Enclosed spaces — the lurking danger: How do we deal with one of the industry’s perennial problems?

21 Июл

Статья посвящена вопросам, связанным с рисками входа человека в закрытые помещения на судне. Исследование, проделанное автором, чрезвычайно интересно своей широтой и актуальностью. В частности и особенности, рассматривается процедура входа в закрытое помещение, а также правила пребывания там членов экипажа вплоть до окончательного выхода. Например: помещение, где производилась фумигация зерна, перевозимого навалом. К настоящему аналитическому материалу прилагается обзор документов Международной морской организации, содержащих правила относительно входа в закрытое помещение на судне, рекомендации и императивные нормы, призванные обеспечить обнаружение, оценку, исключение или минимизацию рисков, надлежащую подготовку и обучение членов судовых экипажей, в том числе, обращению с оборудованием, которые должны обеспечить повышение уровня безопасности жизни моряков на судне.

In the maritime industry, we take something of an ostrich-eye view of enclosed space operations. In spite of coherent, routinely documented guidelines and mandatory regulations adopted and implemented by the industry worldwide, there is still a serious problem — and we still continue to ignore it.

This is something of a back-handed compliment to the prevailing regulations and mandated training. They have managed to substantially lower the rate of human fatalities, but we still see high rates of injuries and loss of life from incidents that seem cast from the same mould.

Where are we going wrong in our approach? Every year we have to try to find a reason to explain why we are still falling short of our ‘zero fatality’ goal. As a seafarer, and now a surveyor and risk assessor, I have worked my fingers to the bone trying to get hold of the missing link.

Hazards and issues

Over years interacting with seafarers, carrying out risk assessment and surveys, I have been disappointed but not surprised to make the following observations about enclosed space entry procedures:

  • On many occasions, the SMS directives and procedures are too generic in nature, and are not commensurate with trade-specific identified hazards. The SMS should include a detailed trade- and ship-specific hazard identification/mitigation section for easy reference and understanding. Consider including an enclosed space checklist specific to the ship type and trade in the SMS, for crew familiarisation, briefing and training. This would ensure that all the possible hazards are discussed.
  • The correct usage and procedures for ship-specific gas measuring equipment are not included in the SMS, and only generic instructions are provided. Until IMO Resolution MSC.380 (94) is well implemented and assimilated across the board, it would be good practice to provide simple explanatory’ diagrams/pictures of the ship- specific gas measuring instruments, along with their limitations and hazards of incorrect use.
  • The risk assessment template or matrix is sometimes too complicated to understand. At this point, it does not mitigate the risk — it becomes merely a textbook and record keeping exercise.
  • The toxicity or the hazards of the present or the previous contents carried in the space are not diligently considered when planning the enclosed space entry.
  • Scheduled enclosed space entry drills are not conducted as per SOLAS Chapter III/Reg. 19/3.6.2. Drills would mean the crew could witness the actual procedures and precautions to be taken, and the correct usage of gas measuring and other safety equipment.
  • Ventilation and atmosphere changes in the enclosed space are not done properly, resulting in isolated ‘gas pockets’ which are not measured diligently by the crew using the gas measuring equipment at various levels and from different locations.
  • Crew measure gas in the enclosed space compartment with the ventilation running.
  • Incorrect use of the toxic chemical gas analyser by not accounting for ‘n=number of pump strokes’ as marked on the chemical gas measuring tube. The correct length of the gas measuring hose not used to draw a sample of the gas from the enclosed compartment. Using expired toxic gas measuring tubes.
  • The gas sample extraction hose used with the multi gas analyser docs not reach the tank bottom, due to design limitations — like ballast tanks — or insufficient length.
  • The enclosed space compartment is checked for gases by lowering a personal gas monitor attached to a heaving line.
  • Crew enter space without personal portable gas measuring equipment.
  • Attendants supervising the enclosed space operation do not carry out continuous/regular monitoring and logging of enclosed space atmosphere.
  • On fumigated bulk carriers carrying grain, hatch covers are opened and toxic gases are measured from the top of the hatch.
  • The enclosed space compartment is not effectively isolated from other compartments by isolating the tank valves, lines or by displaying the appropriate notices in the cargo control console.
  • Crew members enter the enclosed space compartment without Emergency Escape Breathing Devices (EEBD) and without safety harnesses for emergency evacuation.
  • The enclosed space checklist is not filled properly, not signed, or filled in only after completing entry operations.
  • Unqualified personnel — maybe cadets or trainees — coordinate the enclosed space operations or making entry into enclosed spaces.
  • Crew members are not aware of the gas analyser’s alarm set points and the Threshold Limit Value (TLV) of various detectible gases which would activate the gas alarm.

The maritime and commercial industry has successfully implemented many training guidelines and recommendations that should remove all these issues — and the instructions are quite clear.

So where have we failed to assimilate the instructions and where do we need to improve upon them?

Implementing the guidelines

A two-stage process is a must for ensuring successful implementation of the Enclosed Space Entry guidelines and onboard compliance.

Stage 1 is ensuring the onboard SMS is up to the job. The SMS is the key to identifying potentially hazardous areas of operations, and the training needs associated with them, carrying out constant monitoring of the risks, and assessing the procedures for dealing with them.

Detailed SMS modules for enclosed space procedure directives can be structured around Quality Management Systems (QMS) — ISO 9001 standards.«The success of any QMS is associated with ‘Process Approach’ and ‘Risk Based Thinking’.

Process Approach incorporates the Plan-Do-Check-Act (PDCA) cycle, enabling an organisation to ensure that its processes are adequately resourced, managed and that opportunities for improvement are determined and acted on.

  • Plan: This enumerates the objectives and process required, resources required, organisation’s policies, identify and address risks;
  • Do: Implement as planned;
  • Check: Monitor, measure process and activities, and report the result;
  • Act: Take actions to improve as necessary.

Risk Based Thinking is a preventive tool which can be developed and implemented using any established techniques in order to achieve the objectives. This would require the SMS processes to be ship-type and task oriented, identifying all the additional resources and training needs.

Stage 2 is ensuring the crew arc risk aware and properly trained. This is the most vital link when it comes to ensuring correct procedures, assessment and personal safety. Every crewmember onboard is suitably, qualified and holds the competency to serve in their assigned rank — and they should undertake risk assessment as a matter of course.

The concept of risk assessment is nothing new. It is something we have evolved using our basic human ability to identify hazards and then take suitable actions to mitigate them. Take a toddler trying to walk. Once the mother has let go of the toddler’s hand, it is careful, judging each step. After walking a few’ successful steps, on the verge of losing its balance, it will leap for the mother’s hand and take a firm grip to save itself from a fall. This is risk assessment in action. It is not something which is documented for a toddler’s daily activities — but the toddler unknowingly applies it to every daily activity. Risk assessment should be as automatic for the crew onboard as it is for that toddler learning to walk.

Or look at it another way. Most humans are endowed with five primary receptors — sight, smell, touch, taste and hearing. When engaged in a routine activity, we constantly and invariably use these five receptors to analyse the developing hazardous situation around us and take actions to mitigate it. So why do we still fail to do it onboard?

Risk Assessment for an Enclosed Space Operation:

  1. Hazard/Threat Identification: For any enclosed space entry’, the crew must meticulously identify the existing and additional hazards/threats (over and above the well documented SMS procedures), which can cause harm.
  2. Identify who might be harmed and how: At every stage of the process, from the first entry to an enclosed space to the final exit, identify what might go wrong to cause harm.
  3. Evaluate the risk and mitigate it: Use the available risk matrix for Frequency and Consequences to quantify the severity of risk. Every SMS manual will provide a template to assess it.
  4. Record the findings: All the findings of the risk assessment for the particular enclosed space entry operation should be recorded for future reference.
  5. Review and continually improve: At the completion of the Enclosed Space Entry task, take feedback from all members involved and use the feedback to continually improve the risk assessment process.                                              Overall responsibility for personal safety and safe operations is always entrusted to the personnel on board. We need to make a conscious and dedicated effort to remain proactive and not to circumvent safety requirements. This has always taken its toll. Experienced and senior personnel must ensure human safety is seen as everyone’s primary responsibility, above all other factors.


The regulatory position

The IMO adopted Resolution A. 1050 (27) — Revised Recommendations for Entering Enclosed Space Aboard Ships in November 2011. This directs ship operators and ISM implementers to incorporate in the SMS the correct procedures for planning entry into any oxygen deficient or oxygen enriched atmosphere, and/or an atmosphere which contains flammable and/or toxic gases or vapours:

  • Identify the enclosed space and responsibilities of various personnel onboard carrying out the operation.
  • Implement the detailed guidelines and procedures in the SMS under the ISM Code with need of training, familiarisation, record keeping and routine audit.
  • SMS to include risk assessment of all the potential enclosed spaces onboard, with continuous revisions and assessment of available threat.
  • Approved permit system with authorisation of entry to be documented.
  • Guidelines on securing the enclosed space prior to entry, identification of risk, ventilation, measurement, communication, illumination, proper rescue and PPE to be considered.
  • Initial and continuous monitoring of the enclosed spaces, using calibrated gas measuring or other applicable equipment, by suitably trained and qualified personnel.
  • Identify the cargo-specific risk associated with enclosed space entries on various types of vessel.

Training and drills

IMO has amended SOLAS Chapter III requirements for emergency training and drills to read:

3.3 Crew members with enclosed space entry or rescue responsibilities shall participate in an enclosed space entry and rescue drill to be held on board the ship at least once every two months.

3.6 Enclosed space entry and rescue drills

  • Enclosed space entry and rescue drills should be planned and conducted in a safe manner, taking into account, as appropriate, the guidance provided in the recommendations developed by the Organization. (IMO Resolution A.1050 (27))
  • Each enclosed space entry and rescue drill shall include:

. 1 checking and use of personal protective equipment required for entry;

.2 checking and use of communication equipment and procedures; .3 checking and use of instruments for measuring the atmosphere in enclosed spaces;

.4 checking and use of rescue equipment and procedures; and

.5 instructions in first aid and resuscitation techniques.

4.2.5 Risks associated with enclosed spaces and onboard procedures for safe entry into such spaces, which should take into account, as appropriate, the guidance provided in recommendations developed by the Organization.

(IMO Resolution A.1050 (27))

Testing equipment

To connect all the loose ends, IMO adopted Resolution MSC.380 (94) on 21 November 2014, requiring ships to carry ‘an appropriate portable atmosphere testing instrument or instruments. As a minimum, these shall be capable of measuring concentrations of oxygen, flammable gases or vapours, hydrogen sulphide and carbon monoxide prior to entry into enclosed spaces.’

Автор: Capt. Sanjeev Kumar Gupta, AFNI

Источник: Seaways. — 2016. — June. — P. 10 — 11.