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Rules of the Road: Spike in enclosed-space deaths prompts warning

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Rules of the Road: by Capt. Jake DesVergers

Many workplaces contain spaces that are considered to be “confined.” This is because their configurations hinder the activities of employees who must enter, work in, or exit from them. Examples of a confined space on board a vessel are fuel tanks, water tanks, ballast tanks, void spaces and chain lockers.

In many instances, crew who work in confined spaces also face increased risk of exposure to serious physical injury from hazards such as entrapment, engulfment and hazardous atmospheric conditions. Confinement may pose entrapment hazards, and work in confined spaces may keep crew much closer to certain hazards.

In a recent report published by the International Transport Workers Federation (ITF), a large spike in deaths in confined spaces was noted. Since January 2018, the report listed 16 dock workers (longshoremen, contractors, etc.) and 12 seafarers who died from asphyxiation and/or explosions in confined spaces or from falls after passing out because of bad air.

To give those numbers perspective, there have been a total of 145 confined-space deaths since 1999. Alarmingly, 28 of those deaths have occurred in the past 16 months. Because of this recent spike, the ITF emphasized that it is not enough for a worker to rely on opening the hatches for 30 minutes, then hoping for the best. It is imperative to do the best they can to protect themselves on their own.

It is widely recognized that maritime workers are generally aware of the risks associated with entry into confined spaces. However, they may not be aware of the details and extent of the varied dangers posed by other products. On merchant ships, these can include forest products, coal, iron ore and grains. On a yacht, many daily cleaning products, when stored in large quantities or accidentally mixed, can cause the same effect.

In November 2018, two longshoremen in Uruguay died while unloading logs from the hold of a bulk carrier. Preliminary investigation points to an unexpected fumigant in the cargo hold as the cause. A crew member saw the two men in distress and entered the hold wearing only a dust mask, determined to rescue them. During the rescue effort, his mask was reportedly removed. He passed out, but was eventually saved. However, the incident landed him in the hospital with an induced coma. A third longshoreman required medical help as well before the tragic situation was over.

For the most part, in yachting, there is not a regular need for any crew member to enter an enclosed space. This task is normally reserved for the shipyard, where the space can be properly ventilated and declared gas-free by a professional marine chemist.

In those rare situations where an enclosed-space entry is deemed necessary, a clear procedure must be followed. A sampling of the guidelines to include are:

  • Risk assessment to be carried out by a competent officer.
  • A list of work to be done in the space should be created; this helps in carrying out the work quickly and easily.
  • Potential hazards are to be identified, such as presence of toxic gases and oxygen levels.
  • Opening and securing must be done to verify if the enclosed space is pressurized or not.
  • The space must be well-ventilated before entering.
  • Space must be checked for oxygen content and other gas levels with the use of an oxygen analyzer and gas detector.
  • The oxygen content should read 21% by volume. Percentages less than that are not acceptable. More time for ventilation should be given in such circumstances.
  • Enough lighting and illumination should be present in the enclosed space before entering.
  • Permit to work must be checked and approved by the captain.
  • Duty officer is to be informed when entering/exiting the enclosed space.
  • One person always on standby outside the space to communicate with the person inside the space.

Enclosed-space entry is one of those necessary tasks that can turn very quickly from monotonous and boring to extreme and life-threatening. Always take that extra step to be careful and protect yourself.

Capt. Jake DesVergers is chief surveyor for International Yacht Bureau (yachtbureau.org). Comments are welcome below.

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2 thoughts on “Rules of the Road: Spike in enclosed-space deaths prompts warning

  1. Blair Duff

    you’re confusing Enclosed with Confined Spaces. Enclosed spaces on board ships include engine rooms, galleys, staterooms, etc and had 4 walks or bulkheads as well as a deck or floor and overhead. Whereas Confined Spaces are spaces not intended for crew members or other people unless performing a specific work task – like fuel tanks, voids, ballast tanks, sewage holding tanks. Entry in Not permitted unless testing the atmosphere for Oxygen and other potential hazards, depending on the space and the person testing must be trained and certified to do so, in the USA it’s either by a NFPA Certified Marine Chemist, the Shipyard Competent Person or occasionally by a CIH.

  2. Capt. Jake DesVergers

    This is one of those definitions that changes depending upon the regulation being sourced. Per international regulation in SOLAS, enclosed spaces are identified as cargo spaces, double bottoms, fuel tanks, chain lockers, etc. There is no differentiation to confined spaces. In contrast, per national law in the U.S. Code of Federal Regulations, the term of “enclosed space” is found in 29 CFR with a nearly identical definition to that of a “confined space” in 33 CFR.
    Regardless of the exact definition referenced, the precautions to implement are the same. And it is 100% agreed, as mentioned in the article, that tanks that carry fuel, sewage, ballast and the like, whether referred to as an enclosed space or a confined space, should never be entered until declared safe by a certified marine chemist
    Capt. Jake DesVergers
    Rules of the Road columnist

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