and Peter Rimmel

We read with interest your article entitled “HAZWOPER, HAZ what?” [page A1, September issue].

We are glad that The Triton featured this type of safety training. It is needed in all industry, not just the marine industry.

Sadly, the marine industry has fallen behind shoreside industries when it comes to safety training. We know this firsthand because we teach the marine equivalent of the HAZWOPER course. (It is interesting that no mention of this equivalent training was made in your story by someone who wanted to make you aware of a safety need.)

You quoted OSHA regulations 29 CFR 1910.120 as defining who must have training. These rules only cover shoreside industry. OSHA 29 CFR 1915 is an entirely separate set of regulations that covers the marine industry. The reason that there is a separate standard for the maritime industry is that the situations encountered in it are more varied than on shore. 

For example, a shoreside facility has fixed systems, be it storage tanks, refinery reactors or other equipment. They rarely are changed and can have an entire set of rules and procedures written for any expected mishap or emergency.

The maritime industry is in a greater state of flux, and conditions change every time a vessel moves or a different vessel is brought into a facility. Also, entry and access to many areas of a ship, yacht or barge is much more limited.Many of the principles and ways of handling toxic or dangerous situations are similar on shore and afloat, but since so many differences are encountered in the maritime industry, a separate set of rules has been written and must be applied in the marine environment.

HAZWOPER training is good to acquaint shipboard personnel with the hazards and to teach them about chemical safety, but it does not teach any of the marine regulations that must be strictly adhered to under OSHA. Remember, OSHA laws cover every worker in the United States and its possessions, whether on shore or on a vessel in U.S. waters.

For example, every firefighter in the United States has had the HAZWOPER training, but not one of them is allowed to deal with or enter a toxic situation on a vessel afloat or in a repair facility, according to the OSHA 29CFR1915 rules. Only an NFPA-certified marine chemist has the authority and training to deal with such situations.

Your article mentioned the three workers who were overcome and killed by argon gas that escaped into the cargo hold of a ship in Port Everglades. The fire department went in, but should not have. As soon as that was realized, we were called to come to the ship and perform testing to determine when the situation was safe, not only for workers, but for investigators.

Our job further entails certifying that the affected spaces and all adjacent spaces are free from any hazards, so that any person (perhaps in the next port of call) would not encounter an unexpected or hidden hazard. HAZWOPER does not cover that aspect of safety at all.

Since starting Marine Chemists & Testing Company, we have trained close to 1,000 workers in the maritime safety standards of 29CFR1915. We daily visit shipyards to determine and certify what is safe for entry (sufficient oxygen and free from toxic hazards) and also when and where it is safe to perform welding and other types of hot work.

We have been called out day and night when toxic problems have been encountered in emergency situations in our ports and shipyards to evaluate and deal with whatever has occurred. Since there is no professional with equivalent shoreside training, we also perform similar inspections on everything from jet fuel and gasoline storage tanks on shore, underground pipelines in the ports and airports, tank trucks, intermodal tank units full of chemicals that are hoisted aboard ships, and just about anything else in Florida and Caribbean islands that have held chemicals and/or fuels.

Safety training is important, but so is the proper training for the industry in which so many of your readers are involved. We would not want to see them misled to think that a HAZWOPER course is the way to go to keep their vessels safe. It is a start, but the marine training that we teach is just as important, since it deals with the law as written, and what they must know to keep within that law while performing their duties.

Peter Rimmel and Blair M. Duff are NFPA-certified marine chemists with Marine Chemists & Testing Company in Ft. Lauderdale.