TT Talk - Enclosed space risks - Mind the gap

TT Talk - Enclosed space risks - Mind the gap

The issue of enclosed space incidents on ships continues to plague the industry, involving both seafarers and shore-based workers. 

Ships at sea are governed by the International Convention for the Safety of Life at Sea (SOLAS) and are required to operate within the International Safety Management (ISM) Code that mandates the establishment of safety objectives and a Safety Management System (SMS).


Confused safety environment

When a ship arrives in port, however, there is an additional dimension, with shore workers and stevedores employed under local legislation, entering an environment whose physical attributes and safety management procedures are likely to be unfamiliar, and operating under applicable laws relating to the ship’s flag of registry.  So do the regulations on ships and ashore bridge the gap for contractors working aboard? 

“Do the regulations on ships and ashore bridge the gap for contractors working aboard?”

In one example, three stevedores boarded a ship in a European port and entered an enclosed space. There were no known hazards from the cargo, but oxygen depletion had taken place in the access space they entered, during the ship’s 40 days at sea.  The space had not been ventilated sufficiently and correct enclosed space entry procedures were not followed. The ship allowed the shore workers to enter the space without atmospheric testing, and the consequent and tragic death of all three stevedores was probably due to oxygen depletion.

The flag state report identified there was insufficient ventilation prior to entry, no enclosed space entry permit was issued, and the ship did not follow the relevant guidelines to prevent unauthorised entry.  In this case, was it a gap in the regulations between the ship and shore, insufficient training, or poor safety management systems?

Looking at the regulations affecting ships (SOLAS), the ISM Code is to ensure safety at sea, prevention of injury or loss of life, and avoidance of damage to the environment and:

  • provide for safe practices in ship operations, and a safe working environment,
  • establish safeguards against all identified risks,
  • and continuously improve safety management skills.

This is very clear with respect to the responsibilities for the ship’s personnel. For shore workers aboard, guidance for shipmasters states that contractors on ships are entitled to adequate provision against pitfalls and traps, and the Master has a common law duty to provide such protection. 

With respect to regulations ashore EU law outlines that employers’ duties include the need to:

  • Adapt the work to the individual and to technical progress
  • Avoid, evaluate & combat risks
  • Replace the dangerous by the non- or the less dangerous
  • Develop a coherent overall prevention policy
  • List accidents, and inform /consult employees

Interestingly, the employee also has a duty of care to make correct use of PPE (personal protective equipment) and inform and cooperate with the employer when presented with serious or immediate danger.

In terms of lessons that can be learned from incidents such as above, despite a ship master’s responsibility to all contractors that board his ship, shore employers and workers cannot assume there is a consistent application of the ISM Code across each flag states, and the many and diverse ship owners.


Be proactive – don’t assume

Experts affirm that the regulations may be in place, but many believe that either the current regulations are insufficient or the application of them is lacking. Delegates at two recent events (an ICHCA cargo handling conference and one convened by the international Dry Bulk Terminals Group) believed more education and training is needed, accepting that even well-trained people make mistakes. It is more than investing in a safety management system, this is about the long-term development of a safety culture, and leadership that breaks the psychology that “it will not happen to me”.

“It is more than investing in a safety management system, this is about the long-term development of a safety culture”

Ironically, the ISPS Code provides an overarching framework that brings together ship and terminal systems when managing security, but there is nothing similar for safety.  Some ships have developed a joint safety declaration, agreed and signed by terminal and ship prior to the operation, laying out the responsibilities of both parties, including the instruction that enclosed spaces are properly designated by the ship, and that no person is to enter such space without the permission of the Chief Officer and unless comprehensive ventilation and gas testing has taken place, and a permit to work has been issued. Such instructions may also include that nobody should enter a space without back-up and safety equipment standing by, together with requiring the use of a personal detector, on a pendant, allowing it to be put into the next space before entry.

Since 2016 it has also been mandatory under a new SOLAS regulation for all ships to carry portable gas detectors capable of testing for concentrations of oxygen, flammable gas, carbon monoxide, and hydrogen sulphide prior to entering enclosed spaces. Testing of the space should be carried out before any person enters, and at regular intervals thereafter until all work is completed.

Whilst this should improve the testing for the lack of oxygen in enclosed spaces and the ability to detect dangerous gasses, given the responsibility of care required in many jurisdictions to avoid, evaluate and combat risks to workers, port and stevedore employers are urged to develop their own risk assessment, gas testing and risk coding of spaces to ensure their employees may safely work on every ship they board.

“port and stevedore employers are urged to develop their own risk assessment, gas testing and risk coding of spaces to ensure their employees may safely work on every ship they board”

We gratefully acknowledge the assistance in the preparation of this article of Steve Cameron, Principle Consultant at CMR (Cameron Maritime Resources)


We hope that you have found the above interesting. If you would like further information, or have any comments, please email us, or take this opportunity to forward to any colleagues who you may feel would be interested.
We look forward to hearing from you.

Peregrine Storrs-Fox
Risk Management Director, TT Club

Through Transport Mutual Insurance Association Limited and TT Club Mutual Insurance Limited, trading as the TT Club. TT Club Mutual Insurance Limited, registered in the UK (Company number: 02657093) is authorised by the Prudential Regulation Authority and regulated in the UK by the Financial Conduct Authority and Prudential Regulation Authority. In Hong Kong, TT Club Mutual Insurance Limited is authorised and regulated by the Hong Kong Insurance Authority, in Singapore by the Monetary Authority of Singapore and in Australia by the Australian Prudential Regulation Authority. In the United States, TT Club Mutual Insurance Limited is approved as a surplus lines insurer in all states and is accessible through properly licensed surplus lines brokers. The registered offices are: 90 Fenchurch Street, London, EC3M 4ST.

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