any OSHA compliance officer during an
OSHA inspection;
• apply for a temporary variance from a standard if
compliance is not possible due to unavailability of
materials, equipment, or personnel needed to institute
the necessary changes in the specified time;
• apply for a permanent variance from a standard if
proof can be supplied that the employer’s facility,
operation, procedures, working conditions, and
approach provide protection that is at least as safe and
healthful as the OSHA standard;
• appeal an OSHA citation, proposed abatement period,
and penalty to an administrative law judge assigned
to the case by an independent federal agency known
as the Occupational Safety and Health Review
Commission. Any party involved in the case, including
individual Commission members, also can request a
further review by the entire three-member Commission
itself. And, the Commission’s rulings can be appealed
to a U.S. Court of Appeals.13

What Rights Do Employees Have After an OSHA


Inspection?
After an OSHA inspection, employees also have a number
of specific rights. These include the right to:
• have a separate closing conference with the compliance
officer to discuss matters of employee concern relating
to occupational health and safety in the workplace;
• request an informal conference with OSHA in order to
discuss any findings, concerns, or issues identified
during the inspection, including but not limited to any
impending citation, proposed penalty, or employer
contest; this informal conference has to be conducted
by OSHA within the 15-working-day contest period.
31

• request an informal review of any decision issued by


OSHA when this agency has decided not to issue a
citation after an inspection based on an employee’s
complaint;
• contest the hazard abatement time stipulated in an
OSHA citation;
• contest an employer’s request to extend the hazard
abatement period which is filed as a “Petition for
Modification of Abatement (PMA);”14 this has to be
done within 10 days after workers or their representa-
tive have received a copy of this PMA.
• participate in any hearing to appeal an OSHA citation,
abatement period, and proposed penalty.15

What are the addresses, phone, and fax numbers of the


OSHA offices in Maine?
U.S. Department of Labor U.S. Department of Labor
OSHA Augusta Area Office OSHA Bangor District Office
Federal Building, Room G-26 Federal Building, Room 240
40 Western Avenue 202 Harlow Street
Augusta, Maine 04330 Bangor, Maine 04401
Phone: 626-9160 Phone: 941-8177
Fax: 622-8213 Fax: 941-8179

What Do OSHA Standards Cover?


In addition to the general-duty clause, OSHA has estab-
lished safety and health standards that cover virtually all con-
ceivable aspects of the work environment. Examples include:
• control of ventilation, temperature,
and noise levels;
• hazard communication;
• keeping the workplace clean and
orderly;
• emergency exits, fire protection,
sprinklers, and evacuation plans;
• confined spaces and excavations;
Source: www.iwitts.com
by permission • medical and first-aid treatment;
32

• handling and storage of compressed gas, radiation,


flammable materials, explosives, toxic materials, haz-
ardous substances and wastes;
• personal protective equipment, and fall protection;
• training procedures;
• electrical standards;
• general working conditions (waste disposal, toilets,
showers, dressing rooms, and food handling).
The standards also set limits for air contaminants, fumes,
and exposure to toxic chemicals. Periodic testing and moni-
toring of certain substances is required. Some examples are
asbestos, dust, radiation, and carbon monoxide. As cited pre-
viously, when monitoring is required, employees have a
right to observe the testing and have access to the records
which indicate exposure to toxic or harmful materials.
The requirements specified in OSHA standards go
beyond the traditional use of safety glasses, steel-toed shoes,
and ear plugs. For example, OSHA standards can require
changes in work practices, the environment, and machinery
and not simply personal protective equipment, which also
may be needed and required. When the Occupational Safety
and Health Act was passed and as it has evolved, it has been
accepted that the solution to occupational health and safety is
not layer after layer of personal protection, but basic systemic
and structural changes in job environments, practices, and
any other relevant factors.

Which OSHA Standards Apply to Shipyards and Boatyards?


Shipyards
OSHA’s 1915 standards “apply to all ship repair, ship-
building, and shipbreaking employments, and related
employments on the navigable waters of the U.S. (including
dry-docks, graving docks, and marine railways) or at facilities
located adjacent to navigable waters.”16 “Subpart B –
Confined and Enclosed Spaces and Other Dangerous Atmospheres
in Shipyard Employment, and Subpart I – Personal Protective
Equipment, apply to shipyard employment work in vessels
33

and vessel sections and on land-side operations regardless of


geographic location.”17
For clarification, in its directive OSHA points out how,
when a shipyard hazard exists and the 1915 standard cover-
ing it is either limited or nonexistent, then OSHA’s applicable
Part 1910 general industry standard would apply.18
Boatyards
Employees and employers engaged in “boat building,
repairing, or breaking operations, and related activities on or
adjacent to a navigable waterway of the U.S.,” also are covered
by the previously cited OSHA Part 1915 shipyard standards,
and applicable Part 1910 general industry standards.19
However, OSHA’s Shipyard Toolbag Directive of October
2003 allows manufacturers of mass-produced recreational
boats that do happen to need a water launch to comply
under 1910 rather than 1915, at their discretion. Otherwise,
the “navigable waters” ruling still applies.
Boatyards that are not adjacent to or located on naviga-
ble waters of the U.S. are covered by OSHA’s 1910 standards.
This includes enterprises performing boat building, repair,
breaking, and related activities, including recreational boats.

What About OSHA’s General Duty Clause?


It is important to remember that for identified hazards
not covered by a specific OSHA standard, then OSHA’s
General Duty Clause, 5(a)(1), is applicable to both shipyards
and boatyards.

Are Shipyards and Boatyards Covered under OSHA’s


Hazard Communication Standard?
Yes, boatyards covered by 1910 standards are covered by
this standard. Also, the requirements specified in OSHA’s
Hazard Communication standard in the shipyard industry
“are identical” to those specified in the 1910.1200 general
industry standard on hazard communication.20 Appendix III
provides an informational overview on this standard as well
as Material Safety Data sheets.
34

Can a Worker be Disciplined or Penalized for Filing an


OSHA Complaint?
No. It is illegal for a worker to be disciplined or punished
for filing an OSHA complaint. Although a copy of the com-
plaint will be presented by the compliance officer to the
employer, the person complaining may have his or her name
kept confidential. The complaint form provides a signature
line which will not be revealed to the employer. Even if an
employer knows who is invoking the OSHA complaint, the
employee is given legal protection under section 11(c)(1) of
the law, which states: “No person shall discharge or in any
manner discriminate against any employee because such
employee has filed any complaint or instituted any proceed-
ing under... this act... or because of the exercise... of any right
afforded under this act.”21 If the employee notifies the
Secretary of Labor or a local OSHA office within thirty days
of any act of discrimination, the Secretary can investigate the
complaint and go to federal district court to get appropriate
relief including rehiring or reinstatement with back pay.

Can OSHA Ever Give Employers Advance Notice for an


Inspection?
Yes, but only under special circumstances which include:
• imminent danger situations which require swift
correction;
• inspections that must take place after regular business
hours, or that require special preparation;
• cases where notice is required to assure that the
employer and employee representative(s), or other
personnel will be present; and/or
• situations in which the OSHA area director determines
that advance notice would produce a more thorough
or effective inspection. In such a case, employers must
inform their employees’ representative or arrange for
OSHA to take this action.
35

Determining and Evaluating Occupational Health Hazards


Through NIOSH
In addition to working with OSHA on routine hazards,
those employed in ship/boat building and repair also can
utilize the resources of the National Institute for Occupational
Safety and Health (NIOSH) for identifying and evaluating
new or challenging health hazards on the job. An employee,
employee representative, and employer have the right to
request a Health Hazard Evaluation from NIOSH when any
of the following conditions apply:
• “employees have an illness from an unknown cause;
• employees are exposed to an agent or working condition
that is not regulated by OSHA;
• employees experience adverse health effects from
exposure to a regulated or unregulated agent or work-
ing condition, even though the permissible exposure
limit is not being exceeded;
• medical or epidemiological investigations are needed
to evaluate the hazard;
• the incidence of a particular disease or injury is higher
than expected in a group of employees;
• the exposure is to a new or previously unrecognized
hazard;
• the hazard seems to result from the combined effects
of several agents.”22
The typical NIOSH health hazard evaluation involves an
onsite visit of the workplace where a trained NIOSH official
first meets with the employer and employees to discuss the
problem(s). While observing the work areas as part of this
evaluation, this official can interview employees and super-
visors, review records regarding the hazard and employee
exposure, and conduct any necessary medical tests including
the utilization of NIOSH sampling devices. All of this can
involve several visits. After its study is completed, NIOSH
submits its findings to OSHA, the employer, and affected
employees as soon as possible. The findings and recommen-
dations contained in this report are not enforceable. Rather,
36

they are advisory and comprise a useful source for enabling


an employer to address any problems or hazards identified
in the evaluation.
Information to request a NIOSH health-hazard evaluation
can be provided by contacting NIOSH via:
Phone: 1-800-35-NIOSH (1-800-356-4674)
Fax: 513-841-4488
Mail: NIOSH, Hazard Evaluation and Technical
Assistance Branch
4676 Columbia Parkway, R-9
Cincinnati, Ohio 45226
E-mail: Using the form available through the NIOSH
home page by going to: HHE Request Form.

What On-site Consultation


Services are Available to Small
Businesses?
Upon request, consultation
services can be provided to small
employers seeking occupational
health and safety assistance at their
workplace or site. Because the
program is funded by OSHA, there is no cost to an employer
who requests it. This service is designed to provide a thorough
“appraisal of all work practices and environmental hazards
of the workplace and all aspects of the employer’s present
job safety and health program.”23 These confidential consul-
tation services, which are completely separate from OSHA’s
enforcement functions, are administered in Maine by the
Safety Division of the Maine Bureau of Labor Standards
(Phone: 207-624-6460). Since this program is a consultation
service, no penalties or citations can be issued for any occu-
pational health and/or safety problems identified during the
process.24
37

Chapter II:
Case Study Exercises

Instructions: For each of the following case study exer-


cises, select a team spokesperson who will be responsible for
summarizing and reporting on your group’s findings and
recommendations:

Case I
As a group, develop strategies on how labor and man-
agement can work together to achieve a healthful and safe
workplace or site by exercising their rights and responsibili-
ties under the Occupational Safety and Health Act.
38

Case II
At the XYZ Ship and Boat Company employees often
work below a crane while heavy objects are being moved and
placed overhead. There is a rule against doing this while the
crane is in operation, but the company doesn’t enforce it and
the workers want to make more money. Three months ago a
worker was injured severely when a piece of steel slipped off
a hook that lacked a safety latch. Hoists for moving objects
are used far above capacities. A number of employees are
very worried about their safety, but also need the money.
1. What rights do these employees have in this highly
dangerous situation?
2. When exercising these rights, what are the correct pro-
cedures that should be followed by these workers?
3. What should management do in this case?
4. In the future, what approaches and procedures need
to be adopted by labor and management to ensure
greater protections against abnormally dangerous
work situations?
39

Case III
Identify the chemical hazards where you work.
1. How can labor and management work together to
educate each other about the hazards posed by these
chemicals, and the proper safeguards to employ when
using and storing them?
2. Develop a specific strategy utilizing OSHA’s Hazard
Communication Standard and Material Safety Data
Sheets (MSDS) outlined in Appendix III.
40

Case IV
Recently, a boatyard has started using a new chemical
compound in the coating of its fiberglass boats. As this chem-
ical is being applied, a number of employees have com-
plained that it causes dizziness and nausea.
1. What can the employees and employer of this yard do
about this situation?
2. Which government agencies can provide assistance,
and how can they be utilized effectively?
41

Endnotes

1
Occupational Safety and Health Administration, U.S. Dept.
of Labor, All About OSHA, Occupational Safety and Health
Administration, OSHA 2056-08R, 2003. p. 21.
2Ibid., p. 4-5.
3
Ibid., p. 6.
4
OSHA, U.S. Dept. Of Labor, Shipyard Industry, OSHA 2268,
1998 (Revised), p. 9.
5
Ibid., p. 10.
6Occupational Safety and Health Administration, U.S. Dept.
of Labor, All About OSHA, Occupational Safety and Health
Administration, OSHA 2056-08R, 2003. p. 7.
7
Ibid., p. 7, 22. This section is a summary of the detailed
OSHA inspection procedures cited on these pages.
8
Ibid., p. 22-23.
9
Ibid., p. 25.
10
Ibid., p. 23-26 provide detailed information on the entire
OSHA inspection process.
11
Ibid., p. 25.
12 Ibid., p. 28.
13 Ibid., p. 15, 27-29.
14
Ibid., p. 28.
15 Ibid., p. 25, 27-29.
16
U.S. Dept. of Labor, OSHA, “OSHA INSTRUCTION,”
Effective Date: 10/22/03, Appendix A, p. A-1.
17
Ibid.
18
Ibid., p. A-2.
42

19
Ibid., p. 15.
20
OSHA, U.S. Dept. Of Labor, Shipyard Industry, OSHA 2268,
1998 (Revised), p. 192.
21
Occupational Safety and Health Act, P.L. 91-596, 1970, and
amended by P.L. 101-552, 1990, Sec. 11(c)(1), p. 14.
22
NIOSH Home Page, NIOSH Health Hazard Evaluations,
p. 2.
23
OSHA, U.S. Dept. Of Labor, Shipyard Industry, OSHA 2268,
1998 (Revised), p. 194.
24
Ibid.
43

Chapter III:
Attaining Health and Safety in Ship and Boat Yards

This chapter consists of two parts. The first deals with


labor-management safety and health committees, and sug-
gested safety structures, for attaining as well as maintaining
healthful and safe worksites. The second section supplies
information on occupational health and safety resources
available to labor and management in the ship/boat building
and repair industry.

Labor-Management Health and Safety Committees


Joint labor-management committees often can serve as an
efficient means for workers and managers to work coopera-
tively in the abatement of job hazards and
the resolution of disputes over
occupational health and safety.
However, this joint committee
approach only is useful when
both sides are willing to make
an honest and concerted
effort to maintain safe and
healthy working conditions
and eliminate job hazards.
The following recommendations are important criteria for
determining the effectiveness of this type of an approach:
1. In terms of representation, a labor-management safety
committee should be comprised of an equal number of
labor and management. It is a good idea to have at least
1 or 2 members of any worker safety committee serve
on this joint committee in addition to other employees.
2. The committee should be co-chaired by one member
representing workers and one representing manage-
ment. Meetings should be held at the call of either co-
chair or at the request of any member. However, at least
one meeting should be held every month to discuss
health and safety conditions at the worksite. For larger
organizations it is often helpful that a set day and time be
44

established for the monthly safety committee meeting


(e.g., the second Thursday of every month at 1:00 p.m.).
This sets an expectation within the organization that a
specific day and time have been set aside to focus solely
on the efforts of the safety committee. This method
establishes a priority on the meeting calendar for
planning purposes. Also, there should be an agenda
and fixed length established for every meeting, with
each session starting and ending on time.
3. The purpose of this body should involve formulating
and implementing an effective safety program
throughout the worksite. In addition, the safety com-
mittee provides the overall direction to the organiza-
tion by setting realistic goals, reviewing applicable
OSHA standards, and establishing the vision neces-
sary for improved safety performance.
4. Each member should have mobility within designated
sections of the worksite to move around, observe, and
interview employees and supervisors about occupa-
tional health and safety problems. Safety committee
members should establish a specified safety and
housekeeping inspection program where safety com-
mittee members are actively involved in performing
worksite safety and housekeeping inspections on a
rotating schedule. If the committee is working within
a large organization the areas inspected may have to
be broken up into segments. Each area should be
inspected at least quarterly.
5. Follow-up meetings should be held to ensure that pre-
viously identified hazards and safety problems have
been corrected, with written documentation of all activ-
ities completed. Follow up on identified deficiencies
may be done by reviewing work orders, checking off
items completed against the inspection list, or by par-
ticipating in work planning sessions so that priorities
may be set on items identified during the inspection.
6. All committee members should be compensated for the
time spent on all safety committee functions. This
45

would include not only time spent at meetings, but also


time spent on inspections, handling safety complaints,
and disseminating information on occupational safety
and health.
7. The composition of the committee also is a direct
determinant of its effectiveness. It is very important to
have representatives of employees and management on
the committee who are in a position to resolve safety
hazards and problems as they arise.

Safety and Health Committee Roles


Safety and health committees can play a number of effec-
tive and useful roles, which can include:
1. Reviewing safety statistics and trends;
On a monthly basis the safety committee should be
updated on the injury and illness incident rate for the
previous month, types of accidents that occurred during
the month and preventive measures implemented, and
historical injury data for the upcoming month to prevent
recurrence of previous experiences (e.g., heat stress,
exposure to cold, major impacts to work systems from
shutdowns, start ups, contractors). At this time the safety
committee needs to review where the safety effort is in
relation to goals that were established for the year. All
of this information needs to be communicated to all
employees on a monthly basis, so that all members of the
organization will become active participants in the safety
effort.
2. Educating employees and supervisors about the law;
Committee members can play a key role in educating
employees and supervisors about their rights and
responsibilities under the Occupational Safety and
Health Act and the OSHA standards. When performing
this function committee members are in an excellent
position to organize needed training programs on new
changes and developments in these legal areas.
46

3. Recommending approaches on safety and health issues;


By providing an avenue of communication between
employees and managers as well as serving as an infor-
mational resource, safety committees can recommend
solutions to health and safety problems, by addressing
bottlenecks that may occur, and providing the right
resources to address specific issues.
4. Preventing workplace hazards;
Health and safety committees also can help to reduce
accidents, injuries, and occupational disease by playing a
role in preventing job hazards from occurring in the first
place. By having access to information regarding employer
health and safety records, right-to-know data on danger-
ous workplace chemicals and substances, and workplace
injury and illness reports, committee members are in an
excellent position to identify problem areas, analyze
alternatives, and recommend solutions. Accident reports
(without employee names) or news accounts about other
facilities, also may be used as an informational tool to
reinforce the message on preventing workplace hazards.

Determining the Size of the Committee


The appropriate size of a committee depends upon such
factors as the size of the employee workforce, the number
and variety of health and safety problems which exist at the
worksite, the number of shifts in which workers are
employed, and the size of the work area. Essentially, the
exact size of the committee should be based upon the number
of individuals needed to deal with health and safety problems
efficiently and promptly. While such a committee should be
comprised of at least four members, excessively large com-
mittees should be avoided.1

Selection of Committee Members


Committee members should be selected or elected based
upon the following important criteria: 1) their interest and
commitment in working towards the achievement of a safe
47

and healthy working environment, 2) their practical experi-


ence and knowledge in dealing with occupational safety and
health problems, and 3) their willingness to participate in
training programs designed to broaden their expertise in the
field of occupational health and safety.2 Committee members
should serve under staggered term limits in order to ensure
greater participation and continuity.

Preparing Committee Members3


In order to operate efficiently and effectively, committee
members need to be knowledgeable and trained in all
aspects of the safety and health tasks associated with their
work. In addition, members should have the following infor-
mation and resources:
1. past and current records on job-related accidents,
injuries, and diseases on that worksite;
2. basic resource material on OSHA, including the law
itself, and all appropriate safety and health standards,
digests, and pamphlets;
3. worksite occupational health and safety problems iden-
tified by labor and management through the adminis-
tration of a hazard recognition survey questionnaire;
4. bibliographical and audio-visual resources dealing
with occupational health and safety in ship and boat
building;
5. a computer linked to the Internet in order to access
current resources and contacts on occupational health
and safety in ship and boat building;
6. a listing of the names, addresses, and phone numbers
of occupational health and safety resource people,
including federal and state OSHA officials, physi-
cians, attorneys, industrial hygienists, educators, and
any other health and safety specialists who can pro-
vide resource information and assistance to commit-
tee members; and
7. information on available meeting and training oppor-
tunities for learning about trends and developments in
the occupational health and safety field. Committee
48

members should plan on attending at least one training


program per year.

Suggested Safety Structures for Shipyards and Boatyards


Outlined below are suggestions on how a ship/boat yard
may choose to organize a formal safety structure at the work-
site. This outline is very comprehensive and may not apply
to all yards. The best structure for any particular yard depends
on the size and the current health and safety needs of the
yard. Therefore, it is up to the individual yard to establish a
safety structure that will best serve the yard and its employees
to support the health and safety effort.

Safety Department
For larger yards a full-time safety professional may be on
staff to work with all departments within the yard on health
and safety issues. For smaller yards these responsibilities
may be assigned to either designated individuals with other
responsibilities or to supervisors/managers.

Safety Coordinator
A safety coordinator may be needed to assist the person
with designated safety responsibilities in the yard. This posi-
tion may be of limited duration during a time of need or it
may be a full-time commitment. Typically this person main-
tains a presence “on the floor” and attends to specific duties
required of the position.

Safety Committee
The role of the safety committee is to provide goals and the
vision necessary to improve health and safety in the work-
place. This committee should
meet once a month to review
safety statistics from the previ-
ous month, receive updates
from active sub-committees,
respond to proposals from
members, discuss and address
health and safety issues that
49

have surfaced, and oversee the safety effort year-to-date


based upon goals established at the beginning of the year.

Sub-Committees
To support the safety committee several subcommittees
may need to be formed to address specific areas of health and
safety. A sub-committee should be activated to look at issues
that need to be reviewed and make recommendations to the
safety committee for action. Once a sub-committee’s work has
been completed the sub-committee may be deactivated until
its services are needed on future issues. To provide continuity
at least one member of any given sub-committee also should
be a member of the safety committee. Examples of subcom-
mittee activity might be in the following areas: a) proposed
new OSHA standards, b) communications, c) training,
d) inspections and follow up, e) safety policy review.

Yard Safety and Housekeeping Inspections


On at least a quarterly basis, all areas of a shipyard or
boatyard should receive a safety and housekeeping inspection.
These inspections should be comprehensive in nature to
cover areas such as employee training, welding/burning
permits documentation, confined space entry permit review,
lockout audit, life safety equipment inspections, chemical
labeling and disposal, and physical and health hazards identi-
fied by a walk-around inspection.

Department Safety and Housekeeping Inspections


On a monthly basis each department within the yard
should hold its own safety and housekeeping inspection.
These inspections should serve as a learning tool for depart-
ment employees to build upon findings performed by the
quarterly yard inspections. From the yard inspections
department employees will learn hazard awareness and
methods of preventing hazards from recurring in the future.

Crew Safety Representative


The crew safety representative is a person who serves as
designated point of contact for employees within a work
50

group. In some cases employees may be hesitant to make


direct contact with a supervisor or manager and may be
more at ease bringing issues to a designated person in the
work group. Typically the crew safety representative is a part
of the work group. The crew safety representative works
with the department supervisor to address health and safety
issues in the work area. It is important that the supervisor
and the yard provide the support necessary for the crew safety
representative to succeed.

Monthly Department Safety Meetings


Every department in the yard should hold a monthly
safety meeting with all department employees. The monthly
safety topic may be selected by the yard safety representative
or the department supervisor, depending on the standard
that has been established. In addition to a monthly safety
topic the monthly meeting should be a place where safety
goals are reviewed to give an indicator of performance and
any accidents and preventive measures that have taken place
over the previous month. At this meeting employees also
should have the opportunity to bring up any safety issues or
concerns that may need to be addressed.

Toolbox Safety Review


At the start of each work day or shift a brief discussion
of the day’s upcoming activities should take place. This is a
good opportunity to use the “Worksite Systems” approach to
make employees aware of activities that may affect their
work which are outside of the normal day-to-day operations,
or activities they perform which may affect others. Depending
on the particular work plan for the day this is also a good
opportunity to focus on specifics such as condition of hand
tools, cleanliness of glasses, goggles, and respirators, or other
items that may be in use that particular day. This is also a
very useful time to stress the importance of planning and
coordinating jobs that may be particularly hazardous — so
that everyone is on the same page regarding what needs to be
done and how it should be done in terms of health and safety.
51

Ship/Boat Building and Repair


Safety and Health Resources

Internet Resources
State of Maine:
Maine Department of Labor:
http://www.state.me.us/labor/SafetyWorks
http://www.safetyworksmaine.com/consultations/index.html
Maine Safety Council
http://www.mainesafety.org
The Council promotes safety, health, and accident pre-
vention in Maine through education and training. It also
serves as a resource for safety and health and educational
materials for the workplace, the highway, and the home.
Maine Department of Labor publications and resources page:
http://www.safetyworksmaine.com/videos-pubs/index.html
OSHA, NIOSH, Other Government Resources:
http://www.cdc.gov/niosh/ergship/ergship.html
Ergonomic interventions in the building, repair, and dis-
mantling of ships.
http://www.osha.gov/SLTC/etools/shipyard/index.html
Innovative OSHA etool for shipyard industry, focusing on
ship repair. Extensive information on respective
ship repair processes and associated
hazards. Look for future development
of etools for shipbuilding and ship-
breaking, not yet available on this
page. (eTools are “stand-alone,”
interactive, Web-based, highly visual
training tools on health and safety.)
http://www.osha.gov/SLTC/shipbuildingrepair/index.html
OSHA page on shipbuilding safety, hazards, compliance
issues.
52

http://www.osha.gov/SLTC/etools/shipyard/glossary.html
Glossary of technical terminology for shipyard topics.
http://www.osha.gov/dcsp/vpp/index.html
Information on OSHA Voluntary Protection Program for
employers.
http://www.osha.gov/pls/oshaweb/owadisp.show_document?
p_table=DIRECTIVES&p_id=3060
Shipyard “Toolbag,” clarifies relationship of Part 1915 to
Part 1910 for boat builders.
http://www.osha.gov/pls/videos/videoloan.list
OSHA video loan information. OSHA videos may be
freely copied.
http://www.osha.gov/OshDoc/toc_fact.html
Links to OSHA fact sheets, including Spanish versions.
http://www.osha.gov/dts/maritime/
“OSHA Assistance for the Maritime Industry” — extensive
links to resources and information for maritime employers
and workers.
http://www.osha.gov/dts.maritime/sltc/ships/ships_
combined.pdf
Safety and Health Injury Prevention Sheets (SHIPS), jointly
developed by the shipyard community and OSHA. An
important resource.
http://www.osha.gov/pls/publications/pubindex.list
Order or download OSHA pamphlets, required posters,
and other publications.
http://www.chemsafety.gov
Federal information on chemical accidents, investigations.
http://www.ilpi.com/msds/index.html
This is a handy reference site for Material Safety Data
Sheet information. Note, however, that this site should not
be used in place of the hardcopy data sheets. Hardcopy data
sheets should always be on hand in case of power failures.
53

OSHA Print Resources That May Be Ordered or


Downloaded (See Also the Internet Resources Section
For More OSHA Publications):

The following OSHA resources, as indicated, can be found at:


http://www.osha.gov/pls/publications/pubindex.list
This publications page lists which resources may be
ordered or downloaded in html or pdf (Adobe Acrobat
Reader) format. Single copies of up to five publications
may be selected and ordered from the page. For the
electronic downloads, file size for Acrobat Reader
(pdf) versions are provided with the citations here.

If you do not have Acrobat Reader,


you may download a free copy from:
http://www.adobe.com/products/acrobat/readstep2.html

Some resources are also available from Fogler Library


at the University of Maine, Government Documents;
call numbers are provided with the citations. Use web-
site resources for newest revisions. Note: some Fogler
Library records have direct link to electronic file.
U.S. Dept. of Labor, Occupational Safety and Health Admin.
All About the Occupational Safety and Health Administration.
Washington, DC: DOL/OSHA, 2003. (OSHA 2056-08R).
Orono Government Documents, L 35.2:OC 1/2/994 (1994 rev.)
http://www.osha.gov/pls/publications/pubindex.list
Order, or download, 252 KB. Free resource.
This booklet gives general background on such topics as the
history and purpose of OSHA, the law, state programs, stan-
dards and guidance.
U.S. Dept. of Labor, Occupational Safety and Health Admin.
Asbestos Standard for the Shipyard Employment Industry.
Washington, DC: DOL/OSHA, 2002. (OSHA 3145 Revised).
Orono Government Documents, L 35.2:AS 1/5
http://www.osha.gov/pls/publications/pubindex.list
Order only, no electronic version. Free resource.
54

U.S. Dept. of Labor, Occupational Safety and Health Admin.


Crane or Derrick Suspended Personnel Platforms.
Washington, DC: DOL/OSHA, 2002. (OSHA 3100, Revised).
Orono Government Documents, L 35.2:C 85/2002
http://www.osha.gov/pls/publications/pubindex.list
Order, or download, 205 KB. Free resource.
U.S. Dept. of Labor, Occupational Safety and Health Admin.
Model Plans and Programs for the OSHA Bloodborne Pathogens
and Hazard Communications Standards.
Washington, DC: DOL/OSHA, 2003. (OSHA 3186-06R)
Orono Government Documents, L 35.2:B 62/2003
http://www.osha.gov/pls/publications/pubindex.list
Order, or download, 521 KB. Free resource.
U.S. Dept. of Labor, Occupational Safety and Health Admin.
Control of Hazardous Energy: Lockout/Tagout.
Washington, DC: DOL/OSHA, 2002. (OSHA 3120, Revised)
Orono Government Documents, L 35.2:H 33/4/997 (1997 rev.)
http://www.osha.gov/pls/publications/pubindex.list
Order, or download, 174 KB. Free resource.
U.S. Dept. of Labor, Occupational Safety and Health Admin.
OSHA Inspections.
Washington, DC: DOL/OSHA, 2002. (OSHA 2098, Revised)
Orono Government Documents, L 35.2:IN 7/996 (1996 revision)
http://www.osha.gov/pls/publications/pubindex.list
Order, or download, 461 KB. Free resource.
U.S. Dept. of Labor, Occupational Safety and Health Admin.
Respiratory Protection.
Washington, DC: DOL/OSHA, 2002. (OSHA 3079, Revised)
Orono Government Documents, L 35.2:R 31/2002
http://www.osha.gov/pls/publications/pubindex.list
Order, or download, 273 KB. Free resource.
55

U.S. Dept. of Labor, Occupational Safety and Health Admin.


Permit-Required Confined Spaces.
Washington, DC: DOL/OSHA, 2004. (OSHA 3138-01R)
Orono Government Documents, L 35.2:P 42/998 (1998 rev.)
http://www.osha.gov/pls/publications/pubindex.list
Order, or download, 486 KB. Free resource.
U.S. Dept. of Labor, Occupational Safety and Health Admin.
Personal Protective Equipment.
Washington, DC: DOL/OSHA, 2003. (OSHA 3151-12R)
http://www.osha.gov/pls/publications/pubindex.list
Download only, 629 KB.
U.S. Dept. of Labor, Occupational Safety and Health Admin.
Stairways and Ladders: A Guide to OSHA Rules.
Washington, DC: DOL/OSHA, 2003. (OSHA 3124-12R)
Orono Government Documents, L 35.8:ST 1
http://www.osha.gov/pls/publications/pubindex.list
Order, or download, 155 KB. Free resource.
U.S. Dept. of Labor, Occupational Safety and Health Admin.
Hand and Power Tools.
Washington, DC: DOL/OSHA, 2002. (OSHA 3080 Revised)
http://www.osha.gov/pls/publications/pubindex.list
Download only, 171 KB.
U.S. Dept. of Labor, Occupational Safety and Health Admin.
How to Plan for Workplace Emergencies and Evacuations.
Washington, DC: DOL/OSHA, 2001. (OSHA 3088 Revised)
http://www.osha.gov/pls/publications/pubindex
Download only, 251 KB.
U.S. Dept. of Labor, Occupational Safety and Health Admin.
Training Requirements in OSHA Standards and Training Guidelines.
Washington, DC: DOL/OSHA,1998. (OSHA 2254 Revised)
http://www.osha.gov/pls/publications/pubindex
Download only, 720 KB.
56

Regulatory Standards for Boatyards and Shipyards:

Shipyard Industry contains the 1915 standards, and generally


applies to ship and boatyards located on navigable waters.
The Title CRF 29 standards, a two-volume document, con-
tains the 1910 standards, General Industry, for boatyards not
located on navigable waters.
Shipyard Standards (1915 Standards). U.S. Dept. of Labor,
Occupational Safety and Health Administration. Shipyard
Industry. Washington, DC: DOL/OSHA,1998. (OSHA 2268
Revised) Orono Government Documents, L 35.6/4:SH 6/998
Shipyard Industry is a free resource. Write to: U.S. Department
of Labor, OSHA Publications, P.O. Box 37535, Washington,
D.C. 20013-7535; or call (202) 693-1888, fax (202) 693-2498.
You can also review these regulations online:
http://www.osha.gov/pls/oshaweb/owastand.display_
standard_group?p_toc_level=1&p_part_number=1915
General Industry Standards (1910 Standards). The following
two-volume publication contains the OSHA 1910 standards
for General Industry: Office of the Federal Register, National
Archives and Records Administration. Code of Federal
Regulations. 29, Labor. Washington, D.C.: OFR/NARA, 2003
Orono Government Documents, AE 2.106/3:29/pt.900-
1899/992
The 1910 Standards may be purchased from the Government
Printing Office by Visa, MasterCard, or check.
By mail: Superintendent of Documents, P.O. Box 371954,
Pittsburgh, PA 15250-7954.
By phone: (202) 512-1800.
Volume 1, $44.00, order # S/N 869-034-00104-1;
Volume 2, $27.00, order #S/N 869-034-00105-0.
You can also review these regulations online:
http://www.osha.gov/pls/oshaweb/owastand.display_
standard_group?p_toc_level=1&p_part_number=1910
57

See also OSHA’s Shipyard “Tool Bag” Directive, available


online only: http://www.osha.gov/OshDoc/Directive_pdf/
STD_02-00-003.pdf Appendix A of this document contains a
detailed table covering the applicability of specific 1910 stan-
dards to shipyard employment.

Video Safety Resources

http://www.safetyworksmaine.com/videos-pubs/videolst.html
Maine DOL video library page. Call 1-877-SAFE-345 to borrow
videos, which circulate for 2 weeks;
maximum of 2 videos at a time. Hundreds
of titles are available. The video request
form is available on the web page. Titles
include such shipbuilding topics as
welding, confined spaces, cranes.

http://www.osha.gov/pls/videos/videoloan.list
OSHA video loan information. OSHA videos may be freely
copied.
58

Special Safety Training Resources

http://www.safetyworksmaine.com/training/index.html
This link contains information on a 30-Hour General Industry
Safety training course offered by the Maine Department of
Labor. This 5-day course introduces people new to the safety
and health field to the OSHA standards for general industry
(29 CFR 1910), which apply to most boatyards (see Regulations
section of this manual). People who complete all 5 days receive
OSHA 30-hour general industry course completion cards. Site
includes search tool for locating courses for specific dates
and Maine cities. Useful for those boatyards that comply
under the OSHA General Industry Standards.
SafetyWorks
http://www.safetyworksmaine.com/consultations/index.html
Contact information for free, confidential on-site safety and
health consultation, independent of OSHA. Includes sam-
pling for air and noise exposures; information on OSHA
compliance. Also call toll free, 1-877-723-3345.

Professional Associations

Maine Marine Trade Association, P.O. Box 3551 Portland, ME


04104-3551, 773-8725, Contact: Sue Swanton.
59

Periodicals and Related Resources

American Industrial Hygiene Association Journal. http://aiha.org


American Journal of Hygiene. Baltimore, Published by School
of Hygiene and Public Health, Johns Hopkins University
through the Johns Hopkins Press. Available at Fogler Library.
Maine Maritime Trade Association. Summary of Findings and
Action Plan for Maine Marine Trade Association. Portland, ME:
Marine Trade Businesses, Summer 2003. Contact: Sue
Swanton, Maine Marine Trade Association, P.O. Box 3551,
Portland, ME 04104-3551, 773-8725.
Stellman, Jeanne Mager. Encyclopedia of Occupational Health
and Safety, 4th Ed. (print and CD). ILO., 1998. See Chapter 92,
Ship and Boat Building and Repair, by James R. Thornton,
Chapter Editor. Availability information:
www.ilo.org/public/english/support/publ/textoh.htm
Hudock, Stephen D. Compendium of Ergonomic Analyses of
Shipyard Work Processes. Cincinnati, OH: NIOSH, May 2003.
66 pp.; http://www.cdc.gov/niosh/ergship/Compendium.pdf
60

Chapter III:
Case Study Exercises

Instructions: For each of the following case study exer-


cises, select a team spokesperson who will be responsible for
summarizing and reporting on your group’s findings and
recommendations:

Case I
You are working at a yard that has 200 employees. There
are 140 employees who are involved in boat construction, 20
maintenance employees, 20 yard service personnel, and 20
management and office support employees.
Exercise A.
By using your handbook as a reference guide, what type
of formal safety structure would you propose for this
yard?
Exercise B.
Looking at your own yard, what type of formal safety
structure would you propose?
61

Case II
Your company has decided to form a labor–management
safety committee. There are fifty employees at the company
which operates one boatyard. The boatyard is made up of the
following departments:
Marine Services — Provides launching and hauling services,
tends moorings, repairs outboard and
inboard engines, and takes care of boat
storage areas.
Boat Repair — Repairs wooden, steel, and fiberglass
hulled boats ranging in size from 12 to
70 feet.
Maintenance — Takes care of equipment repairs through-
out the yard (this includes mechanical
and electrical) for all yard-owned equip-
ment.
Management — Includes human resources, yard manager,
accounting, and two supervisors.
Sales — Two sales personnel spend 90% of their
time on the road locating new business
for the company.
Manufacturing — Involved in the building of steel and
fiberglass hulled boats and occasionally
a wooden hulled craft of various lengths.
There are four standard models but cus-
tom built models will be made if the
yard is capable.
Parts Room — Storage room for spare parts, rigging,
and daily supplies.
College Student — “Helps out” in the yard in July and
August.
Seasonal Help — Additional staff put on during the sum-
mer months to assist with launchings
and moorings.
Based on the information provided above, a labor/man-
agement safety committee needs to be established, and the
following questions and issues need to be addressed:
62

1. What will be the size of the committee?


2. List what areas will be represented on the committee
and the reasons why.
3. How often should the committee meet?
4. Which workplace safety and health issues need to be
dealt with first and why?
63

Case III
Recent accident statistics show that your yard is experi-
encing a high rate of back injuries. The safety committee, of
which you are a member, needs to come up with effective
recommendations on how to prevent back injuries in the
workplace.
1. Identify resources, organizations, and individuals
who can provide assistance to the committee in this
area.
2. The committee is responsible for the implementation
of certain policies and practices to help reduce back
injuries. How should the committee do this?
64

Case IV
Assume that presently, the yard where you are employed
does not have a safety committee or a formal safety structure
in place. Although there are safety meetings and periodic
training sessions, you and your coworkers feel that health
and safety issues could be improved by having an active
safety committee at the yard along with some type of safety
structure.
You will need to propose this idea to the yard’s manage-
ment and owners by developing a rationale for why a safety
structure and a safety committee are needed. This rationale
should contain the following parts which need to be com-
pleted by you:
Part 1: Using the suggested safety structure information
in the handbook as a guide, propose a safety
structure for your yard and list the reason(s)
why each of the elements of the structure are
necessary.
Part 2: Propose a safety committee by listing depart-
ments within the yard that should be represented,
and the number of employees from each
department that should be on this committee.
Part 3: Propose roles that the safety committee would
play in assisting with specific health and safety
issues.
Part 4: What are you prepared to do as an individual
to support the yard’s new safety efforts?
65

Endnotes

1Fowler, Robert, A Guidebook for Local Union Health and Safety


Committees, Berkeley California: Center for Labor Research
and Education, p. 6.
2Ibid.
3
Based in part on the previously cited source.
66

Appendix I:
Shipyard Trade Occupational Risk Matrix (STORM)
Sustained Awkward Repetition Vibration Excessive
Postures Postures Force
Abrasive (1) Arms (1) Arms (1) Arms (1) Arms (1) Arms
Blasters (2) Shoulders (2) Shoulders (2) Shoulders (2) Shoulders (2) Shoulders
(3) Back (3) Back (3) Back
(1) Knees (1) Knees
(2) Back (2) Back
Burners/ (3) Neck (3) Neck
Torch Cutters (4) Shoulders (4) Shoulders
(5) Arms (5) Arms
(6) Hand/Wrist (6) Hand/Wrist
(1) Back (1) Back (3) Hand/Wrist (1) Back
Electricians (2) Knees (5) Arms (3) Hand/Wrist
(3) Hand/Wrist (4) Shoulders
(5) Arms
(1) Back (1) Back (3) Arms (3) Arms (3) Arms
(2) Knees (2) Knees (4) Shoulders (4) Shoulders (4) Shoulders
Grinders/ (3) Arms (3) Arms (5) Hand/Wrist (5) Hand/Wrist (5) Hand/Wrist
Chippers (4) Shoulders (4) Shoulders
(6) Neck (5) Hand/Wrist
(6) Neck
(2) Shoulders (1) Hand/Wrist (1) Hand/Wrist (1) Hand/Wrist
Insulators (3) Neck (2) Shoulders (2) Shoulders (2) Shoulders
(4) Back (3) Neck
(4) Back
Machine (1) Back (1) Back (1) Back (1) Back
Operator (2) Neck (2) Neck (3) Shoulders (3) Shoulders
(4) Hand/Wrist
Material (1) Back (1) Back (1) Back
Handlers (3) Shoulders (2) Shoulders (2) Shoulders
(3) Arms (3) Arms (3) Arms
Outside (1) Back (1) Back (3) Shoulders (3) Shoulders (1) Back
Machinists (2) Neck (2) Neck (4) Hand/Wrist (4) Hand/Wrist (3) Shoulders
(1) Back (3) Arms (3) Arms (1) Back
Pipefitters (2) Knees (5) Hand/Wrist (5) Hand/Wrist (3) Arms
(3) Arms (5) Hand/Wrist
(4) Neck

Relative Risk High Risk Medium Risk Low Risk No Risk


Factor

Matrix based on analysis of injury and cost data and quantitative risk
factor analysis of targeted shipyard work processes.
Source: Hudock, Stephen D. Compendium of Ergonomic Analyses of
Shipyard WorkProcesses. Cincinnati, OH: NIOSH, May 2003, vii-viii.
67

Appendix II-A:
Some Key Elements in a Worksite System

Employer Union Local

Contractor Workers

Other site
OSHA Worksite employees

Technology
Suppliers and
equipment

Physical environment,
including weather
68

Appendix II-B:
How a Worksite Accident in a
Shipyard Develops Across Time
(Using a Worksite Systems Approach)

Initial conditions at Worksite Later that morning Later Still Accident Occurs
(7:30 a.m.) (8:30 a.m.) (11:17 a.m.) (11:18 a.m.)

time pressure hazardous conditions: e.g.,


confined spaces,
lack of communication Technical volatile fumes
3
Contractor & Physical 2
Site 1
lack of safeguards Contractor Tech.
Site
Employer Environment, 2
Employer Envt.
time pressure weather hot outside 3
temperatures
Workers Site
Other Site
3 emps. 5
Workers Employees
4
lack of knowledge may not be informed
regarding hazards about hazards 1) fumes from fuel seep 5) worker enters confined 6) worker severely
into bilge on ship space of bilge and burned in explosion
2) time pressure to ignites welding torch
complete work fast
3) safety information on
fumes not communicated
4) worker distracted by heat
and stress
69

Appendix III:
OSHA’s Hazard Communication Standard and
Material Safety Data Sheets

The Federal Hazard Communication Standard


The following provides information on employee rights
and employer requirements pertaining to this standard:
Hazard Evaluation
Employers covered by the standard are required to:
(1) review the available scientific evidence concerning the haz-
ards of chemicals they produce, use or import in their work-
place and (2) report the information they find to their employ-
ees as well as to employers who purchase their products.
Written Hazard Communication Program
Employers must establish a written, comprehensive haz-
ard communication program which includes provisions for
container labeling, material safety data sheets, and an
employee training program. Also, it must contain a list of the
hazardous chemicals in each work area, the means the
employer will use to inform employees of the hazards of non-
routine tasks (for example, the cleaning of reactor vessels),
hazards associated with chemicals in unlabeled pipes, and
the way the employer will inform contractors in manufacturing
and non-manufacturing facilities of the hazards to which
their employees may be exposed.
Labeling
All containers of hazardous materials leaving a manu-
facturer must be labeled with information regarding the safety
and hazards of the substance. Specifically, all containers must
contain the following information:
1) chemical or common name of all hazardous materials
in the container;
2) name and address of the manufacturer or importer of
the material;
70

3) warning information describing the hazards of the


chemicals (both physical and health).
Material Safety Data Sheets
Employers covered by the standard must develop and
maintain up-to-date material safety data sheets (MSDS) for
each hazardous chemical produced, imported, and/or used in
their workplace. In addition to the basic identity information
required, the employer must provide data on:
1) the physical and chemical characteristics of the haz-
ardous chemical;
2) known acute and chronic health effects and related
information;
3) exposure limits;
4) whether the chemical is a carcinogen;
5) precautionary measures;
6) emergency and first aid procedures;
7) identification of the organization responsible for
preparing the sheet.
Copies of the MSDS must be made accessible to all
employees in the work areas.

Employee Information and Training


Employers must establish a training and information
program for employees exposed to hazardous chemicals in
their work area at the time of initial assignment and whenever
a new hazard is introduced into their work area.
Information
The discussion topics must include, at least:
1) the existence of this hazard communication standard
and the requirements of the standard;
2) the components of the hazard communication program
in the employees’ workplaces;
3) operations in their work area where hazardous chemi-
cals are present;
71

4) where the employer will maintain hazard communi-


cations programs, lists of hazardous chemicals, and
the required material safety data sheets.
Training
The employee training plan must consist of:
1) how the hazard communication program is imple-
mented in that workplace, how to read and interpret
information on labels and MSDS, and how employees
can obtain and use the available hazard information;
2) the hazards of the chemicals in the work area;
3) measures employees can take to protect themselves
from the hazards;
4) specific procedures put into effect by the employer to
provide protection such as work practices and the use
of personal protective equipment (PPE);
5) methods and observations — such as visual appear-
ance or smell workers can use to detect the presence of
a hazardous chemical they may be exposed to.

Applicability of Federal Preemption


The revised Hazard Communication Standard also clari-
fies (according to OSHA’s interpretation) the “parameters of
preemption.” Specifically, this standard stipulates that any
state or local government occupational “right-to-know” law
is preempted by the Federal Hazard Communication
Standard “unless it was established under the authority of an
OSHA approved state plan.”
72

Sources

U.S. Department of Labor, OSHA, Chemical Hazard


Communication, 1985, OSHA 3084.
BNA, Union Labor Report, Washington, DC: BNA, August 27,
1987, p. 1 and July 28, 1988, p. 1 editions.
U.S. Department of Labor, Federal Register, Rules and
Regulations, Vol. 52, No. 163, Washington, DC: U.S.
Government Printing Office, August 24, 1987, p. 31861.
Research Institute of America, Employment Coordinator, New
York, NY: RIA, December 21, 1988, ed., p. 4.
73

What Should Be Known About


Material Safety Data Sheets (MSDS)?

What Are Material Safety Data Sheets?


Material Safety Data Sheets (MSDS) supply very impor-
tant information about chemicals used in the workplace. In
addition to providing the name and address of the manufac-
turer, they also describe the various properties and character-
istics of the chemical substance, outline basic precautions
which need to be taken for safe handling and use, and supply
valuable information regarding health hazards relating to the
substance. A MSDS is made up of eight sections:
Section I identifies the chemical, the name and address
of the manufacturer, phone numbers for use in emergencies
or to obtain more information, and the date in which the
MSDS was prepared. (Note: The date is particularly important
in making sure the information contained in the MSDS is
fully up-to-date as required by law.)
Section II cites the hazardous ingredients and properties
of the chemical. This includes the identity as well as common
name of the chemical, OSHA Permissible Exposure Limits
(PEL), established Threshold Limit Values (TLV), and any
other recommended limits.
Section III contains information on the physical and
chemical characteristics of the substance including the boiling
point, vapor pressure and density, water solubility, appear-
ance and odor, evaporation rate, and melting point.
Section IV supplies fire and explosion hazard data
including the flash point of the substance, flammable limits,
extinguishing media, special fire fighting procedures, and
unusual fire and explosion hazards.
Section V includes information on some of the condi-
tions which can cause the substance to react dangerously. For
example, this section, entitled Reactivity Data, contains data
on the stability and instability of the substance and condi-
tions to avoid, its incompatibility with other materials, and
any hazardous decomposition properties or by-products
74

associated with it. This section also supplies data on condi-


tions that would cause this chemical to polymerize or break
up and release hazardous chemicals into the work environ-
ment, and conditions to avoid.
Section VI describes both the acute and chronic health
hazards associated with the chemical, its routes of entry into
the body, whether through the skin, inhalation, or ingestion,
carcinogenicity, signs and symptoms of exposure, medical
condition generally aggravated by exposure, emergency first
aid procedures, and whether there is an OSHA regulation on
the chemical.
Section VII deals with precautions for safe handling and
use of the chemical in terms of steps to be taken in case the
material is released or spilled, waste disposal methods, pre-
cautions to be taken in handling and storing, and other pre-
cautions to be adopted.
Section VIII covers control measures needed to protect
employees from exposure to the chemical. These measures
include personal protective equipment, devices, and clothing,
engineering controls including respiratory protection, local
exhaust and mechanical controls, work and hygienic practices.

How Can A MSDS Be Obtained?


There are several ways in which workers can obtain a
MSDS:
1. Employers covered by OSHA’s Hazard Communication
Standard must develop and maintain up-to-date
MSDS for each chemical produced, used, or imported
in their workplace. Copies of the MSDS must be made
accessible to all employees in work areas during all
shifts.
2. A MSDS also can be obtained by writing directly to
the producer of the chemical.
75

Index

A
Abatement of Hazards v, 1-2, 8, 12, 24, 43
Abatement Time 29-31
Abrasive Blasting 66
Absorption
Skin 6, 74
Accidents vi, 1-3, 9-11, 13, 17,
24-25, 28, 45-47,
50-52, 63
Acetone, see also hazards 8
Advance Notice,
see also OSHA inspections 34
Aluminum Boats 8
Anti-Fouling/Anti-Rust
Paint Components 7
Arsenic, see also hazards 7
Asbestos, see also hazards 7, 32, 53
Asphyxiation 5
B
Bilges 68
Biological Hazards, also see hazards 1, 18
Bloodborne Pathogens 54
Boat Building and Repair
Aluminum 8
Applicable OSHA Standards 1-2, 7, 21, 31-33, 58
Fiberglass 2, 40, 61
Metal 2, 4, 16, 61
Special Considerations on Hazards 7
Types of Hazards 1-8, 11
Wood 2, 8, 19, 61
Worksite Systems Approach 11, 19
Boatyards v, 2, 4, 7-8, 10-11, 32-33,
43, 48, 56, 58
76

Bureau of Labor Education vi, 3, 8, 18, 36


Burner 13, 15, 66
C
Cadmium 7
Carbon Monoxide 32
Case Studies
Chapter I 12
Chapter II 37
Chapter III 60
Chemicals, see also hazards and
specific workplace chemicals 1, 4, 6, 8, 18-19, 25, 32,
35, 40, 46, 49, 52, 69-73
Chipping Operations 7, 66
Chromium 7
Citation 24, 29-31, 36
Cold 5, 45
Collective Bargaining 2
Complaint 27-28, 31, 34, 45
Confined Space 4-5, 7, 13, 31-32, 49,
55, 57
Consultation
Maine Department of Labor 51, 58
OSHA 27, 36
Contact Hazards 5
Controls
Administrative 30
Engineering 6, 74
Copper Oxide 7
Cranes 5, 14, 38, 54, 57
D
Decompression Sickness 6
Dehydration 6
Department of Labor
Maine 51, 58
U.S. iii, viii, 19-21, 31, 56, 72
Descaling 4
77

Discrimination iii, 34
Divers 5-6
Drowning, see also hazards 4
Dry-docking 4-5, 32
Duties (OSHA)
Employee 24
Employer 22
E
Electrical Hazards, see also hazards 5-6, 13
Electrocution v, 6
Emergency Response 24, 26, 70, 74
Employee
Representative 23, 26-29, 31, 34-35,
45, 49-50
Responsibilities vii, 1, 15, 21, 24, 29, 45
Rights 21, 24, 26-27, 29-30,
32, 34-35, 37-38, 45-46,
69, 71
Role during OSHA inspections 27-29
Employer
Responsibilities 1, 21, 23, 29, 45
Rights 21, 24, 29, 35
Role during OSHA inspections 27-29
Engineering Controls 6, 74
Environment,
see also Worksite Systems 6, 9-10, 23, 31-32, 36,
47, 74
Epoxy Resins 8, 17
Ergonomics
Hazards v, 1-2, 6, 18, 51, 59, 66
etool (OSHA) v, viii, 51-52
Evacuation 31, 55
Exertion 6
Explosions v, 4-7, 13, 25, 32, 73
Explosive Atmospheres 6, 13, 73
Extreme Weather 5-6, 9-10
78

F
Fabricating and Repair 4
Falls v, 4-5, 32
Fatalities v, 5-6, 24
Fiberglass 2, 40, 61
Fires and Explosions v, 6
Fitting out work 5-6
Flammable 32, 73
Frostbite 6
G
General Duty Clause 22, 29, 31, 33
General Industry Standards (1910),
see also OSHA 1-2, 8, 19, 33, 56-58
H
Hand and Power Tools 5-6, 50, 55
Hazard Abatement v, 1-3, 21, 26-27, 31, 43
Hazard Communication Standard,
see also OSHA 8, 33, 39, 69-71, 74
Hazard Identification
Hazard Recognition Program
(Ohio State) 3, 18
Worksite Systems Approach
(Univ. of Maine) 3, 8
Hazards
Acetone 8
Arsenic 7
Asbestos 7, 32, 53
Biological 1, 18
Boat Building 1-8, 11
Burning 17, 49
Chemical 1, 4, 6, 8, 18-19, 25, 32,
35, 40, 46, 49, 52, 69-73
Cold 5, 45
Confined Space 4-5, 7, 13, 31-32, 49
55, 57
Contact 5
79

Drowning 4
Electrical 5-6, 13
Ergonomic v, 1-2, 6, 18, 51, 59, 66
Eye 17
Falling v, 4-5, 32
Getting Caught 5
Hearing 6-7
Heat 6, 17, 45
Hot Work 16-17, 19-20
Inhalation and Swallowing 6-7, 74
Radiation 6, 32
Respiratory 7, 16, 54, 74
Shipbuilding vii, 2, 5-6, 8, 32, 51, 57
Skin 6, 74
Struck by or Striking Against 4-5
Toluene 8
Toxic v, 4-8, 16, 26, 32
Welding 6-8, 15-17, 49, 57
Health and Safety Committee
Activities 43
Composition 43
Joint Labor-Management v, 2, 43
Member Preparation 47
Member Selection 46
Roles 45-46
Size 46
Health Hazard Evaluation Form,
see also NIOSH 35-36, 42, 69
Heat Cramps 6
Heat Exhaustion 6
Hoists 5, 38
Hull Repair 5-6
Hypothermia 6
I
Illnesses viii, v, 2-3, 23-25, 35,
45-46
Imminent Danger 26, 28, 34
80

Injuries v, viii, 1-3, 5-6, 13-14,


19-20, 23-24, 28-29, 35,
38, 45-47, 52, 63
Inspections 26-31, 34, 41, 44-45,
49, 54
Citation 24, 29-31, 36
Investigations 27, 35, 52
Procedures and Content 28-29
Rights 29-31
Employee 30
Employer 29-30
Triggers for 28
Ionizing Radiation 6
Isocyanates 8, 19
J
Job Hazard Analysis 9
Joint Labor-Management Committee,
see Health and Safety Committee v, 2, 43
L
Launching Operations 4-5
Law (OSHA) v, 8, 21-24, 26, 29-30,
34, 45, 47, 53, 70, 73
Lead Paint 7
Lead Poisoning 7
Legal Responsibilities (OSHA)
Employees 23
Employer 23
Lock Out Audit 49, 54
Lock Out/Tag Out 54
M
Maine Department of Labor 51, 58
Maine Marine Trade Association 58-59
Maine SafetyWorks,
see also Maine Department of Labor 51, 57-58
Maritime v, 19-20, 52, 59
81

Material Safety Data Sheets (MSDS) 8, 19, 25, 33, 39, 52,
69-71, 73-74
Medical Records 24
Mercury Compounds 7
Methylene Chloride 8, 19
Methyl Ethyl Ketone Peroxide 8, 19
N
National Institute for Occupational
Safety and Health (NIOSH) iii, viii, 8, 19, 21, 35-36,
42, 51, 59
Address, Phone, Fax, and E-Mail 36
Health Hazard Evaluation 35-36, 42, 69
How and When to Consult 35
Navigable Waters 32-33, 56
Noise 2, 6, 18, 31, 58
Notice of Contest 29-31
O
Occupational Safety and Health Act (OSHA)
Abatement Time 29-31
Citation 24, 29-31, 36
Confidentiality 30, 34, 36, 58
Coverage 22
General Duty Clause 22, 29, 31, 33
Employee
Responsibilities vii, 1, 15, 21, 24, 29, 45
Rights 21, 24, 26-27, 29-30,
32, 34-35, 37-38, 45-46,
69, 71
Employer
Responsibilities 1, 21, 23, 29, 45
Rights 21, 24, 29, 35
Hazard Communication Standard 8, 33, 39, 69-71, 74
Imminent Danger 26, 28, 34
Inspections 28, 54
Advance Notice 34
Closing Conference 29-30
82

Factors Causing 28
Opening Conference 28
Procedures 27-28, 30, 41
Trade Secrets 30
Log of Workplace Injuries and Illnesses
(OSHA 300) 23-24
Material Safety Data Sheets (MSDS) 10, 19, 25, 35, 39,
68-70, 72
“OSHA, It’s the Law” Poster
(OSHA 3165) 24
Penalties 29-30, 36
Petition for Modification of
Abatement (PMA) 31
Purpose 21
Standard
1910 General Industry Standards 1-2, 8, 19, 33, 56-58
1915 Shipyard Industry Standards 2, 32-33, 56-57
Summary of Work Related Injuries
and Illnesses (OSHA 300A) 24, 27
Training Requirements 18, 55
Occupational Safety and Health Administration
Addresses 31
Cooperative Programs 21
Phone, fax, and e-mail 31
Occupational Safety and Health
Review Commission 30
Organo-Tin Compounds 7
P
Penalties (OSHA) 29-30, 36
Permissible Exposure Limit (PEL) 35, 73
Personal Protective Equipment 7, 23-24, 32, 55, 71, 74
Petition for Modification of
Abatement (PMA) 31
Pigments 7
Pine Tar 8
Poor Housekeeping 4, 10
Poster (OSHA) 24
83

Posture, see also Ergonomics 6, 66


Publications 51-59
R
Radiation 6, 32
Reactivity Data (MSDS) 73
Records of Exposure, Access to 23, 32, 46
Recreational Boats 33
Regulation, see OSHA Standards 1, 22-24, 29, 56, 58,
72, 74
Respirators 7, 50
Respiratory Damage 7
Resources on Occupational
Health and Safety 51-59
Right to Complain 24, 27
Right to Know 24-26
Right to Refuse 26
S
Safety Glasses,
see also Personal Protective Equipment 7, 32
Safety and Health Committees
(refer to Health and Safety Committee) 43-50
Safety and Health Programs (SHPs) v, 1-2
Safety Structure 43, 48, 60, 64
Crew Safety Representative 49-50
For Ship/Boat Yards 43-45
Housekeeping Inspections 44, 49
Monthly Department Safety Meetings 50
Safety Committee 43-46, 48-49, 61, 63-64
Safety Coordinator 48
Safety Department 48
Sub-Committees 48-49
Toolbox Safety Review 50
SafetyWorks,
see also Maine Department of Labor 51, 57-58
Shipbuilding
1915 OSHA Standards 2, 32-33, 56-57
84

Types of Hazards 2, 6, 8, 32, 57


Worksite Systems Approach 3, 8-11, 19, 50, 66-67
Shipyard Employment eTool v, viii, 51-52
Shipyard Trade Occupational Risk Matrix
(STORM) 6, 66
Skin Hazards 6, 74
Sodium Hydroxide 8
Stairways and Ladders 55
Standards, see OSHA
Boatyard 2, 7-8, 19, 33
Shipyard 2, 8, 32-33, 56
1910 General Industry Standards 1-2, 8, 19, 33, 56-58
1915 Shipyard Industry Standards 2, 32-33, 56-57
Stripping Operation 7
Surface Preparation 4
Systemic Poisoning 7
Systems, see Worksite Systems 3, 8-11, 19, 50, 66-67
T
Tank Cleaning/Repair 6
Temperature, see also heat and cold 5-6, 17, 31, 45
Testing and Monitoring 32
Threshold Limit Value (TLV) 73
Toluene, see also hazards 8
Toolbox Safety Review 50
Toxic and Hazardous Substances 8
Training
MSDS 25, 32, 69-71
OSHA 1, 3, 18, 23, 25, 32, 45,
47-49, 55, 58
Turpentine 8
U
Underwater Work 6
Union 2, 26, 28, 65, 72
U.S. Department of Labor iii, viii, 19-20, 31, 56, 72
85

V
Vapors 6
Variance 30
Ventilation 5, 7, 16, 31
Vibration 6, 66
Violation 14, 22-23, 27-29
W
Waste Disposal 32, 74
Welders 15
Welding Hazards 6-8, 15-17, 48, 72
Wood
Dust 8, 19
Other Hazards 2, 8, 19, 61
Workplace Emergencies and Evacuations 55
Workplace Safety Index v
Worksite System 3, 8-11, 19, 50, 66-67
Key Elements 11, 67
Worksite Systems Approach 3, 8-11, 19, 50, 66-67
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ABOUT THE BUREAU

The Bureau of Labor Education, established in 1966,


conducts educational programs, presentations, and
research on labor related issues of interest to workers;
students, leaders in government, labor, and education; and
public policymakers. General topics include employment,
law, occupational health and safety, labor/management
relations, leadership development, and labor economics.
The Bureau also analyzes and speaks on timely issues
involving such topics as discrimination and sexual
harrassment, the Americans With Disabilities Act, produc-
tivity, workplace innovations, the global economy and
competitiveness. For more information on the Bureau, or to
request a program, call 207-581-4124.

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