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R 252234Z JUN 25 MID120002033502U
FM COMNAVSAFECOM NORFOLK VA
TO ALSAFE
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ALSAFE 025/25

SECINFO/U//
MSGID/GENADMIN/COMNAVSAFECOM/30/JUN//

SUBJ/NAVSAFECOM ADVANCED CHANGE NOTICE FOR REMOVAL OF BROW NET REQUIREMENT
WHILE IN DRY DOCK//

REF/A/DOC/OPNAVINST 5100.19//
REF/B/DOC/NAVSEA S0570-AC-CCM-010/8010, REV 1//
REF/C/DOC/NAVSEA GSO//
NARR/REF A IS OPNAVINST 5100.19F, NAVY SAFETY AND OCCUPATIONAL HEALTH
PROGRAM MANUAL FOR FORCES AFLOAT. REF B IS NAVSEA TECHNICAL PUBLICATION,
INDUSTRIAL SHIP SAFETY MANUAL FOR FIRE PREVENTION AND RESPONSE. REF C IS
THE GENERAL SPECIFICATION FOR THE OVERHAUL OF SURFACE SHIPS.//

POC/CAPT SCOTT JONES/NAVSAFECOM/DEPUTY COMMANDER/NORFOLK/DSN 564-3520
X7127/757-444-3520 X7127/SCOTT.A.JONES13.MIL@US.NAVY.MIL//

GENTEXT/REMARKS/1.  This ALSAFE applies to all US Navy afloat commands.
Reference (a), Section D, Chapter 4, paragraph 3.n, which only applies to
submarines in dry dock states, "Safety nets must be rigged extending a
minimum of 6 feet on both sides under all access brows between the ship
and the dock apron."  Reference (a), Section C, Chapter 8, paragraph
5.k.(2), which applies only to surface ships in dry dock states, "safety 
nets must be installed under gangways and platforms that are not fitted 
with both side rails having a vertical height of 42 inches nominal and 
metallic meshing or similar material with small openings (approximately 
2-1/2 inch) between the top of the rail and the gangway platform deck."

2.  The policy incorrectly implies that brow nets are a suitable alternative
to handrails as a fall protection mitigation. This is inconsistent with the
federal code of regulations fall protection requirements. Additionally, the 
policy implements a different standard between ships and submarines while in 
the dry dock.

3.  This ALSAFE serves as advanced notice that NAVSAFECOM is updating the
policy. The requirement by either ships or submarines to use brow nets while 
in dry dock is rescinded. Furthermore, brow nets cannot be used as an alternative
mitigation in lieu of 42 inch handrails for either gangways or platforms. Brow 
nets may be used as a supplemental mitigation measure.

4.  The new policy to be codified in an update to OPNAV-M 5100.23 will be
applicable only to ships and submarines while in dry dock: "Gangways and platforms 
must be outfitted with side rails on applicable sides having a vertical height of 
42 inches nominal and metallic meshing or similar material with small openings
(approximately 2-1/2 inch) between the top rail and the gangway Platform deck."

5.  Request NAVSEA use the requirement codified in paragraph 4 above to
update both reference (b) and (c) as appropriate.

6.  Compliance with this new policy is required by 30 January 2026. Request
NAVSEA work with TYCOMs and shipyards to verify brows are compliant and, if
necessary, develop plan to achieve compliance for all navy ships and
submarines in dry dock.

7.  This ALSAFE will remain in place until OPNAVINST 5100.19F is integrated
into the OPNAV-M 5100.23.//
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