Time to Rethink Safety in Enclosed Spaces

Crew members are often blamed for deaths in enclosed spaces. Human error; so it would seem. But, there are those in the industry who believe that others should be held accountable, that new action should be taken. 

In a submission readied for the IMO this year, the International Dry Bulk Terminals Group (DBTG) reveals that its, admittedly not exhaustive, study shows that over 70 accidents occurred during the carriage or handling of solid bulk cargoes between 1999 and April 2018. The accidents were collated by Captain Kevin Cribbin, and his research showed that they involved the death of both seafarers and shore workers. 88 people lost their lives due to asphyxiation or carbon monoxide poisoning. Another 18 died as a result of fire or explosions. Of the 88 that died of asphyxiation, 76 died on hold access ladders. Another nine died in the the cargo area and three in adjacent forecastle spaces. 

DBTG Executive Director Nic Ingle notes the number of fatalities is increasing. Since the submission was prepared in June, the death rate has increased over 300 percent, taking the number of deaths from 106 to 126 in that short time. Ingle wants the issue on the table at the IMO and is looking to get state endorsement for the submission.

“Ideally what will come out of this is clearer instruction for all, better information to make those involved aware of the potential hazards that some cargoes present - a pile of coal in a hold looks harmless, but it is not in most cases. It can be full of a variety of dangerous gases such as methane and carbon dioxide - which will kill.”

Ingle says that some P&I Clubs believe the issue is already well covered by regulation. “My response to them is that the regulations cannot be working, as the statistics testify. The statistics would suggest that a minimum of six people will die every year in a dry bulk carrier as a result of the cargo - all preventable.”

He says there is an inadequacy of training, but training alone will not solve the problem - awareness across the board is required - including shoreside. He is proposing changes be made to the International Maritime Solid Bulk Cargoes Code (IMSBC Code) to include a specific requirement for a risk assessment to be carried out for all solid bulk cargoes. The existing recommendations for entering enclosed spaces on board ships (resolution A.1050(27)) should be amended to provide guidance on how these risk assessments should be carried out or an new set of guidance developed.

The Problem with STCW

Captain Jeff Parfitt, Director of the confidential incident reporting scheme CHIRP, says that although the IMO recently introduced requirements under SOLAS Chapter III requiring regular enclosed space entry drills, STCW has proven to be a bottom common denominator in respect of international crew certification and training. 

“The concept of STCW is a good one, but it has resulted in a reduction in skill and expertise in the international seafarer market. This is obvious when even senior officers have been shown to lack the knowledge required to, for example, launch a lifeboat or understand the operation of breathing apparatus. Why would a cost-efficient shipping company invest in sophisticated training and education when internationally recognized certification is available at a huge cost saving?

“The result, in our opinion, has been a deterioration in the quality of training for many seafarers. Whilst some companies, notably tanker operators, understand the risks concerned with enclosed spaces, those ship operators that do not have regular exposure to this operational environment are deficient in knowledge and without experience and guidance simply are not aware of their own deficiency.”

Additionally, Parfitt says there is a prevalent cultural pressure to frequently inspect enclosed spaces on the basis that it is planned maintenance or a class requirement. “This mindset needs to be re-visited. There is no reason that such inspections cannot be postponed to a maintenance period when a proper shore side chemist can conduct certification for safe entry. Routine checking on the coating condition of a space could be deemed low priority, and the vessel superintendent would in any event require all inspections to be repeated once the vessel is in maintenance.”

Holding Someone Accountable

Captain Ghulam Hussain, Technical Manager and Head of IMO Delegation at The Nautical Institute, believes that in addition to a designated person on board being responsible, someone needs to be held accountable for ensuring enclosed space entry procedures are actually followed and that it is not just a tick-box exercise. He believes that person should be one of the senior officers on board. “There are times when a number of things in a ship's SMS manual are not followed. Nobody does it purposely. It is not purely neglect, but in real life, you've got to get the hold cleaning done quickly, you've got a survey coming up, you presume it will all go well and before you know it, an incident has occurred.”

Hussain says it is up to the ship manager and the master to ensure that best practice, underpinned by IMO regulation, is documented, available on board and strictly followed. “The major issue is that despite all precautionary measures being mentioned in various documents, and everyone being aware of the dangers, the system of entry into enclosed spaces is not being followed,” he said. “It is a recurring preventable issue which is not being properly addressed. Someone has to be take full responsibility and be held accountable for ensuring all safety parameters are checked before permitting entry. 

“I don't think it can be an IMO resolution. It is best practice and due diligence that managers and ship-board officers need to inculcate amongst crew members. There are many directives available from various authorities including P&I Clubs. These need to be followed.”

Regular drills related to entry into enclosed spaces as well as an educated awareness of the safety equipment available could assist in minimizing casualties. The port state control regime could also assist by inspecting a vessel’s readiness on how enclosed space entries are undertaken. Lessons may be learnt from the mining industry, which has a much higher safety level when dealing with entry into enclosed spaces, says Hussain.

Holding Ship Managers Accountable

Captain Kuba Szymanski, Secretary General of InterManager, believes that the results of Concentrated Inspection Campaigns demonstrate that seafarers generally have a good knowledge of the risks and procedures and that it is a myth that ships don't have oxygen meters on board. The 2015 Paris MOU campaign found scores of over 90 percent in most categories - except crew members being familiar with their duties (88 percent) and the lack of a manual on board (83 percent).

The Tokyo MOU's 2015 Concentrated Inspection Campaign had similar results. In this case, only the lack of a manual was below 90 percent. 

“This is a ship management problem,” says Szymanski, who sees any perceived lack of training also as an InterManager problem. “Why do incident investigations stop at blaming the senior officer. A management company employed him, trained him, scrutinized him, maybe even promoted him, and now it is saying that he is substandard?”

Operational pressures could be contributing to the risks being taken, says Szymanski. “Has anyone checked the voyage instructions? Has anyone tried to wear the master's shoes? Has he been given absolutely incompatible goals – get the ship ready in 24 hours when sticking to all procedures would actually take 72 hours? Has anyone checked how many people he had to do the job? Was he able to delegate? That’s what astonishes me – no one seems to be reading behind the usual 'human error' conclusion.”

InterManager is currently asking seafarers for their opinion on what they believe should be done, and Szymanski is getting plenty of responses. So far, he notes a number of fresh ideas have been received. One is to involve the shore office in on board enclose entry procedures. Make the office aware when and who is entering and prepare a plan in conjunction with them. Make them understand what it takes and how long it takes to enter the space. 

Ship designers should start thinking of ships with enclose spaces in mind: first access then rescue, should something go wrong. Lack of ventilation is a major shortcoming in enclosed spaces at present, along with the size of manholes and passageways.

Another suggestion is that every space has gas metering equipment and every seafarer be equipped with a gas detection system. And another is that there is a seal control mechanism which would only allow one person (the master or chief officer) to open an enclose space, with an alarm system indicating unauthorized entry.

Szymanski hopes by asking seafarers to have their say, it will help to shift the paradigm of blame from seafarers to those responsible for the environment they perform their duties in. “It is up to us, ship managers, to change the situation and end these deaths.”

In return for providing their opinion, seafarers could earn a Macbook Air as a prize for the best response and $2,000 for their vessel’s welfare fund. Responses should be received by January 1, 2019.