Measures for Hot Work
Due to a number of fires caused by Hot Work - whether during minor repairs while a vessel is still in operation, during scheduled/unscheduled yard stays, as well as in connection with construction of the vessels - Norwegian Hull Club wants to highlight the importance of proper Hot Work Procedures being followed.
Hot Work Procedures – Vessels in Operation
For ships in operation, most Owners and Managers have proper Hot Work procedures and checklists in place, suitable for the type of vessels in the fleet.
Hot Work safety guidelines to be strictly followed
Hot Work is a high-risk operation that requires close attention and involvement by ship owners and managers, as well as the onshore organisation, in accordance with the Safety Management System.
With ref to IMO MSC/Circ. 1084, we wish to highlight the following:
List of Principles for Hot Work on board all types of vessels
1.1 Hot Work means any work requiring the use of electric arc or gas welding equipment, cutting burner equipment or other forms of naked flame, as well as heating or spark-generating tools, regardless of where this work is to be carried out on board.
1.2 The Safety Management System on board should include adequate guidance on control of Hot Work and should be robust enough to ensure compliance. Absence of guidance should be regarded as prohibitive, rather than an indication of approval.
1.3 Whenever possible a space, such as a workshop where conditions are deemed safe, should be designated for Hot Work to be performed. First consideration should be given to performing any Hot Work in this identified space.
1.4 Hot Work performed outside this space should be subject to the following considerations:
2. Hot Work outside the designated space:
2.1 The master or designated safety officer should be responsible for deciding whether Hot Work is justified and whether it can be conducted safely.
2.2 A permit-to-work system should be employed.
2.3 Hot Work procedures should take account of national laws or regulations or other national safety and health rules.
2.4 A responsible officer, not involved in the Hot Work, should be designated to ensure that safe procedures are followed.
2.5 A written plan for the operation should be agreed by all who will have responsibilities in connection with the Hot Work.
2.6 The work area to be used should be carefully prepared and isolated before Hot Work commences.
2.7 Fire safety precautions should be reviewed, including fire equipment preparations, setting a fire watch in adjacent compartments and areas, and fire-extinguishing measures.
2.8 Isolation of the work area and fire precautions should be continued until the risk of fire no longer exists.
Hot Work Procedures – Vessels at Yard
In connection with yard stays, Norwegian Hull Club has experienced serious fires on board due to Hot Work carried out by yard or sub-contractors.
We have noted the following with regards to Hot Work during repairs performed in yards:
- Owner’s Specification of repairs consisting of Hot Work to include a detailed work description.
- Relevant ships drawings and photos to be attached to the specification, in order for the yard to be informed of any fire risk in the area where the Hot Work is to be conducted.
- Risks involved to be identified, e.g. risk of fire due to heat transfer to adjacent insulated bulkheads or compartments, fuel tanks/pipes and areas/spaces containing combustible materials or gasses.
- Preferably, owner’s and yard’s Hot Work procedure and check list to be merged, in order to catch up with the ship-specific risk in connection with the Hot Work.
- Agreement between owner’s team and yard team to be made regarding work plan, execution of work, fire watch routine and surveillance after Hot Work completed.
- Fire detection system to be tested and proven to be working satisfactory prior to dismissing human surveillance from area where Hot Work has been carried out.
Hot Work Procedures – Vessels under Construction
Although general responsibility during construction of a vessel lays with the shipbuilder, the owner’s site team may contribute to increased safety by following up Hot Work procedures.
All parties involved in the construction of the vessel should be introduced to and follow the Hot Work procedures. In many ways, the same attention given during repairs should also be given during newbuilding. Strong involvement by the owner’s site team in connection with safety meetings and execution of high-risk work is a very important contributor to increased safety.
If unsafe work is observed being carried out by yard or sub-Contractors, DO NOT HESITATE TO REQUEST A TIME OUT AND STOP THE WORK!
Regarding repair and conversion contracts, owners should make sure that there is a proper and balanced shipyard repair contract in place, that contains reasonable liable clauses to cover for any damages they cause due to negligence or wilful misconduct.
Further, the shipyard should have a Ship Repairer’s Liability (SRL) policy in place, and owners should make sure that the limit of this policy is at a level which is sufficient for the works that are being performed. It is recommended during negotiations to ask the yard to disclose their SRL insurance policy.
Finally, whether the Hull & Machinery policy is continuing while the vessel is at the yard or a new Conversion policy will be taken out, it is important to notify your insurance company. No waiver of subrogation toward the Shipyard should be given without the explicit approval from the Owners’ insurance company, as this might jeopardise the insurance cover. Further, a request from the yard to be co-insured under the Hull & Machinery policy should be rejected.
Please note that the insurance company may provide assistance to Owners with respect to the contract wording and the SRL.
Norwegian Hull Club wishes you all fair winds and following seas.
18. Dec. 2019