It’s not often that I would find myself advocating greater regulation in the shipping industry – but when it comes to the situation regarding enclosed spaces on vessels I will make an exception!

I would however insist that any new regulation would actually benefit the seafarers who are at the ‘coal face’. New regulation is needed, for example, towards the design of the enclosed spaces. I would love to see realistic requirements for the spaces in which human beings are expected to work. That would include entry points, emergency escape points, provisions for ventilation and atmosphere monitoring in the WHOLE space.

Responders to our recent survey into the dangers of enclosed spaces – nearly 5,000 seafarers – were very vocal when it comes to the time pressures placed upon them when working in enclosed spaces and the lack of equipment available to them. Can these issues be regulated? I am afraid so.

Tankers have OCIMF and vetting regimes, these are very prescriptive and represent a pretty well-regulated part of the industry. When it comes to other vessels, in my opinion many owners just do the bare minimum. For example, they might only provide one oxygen meter. That might ‘tick the box’ but we need more than that.



Seafarers need equipment which will help them to assess whether it is safe to enter an enclosed space and then the means to monitor the atmosphere in that space. In addition, to effectively communicate and to response to emergency situations in an enclosed space also requires extra equipment, which is not presently mandated.

Currently there is absolutely no regulation stipulating the minimum/maximum number of people in the enclose space – either working or in the standby party. This frequently results in units of just two seafarers not being supervised by anyone other than the officer of the watch, who is on the bridge. In fact, it is impossible to do otherwise if ship’s staff is requested to do inspections of 18 ballast tanks in just two days with only three to five deck crew. There is no regulation about that at all.! The only requirement is to carry out a risk assessment and an enclosed space entry checklist has to be completed.

Our industry seems to be drawing the wrong conclusions all the time – our seafarers are trying to tell us about that. They are concerned about the way accident investigations are conducted and the feedback we have received is that they would prefer them to be fully recorded with statistics maintained and regularly updated, and for a proper and thorough analysis of the common root causes carried out.

Blaming does not help anyone! No one – whether working in the office or on board –wants to make a mistake. Nevertheless, we all make mistakes from time to time. It would be great if we could help our people to work in a safe environment where mistakes, within reason, are regarded as a learning opportunity for improvement.

Seafarers who responded to our survey were also quick to point out that existing procedures are not compatible with reality, nor even with each other! Frequently Shipboard Safety Management documents are in conflict with COSWP (Code of Safe Working Practices) or ISGOTT (International Safety Guide for Oil Tankers and Terminals) guidance. This could be very difficult to regulate, but proper accident investigation could, and probably should, look closely at the Risk Assessment as every accident is the manifestation of failure of all procedures and RAs.

Tankers have their matrix, which tries to create some sort of continuity of the people working on board of the ship with the same operator. Seafarers identified personnel problems as one of major issues when it comes to teamwork and co-operation. Senior officers are worried about “who will come on board next time” and junior officers dread having a ‘new boss’ who may not work well with the office and could even abuse existing systems. Can this be regulated? Or maybe we should ask ourselves should this be regulated?

Deaths in enclosed spaces, as demonstrated by the survey answers provided by our seafarers, are the result of complex issues and cannot be fixed by just providing more and more training for seafarers. We, as an industry – right from Secretary General of the IMO, through CEO, CFOs, MDs and GMs, down to Crew Operators –have to take ownership of each and every fatal accident in an enclosed space. This is the only this way that we will reverse this tragic trend seen in our industry.

The views presented hereabove are only those of the author and not necessarily those of SAFETY4SEA and are for information sharing and discussion purposes only.

About Captain Kuba Szymanski

Captain Kuba Szymanski is Secretary General of the International Ship Managers’ Association. Formerly, he was a Merchant Navy officer, including Ship’s Command, as well as a Marine, Safety and Quality Superintendent. He was also a tutor at the International Business School, Isle of Man, UK, where he taught management of change, risk management, organisational waste, critical equipment and time and information management.