Maritime safety and security: enclosed spaces
On 14 February 2022, new regulations on enclosed spaces were made. These was came into force in May 2022 for vessels falling under the Safety of Life at Sea Convention (SOLAS), and in May 2023 for other vessels.
According to the new regulations, the operator of any vessel over 500t that has a confined space onboard will need to provide breathing apparatus, portable gas testing and enclosed space training for key personnel on each vessel.
Enclosed spaces are dangerous. If you see someone in an enclosed space requires for assistance: do not attempt to enter. Sound the general alarm, and take action to prepare for an organized entry.
Lets consider guidelines for defining confined spaces, dangers of trespassing, and how to reduce the risk for life.
What is an enclosed space?
Enclosed spaces are not always obvious but can be deadly. An enclosed space is a space which is not designed for continuous worker occupancy and has either or both of the following characteristics:
- limited openings for entry and exit
- inadequate ventilation
Here few examples of enclosed spaces:
- cargo holds;
- pipe tunnels;
- ballast tanks;
- pump rooms;
- peak tanks;
- void spaces;
- bunker tanks;
- cofferdams;
- fresh water tanks;
- chain lockers;
- battery lockers;
- bottom tanks;
- paint / chemical lockers;
- boiler furnaces;
- engine crankcases.
Some spaces such as paint and chemical lockers, CO2 rooms, and battery lockers can be entered through sealed or shipboard doors – but these spaces should still be considered dangerous.
Spaces connected to an enclosed space should also be treated with caution, even when there is a closed door in-between. The connected space should be tested separately, as sometimes it can be dangerous even after the first space is emptied.
Even if a space appears to be safe, toxic gases or poorly oxygenated atmosphere can be trapped in pockets, even if the space has been ventilated and tested. Gas and liquid migration can occur through small gaps and cracks from connected unsafe spaces.
Enclosed spaces can be deadly.
Special attention is needed when dealing with cargo, as some cargo can create hazardous vapors. Even small quantities of harmful gases can kill. An enclosed space may not contain enough oxygen to breathe properly or there could be a build-up of dangerous gases which can cause asphyxiation. This could result in serious injury, brain damage and death.
Oxygen deficiency can be caused by:
- corrosion (rusting)
- organic matter
- paint drying
Hazardous gases can come from many sources, such as leaks and hazardous cargo.
How to reduce risk:
Identify your enclosed spaces:
- identify the hazard of any contents of the space;
- ensure the spaces have hazardous warning signage and permit only access;
- all enclosed space access doors, hatches or manholes should be secured;
- avoid entering closed spaces if possible.
Carry out risk assessments and familiarize yourself with guidance
Familiarize yourself with the advice provided in the Code of Safe Working Practices for Merchant Seafarers (COSWP).
This is the simplest way to establish company procedure for entry into enclosed spaces.
In addition, you must carry out a risk assessment and issue a permit to work.
No enclosed space should be entered without proper precautions.
Before entering:
- a competent person should undertake a risk assessment and identify any potential hazards;
- prepare the space;
- secure the space for entry;
- ensure persons undertaking the work are trained and have participated in appropriate drills;
- test the atmosphere of the space;
- complete a permit to work (PTW);
- make a contingency plan in case things go wrong;
- review risk assessment.
On entry:
- ensure you have a person assigned on standby for each entry;
- the standby person should be equipped with rescue equipment including self-contained breathing apparatus and radio;
- wear protective clothing and boots;
- the standby person should ensure they maintain radio contact with the bridge or engine control room, or in port with someone who can help in case of emergency;
- ensure the space is well ventilated - ventilation should continue during the period that the space is occupied and during temporary breaks.
If something going wrong:
- if you see someone lying motionless do not rush to carry out a rescue by yourself - an unplanned rescue is likely to end in tragedy as personnel rush into lethal atmospheres under the misconception that they will be able to save colleagues;
- stop, think – why are they unconscious, could this be an enclosed space?;
- should an emergency occur, the general (or crew) alarm should be sounded so that back-up is immediately available to the rescue team;
- never enter the space before help has arrived and a plan for rescue confirmed.
Rescue:
- do not enter the space without the authorization of the master or a nominated responsible person;
- do not enter the space without testing the atmosphere;
- rescue equipment including breathing apparatus should be immediately available;
- if the atmosphere is unsafe, do not enter unless it is an emergency - if it is an emergency, you must wear breathing apparatus;
- emergency escape breathing devices (EEBDs) are NOT safe don't use in enclosed space entries including for rescue;
- self-contained breathing apparatus should be used for rescue;
- rescue procedures should be established before entry - the rescue procedure should be specific for each type of enclosed space;
- drills on enclosed space entry must include rescue procedures - they should be practiced frequently enough to provide a level of proficiency that eliminates life-threatening rescue attempts and ensures an efficient and calm response to any emergency.
Safety of enclosed spaces on sea-going vessels is a critical concern. Proper ventilation, access points, and safety procedures are necessary to prevent accidents. Regular inspections and safety protocols are essential to ensure the well-being of crew and the overall safe operation of the vessel.
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