Captain John Taylor, Loss Prevention Manager at Steamship Mutual writes this risk alert concerning the fuel oil tank entry for the soon approaching IMO Sulphur cup 2020 due to the high risk associated with personnel carrying out unusual work activities as well as entering into confined spaces of fuel oil tanks.
Introduction
With the latest regulations regarding the sulphur content of fuel oils used on board vessels due to come into force on 1 January 2020 it is anticipated that there will be a significant increase in the number of fuel oil tank cleaning operations being undertaken on Members’ vessels. These tank cleaning operations will likely necessitate tank entry, an activity that many ships’ crew may not have had an opportunity to regularly participate in and with which they may not be fully familiar. In addition, many of the spaces could be very small with restricted access. It is the associated risk to personnel of unusual work activities and entry into these confined spaces that has prompted the Club to issue this Risk Alert. Furthermore, the tank cleaning activities will result in the collection of waste materials, the disposal of which will require proper consideration and compliance with International and local legislative requirements.
Background
Enclosed space entry activities are recognised as a high risk activity, the risks being elevated where the space is of a particularly confined nature with potentially limited and obstructed access and egress, compounded with the potential for slip, trip and fall hazards associated with the oil coated surfaces. Having successfully cleaned the tanks it will be necessary to ensure proper and appropriate disposal of the tank cleaning residues in accordance with the requirements of MARPOL ANNEX I, including the completion of all appropriate documentation for proper disposal at approved reception facilities.
Guidance
Specific Areas that the Club would like to highlight include:
- Following the Company SMS, including appropriate, robust enclosed space entry procedures, paying particular attention to the requirement for a detailed and thorough Risk Assessment being carried out prior to undertaking the activity.
- All appropriate permits for gas freeing and isolating of tanks must be in place. Gas testing equipment must be certificated and properly calibrated. It should be emphasised that gas testing should take due account of accessing remote areas and that personnel entering the space should each carry their own personal gas monitoring equipment.
- Special care and attention, particularly in regard to personal protective equipment and ventilation, is to be exercised when using cleaning agents and chemicals.
- Persons on stand-by duty at the entrance to the enclosed space must be appropriately trained and exercised in the actions to be taken in the event of an emergency. Under NO circumstances should a rescue attempt be made without the use of breathing apparatus. Speed of response is of CRITICAL importance
- Access and egress from bunker tanks can be very restricted, and the tanks themselves can, in some cases, be very small with limited space for persons to move around, presenting multiple trip hazards.
Due to the presence of oil covered surfaces bunker tanks will be slippery with an increased risk of slips and trips.
Some members will choose to engage specialist tank cleaning contractors to undertake the tank cleaning work. It is important that an equally high level of vigilance is exercised to ensure that the contractor is following robust enclosed space entry procedures and that adequate shipboard oversight is in place.
Above article has been initially published in Steamship Mutual’s website and is reproduced here with author’s kind permission.
The views expressed in this article are solely those of the author and do not necessarily represent those of SAFETY4SEA and are for information sharing and discussion purposes only.
About Captain John Taylor
Captain John C Taylor, Loss Prevention Manager at Steamship Insurance Management Services Ltd, has over 30 years of practical experience in the marine industry covering all aspects of Oil and Gas vessel and marine terminal facility life cycles from FEED through project execution, start up and safe efficient operation. Since 1998 his specific area of focus and expertise has been hydrocarbon marine terminal activities, including their design, construction, operation and assessment.
