09 Mar 12 - 15:38
Revised recommendations update and expand previous guidance
The West of England P&I Club issues Revised Recommendations for Entering
Enclosed Spaces aboard Ships as follows:
On 30 November 2011 the International Maritime Organisation (IMO) adopted
Resolution A.1050(27) "Revised Recommendations for Entering Enclosed Spaces
Aboard Ships". The revised recommendations replace Resolution A.864(20)
published in 1997.
Changes in the Revised Recommendations for Entering Enclosed Spaces aboard Ships
The revised recommendations update and expand the previous guidance and include
a number of changes as follows:
Section 2 - Definitions
Two new definitions have been included in the guidelines for an "adjacent
connected space" and an "Attendant". An "adjacent connected space" is defined
as "a normally unventilated space which is not used for cargo but which may
share the same atmospheric characteristics with the enclosed space such as, but
not limited to, a cargo space accessway". An "Attendant" is defined as "a
person who is suitably trained within the safety management system, maintains a
watch over those entering the enclosed space, maintains communications with
those inside the space and initiates the emergency procedures in the event of
an incident occurring".
Section 3 - Safety Management for Entry into Enclosed Spaces
This section is new and reads as follows:
"The safety strategy to be adopted in order to prevent accidents on entry to
enclosed spaces should be approached in a comprehensive manner by the company.
The company should ensure that the procedures for entering enclosed spaces are
included among the key shipboard operations concerning the safety of the
personnel and the ship, in accordance with paragraph 7 of the International
Safety Management (ISM) Code.
The company should elaborate a procedural implementation scheme which provides
for training in the use of atmospheric testing equipment in such spaces and a
schedule of regular onboard drills for crews.
Competent and responsible persons should be trained in enclosed space hazard
recognition, evaluation, measurement control and elimination, using standards
acceptable to the Administration.
Crew members should be trained, as appropriate, on enclosed space safety,
including familiarisation with onboard procedures for recognizing, evaluating,
and controlling hazards associated with entry into enclosed spaces.
Internal audits by the company and external audits by the Administration of the
ship's safety management system should verify that the established procedures
are complied with in practice and are consistent with the safety strategy
referred to in paragraph 3.1" (point 1 above.)
Section 4 - Assessment of Risk
This section states that the company should carry out a risk assessment to
identify all enclosed spaces on board the ship. This risk assessment should be
repeated periodically to ensure it remains valid. The competent person is also
reminded that the ventilation procedures for an adjacent connected space may be
different from those of the enclosed space itself.
Section 6 - General Precautions
Under "General Precautions" two new points have been added to the previous
guidance. The first states that entrances to enclosed spaces should be secured
at all times when entry is not required. The second point is intended to
minimise the risk of someone mistakenly thinking that a hatch or door that has
been opened in order to ventilate an enclosed space means that the atmosphere
inside is safe. An attendant should therefore be posted at the entrance, or a
suitable mechanical barrier should be placed across the opening together with a
warning sign to prevent accidental entry.
The original recommendations advised that "Ships' crew should be drilled
periodically in rescue and first aid". This sentence has been replaced with
"Ships' crews with rescue and first aid duties should be drilled periodically
in rescue and first aid procedures. Training should include as a minimum:
Identification of the hazards likely to be faced during entry into enclosed
spaces;
Recognition of the signs of adverse health effects caused by exposure to
hazards during entry; and
Knowledge of personal protective equipment required for entry."
Section 7 - Testing the Atmosphere
Additional guidance in this section states that: "In some cases it may be
difficult to test the atmosphere throughout the enclosed space without entering
the space (e.g., the bottom landing of a stairway) and this should be taken
into account when assessing the risk to personnel entering the space. The use
of flexible hoses or fixed sampling lines which reach remote areas within the
enclosed space, may allow for safe testing without having to enter the space".
Although the previous recommendations contained advice on safe limits for
oxygen and flammable and toxic gases, the revised text notes that "National
requirements may determine the safe atmosphere range" with regard to oxygen
content. A further point has been added advising that steady readings of "not
more than 50% of the Occupational Exposure Limit (OEL) of any toxic vapours and
gases" should be obtained prior to entry along with a remark that "It should be
noted that the term Occupation Exposure Limit (OEL) includes the Permissible
Exposure Limit (PEL). Maximum Admissible Concentration (MAC) and Threshold
Limit Value (TLV) or any other internationally recognised terms."
Whereas the earlier version advised that "It should be emphasized that pockets
of gas or oxygen-deficient areas can exist, and should always be suspected,
even when an enclosed space has been satisfactorily tested as being suitable
for entry", the revised text states that "It should be emphasized that the
internal structure of the space, cargo, cargo residues and tank coatings may
also present situations where oxygen-deficient areas may exist, and should
always be suspected, even when an enclosed space has been satisfactorily tested
as being suitable for entry, this is particularly the case for spaces where the
path of the supply and outlet ventilation is obstructed by structural members
or cargo."
Section 8 - Precautions During Entry
The information in this section has been broadened with the addition of the
following;
"Particular care should be exhibited when working on pipelines and valves
within the space. If conditions change during the work, increased frequency of
testing of the atmosphere should be performed. Changing conditions that may
occur include increasing ambient temperatures, the use of oxygen-fuel torches,
mobile plant, work activities in the enclosed space that could evolve vapours,
work breaks, or if the ship is ballasted or trimmed during the work", and that
"In the event of an emergency, under no circumstances should the attending crew
member enter the space before help has arrived and the situation has been
evaluated to ensure the safety of those entering the space to undertake rescue
operations. Only properly trained and equipped personnel should perform rescue
operations in enclosed spaces."
Section 9 - Additional Precautions for Entry into a Space Where the Atmosphere
is Known or Suspected to be Unsafe
Two new sentences have been included in this section advising that "Spaces that
have not been tested should be considered unsafe for persons to enter", and
that "Persons entering enclosed spaces should be provided with calibrated and
tested multi-gas detectors that monitor the levels of oxygen, carbon monoxide
and other gases as appropriate".
Section 10 - Hazards Related to Specific Types of Ships or Cargo
This section now contains a sub-section on the "Use of Nitrogen as an inert
gas" which states that "Nitrogen is a colourless and odourless gas that, when
used as an inert gas, causes oxygen deficiency in enclosed spaces and at
exhaust openings on deck during purging of tanks and void spaces and use in
cargo holds. It should be noted that one deep breath of 100% nitrogen gas will
be fatal." Additional information can be found in MSC.1/Circ.1401 "Guidelines
on Tank Entry for Tankers using Nitrogen as an Inerting Medium". Any vessel
using nitrogen including gas tankers and bulk carriers should also heed this
advice.
The sub-section on "Oxygen-depleting cargoes and materials" has been amended
slightly to emphasise that the list of products referred to is not exhaustive.
Appendix - Example of an Enclosed Space Entry Permit
The example of an enclosed space entry permit in the Appendix has undergone a
number of minor changes:
The question: "Has the space been thoroughly ventilated?" has been expanded
with the addition of the words "by mechanical means?"
The requirement for an oxygen content of at least 21% by volume is now
accompanied by a note stating that "National requirements may determine the
safe atmosphere range."
The "Pre-Entry Checks" in Section 2 were previously required to be carried out
either by the person entering the space or by the authorised team leader. This
requirement has been modified and the items listed are "to be checked by each
person entering the space".
Sections 1, 2 and 3 of the permit were previously signed by the "Responsible
person supervising entry". These sections are now to be signed by the
"Attendant", along with the Master or nominated person.
Members are advised to take account of IMO's revised guidelines and ensure, so
far as is practicable, that their Safety Management System (SMS) procedures and
checklists for entering enclosed spaces are amended to reflect the new
recommendations. Members should also consider the following advice when
carrying out such a review:
Additional Enclosed Space Guidance
Often a question on board will be what constitutes an enclosed space? IMO
defines an enclosed space as being one which has any of the following
characteristics:
Limited openings for entry and exit;
Inadequate ventilation; and
Is not designed for continuous worker occupancy
The definition includes, but is not limited to, the following compartments:
Cargo spaces
Double bottoms
Fuel tanks
Ballast tanks
Cargo pump-rooms
Cargo compressor rooms
Cofferdams
Chain lockers
Void spaces
Duct keels
Inter-barrier spaces
Boilers
Engine crankcases
Engine scavenge air receivers
Sewage tanks
If it is unclear whether or not a particular compartment is an enclosed space,
a risk assessment should be carried out in accordance with IMO recommendations
to overcome any doubts. The process of carrying out a risk assessment to
identify enclosed spaces should be repeated at regular intervals as
circumstances may change.
IMO's recommendations now make reference to adjacent connected spaces. For
example, a forecastle store or deck house fitted with a booby hatch leading to
a cargo space may be considered to be such a space. An adjacent connected space
may be deficient in oxygen, or flammable or toxic gas may be present,
particularly if the seal on the booby hatch or access door to the cargo space
is not gas tight. It should also be borne in mind that less obvious areas of a
vessel may also exhibit the characteristics of an enclosed space. For example,
a recent MAIB Safety Flyer describes a situation where heavy framing on the
weather deck surrounding the entrance to a cargo tank impeded the dissipation
of cargo vapours.
Another MAIB Safety Flyer draws attention to the fitness of shore contractors
engaged to work inside an enclosed space. If concerns arise, they should be
refused entry.
Additional permits, as detailed in the vessel's SMS, may also be required when
working in enclosed spaces, such as for hot work or working from a height. The
need for other permits such as these should always be considered before work
inside an enclosed space is undertaken.
Potential hazards such as unguarded openings, wet or muddy surfaces and
lightening holes in intermediate decks within ballast tanks should not be
overlooked, nor the need for personnel to be properly equipped to minimise the
risk of slips and falls. An MAIB Investigation Report highlights an accident
of this type which took place during a routine inspection of a ballast tank.
Particular care must be taken by personnel in such circumstances, and
sufficient lighting should be provided to enable safe movement through the
space.
Personnel should never enter an enclosed space unless an enclosed space entry
permit has been issued beforehand in accordance with the procedures set out in
the SMS. During the pre-entry checks it should always be assumed that the space
is not safe for entry until proved otherwise. Anyone who remains uneasy about
whether or not an enclosed space is safe to enter after the necessary
precautions have been taken should be encouraged to voice their concerns in
case further action is warranted.
The IMO recommendation that "In the event of an emergency, under no
circumstances should the attending crew member enter the space before help has
arrived and the situation has been evaluated to ensure the safety of those
entering the space to undertake rescue operations. Only properly trained and
equipped personnel should perform rescue operations in enclosed spaces" is of
particular importance. It is a natural human reaction to help others in
difficulty, but the urge to do so must be resisted. Instances of someone losing
their life after rushing to help a colleague in trouble inside an enclosed
space where neither of them followed the correct entry procedures are all too
common.
Enclosed Space Entry and Rescue Drills
Enclosed space entry and rescue drills are, at present, not required by many
flag states. However, IMO is in the process of drafting amendments to SOLAS
that will make enclosed space entry and rescue drills mandatory. It is
anticipated that vessels will need to carry out such drills at least once every
two months to ensure that crewmembers are familiar with the actions to be taken
if it becomes necessary to rescue someone from inside an enclosed space. In the
meantime such drills may be incorporated into the SMS and conducted regularly
as a prudent precaution
Source: The West of England P&I Club
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