Lead Paint And Osha Regulations:
Scraping the Voids on the USS Iowa and the USS Wisconsin

James Houk

In the "good old days," when the vessels that are now displayed as ship museums around the world plied the seas, little thought was given to the toxic nature of many of the materials used to keep these vessels operational. Today many of these materials fall under national regulation designed to protect the health of workers. One of the most heavily regulated materials is lead. Wooden sailing vessels used lead compounds for centuries as lubricants, ballast, and preservatives, so it was only natural that these uses would continue after the advent of the iron hull. White lead has a long history of naval use that continues to this day in the assembly of anchor chains and other items. Lead ballast is still used on some naval vessels and lead based paints were preferred for marine use for many years.

Through the 1970's, sailors and shipyard workers handled lead based materials with little care or respect. Industrial toxicology had not yet become an important issue. This changed with new federal regulations designed to protect the health of industrial workers. Massive lawsuits over asbestos and other hazards made it clear to the ship building and repair industry that times had changed. Unfortunately, many ship museums have failed to realize that occupational safety regulations apply to museums as well as to shipyards, particularly when museums engage in the removal of old, flaking paint. The regulations that exist to protect the health of industrial and shipyard workers also exist to protect the health of museum workers and volunteers. The Occupational Safety and Health Act does not have a clause excluding museums and ship museums, so museums must comply with these regulations because violations of health and safety regulations can result in incredibly expensive fines that could potentially lead to the demise of an otherwise fine museum. The health and safety of museum workers in the United States falls under the jurisdiction of the Occupational Safety and Health Administration (OSHA), which sets forth the rules and regulations that must be followed in order to protect a ship museum against devastating lawsuits and fines. These regulations are published in section 29 of the Combined Federal Register or CFR. These regulations are long, tedious, and seemingly impossible to implement, but between 1992 and 1994 over 800 voids comprising part of the armor system on the USS Iowa and the USS Wisconsin were successfully scraped and cleaned of badly flaking lead-based paint. In the course of this two and a half year project, OSHA standards were strictly adhered to and an OSHA inspection set in motion by a disgruntled employee was passed with only minor discrepancies. The lessons learned during this project are relevant to the problems faced by ship museums in complying with worker safety regulations and the implementation of hazardous waste control programs. This project should be viewed as an extreme case. Most ship museums should be able to legally comply with the requirements set forth in the 29 CFR without developing the intense program that was necessary on the USS Iowa and the USS Wisconsin since museum exposure to lead is usually not as high as it was on the battleship project.

The USS Iowa and the USS Wisconsin were designed during the late 1930's and were completed during World War Two. Two other sister ships were also completed and all four vessels saw active combat duty. By 1958 all four vessels were mothballed and placed into long term storage. During the 1980's the four ships were reactivated as part of the plan to build a 600 ship Navy. The USS Wisconsin received the most extensive overhaul of the class and came out of her reactivation in materially better condition than did the USS Iowa. Additionally, the USS Wisconsin was blessed by a extraordinary damage control organization that maintained the ship in far better condition than did the damage control organization on the USS Iowa. These factors turned out to have a significant impact on the difficulties encountered in removing the lead paint from the voids onboard these vessels.

Voids are tightly sealed watertight compartments that were designed to be left empty. Most of the voids on the Iowa class battleships are part of the armor system that protects the main machinery spaces. The bottom of the machinery spaces is protected by a layer of tanks covered by a layer of voids that extend all the way across the bottom of the hull. The sides of the engineering and weapons areas have two layers of fuel tanks next to the outer hull followed by a void which has the side armor fixed to the inboard bulkhead. Inside of this is another void before one reaches the working areas of the ship. Over the engineering spaces is a layer of armor with a thin layer of voids directly below it. This layer of voids is called the splinter deck since it is designed to catch and contain the fragments that would occur should an armor-piercing shell strike the armored second deck. The actual number of voids varies from ship to ship as a result of deviations and modifications to the original plans, a problem complicated by poor documentation of these changes.

The man hired to supervise the void job was a retiree from the Philadelphia Naval Shipyards. He had spent most of his working life cleaning the tanks and voids of warships and had brought a considerable amount of expertise as well as connections with him when he joined the company. He was also accustomed to having his work packages planned and monitored by outside planning and quality control groups. This was unfortunate since the senior management knew very little about void work, and so expected him to both plan and monitor a very large and complex project without their assistance. With a crew of 39 untrained laborers off the streets of Philadelphia he was able to start the project in February of 1992. From the start there were serious problems in the training and discipline of these workers. Part of the difficulty was that none of the four crew leaders assigned to him had any real experience in this work kind of work and only one of these four crew leaders had significant training and experience in a leadership role. This lack of leadership experience at the deckplate level of supervision was the proximate cause of many of the problems encountered in this two and a half year project.

In an attempt to break the workers and their crew leaders in slowly, it was decided to let them work in the upper voids first, then to let them do the second layer down before progressing to the deep side wall voids. This was an adaptation of the standard shipyard practice of cutting a hole in the bottom of the ship and simply dumping the debris out through this hole into a container placed on the floor of the dry dock. An advantage of this method is that it provides fresh air and an easy entrance for power and light. Unfortunately the USS Iowa and the USS Wisconsin were floating in the Delaware river and there was no hole in the bottom to aid the work. This was not a problem at first, since the crew was working in easily accessible voids that were in relatively good condition and it appeared that a reasonable level of progress was being made. It also looked nice on paper. When the list of the voids had been obtained, it began with the second deck voids, then went to the third deck voids, and so on. Performing the work in the order of the list did not require complicated explanations to higher authority. It was a simple plan that everyone understood. Unfortunately it was not a very efficient plan since it involved repeated setups of equipment in the same location, messing up already clean voids in order to clean the voids below them, and a host of other problems.

At this point the company had very little experience in the cleaning of voids and the safety departments was neither prepared nor equipped to handle the job they were now tasked with. The men were given blood tests to establish their baseline lead levels, fitted with respirators, and sent to work. Training was initially inadequate. The men were told what the law required but their attention to the presentations left much to be desired. The results of this were continuous violations of the most basic safety requirements. The work was hot so the men carried water bottles into their work areas to drink when they got thirsty. Men got tired so they disappeared from their assigned work crew and went to sleep in voids that had not been tested for safe atmosphere. This was aggravated by the fact that the ships were on an isolated pier and that the washing and rest room facilities were a significant distance away from the ship. This excessive distance to the rest room encouraged the smokers to smoke without first cleaning up their hands and face. The distance also encouraged men to eat and drink with dirty hands and meant that even a quick trip to the rest room took twenty to thirty minutes.

At the time the void work was started, the effort to install dehumidification systems onboard the battleships was already underway. Dehumidification had a higher priority than did the scraping of the voids, so the void crews were supposed to stay out of the way of the dehumidification crews. This made planning the void work more difficult and seriously disrupted the foreman's attempts to systematically progress in an orderly manner. The reason that work on the dehumidification system had priority was because the US Navy was pressuring the company to seal the ships and place them under a controlled atmosphere as soon as possible. This project was seriously behind schedule and the company was frantic that nothing should interfere with this work. In areas that had been sealed and had the dehumidification systems installed, the company tried to comply with the Navy's desire to keep these areas sealed up and under dehumidification even though the void workers were working in these areas. This set the stage for disaster.

Tight control over the spread of dust and debris by void workers is usually not required within the shipyard environment because holes are provided to exhaust the dust from the ship and make the work easier, and because shipyard void cleaners usually move on to other voids long before the hole gets re-welded and the area surrounding the work site gets cleaned up. As the crews went deeper and the summer got hotter, forced ventilation was provided but little guidance was given as to its use. The men, naturally, wanted a nice cooling breeze, so they blew air into the void. This unfortunately raised dust within the void, which not only increased the lead level of the air the men were breathing, but carried the dust along with the air as it exited out the hole at the top of the void and spread out to contaminate the interior compartments of the ship. The mess was simply incredible. Most of the second deck of the USS Iowa was covered in dust. Even worse, the men usually placed the blowers in the compartment directly adjacent to the void's entrance so that as the dust came up out of the void some of it would be recirculated back down to the men in the voids, and the man who was top watch and did not usually wear a respirator was exposed to an excessive level of lead. Fresh air was not brought from outside because this would involve additional set up and because this would interfere with the dehumidification. By using the blowers the men had taken a hot dirty job with an acceptable level of exposure and turned it into a nightmare. In some cases the visibility within the void was reduced to less than 15 feet as the red dust swirled around like a scene from Dante's Inferno. Progress slowed down and fights became more common as the working conditions deteriorated and the morale faltered.

During the first five months these 39 men completed approximately 73 voids. This represented an accomplishment rate of about 60 man days per void. This was much slower than had been estimated so the company decided to create a new crew to work on the Wisconsin, while the first crew continued to work on the Iowa. This second crew was a mixture of the complainers and troublemakers who had not gotten along with the foreman in charge of the Iowa, and the laborers from an existing crew that was led by a former Naval officer and a retired chief petty officer neither of whom had significant experience in tank and void work . This combined crew numbered 13 people and started to work on 1 July 1992.

Acknowledging the loss of work that the bathroom situation was causing, the company placed a portable toilet by the brow and activated one of the main deck shower compartments on the Wisconsin to provide shower facilities for the workers. An adjacent berthing compartment was used as a locker room. This was still unsatisfactory since many men avoided the portable toilet and continued walking to a building well over a quarter mile away. Eventually the company purchased a bathroom trailer equipped with sinks and flush toilets and installed it on the pier and this finally resolved much of the bathroom issue. Another important change around this time was the upgrading from regular wet/dry vacuums to proper hazardous material vacuums equipped with HEPA filters. These vacuums significantly reduced the amount of dust that was exhausted by the vacuum cleaners. A planned maintenance schedule for these high efficiency vacuum cleaners was started at the same time as the void operation became more professional.

Having observed the conditions on the Iowa, the new team on the Wisconsin decided to try a different approach. Instead of working from the top down they would work from end to end so that once the men were out of a section they would have no need to return. This would minimize set up time, reduce the amount of air testing required and ensure that no voids would be missed as a result of the discrepancies between the various sets of documentation. This concept was accepted because it also had the advantages of physically separating the dehumidification crews from the void crew and because this approach kept the void crew together and made it more difficult for crew members to wander away and hide. Supplemental training sessions were held to ensure that the workers understood more about the risks associated with the work. Proper ventilation practices were stressed. Starting in an area of the ship that had not yet been placed under dehumidification, the crew placed hoses into the far end of the voids. These hoses were used to suck out the contaminated air and exhaust it outside the ship. This created a suction whereby fresh air was drawn through the entry hatch and into the void. This arrangement allowed very little dust to escape into the interior of the ship and kept the voids reasonably clear of airborne dust. This system worked so well in comparison to the mess on the Iowa that it was mandated by the safety department for both ships even though its use necessitated turning the dehumidification off in the area the men were working in. Ironically the implementation of this system was resisted by the workers on the Iowa, who did not want to give up the cooling breeze provided by an airline fed directly into the void. This system was later modified to place an exhaust hose by each worker in order to further reduce the amount of dust in the air. This approach had mixed results. In voids made up of many small compartments this approach was clearly superior but in large open voids where a strong draft could be established by a single large diameter exhaust the benefits of individual hoses were never satisfactorily proven. The individual hose approach involved additional work but became mandated because it reduced the amount of judgment required by the set up crew and the safety inspectors who checked their work. Considering the level of poor judgment already demonstrated on the job it was deemed safer to simply require individual hoses in all situations.

A considerable amount of time and effort was spent physically verifying the presence and correct labeling of the voids actually present onboard the Wisconsin. This turned out to be a much larger job than expected since the Navy had attempted to change the compartment numbering system from the system in place when the ship was built in the 1940's to the system currently in use by naval warships. Unfortunately, this was poorly done and serious mistakes were made during the renumbering process, both in drawing up the Damage Control prints and in the physical labeling of the voids themselves. All of this caused considerable confusion at the management level, particularly among those managers who did not personally visit the voids and compare the physical reality to the conflicting documentation. In some cases two voids had been given the same number and in others a single void might have been assigned two different numbers on the same plan. Since part of the problem was that management had difficulty believing that the typed computer generated list given to them by the Navy could be seriously wrong, it became necessary to use a computer to create a new list which included the alternate names for the various voids. The computer was also used to reorganize the list from bow to stern of the ship instead of from top to bottom and this new list was used in conjunction with a frequently updated Damage Control Plate to visually present the progress that the crew was making. The importance of creating some simple visual way of presenting this type of information is essential. It significantly reduces the amount of time spent in explanations and gives senior management the comfortable illusion that they know what is really going on. Publicly posted progress charts are also good for encouraging competition between different work crews, which tends to enhance morale.

Work went much more quickly on the Wisconsin than it did on the Iowa. Some of this speed can be attributed to the fact that the average void on the Wisconsin required less work than the average void on the Iowa. This was partly due to differences in the damage control organizations on the respective vessels but the majority of the improvement was tied to improved working practices. In the first six months of operation the crew on the Wisconsin averaged 16 members and completed 170 voids at an expenditure of approximately 14 man days a void. This compares very favorably with the sixty man day per void accomplishment rate on the Iowa. The comparison is even more striking when a comparison is made of the conditions left behind the respective teams. The completed areas on the Wisconsin had been completely cleaned prior to the crew moving on, while the Iowa was still covered with a layer of dust that took months to remove where it had been ground in to the tiles on the deck as the men walked around and moved their equipment.

In accordance with federal regulations, the amount of lead in the blood of each worker was sampled every six months by an outside medical practice. Every man who had been transferred to the Wisconsin showed a decrease in his blood lead level compared to previous testing while working on the Iowa. The improved training and environmental controls had dropped the average blood lead level of the Wisconsin crew to less than half that of the Iowa crew. After considerable efforts the absolute blood lead level was significantly lowered in the other crews as well but even with these improvements the average blood level of the Wisconsin crew continued to average only one third to one half the average blood level of the other crews even though all the crews were working on the Iowa by this time and were using the same toilet trailer, shower facilities, and lunchroom established in a clean area aboard the Wisconsin.

At the time the Wisconsin crew moved to the Iowa the results of the different work practices of these two crews were easily visible on walk through inspections and were documented in the medical records of the workers involved. The dehumidification machine records provided additional documentation. On the Wisconsin machines had been logged out of service during the time that work had gone on in their section. On the Iowa the machines had remained running until the high volume of dust present in the air resulted in the contamination of the dehumidification machines, which lost efficiency and broke down more often as the lead bearing dust overloaded the filters. This totally defeated the point of having the dehumidification machines running in the first place, and this as well as the excessively high blood lead levels found in the workers on the Iowa forced the company to insist that the ventilation practices developed by the Wisconsin crew be applied to all crews in all sections of the Iowa.

On the Wisconsin, a concerted effort was made to open up the voids a week in advance of the working party. A ventilation hose would be dropped to the bottom and allowed to run over night. The air quality would then be checked and an advance party would rig the lighting, ventilation, and any staging necessary for the working party. In most cases newly open voids were ventilated for at least two days prior to the start of work. This made a significant difference in working conditions since the smells present in many freshly opened voids often made the workers nauseous even in voids that were otherwise safe to enter. By removing the smell prior to the start of work, progress was greatly enhanced. Initially only a hand picked crew did the set-up and tear down of the lights and the scaffolding but as the workers gained experience they would be paired with another worker already qualified in void set-up. Eventually this specialized set-up crew was consolidated into the regular crew and it became the crew leader's responsibility to ensure that the advance work was properly accomplished. For the first several months every set up was personally checked by the foreman or his assistant before the scraping was allowed to begin and random spot checks were performed thereafter. In contrast, the Iowa voids were often opened at the last minute and crews were all too often found sitting around and waiting for the conditions in the void to improve to the point where an acceptable gas free certification could be issued. Even then the workers would often sit around outside the void claiming nausea rather than being present inside the void accomplishing some amount of useful work. Supervisory presence inside the Iowa voids was virtually non-existent and in some cases the productive work for a whole crew averaged less than one hour per day per man. During this same time frame useful production averaged between four and five hours per day per man on the Wisconsin.

The result of this was that in six months a crew that averaged sixteen men on board the Wisconsin was able to catch up with a crew that had been working 11 months with an average of 32 men on the Iowa. Morale was running high on the Wisconsin and the crew that had been labeled undesirable by their former foreman were taking tremendous pleasure and pride in trashing his production record. Complaints by the Iowa's dehumidification crew concerning the lack of coordination between the void crew on the Iowa and themselves resulted in the Iowa's void crew being moved to the Wisconsin in January of 1993. The void crew that had started on the Iowa eleven months before had lost about half of its members. During the next three months the size of this crew would take a drastic drop as they learned to work under the system in place on the Wisconsin. By March this crew had been reduced to approximately six members out of the original thirty nine. Terminations and transfers had reduced the crews on both The Iowa and the Wisconsin.

Contemporary with these changes was a movement to unionize the work force. Irresponsible claims by the union organizers had led many of the younger workers to believe that massive pay raises would occur with unionization. In many cases, the void workers expected a 50 to 100 percent increase in pay. In actuality this was a virtual impossibility since the company was under a government contract that specified the pay rates of the workers involved. In order to increase the workers' salaries the government would have had to agree to a new contract with the company and pay the company enough to cover the increased salaries. Otherwise the company's only real option was to default on the contract, shut down the Philadelphia operation, lay off all of the workers and managers at the Philadelphia site, and allow the government to select a different contractor. Eventually the union agreed to accept a very modest package which consisted mostly of measures that allowed the union to save face as opposed to measures that significantly raised the workers' income. This left many of the younger workers feeling very unhappy and their disgruntlement showed up in a series of union complaints that were occasionally very pertinent to the health and safety of the workers but were all too often so ridiculous that even the elected shop stewards admitted that they considered the complaints to be bogus and felt embarrassed to have to bring the complaint up. It was against this backdrop that a disgruntled young man who was having severe problems with his home life filed a complaint with OSHA concerning the void operation on the battleships.

By this point in time the void operation had become very professional and was substantially in compliance with OSHA regulations. Gone were the days of the long hike, no lunchroom, and of drinking water kept in the voids. Documentation was near perfect and the men were well trained. For several days in February of 1993 OSHA inspected the work site and the documentation performed by the safety department. In the end the company was cited for two minor discrepancies. The first citation was for failing to properly submit a copy of form OSHA-73 to the nearest OSHA office. There was no fine associated with this citation. The second citation was the result of one of the inspectors observing one of the crew leaders chipping paint without wearing his safety glasses. The fine for this citation was $1625.00. Considering all the serious issues raised in the original complaint this was a remarkable vote of confidence in our safety efforts. This fine was promptly paid by the company after being advised that OSHA inspectors are expected to always find at least one minor discrepancy in order to remind the companies that they inspect that no matter how good you are there is always room for improvement. OSHA accepts complaints from all workers no matter how vindictive or mentally unbalanced the worker may seem and then OSHA investigates these complaints as they see fit. If an operation is in substantial compliance with the law, then OSHA will document this no matter how vindictive or outlandish the original complaint may have been. If the operation is not in substantial compliance, then OSHA is empowered to shut down the offending operation, levy heavy fines, and even consider criminal charges against the management that allowed the dangerous situation to exist. This is particularly likely to happen if OSHA is conducting an investigation into an accident that has killed or disabled a worker.

About a month after the inspection the Iowa crew returned to the Iowa the and was reinforced with a few additional personnel. This group now averaged about nine men who completed about as much work as had been previously performed by the original crew of thirty nine men. This well trained core was augmented by the void crew from the Wisconsin at the beginning of May 1993 in order to provide a clear working area on the Wisconsin for the dehumidification crews. This decision was partly political in nature. If the Wisconsin was finished before the Iowa it would create a lot of embarrassing questions which senior management did not wish to answer. To avoid these questions it was decided that the original foreman from the Iowa would retain overall control of the job on the Iowa, but the crew from the Wisconsin was to be allowed to retain the operating procedures they had developed on the Wisconsin. Morale fell as the Wisconsin crew was disappointed at not being allowed to win what they considered to be a race of epic proportions. Production faltered, but, the system developed on the Wisconsin still enabled the crew from the Wisconsin to accomplish more per man per day than was being accomplished by a significantly improved Iowa crew. Quality control also slipped when the men from the Wisconsin crew lost their crew leader and went through a difficult period trying to find a replacement. Several good workers tried out the job for varying lengths of time but all lacked the leadership skills to be effective in the role of crew leader. For the rest of the project the Wisconsin crew would muddle along with an inadequate series of crew leaders in training. In spite of this, morale did gradually improve as the work progressed, but it never again reached the heady euphoria that had been present just prior to the move to the Iowa.

With both crews working on the Iowa, overall progress improved. Competition accounted for some of it, but the majority of improvement resulted from improved work methods and increased supervision. Having a supervisor willing to crawl through the dirt on a regular basis to see who was really working and who was failing to perform made a significant difference. The older supervisor from the shipyard felt that his crawling days should be over so he usually stationed himself at the guard booth where he had a telephone and where he could monitor the men who left the ship to go to the rest room or make a phone call. The younger supervisor who had been in charge of the Wisconsin concentrated on maintaining the ventilation and ensuring that the workers were performing actual work. This unofficial division of supervision actually worked reasonably well even though it had not been approved by higher authority.

With the completion of the dehumidification systems aboard both battleships in August, the workers who had been working on the dehumidification were sent to the voids. These workers were predominantly mechanical workers who were highly opposed to doing what they considered as work for unskilled laborers. Their foremen were also upset by the arrangement and did not support the company in this assignment. As a result these crews were inefficient and performed poorly. The existing crews teased these men unmercifully as pay-back for all the times that these mechanics had lorded their higher pay and privileged status over the laborers in the voids. Work was disrupted and some of the mechanic crews staged a work slow down that was frequently supported by their supervisory personnel. These mechanics worked just fine when given special assignments but sandbagged whenever given assignments in the voids. When caught, these workers were defended by their foreman as being too valuable to lose, so the laborers quickly learned that it was acceptable for this group to engage in activities like sleeping on the job which would result in the termination of a laborer. This unequal application of justice caused considerable anger among the laborers that was not improved when a paint and preservation crew was temporarily detailed to help scrape the voids in December of 1993 when winter weather put a stop to topside preservation . This crew was comprised of laborers just as the void crew was, but these laborers did little real work, and acted in the same manner as did the mechanical crews. Their supervisor was personally fearful of being laid off if the size of his crew became too small, so he provided little discipline and subsequently accomplished very little except to keep his crew on the payroll as he waited for spring thaw and the start of the preservation season.

Work on the Iowa voids was completed around the end of March 1994. Without counting the three months during the winter of 1993 when no work had been performed in the voids on the Iowa, the job had taken a total of twenty three months to complete 396 voids and clean up most of the resulting mess. There had been an average of thirty four workers assigned to the job over the course of the twenty three months and this resulted in an expenditure of about forty one man days per void. This man day accounting does not include the efforts of the safety department that performed the air tests and handled the paperwork necessary to keep OSHA satisfied, but only includes the time spent by the workers and their direct supervisors.

With the coming of spring and the accomplishment of the void work on the Iowa, the original void crews resumed work on the Wisconsin voids. The mechanical and topside preservation crews were moved to other duties which resolved many problems and streamlined the work force. The smaller and more experienced crews made good progress considering that many workers were pulled from the crews for temporary work on other assignments. Progress did, however, begin to slow at the very end when the workers became concerned about job security. The frequent detailing of void crew members in the final months onboard the Wisconsin severely upset the calculations for how many man days it took per void since many men were assigned elsewhere for short jobs without any documentation. The frequency of these undocumented assignments grew as the summer progressed and other jobs gained higher priority. However, at the beginning of May 1994 there were 104 voids left out of a total of 402 and by September sixth 1994 there were only 3 voids remaining to be scraped and inspected. This accomplishment rate of 25 voids a month is a little slower than the initial rate of 28 voids a month but included the difficult splinter deck voids. By the end of the job in early September the men had worked on the Wisconsin for 16 months and completed 403 voids with a man hour expenditure of less than 20 man days per void.

One new tool that made a large difference after the return to the Wisconsin was a very large vacuum that was set up on the pier. It was powered by a six cylinder diesel engine and was similar to a truck mounted version used to pick up litter and debris. The dust was passed through several filter stages which efficiently removed the lead and rust from the exhaust. This vacuum was powerful enough to suck dust from the lowest voids more efficiently than any of the portable vacuums tried to date and had the added benefit of dramatically decreasing the amount of airborne dust within the void . While it did take a substantial amount of rigging to run the heavy hoses through the ship theses hoses certainly saved a lot of hoisting and carrying plastic bags full of debris. All too often these bags would rip open creating another mess to clean up so the men were very pleased with the way this vacuum did away with the bags full of lead dust and iron particles. If this machine had been available earlier it could have easily cut several months off of the job.

The big vacuum proved its usefulness on April 12, 1994 when smoke was discovered in the splinter deck voids. These voids were very difficult to work in because the overhead clearance was too low for a man to get on his hands and knees to crawl. A man lay on his back to scrape the overhead and rolled over onto his belly to scrape the deck. Movement was by pulling pushing and wiggling. The fire fighters called when the smoke was discovered were physically unable to enter the splinter deck voids because their air packs could not physically fit into the splinter deck voids with their air-packs so the vacuum was used to de-smoke the area but even then the firemen were unable to discover the cause of the smoke. Two days latter the crew leader in charge discovered a charred rag next to a light bulb, which could have started a serious fire instead of just smoking the place up a bit. This resulted in even greater caution on the part of the splinter deck workers who often had to lay up against the light stringers as they squirmed from pocket to pocket.

Eventually the crew finished all the voids, cleaned up all the equipment, and went on to other work. Starting from scratch, the company had built a lead control program that passed a rigorous OSHA inspection that had been requested by a hostile employee. Many workers left this job with lower blood lead levels than they had possessed at the time they were hired. In one case an employee started his employment with a blood lead level of 15 ug/dl and ended with a level of only 2.1 ug/dl. Considering that the maximum permissible level allowed by OSHA regulation is 50 ug/dl this clearly demonstrates that meticulous personal hygiene and careful work practices can make a significant difference in the amount of lead absorbed by a worker. It is demonstrably possible to remove lead based paints from ships while strictly complying with OSHA regulations. Most of the workers used to scrape the Iowa and the Wisconsin were poorly educated and lacked any motivation other than a paycheck yet a successful program was implemented. Ship museums are usually blessed with staff and volunteers that want to do a good job for their ship. They may not know what they need to do, but at least they tend to be reasonably intelligent and their hearts are in the right place. There is no reason that the vast majority of museum workers could not be properly trained to remove and properly dispose of lead based paint. To do this, however, requires an active safety program which should already be present aboard a museum vessel. Ships are inherently dangerous and accidents happen so easily that any museum vessel that does not have an ongoing and energetic safety program is simply waiting for a devastating lawsuit. Ships are made up of many kinds of hazardous materials and a ship museum must protect its employees, its volunteers, and the general public from the effects of these materials or it is in violation of federal laws and regulations.

The good news is that most ship museums should be able to comply with OSHA regulations without creating the extensive organization that was used on the USS Iowa and the USS Wisconsin. This is because most museum workers will not be as heavily exposed to lead as were the workers on the Iowa and the Wisconsin. In fact, with very few exceptions, the air tests taken of the working environment indicated that the void workers could have legally worked without their respirators and at no point did the exposure level exceed the protection factor offered by the half mask respirators that were issued.

In summery, it is possible for a ship museum to properly comply with OSHA regulations and while this paper is not meant to provide an in depth analysis of OSHA regulations concerning lead paint, confined spaces, and other assorted issues it is designed to impart the knowledge that these issues must be taken seriously. Hopefully, it will help to encourage ship museums to establish a proper safety program that will protect their staff, their volunteers, the general public, and their ship from health hazards and lawsuits. More definitive guidance in what a given ship museum needs to do is available from OSHA as well as from commercial safety consultants in your own area. But each museum should expect to take the following minimal actions to protect their organization:

  • Write out a formal lead control program and make it available to every employee and volunteer.
  • Identify in writing those workers most likely to be exposed to lead on a regular basis.
  • Document how often lead work is performed by each worker on the exposed list.
  • Provide safety training on lead, confined spaces , and respirator use.
  • Take air samples to document the lead levels encountered during your actual work.
  • Have a doctor specializing in industrial medicine take blood samples to establish a baseline exposure level.
  • Make respirators with HEPA filters available for workers to use when dealing with lead and other shipboard dusts.
  • Provide a proper HEPA vacuum cleaner to clean up with.
  • Provide proper ventilation.
  • Provide facilities for proper hygiene and insist that workers clean up before going home.
  • Document everything in the form that is required by OSHA.
After taking the above precautions have someone familiar with the requirements set forth in the 29 CFR to compare your baseline records with the standards set forth in the 29 CFR. Judging by the data taken onboard the USS Iowa and the USS Wisconsin it is probable that the amount of lead encountered by museum workers will be below the threshold that necessitates a full scale lead control program. If this is so then it is legal to make a written determination that lead exposure is within federal limits and that continued monitoring is unnecessary. Should it become necessary to start a large scale paint removal project at a later date then monitoring will have to be resumed, but if the exposure risk remains the same then very little additional is required. It is probably a good idea to maintain a safety lecture on lead on a yearly basis, insist on good hygiene, and continue to provide a HEPA vacuum cleaner for use with lead dust. Maintaining the availability of the respirators and their HEPA filters is also a good concept since HEPA filters also protect against incidental exposure to asbestos, mold spores, and many other types of dangerous or obnoxious shipboard dusts. Lawsuits can occur over exposure to many different materials and it is much less expensive to provide quality respirators than it is to go to court over your failure to provide them.

The bottom line is that most ship museums have failed to develop a safety program that will properly protect the museum, its employees, and its volunteers. The programs in existence are probably insufficient when compared to the requirements set forth in the 29 CFR which makes an institution very vulnerable to fines and lawsuits. Proper documentation of existing conditions can probably avoid the need for a full blown lead control program if an institution is not doing a wholesale removal of lead based paint. If an institution does need to do a wholesale removal of lead based paint then the procedures to properly perform this operation have already been successfully demonstrated and there is no need to reinvent the wheel.

The following is a list of hard learned directives that the crew leaders were expected to enforce on a continuing basis as their crews worked in the 799 voids encountered on the USS Iowa and the USS Wisconsin. This list is compiled from several memos issued during the course of the job. These procedures are draconian, but each one was written to prevent past mistakes. These rules work. The number of accidents and the blood lead levels of the workers were both decreased when these rules were strictly enforced. These rules will also do a serviceable job for most ship museums faced with the problems of lead based paint. Museum workers and the institutions themselves need to take lead paint as well as other aspects of industrial safety more seriously than has often been the case in the past because both the individual and the institution are in danger when safety is neglected.


The crew leader is expected to enforce the proper procedures to produce a safe, high quality, performance of the work package. The procedures for safe working within the voids that follow are not new. All have been discussed on multiple occasions to the point that every crew member should know them by heart. It is not the crew leader's job to physically do each of these jobs. It is the crew leader's job to make sure that the crew does each of these jobs. Most of these rules are part of the lead worker safety program. The items on this list are not recommendations, they are requirements that crew leaders are expected to enforce.
1. Have the men open the void in advance of the day you expect to enter. Post the signs indicating that this will be a lead work area.
2. Have the safety department workers test the air quality before allowing the crew to enter. Voids are confined spaces and the potential for accidental death is ever present. The safety department has tested several voids that have had a dangerously low oxygen level that could have resulted in death if entered without prior testing. Do not place yourself or your crew in a position of unnecessary risk.
3. Have the lights rigged. The voids must be well lit. Dark voids are dangerous and promote unacceptably sloppy work. I do not approve of unnecessary danger nor do I approve of sloppy work. Any and all jobs we do must be done safely and well. I do not like sloppy work. It wastes time, looks bad, and is simply unacceptable. Sloppy conditions are often unsafe as well. I want the crew to always do a neat, safe, and quality job. I expect you to maintain quality and safety in everything we do.
4. Ensure the ventilation is properly rigged. There should be a suction hose in every void pocket that has an employee working in it. If a supply air hose is used it will be placed in the compartment outside the void so that the air will enter the void from this compartment creating an air dam that will help prevent the dust from blowing out of the void and into the ship. There shall be no supply hose placed inside the void as this will weaken the effect of the air dam and allow the void dust to contaminate the ship.
5. Ensure that the proper safety gear is worn at all times. This is very important. As crew leader you are directly responsible for ensuring that the men wear the safety equipment provided for their use. If there are problems with either supply or compliance you must immediately notify supervisor so replacement material can be obtained or written warnings can be issued.
6. Ensure that no reading materials, games, or any other diversions that could distract the crew's attention from safe work practices are present. It is especially important that no radios or tape players are present in the working areas. Personal radios and tape players make emergency communication much more difficult and endanger the whole crew and not just the person wearing them.
7. In order to do this job safely the men must clean up and take showers before going home. The crew leader must ensure the entire crew, including the top watch and any people assigned to cleaning up this dusty ship, take a full shower at the end of the working day. Remember that these showers are provided on company time as opposed to break time. The void workers are still on the clock and are assigned to perform the work of properly cleaning themselves in accordance with OSHA regulations. As with any other assigned work , the crew leader is required to notify his supervisor when any of the men assigned to him are failing to do a proper job of cleaning themselves in compliance with the void safety program and OSHA regulation. The crew leader is expected to personally set the example of a full shower every day.
8. Safety regulations for working with lead require that the workers clean up before they eat, drink, or take a smoke. Ensure that our crew strictly follows these regulations. There must be no food or drink available within the contaminated area. Food is allowed in the designated eating area only. In order to eat, drink, or smoke the men must leave the contaminated area and clean up before doing their eating, drinking, or smoking. This includes the removal of heavily contaminated coveralls or other outer wear before entering the clean eating area. No drink containers or water bottles are allowed near the work site where they might tempt a crew member to violate this important rule. You are to immediately report any worker who violates this rule.
9. Safety glasses and respirators must be worn. As crew leader you are expected to check and ensure that the men are wearing safety glasses and respirators which are in good repair and to see that the men get replacements as necessary. You will ensure that face shields, safety harnesses, and tyvec suits are used as needed.
10. Clean up the work site. Remove the contaminated dust from any and all surfaces that it has settled on. The crew leader must ensure that no dust, debris, tools, or other supplies are left behind. A quality job is essential.
11. Remove lighting and ventilation. Check all light stringers for damage and have the electricians repair as necessary prior to placing the lights in the next void. Ensure that the blowers and hoses handling clean air do not get accidentally mixed up with the equipment used for the exhaust. The fresh air supply must not accidentally become contaminated with lead dust because someone carelessly mixed up the hoses and blowers.
12. Ensure that properly secured safety screens are covering all void openings that present a danger. Ensure all debris from this operation have been removed.
13. Bag and secure all extra bolts. Ensure that the lead work signs have been removed.
14. It is essential that all men maintain a close shave in order to ensure a satisfactory seal between their respirator and their face. Facial hair can also collect enough lead dust to present a threat when eating. As a crew leader it is essential that you monitor facial hair and to report any man who allows his facial hair to interfere with his ability to safely and properly wear his respirator.

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