What is an enclosed space entry?
Enclosed spaces are spaces that have limited openings for entry and exit, inadequate ventilation and are not designed for continuous worker occupancy. The atmosphere in any enclosed space may be oxygen-deficient or oxygen-enriched and/or contain flammable and/or toxic gases or vapours, thus presenting a risk to life.
According to IMO, enclosed space means a space which has any of the following characteristics:
- limited openings for entry and exit;
- inadequate ventilation; and
- is not designed for continuous worker occupancy.
Enclosed space fatalities onboard ships are a main area of concern for the industry, which is struggling to reduce casualties and keep a decent safety record.
A recent survey by InterManager representing more than 5,000 seafarers from about 250 vessels, showed that seafarers and dock workers are still dying while working in enclosed spaces onboard vessels, “because there is not enough understanding throughout the shipping industry of the risks.”
The main issues identified were lack of improvement in the design of vessels, the tight deadlines for cargo hold and tank preparation, as well as lack of training.
Did you know?
ICS has identified the following contributory factors following enclosed space accident investigations:
- Non-compliance with procedures;
- Poor supervision;
- Complacency and over familiarity leading to short cuts being taken;
- Monitoring equipment not used or not working properly; and
- Improper action in an emergency.
The above raise questions regarding the safety assurance that existing regulations provide for enclosed space entry onboard. When SAFETY4SEA asked industry experts if the industry needs more regulations on enclosed space entry, they seemed divided.
Key arguments supporting the need for more regulations referred to the lack of a unified industry standard on training for enclosed spaces, as normally such training is left to the shipping company. Additionally, the fact of the amount of lives still taken rose as an argument itself.
In a recent article written for SAFETY4SEA, Capt. Kuba Szymanski, Secretary General of InterManager, also argued that enclosed spaces do need new regulation, for example, towards the design of the enclosed spaces, and realistic requirements for the spaces in which human beings are expected to work, like entry points, emergency escape points, provisions for ventilation and atmosphere monitoring in the whole space.
On the other hand, respondents highlighted that the need for common sense and a bigger situational awareness supersedes the need for more regulations. The key challenge is for seafarers to understand the definition of an ‘enclosed space’ and comply with the existing framework.
In the same context, shipping experts on the sidelines of SAFETY4SEA Athens Forum 2019, seemed to object to the need for more regulations, when asked to share their views on the issue.
I believe that we don’t need more regulation, we need more implementation of the existent regulation. Take for example when people are dying out of drunk driving, this is not because there is no regulation against drunk driving, but it is because there is no common sense on the implementation of the regulation,
…said Yannis Botonakis, Insurance & Claims Manager, Chartworld Shipping Corp.
On his turn, Jim Allsworth, Regional Director – Claims Director, C-Solutions, agreed and emphasized the need for a proper understanding and a changing culture:
Common sense says going into an enclosed space is potentially dangerous, we shouldn’t need a regulation to tell us that. We don’t need a regulation to tell us not to put our hand on the hot plate of an oven and very few people do it because common sense is telling us not to. And then we need the training and the entire cultural change and then we won’t need regulations at all.
Additionally, Mr. Mark Bull, Director, Trafalgar Navigation underlined the need for a revision and simplification of the existing regulations, providing the example of the ISM Code. The ISM Code, as the cornerstone of shipping safety, prescribes that a company “should establish plans for key shipboard operations” and “identify potential emergency shipboard situations, and establish procedures to respond to them.”
The classic example, Mr. Bull said, is the language employed in the ISM Code, that is “grammatically terrible.”
Nobody should be issued with a non-conformity and they should not accept one, because the word “should” appears 88 times in the ISM Code. “Should” in the English language implies no obligation.
Existing regulatory framework on enclosed spaces
Regulations and guidelines on enclosed space entry have been in force since the introduction of ISGOTT in 1978, SIRE in 1993, ISM Code in 1994 and TMSA in 2004.
In 2011, the IMO Assembly adopted the Revised Recommendations for entering enclosed spaces aboard ships to encourage the adoption of safety procedures aimed at preventing casualties to ships' personnel entering enclosed spaces.
In 2015, the IMO introduced SOLAS requirements for enclosed space entry and rescue drills, and draft requirements for portable atmosphere testing.
The requirements to SOLAS Chapter III, regulation 19, mandated crew members to participate in an enclosed space entry and rescue drill onboard the ship at least once every two months.
In 2016, IMO also finalized mandatory requirements for portable atmosphere testing instruments to be carried onboard ships, under SOLAS regulation XI-1/7.
The way forward
Respondents at InterManager survey recommended changing the phrase from ‘enclosed space’ to 'dangerous space' or even 'fatal space' to hit the message home. While several such measures can be taken to ensure the way forward for more safety in enclosed space entry and while it is not guaranteed that the current regulations completely ensure safety, the above views seem to shift the interest from ‘do we need more regulation’ to ‘how can we comply with the existing regulation’.
