Enclosed spaces - more lives wasted
What is a dangerous space?
Precautions to be taken prior to entry into enclosed spaces
Marine Safety Card - a checklist
Requirement under the ISM Code
Enclosed Spaces - more lives wasted
The death toll continues to mount
Few aspects of personal safety on ships have received more attention than the importance of following the correct procedures before entering an enclosed space. Unfortunately, fatalities and serious injuries continue to happen with relentless regularity - almost every one of which could have been prevented if the correct procedures had been followed.
Serious efforts have been made by many different sectors of the shipping industry to raise awareness of the dangers of entering enclosed spaces - indeed, 'Signals' has regularly featured this important topic. Despite these efforts, the death toll continues to mount. This special edition of 'Signals' will double those efforts by exploring in some detail why these unnecessary accidents continue to happen and what needs to be done to prevent them happening again.
A case of deja vu
The story behind the majority of these incidents is all too familiar; one person enters an enclosed space without having taken the necessary precautions. That person collapses from either lack of oxygen or toxic fumes. The collapsed person is then seen by a second person who, without taking any precautions, attempts a rescue. In those attempts he or she also collapses. It is not unknown for even a third or fourth person to be overcome in the same way in the belief that they can do better. Eventually, someone starts thinking straight and follows the correct procedures. An emergency party, with the correct rescue equipment, is mustered and carries out a controlled rescue. Unfortunately, the emergency party usually brings out dead bodies.
What is most surprising is that enclosed space accidents appear to involve a wide range of people, including highly qualified and experienced seafarers as well as stevedores and even surveyors. It is perhaps understandable, from a human point of view, to appreciate that one's first reaction on seeing a friend collapsed in such a scenario is to rush to their assistance. Whilst the intention is good, it is virtual suicide - compounding an already tragic situation.
Almost all the people who die in enclosed spaces have received training and are well aware of the correct procedures. In the agony of the moment, they choose to disregard those procedures.
How widespread is the problem?
It is difficult to obtain any meaningful statistics from across the international maritime industry on the extent of the problem of enclosed space accidents. North of England P&I Association experiences a small number of these incidents each year. Reports from the Marine Accident Investigation Branch (MAIB) of the British Government and the Seafarers' International Research Centre are inconclusive as far as numbers of incidents are concerned but they do confirm that a significant number of incidents are continuing to occur and the same scenarios continue to repeat themselves.
The issue is not so much how many incidents occur - it is the fact that they are continuing to occur in relatively significant numbers which is sufficient to generate serious concern. Furthermore, of all the accidents which occur on board with a real risk of fatality, there are probably none which are more preventable. Almost every single one of these incidents could have been avoided if the correct procedures had been followed.
Why a special issue of 'Signals'?
This special edition of 'Signals' aims to draw attention to some misconceptions and misunderstandings which seem to exist, particularly concerning what constitutes an enclosed space. It contains yet another reminder about the correct procedures which must be followed before entering an enclosed space. If, by repeating these guidelines, one life is saved it will have been worth the effort. Included too is a brief analysis of the importance of the correct procedures for entering enclosed spaces within a safety management system, which is a requirement of the ISM Code. A possible key to understanding why people respond to instinct rather than training is also given with the suggestion that theoretical training should be reinforced by frequent practical drills and exercises involving the whole crew. Emphasis is also made of the importance of tight security to ensure that shore-side people who do need to enter an enclosed space on board the ship are advised of the correct procedures, and also that they comply with those procedures.
Will more rules and regulations solve the problem?
In the UK the Merchant Shipping Regulations state that procedures for ensuring safe entry to, and working in, dangerous spaces should be clearly laid down by the ship operators and that the Master should ensure that such procedures are observed on board ship.
The regulations further state that except where necessary for entry, a ship should ensure that entrances to unattended dangerous spaces are either kept closed or otherwise secured against entry.
Other flag administrations have similar rules and regulations. Whilst the ISM Code does not contain such explicit rules and regulations they would certainly be implied within a properly constituted safety management system. Indeed, there are few who would doubt that such regulations represent good practice guidelines, irrespective of flag.
The solution is in your hands!
Though governments, shipowners and P&I Clubs can produce an endless supply of 'rules and regulations', and countless books, newsletters and videos can be put on board, will this solve the problem?
It may help, but the truth is that the only way these fatalities will be prevented is if you implement those rules and regulations - those good practices - each and every time you enter an enclosed space for whatever reason, or require others to enter an enclosed space.
Properly plan and prepare the entry, which includes ensuring that the correct equipment and personnel are available. Use the Entry into Enclosed Spaces checklist card. The solution is in your hands!
In conclusion, we all need to make a personal commitment to raising safety to the highest priority. We must work to develop a safety culture on board whereby our first instinct is safety. Only then will the rules and regulations stand any chance of working in practice.
What is a dangerous space?
What compartment should be considered as an "enclosed space"?
Despite the fact that the dangers of entry into enclosed spaces have been known for many years, people are still killing themselves on board ship by entering such spaces.
Most seafarers have seen the training videos, read the bulletins and are well aware of the hazards, yet the death toll continues to mount. How many more seafarers, surveyors, superintendents and shore workers must die?
Every year more partners are left single and more children lose a parent and yet nothing seems to stop the ever-increasing death toll.
North of England has seen far too many fatalities from such incidents, but an interesting factor is coming to light. Spaces which have traditionally been referred to as enclosed spaces are not always the cause of such problems. Indeed, cargo spaces are the areas in which the majority of fatalities have occurred in recent years.
So, what is an 'enclosed space' and is the term sufficiently descriptive? The term enclosed space is a suitable and indeed easily recognised term, however seafarers and others involved in entry into enclosed spaces must be aware that many spaces are potentially dangerous. A dangerous space is any space that has, or may have, an oxygen deficiency, an explosive atmosphere, a toxic atmosphere or an unknown atmosphere.
Clearly it is not possible to list all potentially dangerous spaces which may be encountered on board ship but examples which may have traditionally been referred to as enclosed spaces include:
- cargo tanks
- deep tanks
- void spaces
- tanker pump-rooms
- gas carrier compressor rooms
- double-bottoms
- duct keels
- ballast tanks
- sewage storage and/or treatment tanks
- inert gas rooms (including scrubber towers)
- battery lockers
- fixed fire-fighting bottle/storage rooms
- pressure ships; boilers, air receivers etc
- cofferdams
- cable and pipe trunks
- chain lockers
- incinerators and boiler furnaces
- bunker, diesel and lubricating oil tanks
- gas carrier void spaces
- forecastles and forepeak spaces
- chemical storage lockers.
Cargo spaces on many ship types are potentially dangerous due to the atmospheric conditions within the cargo space. Most seafarers recognise the dangers of oil cargo tanks, inerted cargo tanks and containers carrying toxic chemicals. However, less obvious cargoes can kill. Cargoes such as scrap metal, timber and coal can all create a lethal condition within a cargo hold.
The safest way in which to consider any space is with extreme caution. Treat such a space as a dangerous space if it has been battened down, not fully ventilated or if you are unsure of its condition. The testing of the atmosphere within any space is essential.
Before any person considers entering an enclosed space or a dangerous space, the entry must first be fully discussed and meticulously planned. Safety procedures must be agreed and adhered to at all times.
The atmosphere must be tested at several levels within any space and any such testing can only be carried out by fully trained and competent personnel. All test instruments should be calibrated and certificated.
Spaces should be tested for :
- oxygen deficiency
- flammable gases or vapours
- toxic gases.
Clear company guidelines for an entry procedure must be established to suit each ship and each shipping company as well as sea staff and personnel. Before entry can be considered to any space, oxygen levels must be regularly observed to be above 20% by volume at all test sites and the lower flammable unit readings must fall below 1%. Current internationally accepted exposure level guidelines must be consulted prior to entry into any space which might contain, or may have contained, toxic gases.
Clear instructions must be adhered to and a permit-to-work system adopted. The permit-to-work system has been used in many sectors of industry and has proved to be a very effective loss prevention tool. Under this system, no task should be started without a valid permit; in this case an entry permit.
An entry permit should only be completed by an authorised and competent crew member when all safety aspects have been fully considered. This is not something that can be completed from the warmth and comfort of a cabin, rather the authorised signatory should inspect the entry site and verify the conditions prior to issuing an entry permit. Communication systems must be put in place, the atmosphere must be tested and the space fully ventilated prior to entry. Indeed, communications and ventilation as well as procedures must be maintained throughout the period of entry. Rescue procedures must be established and all necessary rescue equipment must be readily to hand.
With all procedures and safety factors considered, entry must even then be with extreme caution. Entry permits should only be valid for a specified time period and if for any reason the atmosphere changes, ventilation ceases or there are any doubts as to the condition of the atmosphere in the entered space, all personnel should be withdrawn from the space.
The above guidelines have been freely available for many years and yet due to either perceived or very real pressures, lapses in concentration or just ignorance, many people have died as a result of entry into enclosed spaces.
DON'T ADD YOUR NAME TO THE CASUALTY STATISTICS.
Precautions to be taken prior to entry into enclosed spaces
Before an enclosed space is considered safe for entry it is vital that the task is fully planned. Work-planning meetings, which should be a regular part of on-board safety management, are the correct forum to discuss entry into an enclosed space. Participants at such a meeting might typically include:
- Master
- chief officer
- chief engineer
- second engineer
- CPO (chief petty officer).
- The factors to be considered are varied but must include:
- the personnel involved (competence and experience levels)
- the physical procedure of opening the enclosed space
- ventilation methods (before and during entry)
- testing equipment requirements (calibrated and certificated equipment)
- atmosphere testing procedures
- entry permits and authorisation by senior officers
- local conditions including access and lighting requirements
- personal protective equipment requirements
- communications (established and maintained)
- prevailing weather conditions and sea state
- equipment and tool requirements
- requirement for intrinsically safe equipment?
- rescue and emergency response procedures
- resuscitation and rescue equipment requirements
- continuous atmosphere monitoring
- stand-by personnel
- full pre-task briefing and debriefing.
Clear procedures should be identified by shipowners and seafarers and all personnel must be familiar with each of the procedures and understand where they fit in to the overall picture. Perhaps the single most important consideration prior to entry into enclosed spaces is determination of the atmospheric conditions within the space.
The tests available include checking for:
- oxygen deficiency
- flammable gases or vapours
- toxic gases.
The tests to be undertaken prior to any entry vary according to the service for which the space has been used. Whatever the duty, tests should only be conducted by competent and certificated personnel - lives depend upon it. All test equipment should be regularly tested and calibrated on board prior to use and the master instruments should be calibrated ashore at a recognised calibration test house. It is vitally important that carrying cases, straps and handles should be regularly checked and if necessary replaced.
Testing for oxygen deficiency
Oxygen deficiency tests should be conducted using a recognised, calibrated and fully certificated oxygen meter. Entries should only be permitted if the percentage oxygen content by volume has given a steady reading greater than 20% by volume. It is good practice to test the atmosphere at several levels in a space, if appropriate, usually at the top, middle and bottom of a tank.
Testing for flammable gases or vapours
A combustible gas indicator or "explosimeter" should be used to detect the percentage content in the atmosphere of flammable gases and vapours. If for any reason a suitable meter is not available then a space should be either flooded with ballast and then pumped out to induce fresh air or an external ventilation system must be arranged and the space fully ventilated for a specified period. This will be dependent on the volume air changes.
When lower flammable unit readings fall below 1% then the space can be considered safe - but should only be entered when the oxygen reading is as at least 20% by volume and no toxic gases are present.
Testing for toxic gases
On many ships, especially chemical carriers, crude oil carriers and specialist product tankers, toxic substances may be present in enclosed cargo spaces. Indeed all ships carrying toxic cargoes such as containerised cargo should have testing facilities on board. Seemingly innocuous products can release toxic substances into the environment. Examples include vegetable or animal oils which can release hydrogen sulphide when they come into contact with sea water.
Whenever there is a likelihood or a possibility of toxic gases being present, the atmosphere must be tested. Up-to-date internationally accepted exposure level guidelines must be consulted before any entry into a space which may contain toxic gases.
It is important to realise that a combustible gas analyser is not suitable for detecting toxic gases prior to entry into an enclosed space. Specialist detection equipment such as the Draeger tube system must be employed to determine that no toxic gases are either not present or below recognised safe exposure levels. The presence of toxic gases may remain undetected without the use of this specialised equipment which can detect very low levels of toxic gases in any atmosphere.
The importance of the correct prior planning of an entry into an enclosed space should never be underestimated and sufficient time must always be allocated to ensure that the job is correctly planned.
Marine Safety Card - a checklist
The marine safety card 'Entry Into Enclosed Spaces' has been reproduced by North of England with the permission of the British Chamber of Shipping. The card details general precautions prior to entry into cargo spaces, pump rooms, and other enclosed spaces as well as highlighting the fact that any enclosed or confined space may be incapable of supporting human life. The safety card also details general precautions, offers warnings and guidance on protective equipment and clothing. The reverse side of the safety card offers a checklist which should be completed prior to any entry into an enclosed or potentially hazardous space.
The safety checklist is divided into three sections.
Section 1: (to be checked by Master or responsible officer)
- The space should be properly ventilated, tested and found safe.
- Ventilation should be continued throughout the occupancy of the space.
- The space should be tested regularly during occupancy.
- Rescue and resuscitation equipment should be available at the entrance.
- A responsible person should be stationed at the entrance.
- A system of communication should be agreed - such equipment must be of the approved type and intrinsically safe.
- Adequate lighting should be provided and be of a type that is appropriate for the duties in hand.
Section 2: (to be checked by the person entering the space)
This part of the checklist is a check that the persons entering the space have received instruction or permission to enter the space, it ensures that persons entering a space have checked that section 1 has been complied with and that communications are established between themselves and the standby person at the entrance.
Section 3:
The third section of the checklist pertains to breathing apparatus, the operation and testing of them, familiarity with their use and emergency signals. It is recommended that a safety trolley, or box, for ships where access to main decks is difficult, should be prepared with all the apparatus required for entry into enclosed spaces for rescues stowed within. Thus, when entry is to be arranged, the contents should be taken to the point of entry, ready for use as required.
A safety box should contain the following equipment as a minimum:
- two sets of breathing apparatus
- two spare BA bottles
- safety harnesses/rescue harnesses
- life lines
- two spare torches (suitable for duty ie intrinsically safe or as required, depending on the type of ship, etc)
- resuscitation equipment
- stretcher
- safety helmets.
The individual standing by the top of the tank should record entry times, advise the wheel house and monitor movements so that at all times the whereabouts of any person in the enclosed space is known. If at any time the conditions in the space change, the atmosphere becomes suspect or someone feels unwell/appears to be suffering, ALL personnel should vacate the space and the full procedure repeated.
Requirement under the ISM Code
For some shipowners the ISM Code is already a reality - either because they operate ships to which the code applies as a matter of law, for example, passenger ro-ro ships in European waters or because they have implemented the requirements of the code voluntarily ahead of the formal implementation dates for their particular types of ships.
For those shipowners who have not yet implemented the requirements of the code, time is quickly running out. Shipowners operating tankers, bulk carriers and cargo high-speed craft must comply by July, 1998 and those operating other cargo ships and mobile offshore drilling units must comply by July, 2002.
The safety management system required by the ISM Code will be very wide-ranging to cover all aspects of the safe operation of ships and pollution prevention. There is no specific mention of 'entry into enclosed spaces' anywhere in the ISM Code. However, many of the sections of the code are of direct relevance and the more significant ones are discussed here.
The functional requirements for a safety management system
Section 1.4 of the ISM Code requires every company to develop, implement and maintain a safety management system (SMS). It further requires that the SMS has a number of functional requirements - two of the most relevant functional requirements are:-
1.4.2 instructions and procedures to ensure safe operation of ships
and
1.4.5 procedures to prepare for and respond to emergency situations.
The SMS must therefore, amongst many other things, have instructions and procedures in place to control how personnel can enter enclosed spaces safely.
In addition, procedures must be in place within the SMS to deal with emergency situations whereby, for example, someone has entered an enclosed space and requires rescuing. It matters not why the person had found themselves overcome and requiring rescue from the enclosed space - the possibility of such an eventuality arising should be identified and contingency plans put in place.
The other relevant sections of the code will thus be considered from these two aspects:-
- procedures to control the entry into enclosed spaces
- procedures to deal with an emergency situation involving an enclosed space.
Training
Section 6 of the code relates to 'Resources and Personnel'. With reference to entry into enclosed spaces there will be at least the following requirements of the shipowner:
that new personnel are given proper familiarisation with the correct procedures should they be required to enter an enclosed space or should they be required to respond to an emergency involving an enclosed space
that all personnel involved in the shipowner's SMS have an adequate understanding of the relevant rules, regulations, codes and guidelines as they apply to the procedures for entering enclosed spaces and responding to emergency situations involving enclosed spaces
that procedures are established and maintained to identify any training which may be required to ensure that all concerned understand the correct procedures for entering enclosed spaces and how to respond to an emergency situation involving an enclosed space
that information on the correct procedures for entering enclosed spaces and how to respond to an emergency situation involving an enclosed space is provided to ship's personnel in a language they can understand.
There are a number of ways which shipowners can comply with the requirements of section 6. They could, for example, arrange for the relevant training to be given to their seafarers before they join the ship. This could possibly be done by shipowners in-house or in conjunction with a nautical training establishment. The company will also have its own written procedures in place with which the seafarers should be familiar. These may be complemented by additional authoritative publications such as the 'Code of Safe Working Practices for Merchant Seamen', the 'Merchant Shipping (Entry into Dangerous Spaces) Regulations' or similar guidelines published by the relevant flag states or 'Personal Injury Prevention - A Guide to good Practice' the new North of England loss prevention guide.
Development of response plans and on-board training
Of course familiarisation, training and generally raising of awareness of the enclosed-space procedures should continue on board ship. Experienced senior officers could fulfil the role of the trainer. Those efforts could be reinforced by the use of suitable videos, publications, posters and other training and awareness measures. Perhaps the most important training of all, however, is the practice of holding regular realistic drills.
Indeed, section 7 of the ISM Code has much to say about the preparation of plans to deal with potentially dangerous situations and section 8 deals with emergency preparedness including the importance of holding drills.
7 Development of plans for shipboard operations:
The Company should establish procedures for the preparation of plans and instructions including checklists for key shipboard operations concerning the safety of the ship...
8 Emergency preparedness
8.1 The Company should establish procedures to identify, describe and respond to potential emergency shipboard situations
8.2 The Company should establish programmes for drills and exercises to prepare for emergency actions
8.3 The Safety Management System should provide for measures ensuring that the Company's organisation can respond at any time to hazards, accidents and emergency situations involving its ships.
The importance of holding drills cannot be emphasised enough. Learning in the classroom and from books and videos will raise the level of awareness to a certain level. However, in a real emergency, that academic knowledge may not be sufficiently embedded and may be temporarily forgotten in the agony of the moment. Indeed, it is clear that almost all of the personnel who are killed or seriously injured entering enclosed spaces did know, in theory, what they should or should not have done - for some reason they chose to ignore that knowledge.
In that moment or crisis, when one seafarer sees his colleague collapsed in an enclosed space, their first instinct is to go in themselves and attempt a rescue. Inevitably, they also collapse. Only through being repeatedly confronted with that situation in active drills and exercises will the 'first instinct' be to raise the alarm and call for an emergency team with breathing apparatus and the rest of the correct rescue equipment. The response then becomes much more than an academic answer to a theoretical possibility.
Such drills and exercises should not be restricted to members of the emergency team. The possibility of anyone on board being confronted with such a situation should be recognised. By careful planning it should be possible to include all members of the ship's complement in the exercises and drills.
Another important function of drills is to provide a good opportunity to consider whether and how personnel could be rescued from different enclosed spaces. Clearly steps may need to be taken following such drills to learn from problems encountered.
These drills and exercises, as well as the plans for emergency preparedness, should all be subjected to verification, review and evaluation as anticipated by section 12 of the ISM Code.
On-board security
Though it is important to have good procedures and plans in place on-board by a well-trained and disciplined crew, it must be recognised that there may be many bona fide visitors to the ship who may have reason to enter an enclosed space on board.
It is therefore very important that the plans for shipboard operations as anticipated in section 7 of the ISM Code includes procedures to control how visitors on board can gain access to enclosed spaces. These procedures are likely to be much more strict than those that apply to the ship's crew since prior training cannot be assumed. Such procedures should not only apply to obvious enclosed spaces, such as a repair gang wishing to enter a double-bottom bunker tank, but also less obvious situations, such as stevedores entering cargo holds. Lack of control and complacency can and will kill.
Conclusion
The ISM Code, of itself, will not prevent people entering enclosed spaces without having taken precautions and consequently killing themselves.
The only way in which the ISM Code will work is if relevant people actually implement the procedures of the safety management system. Without that implementation the SMS is nothing more than a lot of words in a set of manuals.
Properly implemented, within the context of a safety culture, the ISM Code will provide a safety management system in which fatalities from entering enclosed spaces should be eradicated completely.