Who is to blame for the repeated occurrence of accidents in enclosed space?

According to the IG P&I Club, of the 83 fatalities in enclosed spaces that occurred between 2015 and 2020, 53% of the deaths were due to oxygen depletion and over 60% of the incidents were located in the cargo hold. The International Dry Bulk Terminals Group (DBTG) has had statistics of over 70 accidents during the transportation or loading of solid bulk cargoes between 1999 and April 2018. Of these, 88 people lost their lives due to asphyxiation or carbon monoxide poisoning, with 76 of them dying on ladders in the ship’s hold passages. A further nine people died in the cargo area and three died in the adjacent foredeck space. According to OSHA, 89% of confined space fatalities occur on work authorized by a supervisor and 80% of fatalities occur in locations once entered by the same person who later died.

A lot of efforts have been made by the shipping community to avoid accidents in enclosed spaces, with IMO requiring regular closed space entry drills under SOLAS Chapter 3, and a PSC CIC in 2015 by the Tokyo and Paris Memorandum specifically for closed space entry and rescue. And the results of the inspections were relatively satisfactory, e.g. The results of the Paris MOU CIC showed that seafarers generally had a good understanding of risks and procedures, scoring above 90% in most categories except for crew members’ familiarity with their duties (88%) and the absence of a manual on board (83%). Similar results were found for Tokyo MOU’s 2015 CIC.

In accident investigations, we often find that most enclosed space accidents are attributed to human error, usually the fault of the crew, but rarely do we blame shore management/supervision. With respect to closed compartments, there may also be safety hazards as follows:

Are the enclosed spaces well marked and protected?

In the eyes of the shore management, the above description of enclosed spaces should be understood by the crew. But on board, most of the people who are actually engaged in the closed spaces operation are ordinary crew members, and I’m sure they don’t know the exact rules, especially for new crew members. If the closed spaces on board are not marked with warning signs, the crew will not know which is the closed spaces, because in the crew’s concept, the closed compartments should be ballast tanks, oil tanks, void tanks, etc., which are closed for a long time and need temporary access during inspection. The crew does not have much idea about the cargo spaces, the duct keel and other compartments with square manhole cover, which are very easy to open. The above areas are very dangerous if there are no relevant warning signs.

Also mentioned in the rules, when there is no need to enter the closed spaces, the doors and hatches leading to the closed spaces should always be locked to prevent access. But at present, we are more concerned about the steps to enter the closed space and rescue procedures, few people to pay attention to the closed space marking and protection. And it is precisely because many crew members “breakthrough” the first line of defense, only to cause fatal consequences later.

I wonder if the shore personnel have paid attention to the following details during the audit and inspection/check:

• Are the ship’s self-defined enclosed compartments checked against the ship’s structure?
• Does the list of enclosed compartments on board meet the requirements?
• Are the relevant enclosed compartments marked with warnings?
• Are the enclosed compartments protected against accidental entry?

STCW Training System

Many accidents are basically due to the lack of safety awareness of crew members. We all know that crew members need to get the required certificates before they go on board, one of which is ” Basic Safety Training Certificate”, And this training included the requirements related to closed spaces. But if a crew member is on board a ship for the first time and immediately goes to work without timely familiarization training on personal safety, the risks he faces can be imagined.

The number of gas detectors equipped

A gas detector is currently required on board according to SOLAS Convention XI-1/7. (IMO Resolution A.1050(27) does not have an explicit requirement for the number of gas detectors, but does specify that testing should be conducted before personnel enter the enclosed spaces and at regular intervals thereafter until all work is completed. In addition, the resolution also requires the atmosphere of the space has been tested as appropriate with properly calibrated instruments to ascertain acceptable levels of oxygen and acceptable levels of flammable or toxic vapours;

However, different organization have given different interpretations of the above regulations.

Some ships can pass the PSC inspection with one gas detector, while some PSCOS will explicitly require two on board. However, Some P&I Clubs generally recommend 2 gas detectors be carried onboard.

For safety reasons, it is best to have 2 sets of gas detectors onboard. One point to note is that the simple multi-purpose gas detector carried by personnel entering the closed spaces cannot be used as a pre-entry gas test.

General neglect of adjacent connected spaces

We have been paying attention to the closed spaces, and the rules also mentioned some adjacent connected spaces should also be treated in accordance with the enclosed spaces, such as mooring line storage locker, paint locker, SOPEP room, CO2 room, bosun store, etc., usually these rooms are set up with ventilation fans or vent, if the crew does not understand or negligence and suddenly enter, the same will bring fatal injuries.

Other high-risk operations

Closed space is not just to enter inside for inspection only, but means to carry out a variety of high-risk operations, for example, sometimes may be accompanied by high-risk operations such as work at height, hot work, painting work, etc. Some accidents occur in the process of climbing ladders, which is also easy to ignore, So when working inside a closed spaces, in addition to paying attention to the regular risks, you have to be careful of other additional risks and take more stringent safety measures than other high-risk operations on deck in order to avoid accidents.

In addition, some ships have had accidents in which crew members were injured by falling through the manhole of the enclosed spaces, so it is also important to isolate the operation area of the enclosed spaces, and it is recommended to make special protective rails.

Enclosed space rescue

The golden time for rescue in the closed spaces is 4 minutes, according to the rules need a person on guard outside, if there is danger inside, from the beginning of the report to the rescue team gathered to rescue, how many crew members can complete the above operation within 4 minutes? This is why we see reports, as long as it is involved in closed spaces accidents, most of them are fatal cases, and there are few examples of successful rescue, even according to the Convention every two months to do the closed spaces rescue exercises. Considering the complexity of the enclosed space structure, it is questionable whether the crew will be able to assist quickly when someone collapses in the enclosed space.

Is the work permit checklist reasonable?

Many ships that have had accidents have completed the enclosed spaces entry checklists, but why did the crew not following them? The checklist recommended by IMO is more than 3 pages long. Can you imagine the crew members have to complete the enclosed space entry checklist every time he’s doing the enclosed space operation? Crew members have to complete the enclosed space entry checklist, toolbox meeting and risk assessment. All these checklists may add up to 10 pages. Perhaps some of the forms are not practical and it’s just a solution for the management to shirk the responsibility. Hence, crews are reluctant to perform.

On-shore supervision

When the shipping industry implemented 0.5% low sulfur fuel oil in 2020, many ships carried out fuel oil tank cleaning work, and this work involves a lot of closed spaces operations, why there was not much increase in accidents tat that time? This issue is worth thinking about, and I think one very important reason is that the whole industry was paying attention to this matter at that time, and the management company also paid attention to it, and naturally the crew also raised their safety awareness. Therefore, it is highly recommended to notify the company when the ship is carrying out the higher risk of closed spaces operation, which may avoid many accidents.

Who should be blamed after an accident

When an accident occurs, we can’t just complain about the lack of compliance with operating procedures on board, but can we also look for the causes of supervision ashore? For example, does the PSC inspection checklist include the contents of the enclosed spaces entry? does the Class external audit look at the marking of the enclosed spaces and the completion of the work permit? and do the IMO and the flag state consult the front-line crew when setting the rules for access to the enclosed spaces?

The above discussion is based on my practical experience, the analysis may not be correct, my purpose is to hope that we all pay serious attention to the safety hazards of closed spaces, and work together to find solutions. All rules and procedures can be better implemented only if the user recognizes its importance, which is the root of the problem.

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