We recently wrote an exclusive article for The Superyacht Group regarding the potential impact of the latest inspection regime to be implemented by the Paris MoU conglomeration of port states.
Read the article here on SuperyachtNews.com or the full unabridged version below…
31st July 2015
Written by Mark Robinson, Master Mariner & Principal Surveyor of Mark Robinson Maritime Consultants (MRMC) for The Superyacht Group.
Enclosed spaces… testing, entry and rescue – have you covered the basics?
The Maritime Authorities of the Tokyo and the Paris Memoranda of Understanding (MoU) on Port State Control will be launching a joint Concentrated Inspection Campaign (CIC) on Crew Familiarisation for Enclosed Space Entry. The campaign will be held for three months, commencing from 1st September 2015.
Port State Control inspectors will be using a 10 point check list to ascertain whether your crew members are familiar with equipment, training and whether they can identify and understand the hazards associated with entry into enclosed spaces.
But in essence it’s not just about satisfying the Authorities is it? Surely it’s about saving lives that are being needlessly cast away through poor training, lacklustre approach to risk assessment and broken safety management systems. The most tragic element of course is human emotion; your shipmate is at the bottom of a space, passed out, what do you do? Go into the space and try and rescue them of course, as this is our basic human reaction to help a fellow human being. The same fate befalls you too and so on – we are a suicide of lemmings throwing ourselves into almost certain death. This happens time and again but could be so easily avoided.
Most safety management systems have in place a permit to work for various operations onboard that present more risk than most; hot work, working aloft, working over the side of the vessel and so on. Included in this list of prepared permits to work is ‘entry into enclosed spaces’.
A permit to work is not a risk assessment.
The pre-prepared permits are an amalgamation of procedures that should be followed to safely conduct the operation. In essence, the procedures detailed should have been the product of a number of formal risk assessments.
COSWP has excellent guidance of how to undertake a risk assessment but all too many times we see that a basic understanding of what this involves is lacking. The understanding of ALARP is in most cases met with blank faces. As Low As Reasonably Practical is the bedrock of a good risk assessment. If the risk factor remains too high once procedures have been put in place to mitigate the perceived risk – think harder, involve crew members that are undertaking the operation on more frequent occasions – get their input, look outside the box. It should not be the job of the first officer or DPA to sit at the desk alone racking their brains to implement, on some occasions, non-practical seaman like procedures that are woefully burdensome or ineffectual for the user.
Once the formal assessments have been created, covering every aspect of risk to human life and the environment; from preparation to testing, training, use of equipment, number of crew, lighting, entering, monitoring and exit and not forgetting rescue, the permit should be drawn up detailing the procedures that mitigate all perceived risks to ALARP. Like a risk assessment, a permit to work should be regarded as a live document and should be subject to scrutiny on a regular basis. To underpin their importance they should be an agenda item for your safety committee meetings.
Risk assessments aside, information about enclosed space entry and rescue can be disseminated in many ways around your vessel – it does not only have to be in the safety management system or Mini ISM safety management system.
Does your vessel specific SOLAS training manual have a section dedicated to entry and rescue from an enclosed space; does it detail the equipment that is carried for testing atmospheric conditions? Does it detail where the equipment is stowed for rescue, the equipment used for safe extraction etc. Does your crew familiarisation checklist cover enclosed space entry? Is there a training session dedicated to entry into enclosed spaces for newly appointed crew members? Does your Muster list detail certain crew members for enclosed space rescue? Does your annual training and drill matrix incorporate the frequency of drills as required by SOLAS Chapter III Reg.19?
Flag Administrations are acutely aware of the dangers of enclosed space entry and through the announcement of this concentrated inspection campaign some Flag States are looking to include non-SOLAS yachts i.e. yachts less than 500GT that hold a Mini-ISM to follow as much as reasonably practical the requirements and procedures required for SOLAS/Code compliant yachts. The Republic of the Marshall Islands Administration, for example, has released Marine Notice 7-041-1 detailing their requirements.
Let’s be prepared, well trained and above all, robotic and pre-programmed in our immediate response should our fellow shipmate befall the perils and hazards associated with enclosed spaces – let’s not be Lemmings.
MRMC specialise in performing formal risk assessments to enhance safety management system and associated procedures; we undertake pre-PSC health checks ensuring that a yacht is in the best condition and compliant and meets the expectation of Flag Administrations and Port State control inspectors.
