SCP’s Instructions
3.3.6 Competent Person.
A person who is designated in
writing by their employer in
accordance with 29 CFR 1915.7.
The 2001 edition for the first time defined the well-established
relationship between the Marine Chemist and the Shipyard
Competent Person and the frequency of retesting confined spaces.
4.1 Determining Conditions
The Marine Chemist shall carry out tests in each space ensuring
compliance with the minimum applicable requirements.
Maine Chemist -Ensures
4.5 Issuance of Certificates.
.... a signature for receipt of the Certificate shall be obtained,
signifying understanding of the conditions and limitations and
the requirements for maintaining conditions under which it is
issued.
SCP - Maintains
OSHA 1915.15
Maintenance of Safe Conditions
~ Synopsis of SCP Duties ~
a.
b.
c.
d.
e.
f.
Isolation of piping
Alteration of conditions
Test to maintain conditions
Change of conditions (marine chemist)
Tests to maintain findings
Change of conditions (SCP)
NFPA-306
4.6.2 Maintaining the Certificate
~ Synopsis ~
1. Conditions shall be inspected by the SCP within 1 day.
2. Conditions shall be maintained .
3. Spaces shall be inspected daily or more often.
4. Certificates not maintained are voided.
5. Shifting must be authorized with re-inspection by SCP and
nature of tests included on certificate.
6. Calibration of instruments used to maintain certificate
shall be verified each day.
4.6.2 Maintaining the Certificate
2009 NFPA-306:
4.6.2(3)*Unless otherwise stated on the Certificate, all spaces
including adjacent spaces documented on the Marine Chemist
Certificate shall be reinspected daily, or more often as necessary, by
the shipyard competent person in support of work prior to entry
or recommencement of work.
2014 NFPA-306
4.6.2(3)* Unless otherwise stated on the Certificate, certified
spaces including spaces adjacent to hot work, where work is
being done shall be re-inspected daily, or more often as
necessary, by the shipyard competent person, prior to entry
or external hot work.
2014 NFPA-306
Annex to 4.6.2(3) Spaces shall be inspected daily ...
The intent of this wording is to clarify that spaces listed
on the Marine Chemist Certificate do not need to be
tested by the competent person unless work is being done
on or in a space. For example, spaces on a certificate do
not need to be tested and inspected on a weekend if no
work or entry is taking place. However, nothing shall
prevent a competent person from testing more frequently
than the minimum...
Small Print
“Unless otherwise stated on
the Certificate, all spaces and
affected adjacent spaces are
to be re-inspected daily or
more often as necessary by
the competent person … in
support of work prior to entry
or recommencement of work.”
“In support of work” is the spin.
NAVSEA 009-35 FY-13 CH-2
3.1.3.2 For those certified spaces which employees will enter, a Competent Person
shall visually inspect, test and record each space certified as ENTER WITH
RESTRICTIONS or SAFE FOR WORKERS as often as necessary, and as a
minimum, prior to entry by employees on a daily basis. If a space is not to be
entered on any given day, it is not required to be inspected and tested by a
Competent Person. The initial MCC remains valid if conditions have not changed,
unless noted on the MCC.
3.1.3.3 For those certified spaces affected by hot work, a Competent Person shall
visually inspect, test, and record each space certified as SAFE FOR HOT WORK as
often as necessary and, as a minimum, daily prior to commencement of hot work to
ensure that conditions established by the certificate are maintained. When hot work
is continuous, the affected spaces shall be visually inspected, tested, and recorded
on a daily basis to maintain the SAFE FOR HOT WORK certification.
USCG Safety & Environmental
Health Manual CH-11
8. Vessels Afloat Entry/Repair
C (3) If the Competent Person has not properly maintained
the Marine Chemist Certificate, the Marine Chemist is
required to reissue the certificate prior to reentry into the
confined space.
NFPA rules require a Competent Person to reexamine the
confined space at least every 24 hours or if conditions
under which the certificate was issued under change.
2014 NFPA -306
Safe for Limited Hot Work:
(d) In compartments/spaces on vessels, that are not considered cargo or
fuel spaces and have not contained and are not subject to concentrations of
combustible, flammable or toxic liquids, vapors, or gases.... The Certificate
shall include a statement under the heading "Limitations" describing the
locations and type of Hot Work along with any directions for the
Competent Person to maintain safe work conditions.
Submitted: Alan Bonds, A. Bonds Chemist, LLC - Recommendation: Revise text to read :
The term “maintain” is consistent with the requirement in Section 4.5 of the
Standard and with the requirement for the competent person to maintain safe
conditions in 29 CFR 1915.15, Maintenance of Safe Conditions.
Objective
Fit these SCP requirements on a certificate.
What is the proper language ?
SFLHW
4.3.6.3The Certificate shall include a statement under the heading
"Limitations" describing the locations and type of Hot Work along with any
directions for the Competent Person to maintain safe work conditions.
The Certificate shall include a statement describing limitations
1. Specific location
2. Type of hot work.
3. Permitted to list any areas to be excluded from hot work.
4. These areas shall be listed on the Certificate under “Limitations.”
~ and ~
No work will take place on the weekends
Provide these directions on a certificate for limited hot work
Insert proper
limitations and
instructions for this
normally occupied
space on certificate.