An

IIMS Self Help Guide

What A Marine Surveyor Needs To Know About

Working in Enclosed Spaces

by Adam Allan and

Capt Michael Lloyd


1st Edition


Published by the International Institute of Marine Surveying

First published September 2015 by the

INTERNATIONAL INSTITUTE OF MARINE SURVEYING
Murrills House, 48 East Street, Portchester, Hampshire, PO16 9XS, UK

www.iims.org.uk

Copyright 2015 International Institute of Marine Surveying


ISBN 978-1-911058-00-7


IIMS PUBLICATION
Item number: IIMS-00-7


All rights reserved. No part of this publication may be reproduced, stored in
a retrieval system or transmitted in any form or by any means electronic,
mechanical, photographic, recorded or otherwise, without the prior written
permission of the publisher, International Institute of Marine Surveying.

Although the author(s) and publisher have made every effort to ensure that
the information in this book was correct at the time of going to press, the
author and the publisher do not assume and hereby disclaim any liability to
any party for any loss, damage, or disruption caused by errors or omissions,
whether such errors, or omissions result from negligence, accident, or any
other cause. The authors views are not necessarily those of the publisher.


Front cover photo provided by Mines Rescue Marine

ABOUT IIMS

The International Institute of Marine Surveying (IIMS) is an independent, non-political
organisation promoting the professionalism, recognition and training of marine
surveyors worldwide.

The IIMS defines marine surveying as: The service provided to maritime and transport
organisations in general and the production of guidance reports for all other bodies
connected with maritime operations or maritime trade.

The IIMS is the professional body for marine surveyors and has a worldwide
membership of around 1,000 individuals in over 90 countries. It is the largest
organisation of its kind and seeks to represent its industry to government and non
governmental organisations such as the International Marine Organisation (IMO),
Coastguards, insurance companies and ship owners.

The IIMS provides a range of services to its members, allied organisations and to the
wider shipping and boating world, including:


Maintaining a comprehensive database of qualified marine surveyors
Professional training courses for marine surveyors
A distance learning education programme in marine surveying
The Report, a quarterly publication highlighting key marine surveying
topics and news
Conferences and meetings internationally providing a place for the marine
surveying industry to meet
Acting as an MCA approved vessel coding authority duly authorised by the
Maritime & Coastguard Agency

www.iims.org.uk

CONTENTS

FOREWORDS
PREFACE
Chapter 1. MARINE ENCLOSED SPACES
1.1 Cataloguing and Categorising Enclosed Spaces
1.2 Actions Prior to an Enclosed Space Entry
1.3 Entry Guardian
1.4 Actions During Enclosed Space Entry
1.5 Actions following Enclosed Space Entry
1.6 Action in the Event of an Emergency
1.7 Enclosed Space Box
Chapter 2. ENCLOSED SPACE CULTURE
2.1 The Meaning of A Safety Culture within the Shipping Industry
2.2 Changing Cultural Attitudes and Practices
2.3 Reporting and Recording
Chapter 3. DESIGN FEATURES ASSOCIATED WITH ENCLOSED
SPACES
Case Study 1
Case Study 2
Case Study 3
3.1 Design Factors
3.1.1 Adequacy and Quality of Respirable Air
3.1.2 Suitable and Sufficient Lighting
3.1.3 Ease of Access
3.1.4 Ease of Movement Within the Space
3.1.5 The Ability to Undertake Rescue Operations

Chapter 4. ENCLOSED SPACE EQUIPMENT

4.1 Personal Protective Equipment (PPE)
4.2 Enclosed Space Entry Equipment
4.3 Enclosed Space Rescue Equipment
Chapter 5. ENCLOSED SPACE TRAINING
5.1 Training Courses
5.2 The Marine Surveyors Course
Chapter 6. RESPONSIBILITIES
6.1 The HSE and MCA Memorandum of Understanding
6.2 Legal Case Studies
6.3 Defining Responsibilities
Chapter 7. OXYGEN AND DANGEROUS GASES
7.1 Effects of Oxygen Depletion (examples)
7.2 Safety Alarms
7.3 Effects of Other Gases
7.4 Ballast Water Treatments
7.5 Gas Bubble Morphology in Mud and Sediments
Chapter 8. THE ENCLOSED SPACE MANAGEMENT SYSTEM
8.1 Methodology
CONCLUSION: Keep The Surveyor Safe
ABOUT THE AUTHORS

FOREWORDS


This book has been produced by Mines Rescue Marine (MRM) at the request of the
International Institute of Marine Surveying. It serves as a technical reference for
Surveyor personnel involved in entering enclosed spaces on ships for inspection
purposes. I am confident that it will provide invaluable help for them to fully
appreciate the potential hazards that an enclosed space may contain, or that might be
generated by an inadequate entry procedure.

The apparently simple operation, to enter, inspect and /or undertake work in an enclosed
space, requires consideration of all available information relating to the space. This
might be physical parameters, or procedural in the form of ships rules, company
guidance and details of a readily available emergency response. The professional
manner in which this information is assimilated and assessed by the Surveyor prior to
him attempting entry will reduce considerably the risk of the unexpected and avoid
catastrophe!

The advice and guidance contained here is based upon the considerable experience of
MRM personnel operating and training others to work in such spaces in various
industries. Equipment and techniques outlined here have been well tried and tested in
real applications. Fatal accidents arising from work in enclosed spaces on ships
continue to occur all too frequently. Do not let this happen to yourself. If in any doubt,
there are others available who can provide advice to ensure your safety.


Dr Barrie Jones CBE FIMMM CEng
Chief Operating Officer/Director
Mines Rescue Service Ltd


In dedication to Nicholas J. Wesn

My name is Martine L. Wesn. I am 47 and widowed. I know from personal experience

that working in confined and enclosed spaces can kill. On 22 January 2014, my husband
Nicholas lost his life to mechanical positional asphyxiation in such a space. He was
descaling a small void of rust on board our yacht, together with a colleague, when he
became mechanically fastened within the void. It was a slow drawn out death described
in graphic and confronting detail in a 17 page autopsy report from the coroner.

Nicholas was educated as a Chief Engineer, Controller at a Power Station, Independent
Marine Surveyor, Class Surveyor and lastly a Government Surveyor. Through his
training in working in confined and enclosed spaces he was considered proficient in
understanding the dangers involved with these works.

I cannot describe my disbelief and subsequent grief when he was pronounced dead by
the attending ambulance officer as I held his lifeless body in my arms to say a last
goodbye. I know I am not alone in losing a loved one through these tragic preventable
circumstances.

My training in working in enclosed and confined spaces is similar to that of Nicholas.
For the past five years, as a Marine Survey Administrator, I have been in charge of all
confined and enclosed space works for a fleet of twenty eight vessels including,
dredges, barges, tugs, construction vessels and small work boats.

I now believe that training on what constitutes a confined or enclosed space, and the
hazards and precautions necessary when working in theses spaces, is in need of review.
Current definitions are clearly not enough.

The content of this book, I hope, will save the life of other potential victims and prevent
their loved ones from enduring the pain of losing the one they love.


Martine L. Wesn

PREFACE


Many years ago, fire was the biggest cause of death and injury at sea. Eventually,
through legislation, compulsory training & equipment, and improvements to ship
design, casualty numbers were drastically reduced.

Fire is, of course, a potentially serious on-going problem and it is essential that such
safeguards are in place, but you can see it, you can feel it, and to a certain extent
dependant on the fire, there is an element of time to deal with it, especially with the
compulsory training and modern equipment, both automated and manual, available to
the ships.

But what about enclosed spaces?

While many accidents in enclosed spaces are caused by a variety of reasons, the biggest
killer, by far, is the lack of breathable air. This cant be seen, rarely detected by smell,
and never felt until it is too late. If the lack is severe, one second you are alive, the next
unconscious and dead. Always be aware that an Oxygen deficient atmosphere is deadly
and can exist in any space, even in those that are supposed to be safe.

It is now a matter of record that enclosed spaces cause more incidents, accidents and
fatalities than any other single issue associated with the marine sector. These accidents
and subsequent fatalities are predominantly the result of people entering, working in or
ironically attempting rescue from those spaces. This unacceptable situation is no longer
tolerable and concerted efforts to address the safety aspects of entry and rescue from
these spaces are currently under way. The first step toward this change process began
with the identification and acceptance that a problem exists. Many reputable
organisations have written about the situation and suggested potential solutions but until
legislation is enacted governing purposeful training and dedicated equipment, the
problems and accidents will continue, with most of them fatal. If anything, the numbers
of fatalities attributed to enclosed spaces are increasing not just to those who work on
the ship, but also those who board in the various ports such as stevedores, repair or
maintenance contractors and surveyors.

Of all those who board a ship for work in enclosed spaces it is the surveyor who is

most at risk. Under the present prevailing systems on almost all ships, they are totally
reliant on the ships staff having correctly prepared the space, carried out all relevant
gas and oxygen tests, completed the risk assessment and work permit procedure (which
includes a safe system of work) and provide a well-trained rescue team with the correct
enclosed space equipment in case an emergency situation develops.

Very few ships or companies, regardless of their names or claims, have all these.

There is as yet, no requirement for specific enclosed space rescue training and no
requirement for enclosed space rescue equipment. Instead, all too often the surveyor
boards ships with little knowledge of the space to be entered, inadequate PPE and total
reliance on the ships entry and rescue procedures being effectively implemented. Such a
situation as this demands that, as a minimum, all surveyors should be able to recognise
the potential dangers facing them and make their own dynamic risk assessment of the
space prior to entry.

This book is intended to assist a surveyor in making such an assessment and provide a
guide to the various situations that may be faced with when entering an enclosed space
on a ship or marine platform.

Chapter 1.
MARINE ENCLOSED SPACES
For clarity: The shore uses the term confined space while the sea uses the term
enclosed space, for the purposes of this book, whilst there is a semantic difference, all
references made will be to an enclosed space.

It is generally accepted that the definition of an enclosed space is a space which has
limited openings for entry and exit and is not intended for continuous worker
occupancy.

This inevitably leads to:

Inadequate ventilation
Poor lighting
Hazardous obstacles preventing ease of movement
Limited access for entry and rescue

1.1 Cataloguing and Categorising Enclosed Spaces

One of the main problems encountered with enclosed spaces is that, until very recently,
there was no requirement to audit and identify all of these spaces. Even if this was done,
which is still very rare, they were not individually identified and risk assessed bearing
in mind that the risks associated with a space may change because of gases or materials
migrating into and through that space thereby changing its risk classification from being
safe one day to unsafe the next. (See Chapter 8, Enclosed Space Management System.)



Examples of this being:

1. In bad weather, vents on the forecastle and sometimes the main deck will be
covered in order to prevent water ingress. In this way spaces that are normally

safe and entered without a second thought now become hazardous, and more so
depending on what is stored there and how that will affect the oxygen levels in the
compartment.
2. Most substances give off gases of some kind or other, even the bulkheads of an
empty space can do through rust (oxygen deficiency) and paint (toxic or
flammable fumes), so any space that has been closed for some time without any
ventilation must be considered dangerous.

It therefore follows that there are a wide range of enclosed spaces on board a ship
examples of which (identified above) may be termed as dangerous spaces because of
their ability to change from safe to unsafe at any given time. Therefore, the principle we
must follow is that all spaces which have been closed for any period of time, especially
those with seals such as tanks and stores with weather or storm doors, are potentially
dangerous.

1.2 Actions Prior to an Enclosed Space Entry

Before entering any space, the surveyor should ensure that all standard precautions have
been taken. The tank having been ventilated for at least 24 hours and all relevant checks
made with the oxygen / multi-gas meter. The surveyor should also ensure that all
relevant procedures are complete and in place and should familiarise themselves with
the risk assessment, any permits to work raised, the adopted action plan (safe system of
work) and emergency procedures.

Prior to the work beginning, they should participate in a tool box talk where all aspects
of the work are discussed (action plan) and issues resolved before proceeding. All
equipment which has been identified as PPE and for safe entry should be checked and
verified fit for purpose.

Lone working should be frowned upon and the space not entered by the surveyor unless
accompanied and they have assured themselves that an entry guardian is present
throughout with rescue equipment (and personnel?) positioned at the entrance point.

1.3 Entry Guardian

The entry guardian is probably the most important link in the enclosed space entry
chain. It is their responsibility to prevent unauthorised entry, control and log all entrants
into and out of the space, establish and maintain communications with both the entrants
and bridge or OOW, record information, in particular gas readings, where appropriate
cause the emergency procedures to be initiated and should not at any time enter the
space but control all actions at and around the space entry point. The entry guardian is
your protector whilst you are in the space and, therefore, must always be regarded as an
important person undertaking a critical role.

1.4 Actions During Enclosed Space Entry

The surveyor should at all times be in communication with the entry guardian and
follow the pre-determined action plan. At no time should that plan be deviated from. If
anything untoward happens or is observed whilst inside the enclosed space, the entrants
should report the anomaly and where necessary remove themselves from the space to a
place of safety. Throughout the entry, regular gas samples should be taken to verify the
breathable condition of the air, these readings should be communicated to the entry
guardian who will record them on the entry log. At no time should the surveyor enter a
compartment, tank or space where an alarm has activated on their gas detector. In the
event of this happening whilst inside the enclosed space, they should don their EEBD
immediately and make their way out of the enclosed space.

1.5 Actions following Enclosed Space Entry

On completion of the task(s) agreed on the action plan, the entrants should remove
themselves from the enclosed space and report to the entry guardian where they will be
recorded as being out of the space. They should then account for all PPE and equipment
taken into the space thus ensuring that nothing is left. The entry guardian having logged
their movements, reports to the bridge/OOW that the space has now been vacated and
awaits instruction. In the meantime, the entry point should be covered in order to
prevent inadvertent entry. A full and accurate de-briefing should then take place
whereby accurate and timely information may be documented in the form of a report.

1.6 Action in the Event of an Emergency

In the event of an emergency situation being declared in contaminated air, the

surveyor should:

1. Immediately don their EEBD and make their way to the entry point by the
quickest travelling route.
2. When possible and without prejudicing your own safety, inform the entry
guardian.
3. The entry guardian should:
1. Cause the emergency procedure to be implemented by contacting the
bridge/OOW
2. Control the situation at the entry point, preventing further entry with the
exception of the ERT / rescue team
3. Log all persons out of the enclosed space
4. Under NO CIRCUMSTANCES enter the space to render assistance
5. Maintain communications and update the bridge/OOW frequently

In the event of an emergency situation developing in fresh air, the surveyor should:

4. Immediately contact the entry guardian, explain the situation and instruct them to
cause the emergency procedure to be implemented.
5. If trained to do so administer emergency first aid measures.
6. Where possible, assist the ERT/Rescue team to and at site.
7. Vacate the enclosed space at the earliest opportunity if not required.

In both cases, the entrants should be available to undergo a full de-briefing following
the incident thus ensuring that a full and accurate report is compiled for the relevant
company management and local authorities.

1.7 Enclosed Space Box

You have all heard of the fire triangle. Here is the enclosed space box. Think about this.


Referring to the model above, design of an enclosed space can affect the training
required and that training must reflect the equipment needed for any entry and rescue.
All, like the web of a spider, are interlinked and one cannot function without the other.

All sides of the box contribute equally to the problem of enclosed spaces and while
design is a major cause of the problem, it is the training, equipment and the culture on
board the ship which will get you in safely and more importantly, get you safely out.

To go into an enclosed space, it is essential that you are:

Aware of potential dangers.
Adequately trained.
Have the correct equipment PPE and entry equipment.
Aware of the emergency procedures.

If any one of these points are not in place, then you should not enter.

Chapter 2.
ENCLOSED SPACE CULTURE
Referring to the Enclosed Space Box model discussed earlier, Chapter 2 deals with
enclosed space culture whilst later sections of this publication will focus on how the
design of an enclosed space will determine training requirements and how that
training must reflect the equipment needed for that entry and rescue. All, like the web
of a spider, are inextricably linked and each is interdependent on the other. This is a
complex situation of interdependency which merits a high degree of consideration
when making decisions on what and how the correct equipment and training should
be given relating to the particular design features of the space. Bearing in mind that
these decisions will have a direct influence on any safety procedures formulated for
inclusion into the companys safety management system for enclosed space entry,
they are at least tangible and can, therefore, be dealt with. Whereas the fourth element
culture, is totally different. It is a mindset, a mental attitude if you like, normally
having an accepted and adopted methodology already in place. How many times have
you heard this being said? Its how we do things on this ship or Its always been
done like that. Classic statements, same old same old, nothing new here, however,
the real question should be - are we doing things the right way?

2.1 The Meaning of A Safety Culture within the Shipping Industry

At sea as well as ashore, culture is formed by individuals. The way we do things
becomes implanted as custom and practice and, therefore, very difficult to change.
However, change we must as we cannot continue to go on as we are, too many people
are still dying in enclosed spaces on board ships.


It is therefore essential, that all surveyors recognise the safety culture situation which
exists on many ships and at their operating offices as this may explain the lack of
training, equipment and poor design features which they encounter, compounding the
degree of danger that ships may place upon them.

There is a tendency in shipping towards a macho attitude when it comes to safety.
Those of a certain age or seniority often reflect on when they were younger and went
into such spaces without any protection and see no reason for the care being required

today. What they do forget is just how many people died in these spaces, often
unreported and unrecorded and that it could be that they are lucky to have come
through unscathed.

Also ships have changed. Vast cargoes are carried in bulk giving off more gases.
More chemicals are carried both for use on board or as cargoes. Containers are
carried often with little knowledge of their contents. Ships are larger with more
spaces while crews are smaller with less personnel available for standing by at
enclosed space entry points. Consider the depth of a 250,000 ton bulk carrier hold or
the length and breadth of an amidships DB compared to the bulk carrier of thirty
years ago. Often it is an expedition just to get into such spaces.

Many accidents occur not because of the safety culture of others, but because of the
safety culture of the individual who is undertaking a task. So much now depends on
your own personal safety culture. Age and experience is no defence against accidents.
The fact that you have been going into spaces for years without a problem does not
mean that the next space might be the one that kills. Too often the pressures of time
are used as excuses for taking short cuts. The manning situation on board is
sometimes used as a reason not to provide the correct rescue or standby personnel.
None of this should be your concern, which must be above all else for your safety.
The need to sail the ship is no excuse for not ensuring that all the previously stated
requirements have been adhered to. You will not be the first surveyor to refuse to
enter a space until all the safety requirements have been carried out or because correct
safety equipment is not available.

2.2 Changing Cultural Attitudes and Practices

As always, to begin changing embedded culture the focus should be on the individual.
It is true to say that changes are normally driven from the top, but, if those who are
doing the job can be used to embrace that change then it makes the change process
easier to accomplish. Effecting change by winning the hearts and minds of people is
probably the most effective method as it employs the use of emotional or indeed
intellectual sway, dependent upon what position the person holds within the
organisation.

Emotional sway, for example, can best be employed on far eastern personnel who
would take on board more readily information relevant to enclosed spaces, knowing
that if they perished there would be no more money sent home to support their family,

effectively leaving them destitute. Something which would be difficult for them to
come to terms with given their close family philosophy.

Whereas intellectual sway may be applied toward officers and senior personnel by
essentially highlighting the potential consequences which could be faced by the
company or indeed themselves in the courts. Corporate manslaughter and masters
responsibilities are two phrases which are now beginning to be read in the same
sentence, a sobering thought and one which always should be borne in mind.

In order to change attitudes, we need to break that CYCLE OF EVENTS and
introduce alternative practices which may best be achieved by education and training,
then tested by carrying out enclosed space drills to check whether or not these newly
acquired skills are being implemented. As two monthly enclosed space drills are now
a mandatory requirement of the IMO, verification of the correct enclosed space
rescue procedures should be easier to validate.

2.3 Reporting and Recording

Finally, reporting your own experiences and any observations of poor safety standards
on ships will assist others in their culture of safety. Other surveyors will be following
you and if a ship or even a space on a particular ship is badly prepared, or the attitude
towards safety is poor, then those facts should be recorded in order that other surveyors
can be informed. In this way, a data base can be established of rogue ships and
enclosed spaces for the benefit of those surveyors coming after you, with a secondary
benefit of acting as a warning to those operators of any such recognised ships.

Chapter 3.
DESIGN FEATURES ASSOCIATED
WITH ENCLOSED SPACES
As we have said, it is design that gives us most of our problems with shipboard
enclosed spaces. It is regrettable that in any review of enclosed space incidents, the
impact and effect that enclosed space design has on entry, work and rescue had not been
considered. Our many years of experience operating in and rescuing from enclosed
spaces, enables us to realise the importance of design safety and to suggest solutions to
the marine industry where potential problems are identified.

In industry ashore, entry, work and rescue are major considerations in the design of any
structures which contain enclosed spaces. It may come as a surprise to some that the
only regulation on tank design for ships is that regarding the manhole size on bulk
carriers and tankers, which requires sizes of 800mm x 800mm for vertical and 800mm x
600mm for horizontal entries and these dimensions are specified with the sole intention
of allowing a person wearing a BA set to enter them. It is strange that only these ships
are singled out for even this very basic requirement as accidents and fatalities are shown
to occur on all types of ship.

Case Study 1

We are all familiar with the case of the Viking Islay and the tragic death of three crew
members, but what was missed by the investigators in their conclusions was that of the
contributory factor of tank design, especially the entry point.

The following is an extract of the report:

During the consequent rescue efforts, the first rescuer found he was unable to enter
the chain locker wearing a BA, and therefore donned an EEBD. He subsequently
entered the space, but at some point the hood of the EEBD was removed, (or became
dislodged) and this rating also collapsed

Of course the rescuer should not have entered the tank with an EEBD, but it was the
inability to get in with a BA set that caused him to wear it. If he had been able to enter
the chain locker wearing a BA then it could well be that he would be alive today and
possibly able to rescue at least one of the casualties.

Case Study 2

Extract of the investigation into the fatality on board the M.V Saga Rose which
occurred in Southampton in September 2008.

The rescue team entered the cofferdam wearing SCBA at 15.25hrs and assessed the
second Bosun to be deceased shortly before 16.00hrs. The limited room available,
the possibility of contaminated air and low oxygen levels, and the high temperatures
experienced, all hampered the removal of the second Bosun from the tank which was
not completed until 19.10hrs

This prolonged and unacceptable rescue time was not suggested as the responsibility of
the ship as the report goes on to say that;

the ships internal procedures worked very efficiently. The response team assembled in
the purifier room within about 3 minutes, and the safety officer, staff & chief engineer
were quick to enter the space with ample breathing apparatus.

Apart from accidents due to lack of oxygen or the presence of dangerous gases, there
are numerous accidents in enclosed spaces due to falls.

The MAIBs accident database records numerous instances of falls from relatively low
heights which have resulted in minor injuries. Since 2005 there have been 16 serious
injuries occurring on board UK registered ships of 500 gross tonnage and over as a
result of falls from fixed ladders, including those fitted in tanks, when the casualty was
not wearing a safety harness or fall arrestor. It must be remembered that these accidents
are only those investigated on UK registered ships. It can only be surmised that the total
worldwide must be many times higher.

Case Study 3


On 28 January 2009 the chief officer of the UK registered Ville de Mars entered a water
ballast tank for inspection purposes. During his inspection he fell.

Extract taken from the report:

Without an eye witness, it is not known exactly how or why the chief officer fell. Given
the oxygen levels measured during his entry, and that none of the crew who rescued him
from the tank wore BA, it is extremely unlikely that he lost consciousness through
asphyxiation. It is also extremely unlikely that he fell through the access hole in the first
stringer; otherwise he would have landed on the middle stringer where the ladder
terminated. Also, had the chief officer fallen backwards from the ladder, he would
probably have landed near the centreline, not on the port side of the tank. Therefore, as
the chief officer stepped onto the stringer moments before he fell, it is almost certain
that he fell off its un-guarded edge, possibly as a result of slipping on its sludgy coating
while holding his torch in one hand and the gas analyser in the other.

On this occasion, the absence of lighting was significant. The chief officer was totally
reliant on his torch, which was probably of limited use as he descended the ladder.

The stringer from which the chief officer fell was wide enough to stand on comfortably
but, unlike the stringer below which was a permanent means of access between the two
vertical ladders, it was not required to have guardrails fitted. The requirements of MSC
133(76) apply only to structures in the tanks of oil tankers and bulk carriers which are
also designated as permanent means of access for the purpose of inspection.

There are many more such cases each different in their own way, but all of them
involving some aspect of failure of human design in these spaces. Essentially, we need
to recognise that, when designing any enclosed space on board a ship, consideration
should always be given to the fact that people may require to enter these spaces and, in
some instances, be rescued from them.

3.1 Design Factors

Human activity within the space should always be the prime consideration and it must
be seen as the starting point in the design cycle. Safety procedures, training and

specialist equipment can be put in place when the ship is completed but the design of
the spaces will determine the effectiveness of those measures.

All surveyors should be aware of the factors which may affect human survivability and
hence their personal safety whilst on board. Amongst these are:

1. Adequacy and quality of respirable air
2. Suitable and sufficient lighting (illumination)
3. Ease of access into and out of the space
4. Ease of movement within the space
5. The ability to undertake rescue operations

An example of a difficult access

As can be seen (from the example above), it is not possible to wear any type of BA set
to enter this compartment. Therefore, if, at the earliest stages of ship design, these

factors could be considered and, where possible, the space designed to an established
standard, then undoubtedly there are many improvements which can be made to present
layouts.

3.1.1 Adequacy and Quality of Respirable Air

The first and foremost requirement for any person entering an enclosed space is to be
able to breathe freely and without hindrance. It therefore follows that the adequacy and
quality of respirable air within the space is of utmost importance.

Prior to opening up a possible hazardous space, consideration should be given to the
previous contents which may have produced substances or gases which are or may be
injurious to health. An obvious benefit would be to check the air quality prior to
opening the space thus lessening the risk by minimising exposure. This may be achieved
by allowing samples of air to be drawn off through sampling pipes which are fixed in
place through bulkheads and employing an external valve arrangement, thereby
allowing the air quality to be determined. Internally, the open end of the sample pipe
can be positioned where required to give the most effective representation of the air
inside the space. This would be particularly advantageous in horizontally accessed
spaces.

If this could become a shipbuilding standard, it would ensure that all spaces classified
as permanent risk spaces could be continually monitored by those on the ship in safety
and, in particular, prior to entry.

Regardless of this function being present, when opening up an enclosed space,
sufficient time should be given to enable a ventilation system to be established thus
ensuring that air containing a sufficiency of oxygen is introduced into the space in order
to sustain life.
Air may be introduced into the space in one of two ways:



Natural Ventilation
Where a compartment has two or more access points, these need to be opened
simultaneously, preferably one at either end of the compartment, in order to create a
natural flow through of air. If the presence of contaminants is suspected and the

direction of flow has not been established, care should be taken. Where the direction of
the natural flow is known, the outflow air from the space should be ducted to an
external point thus preventing potential contamination of the area surrounding the
space. Unfortunately, in too many spaces, natural air ventilation seems to be depended
on whereas mechanical ventilation should be the preferred option.

Mechanical Ventilation
Includes mechanical apparatus (such as fans or air movers), to either force air into or
exhaust air out of a space. Whatever the system, entrances are opened simultaneously
and the mechanical system introduced to the space. Again, care should be taken to duct
away outflow air from the space if the presence of contaminants is suspected. Portable
ventilation systems are available but it is our observation that many more spaces would
benefit from fixed forced ventilating systems.

3.1.2 Suitable and Sufficient Lighting

The vast number of spaces entered will not have a natural light source therefore some
means of artificial lighting is required. On the majority of ships, crew members carry an
artificial light source into the space in order to see where they are going and to
illuminate the immediate work space. Often such lighting encumbers the users, or is not
adequate to light up dangers within the space. Whilst accepting that there are certain
spaces in a ship, where for safety reasons, fixed lighting cannot be fitted, there are many
spaces where fixed lighting could be installed. This would considerably improve the
safety standards of those entering and working in the enclosed space. There are two
main systems of internal lighting, namely:

Fixed Internal Lighting
Obviously, fixed permanent lighting is the best and most suitable option, utilising
fittings which are robust, waterproof and where required intrinsically safe. This system
is hard wired inside the space with the supply cabling coming outside the space to an
isolation breaker. Switching arrangements can be either inside or outside the space.
Although the most expensive option of the two, it meets all the requirements of the
entrant in relation to luminosity.

Temporary Internal Lighting
A second and more commonly used method of fixed lighting is string lights,
frequently used when in port or dry dock, these low voltage light units may be
installed throughout the space on a temporary basis and removed on completion of the
work. This option gives high levels of luminosity but cabling can get tangled and

there is, of course, the opportunity for damage to occur to cables, junctions and
fittings if they are not properly supported.

3.1.3 Ease of Access

Access into and egress out of an enclosed space are a particular concern, in the majority
of cases, they are not designed with safety and rescue as the prime consideration.

The following are points to consider:

Manholes

Due to the design of certain openings, it can be a time consuming and labour intensive
task to remove the nuts (or bolts) and open up the space.


Covers, normally being of heavy plate construction, have a notable lack of bespoke
lifting handles, giving rise to the opportunity of nipped or fractured fingers or toes.
During a temporary stoppage of work the covers are rarely replaced due to time
constraints. At best they are placed across the manhole leaving gaps at each end and in
heavy weather, they are prone to slip away if not secured. This problem could be easily
addressed by employing quick release mechanisms and built in lifting points, thereby
saving time and increasing safety effectiveness.

Of paramount importance is the physical size of the opening. It is essential that anyone
going into an enclosed space must be capable of being rescued from that space. It
therefore follows that the openings must be of a sufficient size to allow rescuers to enter
these spaces wearing a BA set and also allow a stretcher to be taken in and hoisted out.
(see 3.1.5 Rescue)

Restrictive Openings
Raised hatches on deck are undoubtedly designed to prevent the possibility of water
entering the space but they can be a hazard to those entering, especially if there is no
thought given to the placement of hand holds and hand rails to assist those entering.
These should always be present at the point of entry and immediately inside the space in
order to provide the entrant additional support and confidence. All platforms inside a
space should have guard rails.

Ladders and Foot Holds
Most vertical access points into tanks or compartments have permanently fixed ladders
or foot holds to enable safe and easy entry. Positioning of the ladders need to be
immediately below or inset from the openings thereby not restricting the person when
entering. On many ships these are bent, broken or corroded. As with all ladder systems
they should be continually maintained to ensure that they remain in good order. It is
extremely difficult for the ship to maintain these vertical ladders whilst they remain
fixed in position. If they are not maintained regularly at each docking, the best way to
maintain these ladders is to enable them to be disconnected and taken out of the space.

If the ladders could be designed in short removable sections, the necessary maintenance
could be carried out on board the ship.

Anchorage Points
Permanent anchorage points are essential and should be fitted above each vertical entry

point where a temporary tripod or quad pod lifting system cannot be deployed. They
should be checked and load certified at the required intervals in conjunction with the
winch system.

Limited Height and Width
Ideally, these issues should have been picked up at the design stage and the problem
engineered out. Unfortunately that is not always the case.

3.1.4 Ease of Movement Within the Space

Entering an enclosed space on board ship may be for one of many reasons, not least of
which for the purpose of:

Inspection
Repair
Maintenance

Once inside, the entrant can find it difficult to traverse due to the physical constraints of
the space, awkward bulkheads, strengthening girders, pipes and lightening holes.

Consideration should also be given to the numbers of persons having to enter the space,
their physical and mental state and any additional equipment or tools which may be
required to be taken in to do the work.

It is recognised that many of the physical attributes of the space cannot be changed,
however, travel routes within the space can be made easier by tackling the most obvious
obstacles; those of manhole entrances and lightening hole dimensions.


Access within a tank restricting movement

By increasing the size and shape of the opening, it will allow for easier movement and
lessen the stress on the entrant by physical exertion. There may be structural reasons
why these lightening holes are of the size they are, however, by increasing their
dimensions or altering their shape where possible, it will considerably benefit the safety
of persons operating in these spaces and assist in their rescue if required.

Other internal design factors to consider would be to install hand holds, safety rails and
internal walking or working platforms to prevent people having to negotiate beams and
girders. This would inevitably help to make the space safer for the entrant and reduce
the possibility of accidents from slips, trips and falls.

3.1.5 The Ability to Undertake Rescue Operations

The problem of rescuing someone from an enclosed space is a most difficult operation
and requires specialist equipment and trained personnel. At some time or another most

seafarers have had reason to enter a difficult enclosed space. It is therefore essential that
any surveyor entering a space has confidence in the knowledge that they can be rescued,
and that those in charge of the operation have confidence that they can perform such a
rescue. In all enclosed space design, it must be anticipated that for the purpose of rescue
a BA set will be worn by the rescuers. It therefore follows that all access and entry
points and indeed the areas within the space need to be able to accommodate the
additional width of a person and breathing apparatus.

It is just as important that the area in front of and adjacent to the entry point is kept as
clear as possible to enable an effective rescue to be carried out.

Note: The access point is adequate but regrettably, the builders have put cable run
across the front of the entrance.

Existing legislation regarding minimum manhole sizes, only apply to tankers and bulk
carriers, which in modern day shipping is totally inadequate and raises many safety
concerns. Even in the absence of legislation it is difficult to understand how those
involved with ship design have not concerned themselves previously with the problem

of rescue.

Removing casualties from enclosed spaces if they are incapacitated is of primary
importance. In the case of a vertical entry, a hoist arrangement fitted above the entrance
is an essential element of the rescue. In many cases, this can be achieved by the use of a
tripod which can hold the winching system, but if the area above the entry is too
restricted for a tripod, some other anchorage point should be positioned to facilitate a
strop or shackle which can accommodate the hoisting system.

One of the most important issues, certainly from our perspective, is that of rescuing
someone should that be required. The current arrangements make it difficult to enter
many spaces wearing BA sets, surely, a fundamental issue which requires immediate
attention.

If the entrance is too small to get in wearing a BA set, then we must

question why personnel are required to enter these spaces.

Chapter 4.
ENCLOSED SPACE EQUIPMENT
Over the last several years, we have been evaluating enclosed space equipment
specifically for the marine industry. Any such study is not helped by the fact that such
equipment, which is recognised and legislated for ashore, is not recognised by any
marine legislation.

To begin the study, Mines Rescue Marine (MRM) met with a number of manufacturers
and tested various types of equipment in marine exercises. This resulted in MRM being
able to define equipment which they regard as suitable and also suggest design changes
to ensure that equipment was fit for purpose.

It was interesting to note that, in the majority of cases, enclosed space protection and
rescue was wholly reliant upon equipment used for fire control. Case studies have
shown that the use of such equipment, which is not designed for enclosed space use, has
been instrumental in several deaths and accidents. For this reason this chapter is
intended to give the surveyor sufficient information in order to allow them to select the
correct equipment necessary for the safe entry into the enclosed space and, hopefully, to
throw light on a subject which, certainly in industry ashore, is recognised as an essential
part in the entry and rescue of persons from enclosed spaces. Enclosed space entries at
sea are an inevitable part of life. The topic has and is being debated continuously with
many wide and varying views on the subject. When looking at potential problems
involving enclosed spaces, we tend to look at the safety aspects which involve the
personnel entering the space. In the event of something not going to plan, consideration
should be given on how we would be able to get those entrants safely out of that space.
As an integral part of the ships management system, a major part of that documented
process is the selection and use of the correct equipment to assist those mariners doing
the job. In looking at the equipment available we are concerned with best practice and,
therefore, look for the best equipment available and that which is easy to use, robust in
construction and from reputable companies.


As far as the surveyor is concerned they should consider equipment for:

Personal protection (PPE)
Entry
Rescue

There are many manufacturers and suppliers of excellent equipment, designed to do
whatever the buyer requires of it. But when choosing equipment you should ask
yourself two questions: Is it the correct equipment for the job? and Is the selected
equipment fit for purpose?

4.1 Personal Protective Equipment (PPE)

Minimising the risk of accidents and protecting people must always be the primary
concern and personal protective equipment seen as the last line of defence. A review
of PPE equipment used for enclosed space entry should always be part of the surveyors

thinking when preparing to enter an enclosed space.

Individual PPE requirements will vary dependent upon the work in hand and any
specific hazards identified on the appropriate risk assessment prior to entry, therefore
this is an appropriate place to start.

Head Protection
The requirement for a good quality, well-fitting helmet which affords protection from side
impact as well as from falling objects is essential. Accidents from bruised and split scalps
are either minimised or eliminated entirely by ensuring that helmets are worn at all times
when operating in an enclosed space. Chin straps are essential, they prevent the helmet
falling off or indeed being blown away in heavy weather. Additional benefits are to be
gained where fitments are available to accommodate a head torch or light essential for
hands free operations. All helmets have a user life (see manufacturers recommendations)
and are normally date stamped inside the helmet giving an indication to those responsible
as to when helmets should be replaced.

Eye Protection
Various types of good quality eye protection are available on the market which meet
current impact standards. These are an essential component of PPE. They help to

prevent accidents due to impact injury or foreign bodies entering the eye. This type of
protection may come in the form of glasses, goggles or helmet mounted visors and may
be designed to meet your personal preference. A common problem with eye protection
is misting up, if the wearer is working in a hot environment and sweating a lot this tends
to happen. There are many proprietary anti-misting agents which if applied before use
help to prevent misting up of the lenses.

Ear Protection
As with eye protection, many forms of hearing protection are available for an
individual to use. In any enclosed space area where the entrant is required to work in
a noisy environment, ear protection is essential, indeed mandatory use may be
required in some areas.

This protection falls into two main categories:

Ear plugs which fit into the outer ear can afford a certain degree of protection,
they may be separated pairs, or paired up and attached to a cord. These can then
be shaped and fitted. In certain instances moulds of the persons ears may be
taken to ensure a comfortable fit.
Ear defenders are the second means of protection, they may have an integral
adjustable head band which make them independent of the user or have a
fitment which attaches to a helmet. In either case, they are colour coded
indicating the attenuation (loudness) levels for which they afford protection.

Full Body Protection
At sea, coveralls are widely used, they prevent contaminants coming into contact with
the body and exposed skin surfaces. In the main, poly/cotton coveralls are sufficient for
day to day use. However, there may be circumstances where additional protection may
be required, an example of this being where the person may come into contact with
absorptive or corrosive contaminants. In such cases, it may be more beneficial to wear
sacrificial paper over-suits, or indeed PVC or other non penetrative suits to give added
protection to the entrant when operating in the enclosed space. Heat retention and
preventing the body temperature to self regulate, should always be a consideration when
deciding to use non penetrative suits as a total barrier.

Hand Protection
It is always advisable when operating in an enclosed space to wear hand protection. It
helps to minimise injury such as minor cuts, abrasions and contamination. Light hand
protection is preferable to ensure dexterity is not impaired, whilst protection against

liquid contaminants may be achieved with barrier creams, inner gloves or gloves made
from liquid repellent materials.

Foot Protection
In most, if not all workplaces, foot protection is a mandatory requirement and may take
the form of shoes or boots. Numerous proprietary brands of foot protection are
available, however, our preference is to wear a leather lace up boot with internal steel
toe protection and composite sole. They are lightweight, flexible and with the additional
benefit of giving support to the ankle joint thereby helping to avoid sprains and strains.

4.2 Enclosed Space Entry Equipment

On shore, the Confined Space Regulations deal with specific equipment issues
ensuring the safety of entrants into an enclosed space, whereas at sea SOLAS make
recommendations for all on board equipment. At present, SOLAS does not take into
account the specific equipment requirements for the safe entry into and rescue from
enclosed spaces at sea. In an endeavour to address this issue some individual marine
companies prescribe their own equipment lists for safe entry and rescue. However, all
too often this equipment is supplied by third parties or ordered from catalogues with
those making the recommendations knowing little about the equipment or the
environment where it will be used.

In many cases, the type and design of a ship or platform will dictate the equipment
required, however, consideration should be given to the following before making that
decision.

Gas Detection Equipment


Adding to the many dilemmas faced by the purchaser, there are a plethora of
manufacturers who will supply and distribute gas detection equipment for use in
enclosed spaces. So how do you choose?

In the first instance, you should be guided by your risk assessment. This will highlight
the hazards and help in the selection of the correct type of monitor to use in relation to
the gases likely to be encountered.

As an enclosed space should always be checked prior to entry, it is preferable that the
equipment comes equipped with a means of remote sampling such as a length of tubing
and internal pump or aspirator in order to pull the air sample out of the space to a place
of fresh air. Only when a determination of safe breathable air is confirmed should an
entry into the enclosed space take place. Other beneficial considerations would be that it
is lightweight, portable, water resistant, monitors continuously, and the instrument is
intrinsically safe (carries ATEX approval). In addition to remote sampling and as an
added safety feature, personal gas detectors should always be carried into the space to
monitor the entry and work area continuously thereby helping to safeguard the entrant.

Lighting
Inevitably, most enclosed spaces encountered onboard a ship or installation are dark with

no means of natural or artificially installed lighting. In order to overcome the problem,

artificial light needs to be introduced into the space.

Portable lighting such as hand lanterns and torches are the most common form of
lighting taken into enclosed spaces. The benefits of this method being that they
illuminate the immediate travelling route and at the work place give a concentrated light
source for detailed examination of equipment or chambers.

The problem with lanterns or torches is that they normally have to be carried thereby
impairing movement when climbing ladders or moving through tight spaces. This can
be overcome by fitting the torch or light to the entrants helmet, thus making the
operation hands free, improving safety and has the added advantage of being able to
point a helmet mounted light beam in the direction of travel at all times without the
need to stop and re-adjust the light source.

Communications

Having an effective means of contacting the entry guardian in order to pass information or
raise the alarm in the case of an emergency is an essential requirement for any enclosed
space entry team. Communications come in many forms, from basic systems such as: tugs

on a rope, air horns or whistles which are dependent on pre-determined signals, to more
sophisticated methods employing radios or hard wire systems. The latter two being
preferable as the entrant has direct voice contact with the entry guardian and can have the
added advantage of being hands free.

Of the two main electronic methods (radios and hard wire), radios are lighter and more
portable than hard wire systems. However, the signal may be lost due to black spots in
the ship thereby reducing the effectiveness of the system, whereas hard wire systems,
although cumbersome to run out, ensures continuity of voice communication. An added
advantage is that the hard wire system doubles as a guide line and, in some instances,
may be illuminated giving an additional safety feature.

Escape Respiratory Protection
May be carried into the enclosed space by entrants as part of their personal safety
equipment should the risk assessment identify the need. Known as EEBDs (emergency
escape breathing devices) they provide the wearer with an independent breathable air
supply for a short duration, usually 10 to15 minutes, enabling the entrant to get back to
the entry point safely if the air quality deteriorates.

The most common EEBD used is the compressed air type but alternatives such as a
chemical type are available. Whatever the preferred option, it must be remembered that
EEBDs are designed for ESCAPE PURPOSES ONLY.

Compressed air EEBDs fall into two main types:

Constant Flow (or Hood type) - when activated, delivers a constant flow of air
from the cylinder to a hood which is pulled over the wearer,s head. This is the
easiest type to wear as it requires very little training or knowledge to use, simply
open the bag which automatically activates the cylinder valve, take out the hood
and pull it over your head. A constant flow of air is then delivered to the wearer.
The disadvantages of this type being that your vision is partially impaired because
of the hood, it is a bit noisy due to the air feed into the hood and some wearers may
get a feeling of claustrophobia.

Positive Pressure (or face mask type) - this type of EEBD uses a face mask in
place of the hood. When activated and the face mask donned, air is delivered to the
wearers face mask on demand. This type requires a little more technical ability
to use as the seal is made only when the face mask is in position and secured in
place by a head strap.


Both types are similar in size and weight and can be carried either by a loop strap or
worn as a jacket for added comfort and hands free operation.

Chemical EEBDs - have the advantage of being smaller and lighter than their
compressed air counterparts but require to be stored in sealed containers which when
opened and used must be returned to the manufacturer for re-servicing. They operate
on the principle of a chemical reaction i.e. the CO2 and moisture from your exhaled
breath activates the chemical (KO2) which in turn produces oxygen for the wearer to
breathe. Operational durations vary dependent on the model purchased and can range
from 30 to 90 minutes usage.

Harnesses
The wearing of a harness for entry into an enclosed space on a ship, whilst part of shore
legislation in many countries, is a relatively new concept for those at sea. The need of
such equipment is apparent when the rescue of a person is to be attempted. If a harness
is already worn by the casualty, essential minutes are saved by clipping the harness onto
the hoist and evacuating the person quickly.

Harnesses come in many designs and are normally worn to act as part of a fall restraint
system. The type of harness which should be worn are rescue harnesses. They are
specifically designed to ensure that during vertical extrication operations the person will
lean not more than 10 degrees from the vertical axis, ideal when winching through
restrictive openings such as those encountered on board a vessel. Although they may be
awkward to wear in an enclosed space, they have the added advantage of giving robust
lifting points for manhandling a person during horizontal extrication.

4.3 Enclosed Space Rescue Equipment

Although not required for use by the surveyor it is always prudent to understand that
rescue equipment should be available and strategically positioned for use when you
enter the enclosed space. The worst case scenario during any enclosed space entry is to
have to effect a rescue of casualties. To ensure this happens quickly and efficiently
dedicated rescue equipment is essential. In this section a selection of what is considered
best practice equipment is included for your information.

Winching Arrangements
Most cases of enclosed space entry on board a ship will involve ascending or
descending through restrictive entries into a tank or chamber. Where a vertical entry is
being made, extrication equipment should be set up prior to entry in order to enable an
effective rescue to be implemented immediately. Removing someone with a rope and
pulley is strenuous, time consuming and carries a serious risk of injury to the casualty.

Currently on many ships and installations, chain blocks, rope & pulley systems or
indeed man handling are accepted methods of rescue. These methods should be
replaced, where possible, by using mechanical man-riding winches. Dependent on the
manufacturer, these man-riding winches have varying design features such as those
which are dependent on a tripod / quad pod arrangement or others which can operate
independently.

Man access into a Barge Tank


Mechanical winches drastically reduce the need for manual handling and make casualty
extrication less onerous on the rescuers. Man-riding winches can effect casualty retrievals
from varying depths and are certified to lift up to 150kg on the man-riding mode. Winches
of whatever type depend on an effective anchorage point. These anchorage points may be
of the fixed type such as eye bolts, lifting beams and certified cross members or mobile
anchorage points such as davit arms, tripods, girder clamps or strops and shackles.
Whatever type of winching arrangement chosen, forethought should always be given to
the location and adequacy of anchorage points.

Fall Arrest Units
By definition, fall arrest units are safety devices which are attached to a suitable
anchorage point and harness in order to prevent serious injury due to a fall. In practice,

they limit the vertical distance dropped should that person slip whilst ascending or
descending a ladder thereby preventing serious injury. They come in various types, rope
lengths and designs. The most common type act on the inertia reel principle which is
similar to the operation of a car seat belt.

Many of the inertia reel type, also incorporate the use of a handle for retrieval
purposes. In other words, if the unit is activated, the handle will allow the person to be
wound to safety. They are not specifically designed for man-riding purposes.

Stretchers
Moving a person through and out of an enclosed space is always difficult. The most
common method is to man-handle the person using their clothing, a board or such other
device. Where space allows, it is always preferable to move a casualty on a stretcher for
two reasons. It is a stable structure which is more comfortable for the casualty and it
gives the rescuer a rigid lifting platform to work with. There are many types of
stretchers, each with their own advantages (and disadvantages). When choosing the type
for enclosed space rescue the following should be considered:

Can it get in and out of the space
Is it lightweight
Does it have the necessary rigidity required
Are there adequate lifting points
Can it perform both horizontal and vertical rescues
Is it compatible with a winch


Internal access between compartments


Entrance to a Coffer Dam


Respiratory Protection
SCBA - For rescue, a working BA differs significantly from that required by enclosed
space entrants insofar as they need an extended usage time and training in their use. A
normal working BA has a duration of around 20 to 40 minutes, dependent on the wearers
stature, temperament, nature of the space encountered and work activity. The nature of the
space will have a limiting effect on the ability of the wearer to operate effectively as the
physical size and weight of the BA will impair task achievement. Too often fire fighting
BA sets are used for enclosed spaces and case studies have shown that, due to their
physical size and weight, they have limited or indeed even prejudiced attempts at rescue.

It is essential that the BA sets chosen for enclosed space rescue meet the criteria for
enclosed space rescue, with attention paid not just to duration but also to its physical
size, weight and comfort when worn.


Compact Jacket Type BA in use

Matching these exacting requirements is difficult, but there are BA which employ slimline 4.7ltr lightweight cylinders, having 300 bar capacity for extended use and fit into a
jacket arrangement around the wearer for comfort. These BA are designed for use in
restricted spaces and have an added advantage of enabling an airline to be connected to
them to extend their working duration further.

Airline This type of respiratory equipment is used on many ships, essentially it
consists of a bank of cylinders (2 or 4) attached to a manifold and first stage regulator.
The air is transferred to the wearer through a fixed hose line which terminates at a face
mask with demand valve arrangement similar to the BA, discussed earlier. As an added
safety feature, the air hoses are normally attached to a waist belt thereby helping to
prevent the face mask being dislodged by movement.

The main advantages of this system are extended usage due to the bank of cylinders
arrangement extending the wearing time and it allows entry into spaces where a BA set
may restrict the wearer.


The main disadvantages of the system are limited range, movement and hose handling,
particularly if more than one person is using the system.

Oxygen Resuscitation Equipment
Oxygen is essential to keep the body alive, it therefore follows that when entering an
enclosed space in order to rescue a person, an independent supply of oxygen is needed
to support the casualtys respiration. One way of achieving this is to fit an oxygen
powered resuscitator to the casualty. The unit should be capable of operation in both a
positive cycle mode (delivering set quantities of oxygen at precise intervals to the
casualty when they are not breathing), whilst at the same time being capable of
automatically changing to an on demand mode (when the casualty is capable of
breathing for themselves). The unit should be independent, transportable, lightweight,
easy to use and reliable, thereby allowing the rescue party to concentrate mainly on the
task in hand, assured that the resuscitation equipment is doing its job.

Oxygen Resuscitator in Carrying Pack

Oxygen Resuscitator In Use


First Aid Equipment
Basic life skills first aid should be a mandatory requirement for all rescue workers. The
ability to prevent the casualtys condition worsening, by stemming blood flow from a
wound or immobilising a fracture before moving them, is a fundamental component of
casualty management. In order to support the application of life saving first aid
techniques, a well stocked first aid kit should be available for use by the rescue party at
the enclosed space entry point.

Analgesic Gas Equipment
The main function of analgesic gas is to offer pain management. It is inhaled into the
body and is self administered. In essence, the person taking the analgesic gas will
continue to breathe in the analgesia until the pain eases. It is carried in a self contained
carry bag which includes a cylinder of ENTONOX gas, regulator, delivery hose and
demand facility. It is an excellent piece of equipment used for pain management during
the rescue process, having distinct benefits to both the casualty and the rescuers when
manoeuvring within the enclosed space.



De-fibrillation Equipment
Automatic external de-fibrillators are life-saving instruments which should be readily
available and on hand outside the enclosed space. These AEDs are predominantly used
to shock the heart back into its normal rhythm should cardiac arrest occur. The earlier
an AED is used, the greater the chance of casualty survival. Most modern units give
voice prompts to the user, (available in various languages) and are supplied in either
semi or fully automatic modes. These units are compact, portable, lightweight,
battery operated and generally manufactured for ease of use, which benefits the rescuer.

In consideration of the number of casualties which continue to occur in enclosed spaces,
there must come a time, in line with industry ashore, when enclosed space training and
rescue equipment becomes mandatory. The continued use of fire fighting equipment for
rescue from these spaces remains questionable as previous case studies have shown fire
fighting equipment to be inadequate in some instances and indeed having fatal
consequences in others.

Chapter 5.
ENCLOSED SPACE TRAINING
As indicated in The Enclosed Space Box (section 2) training is one of the most
important preparatory aspects required for working in enclosed spaces. No person
should enter any space until they are adequately trained and fully aware of all
procedures associated with that entry. Training is a very important issue (and costly),
therefore consumers should be circumspect and hopefully know exactly what they need
before placing orders. Much is made of the word competent. In regard to enclosed
spaces, competence is exactly what the surveyor should have before entering the space.

Competence, based on knowledge of:

what procedures should be in place before entry
what equipment should be taken into the space for their safety
how they should conduct themselves whilst in the space, and most importantly
what to do in the event of something going wrong

Too many accidents and near misses are now being recorded in these spaces which
unfortunately are resulting in severe injury and in some cases death to the entrants. This
is a situation which must not be allowed to continue. In this section we are dealing with
training and how we can give the entrant an awareness of the hazards associated with
enclosed space entry.

5.1 Training Courses

Mines Rescue Marine have been involved with training for entry and rescue from these
spaces for many years as well as being consulted about the subject internationally.

Over the period MRM have created and delivered a complete suite of training courses
focused solely on the marine industry for differing levels of personnel within the
organisation. The courses listed below would be a good bench mark to choose from
when selecting appropriate training.

High Risk Enclosed Space Course

Medium Risk Course
Low Risk Course
Rescue from Enclosed Spaces
Management of Enclosed Spaces

Always ensure that training courses are being delivered by competent trainers/lecturers
and where possible to a standard such as for instance UK National Occupational
Standard for Enclosed Spaces. The duration of each of the courses listed above varies
and is dependent upon the degree of risk associated with the task and level of
knowledge required. With the exception of Rescue from Enclosed Spaces all of the
other courses would be relevant to marine surveyors dependent upon their respective
position within the organisation and are intended to give a working knowledge of entry
procedures and equipment, and just as importantly, an appreciation of the very real
dangers associated with these spaces.

5.2 The Marine Surveyors Course

Previously MRM were approached by the IIMS to draft a training course specifically
aimed at marine surveyors focusing on the areas of concern that surveyors may have to
deal with. The course produced was is in line with the UK National Occupational
Standard for entering Enclosed Medium Risk areas (i.e. tanks, double bottomed cargo
holds, void spaces etc.) and was therefore able to be assessed to a nationally recognised
standard, this in turn will deem the candidate to be competent for entering the area.
This one day course (outlined below), can be delivered at the work site or undertaken
out at any of the MRM approved sites, thus allowing for greater flexibility.

Target Audience
The course is aimed at surveyors who may be involved in entering enclosed/confined
spaces with difficult entry/exit portals. The course will cover the use of monitoring
equipment, EEBD (escape breathing apparatus), awareness of existing confined space
regulations, safe systems of work (SSOW), permit to work, emergency procedures,
personal protective equipment (PPE) and entry & rescue equipment.

Objectives
Are to prepare the candidate to:

Work safely in medium risk enclosed spaces

Enter and exit enclosed/confined spaces safely
Prepare and use escape breathing apparatus in accordance with manufacturers
specification
Use all equipment safely in accordance with manufacturers specifications
Follow all relevant procedures and work safely
Deal with emergencies

The training course is about working in enclosed space environments where there is a
medium risk that a specified hazard may be present, such as:

1. serious injury to any person at work arising from a fire or explosion;
2. without prejudice to paragraph (a)
1. the loss of consciousness of any person at work arising from an increase
in body temperature;
2. the loss of consciousness or asphyxiation of any person at work arising
from gas, fume, vapour or the lack of oxygen;
3. the drowning of any person at work arising from an increase in the level of liquid;
or
4. the asphyxiation of any person at work arising from a free flowing solid or the
inability to reach a respirable environment due to entrapment by a free flowing solid.

Specified Hazard as described in the UK Confined Space Regulations.

Course Content
The course content will incorporate those items specified in the course objectives,
including the use of escape breathing apparatus (EEBDs) and will involve the presence
of one or more people - positioned outside the enclosed space - who have designated
responsibilities for controlling the entry and dealing with emergencies.

Entry into the enclosed space may involve:

Vertical entry - normally via a restricted hatch, using a ladder or man-riding
winch, both requiring fall protection and means of assisted rescue such as a rescue
winch.
Horizontal entry - such as walking or climbing into the enclosed space or
working away from the bottom of a vertical entry, with limited use of a rescue
line. Such types of entry may involve more than one person entering the confined
space.


Assessment Criteria
The course will conclude with a written and practical assessment.

Chapter 6.
RESPONSIBILITIES
Strangely, the responsibility for the safety of those coming on board a ship for work or
surveys, whether the ship is at sea or in port or dry dock, is a grey area in the marine
industry. Some time ago, the Mines Rescue Service, through their Marine Division,
were called for advice on a case involving a shore contractor who was severely injured
in an enclosed space on board a ship. During the course of the investigations it became
clear that there was confusion as to responsibilities for shore workers in such a position.

This confusion was even more apparent when, in conversations with ship owners and
dockyard managers, it was revealed that there was a practice in place of the yards giving
a letter stating that they were assuming responsibility for the safety of workers on ships
and installations, even though these were still under the command of masters or the
responsibility of the installation managers.

This assumption in many companies that contractors are responsible for the safety of their
workers, or that a port or dry dock can issue an indemnity stating they accept
responsibility for safety of shore workers while on board the ship or installation, is very
unsafe, especially when considered internationally. As many countries are quite definite in
their legal interpretation that, while the ship or installation is under management, in other
words, not a dead ship, then the captain or manager of that ship or installation, is
responsible.

6.1 The HSE and MCA Memorandum of Understanding

The responsibility is even more problematic in countries like the UK, where shore
workers are under the auspices of the Health and Safety Executive while the ship and
crew are under the Maritime and Coastguard Agency. This leads to strange anomalies
where an FPSO unit has two administrations working on board. The two authorities
have a memorandum of understanding that is mainly directed at a recognised division of
responsibilities, especially for investigation, however, there are a number of
implications from this memorandum that the industry should be aware of. These are;
HSE inspectors may;

Enter all work places including docks and offshore installations.

Investigate accidents to shore workers working in a port while loading and
unloading a ship and similarly investigate accidents occurring to a ships
crew.
The HSE is primarily responsible for enforcing legislation covering the safety
of shore based personnel and work equipment supplied by the shore even
when working on a ship.
HSE is the lead authority for all dock operations whether or not crew are
involved. HSE has enforcement responsibility for the provision and use of any
work equipment supplied by the port irrespective of who is using it.
HSE is responsible for all shipbuilding or conversion work ( whether shore
workers or ships crew), in any shipyard, harbour, dry dock or wet dock.

Where a ships crews is carrying out voyage repairs under the masters authority in
harbour, responsibility is that of the MCA. All other ship repair activities in dry dock
and major work not considered to be normal ship voyage repair activities are the
responsibility of the HSE, whether carried out by shore labour or crew.

For voyage repairs where ships crews and shore labour are working concurrently, both
MCA and HSE have equal responsibility. They must then agree a lead authority.

We suspect that many other countries will have a similar type of arrangement.

The factors to bear in mind regarding any memorandum of understanding between the
shore safety executive and the marine safety executive is that ships rarely carry any
information regarding shore safety legislation and many may not have any knowledge
of this document. If this is the case, most masters are ignorant of any responsibilities
they have to shore workers. Equally there is ignorance ashore, demonstrated by the fact
that when some dry docks assume responsibility of all safety matters on the ship for
their workers, quite often this is assumed to cover outside contractors and surveyors
employed by the dry dock for work on the ship.

The most important question is, does the law recognise this transfer of responsibility
and exonerate the master from any responsibility for any accident involving workers on
the ship during that docking? All evidence points to the contrary and that legally the
master would be responsible for any breaches of safety legislation.

Finally, according to the ISM-Code section 1.2.1 the objectives of the Code are:

To ensure safety at sea, prevention of human injury or loss of life and avoidance of
damage to the environment, in particular, to the marine environment and to property.

In section 1.2.2 the objectives are, among others:

provide for safe practices in ship operation and safe working environment;
establish safeguards against all identified risks; and
continuously improve safety management skills of personnel ashore and aboard
ships, including preparing for emergencies related both to safety and environmental
protection.

This Code does not say only at sea, nor does it say only the crew of a ship.

Section 5.2. states;

The Company should ensure that the SMS operating on board the ship contains a clear
statement emphasizing the masters authority. The Company should establish in the SMS
that the master has the overriding authority and the responsibility to make decisions
with respect to safety and pollution prevention and to request the Companys assistance
as may be necessary.

This is of particular concern to the master for it means that, regardless of whatever the
company says or any superintendent signs on behalf of the ship in a port or dockyard, it
is the master who has the complete authority over safety and, of course, will be
ultimately held to account for any breach of safety regulations or casualties resulting
from such a breach should it have occurred.

This is supported by common law which states that the master is the supreme authority
on his ship, even when the ship owner, charterer or employer is on board.

6.2 Legal Case Studies

A recent judgement in the High Court of the Hong Kong special administrative region
was made concerning the death of a surveyor and an assisting crew member from
oxygen depletion in an enclosed space on board a ship. The following is an extract;


A harsher criterion was applied to the conduct of the Master who was found to be 50
per cent to blame. The court started from the premise that the Master is in overall
charge of the vessel and responsible for the safety of all persons on board, including
lawful visitors. The relevant safety codes provided for a planned entry into any
enclosed space with a competent officer or other person appointed specifically for that
operation. There was no such operation planned in this case. The fact that the Master
had offered the services of the Chief Officer whose presence might have avoided the
accident, and that the Surveyor rejected this offer, did not detract from the overriding
responsibility of the Master.

The most important finding of the court was on the question of whether the Master was
entitled to assume that the Surveyor was qualified and competent to carry out the tasks
expected of him and to follow safety procedures, in particular those relating to entry
into enclosed spaces.

The court held that the Master was not in possession of sufficient information to make
a decision about the ability of the Surveyor to deal with any dangerous situation that
might arise. The Master could make no assumptions in this respect.

This makes very uncomfortable reading but certainly emphasises the case for the overall
responsibility of the master for all on board regardless of who they are, who they are
working for or what work they are doing.


A further case involves a bulk carrier undergoing repairs to the stern seal in a European
port.

Subcontractors were contracted to build scaffolding around the stern and propeller
blades in order to gain access to the stern tube seal.

At the same time, a second technician was contracted to carry out repairs and
adjustments to the main engine controls in the engine room. To carry out this work, the
technician required the turning gear to be rotated manually. As this was done, the
propeller shaft turned, rotating the propellers, which knocked down the scaffolding. One
of the contractors was killed by falling from the scaffolding.

The Master and Chief Engineer were accused of negligence and ordered to attend a
criminal court. They were given a prison sentence, although this was overturned on
appeal.

Here we have a situation where two separate contractors were working independently but
unfortunately their safety arrangements were not co-ordinated. Even though the ships
officers were not involved in the incident, again the Master is assumed to be responsible.

All of the above suggests that regardless of what any port or dockyard claim, whether at
sea, alongside or in port waters, the responsibility of the ship or installation owners for
safety for the shore workers cannot be abrogated to any other authority while the
owners managing representative, be it the captain, safety officer or manager, is on
board.

6.3 Defining Responsibilities

Fifty years ago, Hopkins in Business and Law for the Shipmaster wrote;

Stevedores and other contractors who board a ship as invitees and persons who come
on board as licensees for their own private purposes or as guests, are all entitled to
adequate provision against pitfalls and traps. Apart from specific regulations, the
master has a common law duty to provide such protection.

The now common practice of signing on shore workers for seagoing as passengers
instead of supernumeraries further enhances the masters responsibilities to them as, unless
their contract includes a Himalaya clause, which protects the ships owners employees
from legal action, the master may be personally liable for any injuries they suffer.

This all leads to two separate responsibilities, that of the owner to protect the
contractors or surveyors from risks and dangers on the ship or the installation and that
the contractors or surveyors co-operate and follow the masters and crews instructions
to ensure their own safety and avoid putting others at risk.

However, should any accident involve the shore personnel, it would seem that the
owners cannot avoid the consequences of any negligence resulting from the actions of
those workers while on the ship or installation.


For this reason it is essential that the SMS that is in place for the ship or installation has
a clear and concise section outlining these responsibilities and the procedure in place for
them to be implemented.

This is not as easy as it sounds. Consider the following;

In the UK, A surveyor arrives on board a general cargo ship for inspection of a ballast
wing tank. He is operating under the legislation of the HSE. The ship is operating under
the MCA which has no enclosed space legislation. The surveyor has no knowledge of
the legislative arrangements and the ship does not know what is required under the HSE
or even probably that they are also now temporarily under the HSE.

Hopefully the ship shows the surveyor the risk assessment for the space or the surveyor
asks for this. The surveyor checks that the space is gas free and safe for entry. A work
permit is issued by the ship and they enter. The ship does not require specific enclosed
space entry equipment such as harnesses and EEBDs as they have no legislation
requiring this. Nor does it check that those entering the space have enclosed space entry
training as, again, the MCA does not require this although the HSE does. (Ref. The
Management of Health and Safety at Work Regulations 1999, regulation 7).

While it can be expected that the surveyor will bring their own PPE, It is very unlikely
they will bring a rescue team with equipment with them, they are therefore relying on
the ship to provide this.

While dealing with fire is urgent, there hopefully is time for the shore fire services to
arrive to assist the ship. With enclosed spaces, the emergency response must be made
within minutes, therefore, even if in a dock or port, any available shore rescue team will
not arrive in time. Clearly the ships rescue team is the only response that can deal with
an emergency.

An accident happens and a rescue team is required. The ships general emergency party
arrive, which although trained for fire fighting has no enclosed space rescue training.
They do drills every two months but without the training to base those drills on, that is
not adequate. If the ship is under 1000 tons, then even drills are not required.

The HSE document, Safe Working in Enclosed Spaces states;


The Preparation of emergency arrangements
This will need to cover the necessary equipment, training and practice drills.
Provision of rescue harnesses
Lifelines attached to harnesses should run back to a point outside the confined space.

Yet the ship has no requirement to have harnesses or equipment or emergency training.
The rescue party then attempt to enter the space, but cannot get through because they
are using fire equipment not designed for enclosed space entry and their BA sets are too
large for the manhole. Again, there is no legislation on the design.


Confined Spaces Regulations 1997 Regulation 4 Work in confined spaces
Regulation 11 of the Construction (Design and Management) Regulations
2007 places a duty on designers to ensure that any design includes adequate
regard to the need to avoid foreseeable risks to the health and safety of any person on
the structure at any time.

Eventually they manage to pull the surveyor out using a length of rope as no tripod or
winch arrangement is required.

Confined Spaces Regulations 1997 Regulations.
82 Rescue equipment will often include lifelines and lifting equipment (since even the
strongest person is unlikely to be able to lift or handle an unconscious person on their
own using only a rope),.

The ship has no resuscitator to help revive him. Again, not required.

Confined Spaces Regulations 1997.
Regulation 5 Emergency arrangements
(b) They require, where the need for resuscitation of any person is a likely consequence
of a relevant specified risk, the provision and maintenance of such equipment as is
necessary to enable resuscitation procedures to be carried out.

We accept it is easy to paint a scenario and develop it the way you wish to prove a case,
but the base of what is described above is constructed on an actual event. It certainly
shows the difference between the marine legislation and that of shore legislation in the
UK. What is obvious is that owners should seriously consider the inclusion in their SMS
the requirement to take into account their responsibilities in ports and docks as well as
to contractors and surveyors at sea, and the fact that it is the HSE legislation and
investigation that needs consideration.

Finally, it is essential that there is agreement in place between the dock and the ship
as to the responsibilities for rescue, especially in enclosed spaces where minutes
count. Unless the dock provides a permanent rescue team on standby on board the
vessel during enclosed space work, it is highly unlikely that a rescue team on standby
somewhere in the dockyard will be effective. On the other hand, if the ship is
responsible for this, they must have a trained and equipped rescue team on board,
which presently is very unlikely.

What is vitally important is that any surveyor going on board a ship in port or dry dock,
knows whose legislation he is working under and that that legislations enclosed space
provisions are complied with.

Chapter 7.
OXYGEN AND DANGEROUS GASES
In an international industry with no legislation regarding enclosed spaces and the accident
levels prevailing in such spaces, there is considerable variation on advice and procedures
emanating from many sources. While all advice is well intentioned, In some cases this can
be misleading and lead to safety requirements being suggested to such high levels that if
followed, work would be prohibitive in any space. Safety is a prime requirement, but
safety procedures will only be followed if they are seen to be workable and sensible.

The basis for safe entry into an enclosed space is the presence of safe and breathable air.
Safe and breathable air are not the same. Safe air is generally set at 20.8 % of oxygen,
however, breathable air is far lower and in many countries legislative requirements it is
considered to be acceptable to enter spaces with 19.5% oxygen and there is an example
of one major industrial country allowing 18%. There appears to be no set international
standard as can be seen below with examples of relevant legislation.

Country

Standard

Australia

Occupational H&S Maritime Standard 2003

Oxygen
Levels
23.5 - 19.5 %

4.01
Canada
Germany
USA

Occupational H&S SOR/86-304 2011

23 - 18 %

DIN3188 1984

21 - 20%

Occupational H&S Administration

22 - 19.5 %

1915.12(a)2
Singapore
United kingdom

WSH Council Confined Spaces

19.5 %

BS4275 1997

23 - 20%

BCAS Gs 901031: 1990

24 - 18%

Upper level limits are in place due to the fact that highly concentrated sources of
oxygen promote rapid combustion and, therefore, the entrant should be aware that they
may be entering an oxygen enriched environment.

It is accepted by most scientists that what would be termed as normal oxygen levels in
the atmosphere in prehistoric times averaged around 30% to 35%, compared to only
21% today. These levels may be even less in densely populated areas such as polluted
city centres and industrial complexes, reducing those levels to perhaps only 17 % or
lower. Scientists claim that anything under 7% oxygen in the air is too low to support
human life.

The IMO recently issued a guideline of 21% as the limit for entering an enclosed space.
Obviously this cannot be followed as with normal air being 20.8%, no ship would ever
sail!

The aim of the oxygen meter is to determine the level of oxygen in the air and to
indicate any variation in that content as various spaces are entered. It would be
convenient to say that, if there is any reading below 20.8%, then the space should not be
entered but as the oxygen content in the air outside a space can vary this has to be taken
into account. For example, a ship alongside in a heavily industrialised city could have
an open air reading of less than 20.8% before entry. The meter must, therefore, be used
as an indication of deterioration of oxygen content rather than a go, or no go, indicator.
Should it indicate that any space has a lower content of oxygen than that existing
outside the space, then, regardless of how small the difference, the cause of this
difference must be determined and the safety of the space verified before entering.

7.1 Effects of Oxygen Depletion (examples)

21% to 19% - Fit for respiration (as long as no other
contaminants present)
16% - Dizziness, shortness of breath, increased heart
and respiration
rate, concentration and reasoning diminished, ability and
awareness to make recovery decisions highly impaired.
10% - Nausea, vomiting, muscular incapacity.
6% and below - Rapid loss of consciousness and
death.

7.2 Safety Alarms

All oxygen detectors have alarms and the setting of this alarm can vary dependent on
the manufacturer and the legislative acts to which they are conforming. Again there is
no internationally agreed setting. With alarm settings of around 20.8% it is not
uncommon for detectors to alarm in accommodation areas which can lead to
complacency and worse, by ignoring such an alarm. There does seem to be some
consensus that alarm settings should be at 19.5% of oxygen content. Again, if due to
pollution, the air content outside the space is at this level or below, the alarm will go off
outside the space before entering, then the alarm setting would be ineffective.


Regardless of this, if the equipment alarm is activating, whether inside a space or not,
under no circumstances should a space be entered until the cause of this can be
determined.

7.3 Effects of Other Gases

While lack of oxygen can have serious or even fatal consequences, other gases can
create the same situation.

Various gases can be given off by numerous cargo substances which may be of a toxic
or indeed flammable nature. Indeed gases used for inerting potentially flammable
substances or liquids in transit should also be noted. It would always be prudent to
know and understand the potential hazards to life posed by these gases and that,
therefore, any surveyor entering enclosed spaces on a ship must question the cargo the
ship is carrying and the proximity of that cargo space to the space he is destined to
enter.

7.4 Ballast Water Treatments

Apart from cargo or substances the ship may be carrying, new ballast management
systems also give rise to concerns where chemical controls are used.

The need to meet the new regulations on ballast water treatment and the associated
significant expense is a serious concern to modern ship owners.

When evaluating ballast water treatment options a number of general factors must be
considered but, without doubt, the monetary cost is the deciding factor for the majority
of ship owners, especially on ships already built that may have to be retro-fitted with
equipment. Amongst the many methods which now exist are:

Chemical Biocides
These chemicals act by destroying cell membranes, which leads to cell death. They
come in two general types, oxidising and non- oxidising.

With the problems and expense of these various systems, there is evidence that a
considerable number of owners are turning to chemical treatment. These biocides are
supplied in either liquid or solid form and can easily be stored on board a ship. As they
have been widely used ashore, the chemical data sheets for the biocides are easily
available and well understood. The machinery required for applying these chemical
biocides is reliable and needs little maintenance with the only problem being the size of
some of the plants.

It is important to note, however, that the reactions between biocides and seawater that
could produce harmful by products have not been extensively studied. More
importantly, there is definite concern now being expressed regarding the release of
gases in enclosed and confined spaces by these agents, especially the oxidising agents
of ozone and chlorine.


Ozone
Ozone is an oxidizing biocide that has been used to disinfect water supplies ashore for
over one hundred years. It is the major component of smog and is a harmful pollutant. It
is also often used as a biocide in water. Ozone is inherently unstable and dangerous to
produce, but it is a very powerful oxidizing agent.

The system works by passing water through machinery that releases ozone bubbles into
the water. The gas then dissolves in the water and reacts with other chemicals in the
water to kill the organisms. As not all the gas dissolves in the water, this must be
destroyed before it enters the atmosphere as it is toxic to humans. Further, reaction
between the ozone and the components of sea water may also result in toxic chemicals.

It must also be mentioned that when ozone is used, if the treated ballast water is
pumped out in fresh water, the ozone will remain active for up to 30 minutes, thus
having the potential to harm sea life in the area.

Chlorine
Chlorine for ballast water treatment is generated on the ship from sea water. It is
commonly used to treat drinking water and has been used for such treatment for many
years at sea, but recent studies suggest that it may not be as safe to humans as once
thought. There is also a possibility that chlorine may react with sea water to form toxic
chemicals.

Chlorine is a greenish-yellow gas, which combines with nearly all elements. It is a
respiratory irritant to the mucous membranes and lungs and causes cancer. Chlorinated
liquids burn the skin and many fabrics. As little as 3.5 ppm can be detected as an
odour.

7.5 Gas Bubble Morphology in Mud and Sediments

Other ways in which gases may be produced is from mud or sediment which forms as a
residue in the bottom of tanks on board the ship. These gases may be released
continuously when open to atmosphere or if the residue is disturbed for example by
walking through it. In 2005, a micro computed tomographic evaluation completed by a
US Navy department showed the feasibility of gas bubble formation in sediment and
mud using examples of bay mud. Even with a forced ventilation system, gas contained
in mud may not be entirely released and this is dependent upon the gas composition,
mud volume, rheology and ambient temperature. In other circumstances, a quantity of
gas may remain in stable solution in the mud and not be released until changes in the
mud chemistry, temperature or other conditions.

This could give rise to a situation where a ship with a depth of mud in a tank could
assume that the tank is clear of gas. Then when the tank has been closed for some time,
the gas could be released from the mud and now become a potential danger to crew
entering the tank later.

Both chlorine and ozone are heavier than air gases and this means that any ballast tank
or hold that has been treated with these chemicals should be uprated in the ship
enclosed space management plans to dangerous until they are completely ventilated and

tested. Natural ventilation will be inadequate for these spaces and forced ventilation that
reaches to the bottom of these tanks will be necessary for complete ventilation.

No one should enter tanks that have contained chlorine or ozone treated ballast water
until the tanks can be verified as being clear of the gases. This could be problematic for
vessels that need to have tanks surveyed or examined in the port of discharge. Without
adequate forced ventilation equipment, delays could be experienced.

All ships that use chlorine or ozone treatments should carry ozone and chlorine gas
detectors.

Where vessels are using ozone or chlorine ballast water treatment, mud or sediment
build up must be avoided and the bottoms of ballast tanks should be water blasted
periodically to clear the mud or sediment from the bottom.

Chapter 8.
THE ENCLOSED SPACE
MANAGEMENT SYSTEM
Over the years, with reducing crew numbers, changes in cargoes, increasing amounts of
chemicals being carried and the nature and design of enclosed spaces, the pressures of
work and the accompanying fatigue has resulted in a gradual increase of enclosed space
incidents, until they now have reached a critical situation, with more people injured or
dying in enclosed spaces than through any other related on board work activity.

Without any legislation in place, the methods for coping with enclosed spaces on ships
and installations are risk assessment driven based on individual company safety
management systems. In some instances, this system may be flawed and vary from a
comprehensive range of risk assessments with one for each space, to just one generic
risk assessment regardless of any particular hazards or design features associated with
each individual space.

In the majority of cases, in depth knowledge of any particular space rests purely with
the local knowledge gained by those on board and when they leave that knowledge goes
with them compelling the next crew to start the whole learning process again. It can be
said that on the majority of ships, regardless of their safety regimes, there is little
consistency in the overall control and protection of these spaces.

As if the potential for failure wasnt complex enough, the situation is compounded
when introducing shore personnel, especially surveyors, who are often required to work
in these spaces. They are in a potentially more precarious position than the crew, as they
have no prior knowledge of any poor design features, or hazard problems. Even if they
are shown the risk assessment, this will probably not include such information. There
exists a dependency that the marine Industry has similar robust training and rescue
procedures as the shore industries which, of course, is not the case.

SOLAS Enclosed Space Recommendations (extract)

Owners should carry out a risk assessment to identify all enclosed spaces on board the
ship. The risk assessment should be carried out periodically to ensure that it remains
valid


Internal audits by the owners of the ships safety management system should verify
that the established procedures are complied with in practice.

Similar to the fire situation, the enclosed space problem will only be dealt with
effectively by definitive legislation rather than suggestions, particularly in relation to
enclosed space training, equipment and rescue arrangements. However, in the meantime
there are certain measures which can be put in place that would considerably alleviate
the problem. The most obvious of these is that ships and installations should adopt an
enclosed space management system similar to the fire fighting arrangements which have
served the marine industry so well since their implementation. Such a system would
provide those on board, whether crew, surveyors, shore contractors, visitors or company
representatives, with a better system of protection than presently exists.

The main aims of such a system is to:

Offer protection to all those working on board;
Be simple to understand and use;
Cope with the disparity of ships, installations, companies and their respective
procedures;
Provide a comprehensive risk assessment for all spaces;
Provide a basis for the initial entry of all enclosed spaces regardless of their type
and, where necessary, deal with responsibility issues;
Provide a continuity of knowledge of the spaces on a ship or installation.

It must be understood at the outset that the enclosed space management system does not
deal with the lack of training, equipment and design enhancements which currently exist
in varying degrees throughout the entire marine industry, however, it does increase
awareness by highlighting potential problem areas thus supporting a culture of safe
practice and, for the first time, provide a comprehensive knowledge data base of all
enclosed spaces.





Once adopted, the system would:


Provide a definitive list of all enclosed spaces.
Be easy to access and understand and therefore capable of updating as it is
intended to be a living document.
Reduce existing paperwork.
Have the ability to be implemented in any fleet or collective of installations
regardless of their disparity in size or type.
Cope with the problem of continuous crew changing.
Provide instant up to date information to both on and offshore offices.
Deal with the responsibility issue between the ship/installation, company and
outside contractors.

Categorising Spaces

Space Information uploaded into the database

The confined space management system is based around a simple traffic light warning
system already implemented and working successfully in industry ashore.

Under this system, the ship or installation would define the three types of enclosed
spaces based on a physical audit and not just the previous references of the space.
Consideration would be given to the degree of difficulty of entry/exit, freedom of
movement within and ability to rescue from any particular space. Any space from
which there is considered a difficulty for rescue will be classified as a Red space
regardless of any risk assessment.

8.1 Methodology

To begin the process, a full audit of all spaces where workers may have to enter should
be undertaken. Each space should be given a unique identification number and its
location recorded on the enclosed space list and annotated onto a ships plan. The audit
must be comprehensive and cover all aspects of the space both internally as well as
externally if possible. Where available, previous risk assessments should always be
referred to for background information.

Whilst recognising that the audit process will undoubtedly be time consuming, once
completed, it will not have to be repeated, unless major modifications to the space have
been made. It must also be noted that any outputs from these audits are wholly
dependent on the auditor, therefore always be mindful that to carry out this process the
auditor should at least have a good understanding of enclosed space procedures.

The format of the enclosed space management audit looks particularly at four areas:

Potential dangers
The entry point
The enclosed space
Capability of rescue

The first section deals with potential dangers and looks at the existing risk assessment
for that particular space. A review of the risk assessment will highlight previously
identified hazards and the relevant control measures which can be updated and
recorded. In the absence of an existing risk assessment, one will have to be carried out
and the information documented.


Section two moves onto the entry point and, in particular, reviews the space available
at the entry point for entry and rescue equipment, the height and width available to erect
man-riding winches, the availability of anchorage points, whether the entry point is
inside or open to the elements, if there is adequate lighting at that point, and dimensions
of the entry point, whether horizontal or vertical.


Section three deals with the space itself and, in particular, identifies the previous
contents, if the space has to be entered vertically the depth and condition of internal
ladder systems, the internal distance to be travelled within the space, the presence of
obstacles (pipes etc.) or internal design issues such as lightening holes which would
impair travel or indeed rescue operations.


Other issues such as internal height and/or width restrictions would be recorded as
would be the potential presence of solids, liquids or gases which could present
additional hazards. Completing this section would be a review of communication
feasibility, presence or absence of internal lighting and ventilation requirements.

The final section addresses the issue of rescue capability and would consider how,
should the need arise, a rescue team would recover a casualty to the entry point and
transfer them onto the medical centre.

The information derived from the audit process will then be analysed and recorded onto an
electronic data spread sheet. When completed, together with the relevant risk assessment,
colour coding and ship or installation plan identifying the location of that particular
enclosed space will then form part of the overall enclosed space management system.


One of the main beneficiaries is contractors who are increasingly being used on board to
carry out work. The enclosed space management system helps to underpin and support
the masters/managers responsibility of care toward all persons on their ship or facility.

The system is capable of providing a full printout of any particular space together with
the relevant risk assessment, observed hazards, recommended rescue equipment and
rescue team availability. This information can be sent direct to the contractor prior to
the work commencing in order to help with the compilation of their safe system of work
and rescue arrangements. Issues or discrepancies, such as particular hazards, training
and equipment or rescue arrangements can be flagged up and resolved in advance.


An example of the data printout for the surveyor

In this way, for the first time in this Industry, all personnel, whether from the ship,
installation or from ashore may be provided with comprehensive information regarding
all enclosed spaces at the workplace. In addition, and probably more importantly, it
ensures that there is an effective exchange of safety information between the
ship/installation, managing offices and surveyors and contractors

The simplicity of the enclosed space management plan is apparent. The main benefit
being that any worker tasked with entering an enclosed space can refer to the electronic
database for that space and download relevant information regardless of their previous
work history at that location. The system is a living document which contains an up to
date and permanent record of information of all enclosed spaces on that ship or facility.
If this system could be adopted by the marine industry as a standard requirement it
would, for the first time, ensure that there exists comprehensive knowledge of enclosed
spaces and their individual dangers on each ship or installation and allow access to that
same information by the operating office of the ship. Equally important, it would
provide a safety net for shore personnel when engaged in work in these spaces.

CONCLUSION:
Keep The Surveyor Safe
It is impossible to say what the state of enclosed space safety is on board any ship
regardless of the repute or disrepute of the operating company. So much depends on the
safety ethic and culture of those in the company, both ashore and afloat.

In the majority of cases, there will be little bespoke enclosed space equipment on the
ship or installation, indeed, too often a rope is considered to be an adequate means of
raising or pulling a person to safety from the enclosed space. For that reason, it is
essential that surveyors themselves make provision in the interests of their own safety
and ensure that they ask all the relevant questions prior to entry.

If there is no advance information given by the ships operating office or the ship on the
spaces being entered or the state of equipment and training on board, then the surveyor
must presume the worst case scenario in that there is no specific equipment or rescue
trained team. If that is truly the case, our advice can only be to request a dedicated
enclosed space entry and recue company to provide standby cover while the space is
being entered.

Remember that, in many cases, such as in the UK, you are working under the HSE
legislation and thus the work space must conform to that legislation, regardless of the
marine administration and the IMO SOLAS requirements under which the ship is
operating. This can make a considerable difference and it is important that you are
aware of this and require the ship to conform as required.

On the other hand, as we all know there are many ports in the world where you are on
your own, with not even the port having any emergency cover or knowledge of these
spaces.

It is, of course, as always, your decision, but remember that this is just a job and that if
any delay is caused to the ship this is the owners fault not yours.

We suggest that your own PPE equipment should include as a minimum: a hard hat,

from a recognised company, coveralls, protective boots/shoes, eye, ear and hand
protection.

In addition to this we suggest that you wear a harness (rescue), a hands free light (which
could attach to the hat), your own oxygen/multi gas meter (as you never know if the
ships meter has been calibrated properly) and an effective means of communication.
Finally, your own ELSA which is your emergency get me home equipment if required.

Regardless of what the ship advises you, you must do your own dynamic risk
assessment of both the opening you are to proceed through and of the tank itself.

Only then, when you are completely satisfied, should you enter the space.

Always remember:

Think Safety
Work Safely
Be Safe

ABOUT THE AUTHORS

Captain Michael Lloyd, RD**, MNM, FNI, RNR

Michael trained on HMS Conway and was then seagoing in both the Royal and
Merchant navies for 50 years. He held command for 35 years on almost every type of
ship ranging from 300 DWT to 300,000 DWT.

On leaving the sea, Michael published ten seamanship text books including In Command
and, The Ice Navigation Manual and five novels. His latest collaboration with
Witherbys Seamanship Ltd has resulted in a new seamanship book, Seamanship 21st
Century.

He is elected to the Council of Nautilus International and sits on the Technical and
Welfare committees.

Michael sits on the Technical, Education and Training committees of the Honourable
Company of Master Mariners, is a Younger Brother of Trinity House and a Fellow of the
Nautical Institute.

He was awarded the Merchant Navy Medal in 2010 for services to training and
education for the Merchant Navy.

Michael is the Marine Consultant to Mines Rescue Marine Ltd and Salvare Worldwide
Ltd.

Adam Allan, Managing Director - Mines Rescue Marine
Non executive Director (Trustee Director) - Mines Rescue Service Ltd, Director - MRSL
Trustee Ltd

On leaving school at 16, Adam joined the National Coal Board spending 12 years
working underground during which time he trained as a part-time rescue worker before
transferring into the Mines Rescue Service in 1983 in a full time capacity.

Qualifying two years later as a Mines Rescue Officer, Adam moved around the UK coal
mining industry attaining promotions. During this time he participated on and chaired
many national committees relating to enclosed spaces and rescue procedures. Promoted
to Station Manager in 1994 he gained an MBA in 2000 at Northumbria University.

Adam established a new division of mines rescue, (focused on the Marine and Offshore
Industry), in 2009 and instituted an intensive programme of familiarisation. He gained
marine experience by visiting, exercising and training on ships and oil and gas
installations in the North Sea, Europe and in West Africa.

Appointed as Managing Director (MRM) in 2013, Adam was appointed to the board of
MRSL in 2015.