The cargo hold was not considered as a dangerous space. An enclosed space is defined in the International Maritime Organization (IMO) ‘Resolution A.1050(27) Revised Recommendations for Entering Enclosed Spaces Aboard Ships’ as follows:
Enclosed space means a space which has any of the following characteristics:
- Limited openings for entry and exit; - Inadequate ventilation; and - Is not designed for continuous worker occupancy, and includes, but is not limited to, 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, and adjacent connected spaces. This list is not exhaustive, and a ship-specific list should be produced to identify enclosed spaces.
Unauthorised entry into cargo hold
The cargo hold had been shut for six days, and the oxygen in the hold had been depleted by the corn cargo. Therefore, the cargo hold should have been considered an enclosed space. The involved parties did not recognise the danger of the cargo hold, loaded with grain and closed for a long time, so they did not consider it an enclosed space. Entry into an enclosed space should only occur after the ship’s master authorises it and completes the entry permit system. Although the booby hatch for accessing the hold could be locked to prevent unauthorised entry, it was not locked, possibly because the final loading was incomplete, and they did not anticipate oxygen depletion or unauthorised entry. Since 21 fumigation contractors boarded the ship, the crew could not monitor every action of the contractors.
Impulsive rescue
Enclosed space incidents regularly involve a person entering or re-entering a dangerous space to rescue a fallen colleague and then subsequently becoming unwell and also requiring rescue. Worker A’s attempt to help his colleague cost him his life. The chief officer’s action to rescue contractors was brave, and he managed to save the life of one worker, but he jeopardised his own safety. As per paragraph 8.5 of Resolution A.1050(27), ‘only properly trained and equipped personnel should perform rescue operations in enclosed spaces.’ The chief officer was not properly equipped to enter the space for rescue as the EEBD worn by him supplies only 10-15 minutes of air and is designed to be used for escape from a compartment with a hazardous atmosphere. It should not be used for fighting fires, entering oxygen-deficient voids or tanks, or worn by firefighters. Instead, a self-contained breathing apparatus (SCBA) should be used.
Equipment and training for fumigation contractors The fumigator’s unauthorised entry into the cargo hold suggests they were not trained on the hazards of cargo holds and general conduct on board. Due to the nature of their work, fumigators should have been trained on the dangers of oxygen deficiency and the presence of other toxic gases that can be present in cargo holds. External visitors should not have entered any cargo space or other space on board without authorisation from the ship’s crew. They should ensure that the atmosphere is tested, safe to enter, and that all necessary precautions are in place. The contractors were carrying a phosphine detector and a gas mask, anticipating hazards relating to phosphine; however, all contractors tasked with entering the cargo hold to set up fumigation arrangements should have been provided with a personal multi-gas detector. This would have enabled them to swiftly identify the lack of oxygen in the hold and exit quickly.
Enclosed space training and drill The circumstances that led to this incident and the shortcomings in the rescue operation highlight the need for continuous and ongoing training on enclosed space entry, emphasising the points from IMO ‘Resolution A.1050(27).’ SOLAS Ch III regulation 19 states, ‘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.’ Regular enclosed space rescue drills should be conducted in a safe and realistic manner. The master should conduct drills in all enclosed spaces on the ship to practice and address the specific procedures and equipment needed for each space.
Conclusion
Enclosed space-related accidents on board ships are mostly caused by insufficient knowledge or disregard for necessary precautions, rather than a lack of guidance. Shortcomings in the attempt to rescue and the use of improper equipment highlight the need for more awareness, training, and drills. When a large number of shore workers board, it is difficult for the ship’s crew to monitor all their actions. However, this should be discussed with the person in charge of the shore workers, and a system should be agreed upon for control of work. Access control to all dangerous spaces on board is paramount. In an emergency rescue, the atmosphere of an enclosed space should be considered unsafe unless confirmed otherwise, and proper procedures should be followed. Rescue operations should only be conducted by properly trained and equipped personnel.
Our thanks to Britannia P&I Club for sharing this incident case study. The case study is available to download in PDF format at
https://bit.ly/3Z2S9ag.
THE REPORT | DEC 2024 | ISSUE 110 | 77
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