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Safety At Sea - Magazine - Features

03 May 2012

Tackling enclosed-space safety means holding regular drills, according to the industry regulator. Martin Watts guides you through the latest IMO recommendations

Enclosed space safety: More drills for safer spaces



Tackling enclosed-space safety means holding regular drills, according to the industry regulator. Martin Watts guides you through the latest IMO recommendations



As regular readers of SAS will know, one of the persistent causes of death and injury to seafarers and stevedores is entry into an enclosed space. The many types of enclosed space on board ships include machinery, cargo and hull spaces, each of which will be defined by limited access and poor ventilation.

Enclosed spaces are, according to the IMO’s definition, “not designed for continuous worker occupancy”. During normal shipboard operation, however, access to such spaces is required for inspection, maintenance, repair and, where appropriate, cargo operation. Hazards associated with work in an enclosed space include the toxicity of the atmosphere, poor lighting, poor ventilation and restricted access for the retrieval of casualties.

The IMO issued its recommendations for entering enclosed spaces on board ships in 1997. Twelve years later work began on a review of this guidance following the publication of a disturbing report on enclosed space casualties compiled by the Marine Accident Investigators’ Forum (see page 36 for further details).

The IMO Sub-Committee on Dangerous Goods, Solid Cargoes and Containers (DSC) endorsed MAIF’s conclusion that many of these casualties were caused by a lack of training and a failure to carry out the recommended drills.

The DSC sub-committee was concerned that these failures would persist unless the recommended procedures were supported by a firm commitment at management level. In response, a correspondence group was set up to revise the IMO recommendations, which included contributions from the Bulk Liquid and Gases, Fire Protection and Standards of Training and Watchkeeping sub-committees.

Once the committee’s work was completed, the revised recommendations were formally adopted on 30 November 2011 at the 27th Assembly of the IMO and published in the organisation’s Resolution A.1050 (27).

The main difference between the current and previous recommendations is the inclusion of a new section, ‘Safety Management for Entry into Enclosed Spaces’, which emphasises the need for a “comprehensive approach” to this type of operation. It specifies that the procedures must be included in the ship’s safety management system (SMS) in accordance with the International Safety Management Code.










Revised recommendations



The section reflects the work by the sub-committee in several clauses emphasising the importance of training and drills, both in the management and execution of work in confined spaces. Risk assessments, atmospheric testing, authorisation of entry and general precautions are to be included within the

SMS, which is itself subject to internal auditing by the company and external auditing

by the responsible administration.

In addition to the revised recommendations, the DSC also agreed SOLAS amendments “to mandate enclosed space entry

and rescue drills” that would have the effect of imposing, through SOLAS, the obligation to carry out enclosed-space entry and rescue drills every two months. These drills will include the inspection and use of personal protective equipment, communication

equipment, rescue equipment, first aid equipment and all associated procedures. It is the intention that these mandatory requirements will be finalised at the next meeting of the DSC in September, after which they will be submitted to the MSC meeting in May 2013 for approval.

Captain Phil Griffin, a maritime consultant with experience of command, inspection and survey, told SAS that he “completely agreed with the proposed SOLAS amendments”. He recalled the 1970s when, in the UK, “such exercises were an integral part of the Board of Trade safety drills on board ‘regular’ trading vessels”. For Griffin, familiarity with the risks of working in enclosed spaces is crucial to increasing seafarer competence. “Confined-space entry needs to be a routine part of

work on board ships,” he reasoned. “It does,

of course, involve hazard, but training and competence mitigate the risks and permit

safe working in such spaces.”

Last year some reports suggested that companies were forbidding entry to confined spaces by crew members, but Griffin observed that probably this was the case in vessels that are not covered by SOLAS. “There are very many confined spaces out there that are not in large international trading vessels, but rather are in smaller ships in many different levels

of trade and occupation, regulated to different benchmarks,” he observed. “Their crews are not necessarily ever exposed to the basis of training that will flow by way of SOLAS into marine practice and regulation.”

There can be little doubt that, by following the new recommendations and the proposed SOLAS amendment, seafarers can seriously reduce the risks involved in working in confined spaces. However, as Griffin’s observations and our feature beginning

on page 34 have illustrated, there is still no room for complacency across the industry, if maritime workers are to be protected from the worst effects of this hazardous operation.


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