If Nobody Entered Enclosed Spaces...

It may be stating the obvious, but it is also an infallible truth. If human beings and enclosed spaces are potentially fatally incompatible, the engineering solution to the problem is to keep the two elements separated as far as practicable. 

How many times have the phrases “routine inspection” or “planned maintenance inspection” been inserted on the “Entry into an Enclosed Space” forms on vessels throughout the world on a six monthly or annual cycle? To what ends? If, during the inspection, anything untoward is identified by ships staff, inevitably the next step will be yet another inspection by the vessel superintendent or a class surveyor, inducing yet more interaction between humans and enclosed spaces.

If the external areas of a vessels’ hull can be inspected on a two and a half year or even a five year cycle, then surely confined spaces can be inspected at the same frequency? Obviously if there were other indications of defects then an inspection could be carried out, but that would not be routine and the number of such inspections would be a fraction of the current world wide routine inspection program. 

There are other aspects concerning confined space entry that if changed would help prevent further deaths in confined spaces.

Is the space fit for purpose?

Or to put it more accurately, are the access and egress points on the enclosed space fit for purpose? What may look like reasonable accessibility on the ships plans can be totally impractical once pumps, brackets and pipe runs have been added later in the construction of a vessel or during any subsequent modifications.

Apart from the simple inaccessibility of certain access points, vessels are still being constructed with enclosed spaces that only have a single access/egress point. How is it possible to maintain continuous mechanical ventilation, a box frequently required to be ticked on the confined space entry permit, if the vent ducting has to be removed to allow access for the personnel entering the space or to pass items into or out of the confined space? If a minimum of two manholes cannot be incorporated into a confined space then a single manhole with a separate, smaller, utility access point for ventilation and lighting cables would be an improvement.

Another scenario is where the crew have to enter one enclosed space to gain access to the manholes for another enclosed space. This situation is not acceptable and should be engineered out during the design and construction phases, instead of leaving it to the ships’ crew to overcome the design shortfalls and sort it out.

Crewing Matters

A dedicated responsible and accountable person in charge of tank entry operations would be a real asset, but this cannot be another paper exercise where some already fully employed officer or senior crew member is given yet another hat to wear.

So this brings our attention to crewing numbers and the ability of ships’ crews to safely fulfill all their roles within their increasing workload. It is our opinion that crewing numbers have been reduced too far. Too often the unrealistic numbers appearing on “Safe Manning Certificates” are being taken as the operational crewing levels by vessel owners and operators inducing high workloads which must then be contained within the “Hours of Rest.” 

Workloads for all ranks of the marine crew on virtually every vessel have increased in recent years (we only have to mention ISPS,) and yet the numbers of crew have either remained constant or even decreased. Regardless of automation and computerization, there are still a large number of tasks on vessels that need experienced personnel and boots on the ground. Far too often when planning a routine tank inspection on board ship with available personnel, the first order of business is to rob Peter to pay Paul. Is it any wonder shortfalls in safety standards are occurring? 

Howard Nightingale is Maritime Advisor for CHIRP Maritime.