Safety in docks

The Management Regulations require employers to put in place arrangements to control health and safety risks. As a minimum, employers should have:

• a written health and safety policy (for employers of five or more people);
• assessments of the risks to employees, contractors, customers, partners, and any other people who could be affected by those activities – and record the significant findings in writing (for employers of five or more people). Any risk assessment must be suitable and sufficient’;
• arrangements for the effective planning, organisation, control, monitoring and review of the preventive and protective measures that come from risk assessment;
• access to competent health and safety advice;
• arrangements to provide health surveillance where appropriate;
• arrangements to provide employees with information about the risks in the workplace and how they are protected;
• arrangements to provide instruction and training for employees in how to deal with the risks;
• arrangements to provide adequate and appropriate supervision;
• arrangements to consult with employees and their representatives about the risks at work and current preventive and protective measures.

Where a confined space on a ship is involved, co-operation between the shoreside employer and master is essential to ensure that all relevant risks are managed and duties are adequately discharged.

Avoid carrying out tasks in confined spaces but, if this not possible, the risks will need to be assessed and control measures implemented.

Items to consider will include:

• testing for noxious fumes or flammable atmospheres and how these can be vented or removed;
• the risk of liquids or gases flooding in and how to stop or limit this, eg lock valves shut;
• the lack of oxygen and the need to provide breathing apparatus;
• the job being done and the equipment being used, eg welding gear that will reduce the amount of oxygen in the room, chemical cleaners that may require ventilation, gases released when disturbing residues, using appropriate electrical equipment in ignition risk areas etc;
• the person identified to do the job, eg training, physical ability, pre-existing medical conditions and any personal protective equipment (PPE) needs etc;
• the need for rescue arrangements – this should cover the necessary equipment, training and practice drills. Ensure that the equipment provided is actually suitable for the space.
• the use of permit-to-work systems – these are a formal check to ensure that all elements of the safe system of work are in place before people are allowed to enter the confined space;
• communications – ensure workers inside a confined space have a mechanism for communicating with others inside and those outside, especially if they cannot be physically monitored;

On each occasion for the same confined space the risks will need to be reassessed as things may have changed, the task and equipment being used may be different and it may not be the same person doing the work.

Making the workplace safe includes providing instructions, procedures, training and supervision to encourage people to work safely and responsibly. Even where engineering controls and safe systems of work have been applied, some hazards might remain. In these cases, employers have duties concerning the provision and use of PPE at work, and employees have a duty to use PPE correctly and in accordance with instructions.

PPE must only be used as a last resort. If PPE is still needed after implementing other controls, employers must provide this for their employees free of charge.

PPE is equipment that will protect the user against health or safety risks at work. It can include items such as life jackets, safety helmets, gloves, eye protection, high-visibility clothing, safety footwear and safety harnesses. It also includes respiratory protective equipment (RPE).

When selecting suitable PPE, consider:

• Who is exposed and to what?
• How long are they exposed for?
• How much are they exposed to?

To ensure the suitability of PPE:

• Choose products which are CE marked in accordance with the Personal Protective Equipment Regulations 2002 – suppliers can advise. If in doubt, seek further advice from a specialist adviser and explain the job to them.
• Choose equipment that suits the user – consider the size, fit and weight of the PPE and the health of the user. If the users help choose it, they will be more likely to use it.
• Make sure that if more than one item of PPE is being worn can be it used together, eg wearing safety glasses may disturb the seal of a respirator, causing air leaks.
• Instruct and train people how to use it. Explain why it is needed, when to use it, what its limitations are and know how to detect and report any faults.
• Ensure that the right replacement parts that match the original are used, eg respirator filters, and have replacement PPE available.
• Clarify who is responsible for maintenance and how it is to be done.
• Ensure PPE is properly looked after and stored when not in use. If it is reusable it must be cleaned and kept in good condition.

Never allow exemptions from wearing PPE for those jobs that only take a few minutes’.