1. The Republic of the Marshall Island (RMI) has published Marine Safety Advisory No. 23-20 warning that shipboard incidents relating to improper entry of and rescue from enclosed spaces continue to occur. According to the flag State’s records, six seafarers died in four enclosed space entry incidents onboard RMI-flagged vessels during 2018-2019. Both tankers and bulk carriers have experienced such incidents and although the details of each incident differ, the RMI has noted that there are some similarities, including.
a. crewmembers lacking awareness of the potential hazards posed by the improper entry into enclosed spaces.
b. senior crewmembers failing to ensure that the ship management’s enclosed space entry procedures are followed prior to directing junior crewmembers to enter an enclosed space.
c. masters not being notified that an enclosed space was going to be entered.
i. At the discretion of Master, Tug assistance is to be provided, while entering & leaving port and while navigating in confined waters, etc.
ii. Whilst at anchor, Main Engine / propulsion should be available in stand-by mode at any time (In ready mode depending on weather / navigational conditions).
d. Upon the request of the shipowners, based on the national law and international Convention, MTA will issue an Exemption letter.
2. As highlighted by the RMI, these incidents serve as a stark reminder that failure to observe and understand simple enclosed space entry procedures can result in seafarers being killed or seriously injured. They are also reminders that a well-intentioned seafarer who enters an enclosed space to assist a fellow crewmember is likely to become a victim requiring assistance, as well as delay a proper rescue operation and increase the potential for additional deaths.
3. In view of above, the Administration has recommended following to ensure the safety of crewmembers:
i. Recommendation No.1: Review existing procedures:
A. The RMI recommends that ship managers review their enclosed space entry procedures and, if necessary, revise them to ensure they comply with the applicable requirements.
a. The IMO’s recommendations for entering enclosed spaces aboard ships are outlined in Resolution A.1050 (27) and its guidelines for selecting portable atmosphere testing instruments can be found in MSC.1/Circ.1477.
b. For RMI-flagged ships, the requirements and safety standards that must be followed by personnel entering enclosed spaces are outlined in RMI Marine Notice 7-041-1.
c. Other flag states will have similar requirements and one such example is the UK “Code of Safe Working Practices for Merchant Seamen” (COSWP) and its Chapter 15 deal with the entering of dangerous enclosed spaces.
d. Section 10 of the ILO’s “Code of practice for accident prevention on board ship at sea and in port” provides similar practical recommendations and guidance.
B. Ship managers to ensure that a risk assessment is conducted to identify all enclosed spaces on board the ship and periodically revisit the assessment to ensure its continued validity.
C. In this regard, GARD P&I Club also recommends that an inventory of all enclosed spaces on board be established where seafarers may enter and where there is any likelihood that they might become dangerous. The inventory should record the particular characteristics of the space, the likely hazard involved, and the measures taken to prevent entry unless safety procedures are followed. Any difficulties inherent in a rescue from the space should also be considered, and solutions identified, so that in the event of an emergency, the crew is in the best position to respond quickly.
ii. Recommendation No.2: Ensure that procedures are fully understood and followed:
The RMI recommends that ship managers send a letter or bulletin to all ships in their managed fleet addressing:
a. the dangers of improperly entering an enclosed space;
b. how to recognize an enclosed space and examples of the different types of enclosed spaces a seafarer might encounter while performing their day-to-day shipboard tasks;
c. that all seafarers, regardless of seniority, must not enter an enclosed space without permission and then only in accordance with the ship management’s established procedure;
d. who on-board is authorized to permit entry into an enclosed space;
e. that the best way for a seafarer to assist a fellow seafarer inside an enclosed space is to immediately raise the alarm so that an organized rescue can be conducted in accordance with ship management’s established procedure.
iii. Recommendation No.3: Provide proper onboard training:
It is important that seafarers are given proper onboard training to help them recognize, evaluate and control hazards associated with entry into enclosed spaces. In addition to conducting mandatory enclosed space entry and rescue drills every two months, the RMI recommends that masters hold a special safety meeting with particular emphasis on enforcing the responsibility that all seafarers have to prevent enclosed space entry related incidents and the need for crew members to resist their natural urge to immediately enter an enclosed space in order to assist a fellow crewmember.
4. A poster intended to provide a visual reminder to seafarers that they should not enter an enclosed space without proper authorization can be downloaded from the Marine Accident Investigators’ International Forum (MAIIF) website in PDF format for printing and distribution, and in JPG format for computer desktop use. Ship managers are encouraged to use the poster and/or computer desktop image as part of their efforts to reduce the potential for future confined space incidents.
5. GARD has launched a safety awareness campaign website which contains video, a case study and additional loss prevention material addressing entry into enclosed spaces which can be accessed through following link: http://www.gard.no/web/content/enclosed-space-entry-training
6. Ship owners, managers and masters are advised to be guided by above
This Technical Circular and the material contained in it is provided only for the purpose of supplying current information to the reader and not as an advice to be relied upon by any person. While we have taken utmost care to be as factual as possible, readers/ users are advised to verify the exact text and content of the Regulation from the original source/ issuing Authority.