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On 1 January 2015 amendments to SOLAS regulation III/19 Emergency training and drills entered into force, requiring that each enclosed space entry and rescue drill, which is to be conducted at two-monthly intervals, shall include checking and use of instruments for measuring the atmosphere in enclosed spaces.
So far no carriage requirements for atmosphere testing instruments for enclosed spaces are in place, but this will change in the near future. SOLAS Member States have been requested to already voluntarily implement SOLAS regulation XI-1/7, with a final entry-into-force date of this SOLAS-amendment set at 1 July 2016: Every ship is to carry at least one appropriate portable atmosphere testing instrument which as a minimum is capable of measuring concentrations of oxygen, flammable gases or vapours, hydrogen sulphide and carbon monoxide prior to entry into enclosed spaces.
The instrument that is used to test the atmosphere in an enclosed space, before entry and at appropriate intervals thereafter until all work is completed, is not a personal gas detector that is intended to be carried by an individual whilst inside the enclosed space. The instrument should be capable of remote sampling and detection for all gases that it is designed for, without interference from the atmosphere or other characteristics of the intervening space. Upon activation, the instrument should perform a self-test which indicates that the instrument is functioning correctly.
Additionally, training requirements should be considered when selecting the instrument. Any atmosphere testing should be performed by trained personnel, whom are to be aware of e.g. calibration routines, required measurement time of the instrument in function of measuring distance, etc.
An enclosed space means a space which has any of the following characteristics: limited openings for entry and exit, inadequate ventilation, and/or not designed for continuous worker occupancy. Examples include, but are not limited to: cargo spaces, double bottoms, fuel tanks, ballast tanks, cargo pump-rooms, cargo compressor rooms, cofferdams, chain lockers, void spaces, duct keels, inter-barrier spaces, boilers, engine crankcases, engine scavenge air receivers, sewage tanks, and adjacent connected space. A list should be produced on a ship-by-ship basis to identify enclosed spaces.
Shipowners and managers are advised not to await the entry-into-force of this new requirement and, if not yet available, provide the appropriate instrument on board of their vessels soonest in addition to personal gas detectors carried by individuals whilst in the enclosed space. Shipowners and managers are also reminded of the Marine Equipment Directive-certification requirements for this type of equipment. Portable oxygen analysis and gas detection equipment is listed in MED Annex A.1/3.30.
For more information, reference is made to:
- Early implementation of SOLAS Regulation XI-1/7 on atmosphere testing instrument for enclosed spaces MSC.1/Circ.1485
- Guidelines to facilitate the selection of portable atmosphere testing instruments for enclosed spaces as required by SOLAS regulation XI-1/7 MSC.1/Circ.1477
- Revised recommendations for entering enclosed spaces aboard ships Resolution A.1050(27)
Peter Bormans
Senior Specialist (ILO) at Lloyd’s Register
Above article has been initially published at Lloyd’s Register Blog and is reproduced here with author’s kind permission
