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Entering enclosed spaces:

how to survive
Captain Michael Lloyd FNI tanks. These are similar to a coal mine
with the added difficulty of an obstacle
course. They are unlit mud-covered spaces
honeycombed with steel subdivisions that
Last year (2009) the master of the Viking Islay was separate the tanks into small separate
prosecuted in Sheffield Crown Court following the deaths of compartments with often only four to five
three crew members asphyxiated in a chain locker on the feet head room - barely enough space to
turn around and each one entered through
ship in September 2007. The master of the vessel was found
holes of around 18 inches in diameter.
not guilty, but despite all the advice available, deaths in On larger vessels they can span
enclosed spaces continue to haunt the industry. hundreds of feet. Such tanks also present
the problem of rust which depletes the
Accidental death at sea is tragic, wasteful and
oxygen and not just in large ships. One 500
distressing, especially when the death could have been dwt ship took five tons of rust out of two
avoided by following the correct procedures or having the after ballast tanks while engaged in
cleaning them.
right equipment.
So much has been said about enclosed spaces that it
Equipment
would seem there is nothing left to say. Booklets, posters, Proper equipment for entering and rescue
videos, ISM procedures and safety meetings all give the from these spaces is essential. Obviously,
before entering such a space, the normal
warnings; so why are seafarers still dying?
precautions should have been taken. The
tank will have been ventilated for at least
24 hours, and all the checks will have been
he initial problem with enclosed that has less that 20.8 per cent oxygen is

T
spaces is one of definition,
coupled with the difficulty of those
on the ship in distinguishing
between shore and sea a particular
problem for those new to ships. After all,
who mentions or worries about enclosed
spaces at home?
The crew member comes from a shore-
based environment on to a ship, sails the
next day and suddenly has to think about
what spaces can and cannot be entered.
Allowance has also to be made for the
changing nature of some of the spaces. In
bad weather vents on the forecastle and
sometimes the main deck will be covered.
In this way spaces that are normally safe
and could be entered without a second
thought now become hazardous, and the
more so, depending on what is stored there
and how it affects the oxygen in the
compartment. Even the main deck
becomes an enclosed space for the
definition of gases that can escape on
some types of vessels.
The human being requires an
atmosphere of 20.8 per cent oxygen and 78
per cent nitrogen for well being. Any space
Seaways February 2010
dangerous and will be eventually fatal to
any human.
We know that most substances give off
gases of some kind: even the bulkheads of
an empty space can do so through rust and
paint; so any space that has been closed
for some time without any ventilation must
be considered dangerous.
Perhaps one day all compartments
which have no permanent natural
ventilation will be fitted with a gas
detection meter that will show the reading
from the outside in order that it can be
checked before anyone enters. Until then
we rely on a rigid risk assessment system
in place to ensure that this check is made.
The principle must be that all spaces
that have been closed for any period of
time, especially those with seals such as
tanks, stores with weather or storm doors,
are potentially dangerous.
to go through lightning holes often less
Double-bottom tanks
For those who are unfamiliar with these
spaces, all are dangerous but the most
unpleasant areas are the double bottom
made with a gas detector, which will check
for oxygen levels and gases.
Unbelievably, there are still many ships
without these, as Solas does not require
them to be carried on ships other than
tankers and chemical carriers.
The problem with this is that the
oxygen testing is done at the entrance.
What is the state of the air in the centre? It
could be said that those entering should
carry the oxygen meter with them; but they
already have a lamp and a walkie talkie to
carry and need both hands to crawl
through the lightning holes.
There are oxygen meters available that
can be wrist or hard-hat worn, giving
audio, visual and vibratory warnings.
These would solve the problem, but very
few ships have them as they are not
required by Solas.
Consideration needs to be given to the
fact that any entrants or rescuers will have
than half a metre in diameter. The only
self-contained breathing apparatus (SCBA)
sets most ships carry are designed for
fighting fires. There are SCBA sets
designed for such tight spaces but there is
15
p15-16, 21-23 Entering enclosed spaces
no Solas requirement to carry them. Thus
the SCBA set cannot be worn on the back.
So how can it be worn?
Communications rely on walkie-talkies
that function well at the entrance or on
open decks but will often deteriorate the
further into the tank the crew goes. Contact
can and does become lost, yet guidelines
incorporating dedicated communications
are available but not required.
Stretchers
Stretchers are often not designed for such
spaces and require four people to carry
them. Yet ashore there are stretchers used
by rescue organisations that can be used
in such spaces, that can be manoeuvred
through small holes and can be carried by
only two persons.
An example of these is one that for
storage and ease of transport folds in half
to fit into a back pack supplied as standard.
It can be seen from the dimensions below
that the width of the stretcher is sufficient
to be put through the average lightening
holes in a ships double bottom (DB):
G Length full: 182cm (92cm folded)
G Width: 25cm (27cm folded)
G Depth: (15cm folded)
G Weight with no accessories: 11.5kg
G Max load: 136kg.
Breathing apparatus
If the space is not easily accessible, such
as a deep tank or a double bottom, then
considerable difficulties arise. If the
situation involves a difficult access and
even more difficulty in getting the casualty
out such as through a succession of
lightening holes in a double bottom it is
essential that the casualty is supplied with
oxygen as a priority. If this cannot be
done, the time in getting the casualty out
will prove fatal.
How this can be done will depend on the
equipment there is available. Some SCBA
sets have a buddy-breathing system that
allows another face mask to be connected
to the users set. If this is not available, the
alternatives are a direct airline with mask,
or another SCBA set taken into the space
and strapped on to the casualty.
Emergency air escape systems could
also be used but the problem with these is
that they only give up to 15 minutes air
supply and it may well be that this will
again have to be renewed if the rescue is
going to take longer.
In getting the casualty out of tanks,
there are a number of problems to deal
with. If there are lightening holes to go
through, as well as ensuring that the
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22/1/10 10:14 Page 2
Feature
casualty has a constant air supply, a
minimum of two strong persons in
breathing apparatus (BA) sets will be
required to get an unconscious person
through them.
The difficulty could be increased by the
necessity of having to remove the BA sets
in order to pass through the holes. The
increased exertion will require the tanks
to supply full air and since this will be
using up the air available very quickly,
spare tanks will have to be kept ready.
Alternatively, air lines can be used
instead of SCBA sets but these carry with
them the risk of entanglement if various
obstacles have to be negotiated.
What the above shows is that the
standard BA set carried on the majority of
ships is for fighting fires, not for entering
enclosed spaces, and certainly not for
rescuing persons from them.
Compressed air lines
In spaces where it is not possible to enter
using the standard SCBA sets, there are
only two alternatives. One is to use an
SCBA set with small cylinders, which will
limit the rescue time available; the other to
use outside cylinders with breathing lines
attached.
The supply of air can either be from a
dedicated onboard air line, a compressor,
or from cylinders on a transportation
trolley. One advantage is that a number of
rescuers can use the same system,
provided there is enough air supplied.
Resuscitators
If a casualty is deep inside a double
bottom, the chances of getting him or her
out and then treating them in time are very
poor. Therefore the best method or rescue
is to treat the casualty immediately the
rescue party reaches him.
The best way to do this is with a
resuscitator. This is a quick way of getting
air to the casualty while the rescue is
being carried out. It is portable and small
enough to be placed on to a casualtys
chest on a stretcher to ensure a constant
supply of air throughout the rescue.
Lifting systems
Where a casualty has to be lifted out of a
tank, a lifting system is essential. All too
often ships are reliant on an improvised
cargo residue hoist rather than a
dedicated rescue device.
These have self-supporting anchors.
Quadpods are stronger and more versatile
than tripods. The fourth leg allows them to
straddle manholes and also gives them
more stability on a rolling deck. A typical
one is light with aluminium legs and an
SWL of around 300kg a system which
again is in standard use ashore.
I See pictures of rescue equipment, p16.
Training
Finally, and most important, on the
majority of dry cargo ships, those entering
the tanks have to rely on fellow crew
members, who have had no formal
training, to rescue them; and those
directing the attempt are also likely to
have had no formal training in enclosed
space rescue management.
The situation ashore in the UK is far
different. Realising the severe dangers of
enclosed spaces the Health and Safety
Executive passed the Confined Spaces Act
in 1997 which combined with various work
acts ensures that all shore industry with
employees entering confined spaces as a
regular part of their working practice have
training in confined space entry and
rescue: however section 2 (a) states that
these regulations shall not apply to the
master or crew of a seagoing ship or to
the employer of such persons in respect
of the normal shipboard activities
carried out solely by a ships crew
under the direction of the master.
Why was this clause allowed to be put
into the act? Regardless of the reasoning, it
is essential that this is revised before there
are more needless deaths.
In the UK there are many courses
available for occupations ashore where
personnel are working regularly with such
spaces, training in entry, rescue
management and rescue is mandatory. No
shore company would consider anyone
entering such spaces without this training
being in place.
Specific training
Although required in many industries
ashore, formal training in enclosed space
entry and rescue is as yet not required for
seafarers on ships other than tankers and
chemical carriers. Yet the Marine Accident
Investigators International Forum has
found that of the 93 such deaths that have
occurred at sea since 1997, 76 per cent of
these were on ships that were not tankers
or chemical carriers.
In their findings, which will not come as
any surprise to those at sea, they list
among the areas of concern:
I 1. Lack of knowledge, training and
understanding of the dangers of entering
enclosed spaces.
I 2. Personal protective equipment or
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Feature
rescue equipment not being used, not
available of appropriate type, improperly
used, or in disrepair.
This means that any ability and
Mines Rescue Service courses
knowledge for this has to be taught on Low risk confined space G Enter and exit confined spaces
board, often by those with no experience I Target audience safely
either. In the UK, the Mines Rescue Aimed at persons who may be lone G Prepare and use self-contained
Service specialises in training for workers. open circuit breathing apparatus in
conditions very similar to that experienced I Objectives: accordance with manufacturers
in deep and DB tanks at sea and trains G Prepare to work safely in low risk specifications
personnel for the Atomic Energy Authority. confined spaces; G Use equipment and tools safely
The composition of their courses is shown G Enter and exit confined spaces and in accordance with
in the box, on the right. safely; manufacturers specifications
G Use equipment and tools safely G Follow procedures and work
Solutions and in accordance with safely
The answers, as always, are in equipment manufacturers specifications; G Deal with emergencies
and training. Safety conscious companies G Follow procedures and work Duration: three days
will do what they can but it is always the safely;
same companies that do this while many G Deal with emergencies.
Emergency rescue and
do not. Duration: one day
Of course the ship will follow the Benefits: Ideal for lone workers. recovery of casualties from
procedures laid down in the ISM Code and Covers good practice to be followed a confined space
all the recommendations in various when planning to enter a low risk I Target Audience:
literature disseminated by concerned confined space Aimed at people who have been
bodies but is this enough? Let us pose a trained to work in high risk confined
theoretical situation where a master, Medium risk confined spaces, and who may form part of a
following these guidelines, ensures that all space team of rescue workers who may
the procedures are correctly carried out, I Target audience need to enter and assist persons to
allows a DB to be entered. All goes well Aimed at persons who may be exit the confined space in the event of
until communications cease. Is this the involved in confined spaces with an emergency.
fault of the communications equipment not difficult entry/exit, may need to use I Objectives:
being adequate from inside the tanks or monitoring equipment and escape G Prepare to work safely in confined
something else? So the emergency team breathing apparatus. spaces under emergency conditions;
are called to enter the tank. If there is only I Objectives G Enter and exit confined spaces
standard Solas equipment on board, they G Prepare to work safely in medium safely;
find it impossible to rescue the persons risk confined spaces; G Prepare and use breathing
from inside in time. G Enter and exit confined spaces apparatus in accordance with
Now, if the master knew, as he must, safely; manufacturers specifications;
that the equipment was not satisfactory to G Prepare and use escape breathing G Use rescue equipment safely and
rescue the persons, why did he allow them apparatus in accordance with in accordance with manufacturers
inside the tank? If the crew had had no manufacturers specifications; instructions;
formal training in entry or rescue, the only G Use equipment and tools safely
G Follow procedures and work
experience they have had is in the and in accordance with
occasional drill but that drill would not be safely;
manufacturers specifications;
from deep inside the tanks as they could G Deal with emergencies.
G Follow procedures and work
not enter without the correct equipment, Duration: two days
safely;
further how could they be trained in those G Deal with emergencies.
drills if those in charge had had no Duration: two days. Managing confined space
training either? Knowing that, why were I Target audience:
the crew members allowed to enter? Supervisory staff, key permit/safe
Possibly another question that should
High risk confined space
systems of work personnel or anyone
I Target audience:
be asked is why classification societies, who needs an appreciation of safe
Aimed at persons who may be
knowing of these existing problems, entry into confined spaces.
involved in confined spaces which
require an enhanced hull survey I Objectives:
involves difficult entry / exit, and
programme that forces the constant G To give candidates knowledge of
wearing of self-contained open circuit
entering of these tanks but require no risk assessments, safe systems and
breathing apparatus when work is
minimum equipment or training standards categorisation of confined spaces.
being carried out within the confined
on the ships under their classification, if
space Duration: one day.
not out of concern for the seafarers on that
I Objectives: G Mines Rescue Service:
ship, then at least in concern for their
G Prepare to work safely in high risk www.minesrescue.com/about-mines-
surveyors.
confined spaces rescue.asp
Solas governs our mandatory
equipment on our ships and STCW78/95
Seaways February 2010
21
p15-16, 21-23 Entering enclosed spaces
L Paraguard Stretcher, courtesy of L E West Ltd
L Quad Pod rescue hoist photo, courtesy of Hightec
Ltd
L Compress air breathing line photo, courtesy of
Scott Health and Safety Ltd
L Wrist gas monitor, courtesy of RKI
Instruments Ltd
L This shows an illuminated guide line with built in
dedicated communications and rechargeable battery
built into the reel, courtesy of Lifelight Ltd.
22
22/1/10 10:15 Page 4
Feature
our training. While these are essential
regulations for the well-being of ships and
their crews overall, the necessarily very
slow process of change, and in getting
consensus for this change, means that it is
beholden on individual marine authorities
to realise that these standards should be
accepted as the lowest criterion required
and that these must be enhanced by
individual national requirements where
the need is perceived.
Immediate action
With our seafarers dying like this, there
never has been a more urgent need for
immediate action. It is not that the facts
are not known. The Merchant Navy
Training Board, this Institute, the
Maritime and Coastgard Agency and many
more esteemed bodies all know the
situation, so why is it allowed to continue?
As the claimed representatives of the
merchant navy they at least should tell our
men and women at sea just why all the
industries involved in enclosed space entry
ashore are required to have the
appropriate equipment and training and
why those on the ships should not.
If these representatives choose to,
acting together, they have enough pressure
to rectify this situation and such resolve
would be far more meaningful than
printing yet another pamphlet.
As officers of the merchant navy, if we
too added our voices to the requirement to
remove this exemption, we will also be
doing our duty to our people. For those of
other nations serving on other flag ships,
you also should be demanding this
equipment and training if not in others
interests, then in your own.
As we all know, when there is an
accident, the first to be blamed is the
master and the officers, not the
organisations that allowed the state of
affairs to continue.
During the consultative period of the
1997 confined spaces legislation, 150
organisations, agencies, unions and
government departments were consulted.
Unfortunately, no Merchant Navy
consultation took place probably because
seamen were seen as being covered by the
existing shipping acts.
It is interesting to note that the docks
industry raised one concern at the
exclusion clause: that is if dock workers
were engaged in shipboard enclosed space
entry under the Merchant Shipping Act,
they would be working under a lower
standard of protection than that afforded
by the docks industry.
In the draft of these regulations, only
one person raised an objection to the
exemption, writing: Why? There have
been a number of accidents. This was
answered by the bland statement: Covered
by Marine Safety Regs.
The safety regulations they referred to
are contained in the Merchant Shipping
Act 1988 SI 1638 (Entry into dangerous
space regulations). This Act requires no
training whatsoever except in Clause 6
referring to drills. This states:
The master of:
(a) any tanker or gas carrier of 500
tons and over, and
(b) any other ship of 1000 tons and
over
shall ensure that drills simulating
the rescue of a crew member from a
dangerous space are held at intervals
not exceeding two months, and that a
record of such drills is entered in the
official log book.
Apart from the obvious realisation that
thousands of seafarers employed on
vessels under 1000 gt are not even
required to do that, it would seem that
those writing this legislation had no real
understanding of what the Merchant Navy
safety acts covered and relied on a
precedent of non-interference in shipping
by other departments of the government.
This, however, has now placed
seafarers, as pointed out by the docks
industry, at a disadvantage to those who
work ashore. In the British discrimination
laws, indirect discrimination is stated to
exist when: A working condition or rule
disadvantages one group of people more
than another. Indirect discrimination is
unlawful, whether or not it is done on
purpose.
Discrimination
Obviously no discrimination was intended
yet, if this definition of indirect discrimina-
tion stands, and it can be shown that those
ashore have better protection than those at
sea, then clearly discrimination does exist.
No company ashore would be allowed to
have a business where the employees
regularly are expected to enter deep tanks,
through difficult openings, where dangers
are known to exist without trained rescue
personnel and proper rescue equipment
being ready.
This is not about blame: if it were, then
all of us to some degree must accept a
proportion of that for acceptance of the
situation. The predicament is that there
are so many other serious problems on our
ships such as manning, safety equipment,
training and fatigue all coming to a head at
the same time. The industry could have
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Feature
dealt with these during the years of plenty
that have just passed but we did not. The

Welcome Faye
question of course is why, when we all
know the root causes of the majority of the
accidents, the collisions, the groundings
and indeed the deaths, we continue to
wring our hands, debate, issue pamphlets,
and client base. Faye is well qualified
in fact anything but actually deal with the
to help in driving this forward
heart of the situations.
and to assist in the NIs publishing,
Is there fear in the industry that stops
public relations and events
people speaking out? Certainly rumours
management activities. She will be
about losing jobs, certainly an assumed
working under the direction of
danger to career but does the reality
Bridget Hogan, Director of Publishing
support this? I cannot conceive of a
and Marketing.
responsible company so acting against
Faye worked recently for aka
those who are sincere in their efforts to
Promotions Ltd, a marketing agency
improve the safety of ships and those who
for live events and before that for the
sail on them and I do not believe that there
Royal Shakespeare Company and the
is any evidence of this.
Royal Opera House, where she
There is much we cannot change
gained her marketing skills and
without international agreement, but over
membership experience.
this issue of enclosed spaces we can
I am proud to be working at the
through our own government legislation.
NI, said Faye. I am looking forward
All it requires is for those who are able to aye Turner has joined The to developing the benefits of
bring about this change to accept the
problem and acknowledge that the time
F Nautical Institutes London
headquarters in the newly created
membership and the communication
of the Institute, which has an
has come to act, not just in our own post of Assistant Manager, Marketing impressive international reach.
country, but internationally, on behalf of and Communications. Faye will be Added Bridget: We are pleased to
all seamen. instrumental in implementing the welcome Faye, whose experience will
NIs marketing strategy, particularly add to the skills serving members.
Enclosed space and IMO in developing the use of the website Membership and book sales are
The subject of entry into enclosed spaces
and other electronic means of increasing and we need the back-up
was mentioned at the STW sub-
communication. to serve this growth as well as push
committee, however as there were no
It has been acknowledged that this forward new titles and events.
papers presented it will be placed on the
is a powerful tool in keeping in touch Growth is on the agenda for the next
agenda of the Dangerous Goods, Solid
with our international membership few years.
Cargoes and Containers sub-committee
which is meeting on the 13th 17th
September 2010 for deliberation.
This committee is the coordinating

Councils IMO Committee:

committee on the subject.
If any member has views on this
important issue, please contact John
Dickinson so that representation can be
made at the appropriate time:
the members
jmd@nautinst.org The Institutes election as a non-governmental organisation (NGO) with consultative
status has led to the setting up of an IMO Committee made up of volunteers (see
Council report, pp5-7). We were encouraged by the number (over 80) and quality of
MARINE SOFTWARE applicants and it was a hard job for the Finance and General Purposes Committee
(F&GP) to reduce the number to a shortlist of 15, from whom Council elected eight.
Marine Software programs for Navigation, AIS, The remainder of the volunteers are being formed into correspondence Advisory
Radar, Loading, Surveying, Pilotage, Tides &
Electronic Charts. For Windows PC, Psion and Groups. Some will attend relevant IMO meetings as delegates. The committee
Pocket PC computers. All at affordable prices. membership is:
All software supplied with free lifetime
worldwide support. Name Location
NEW! AIS Receivers, Transponders and PC AIS Captain Karsten Bruenings, MSc MNI (Chairman) Germany
Ship Tracker for Harbours and Onboard use.
Captain David Harrod, BA FNI (Vice Chairman) Australia
Mike Harrison MNI Professor Craig Allen, JD FNI USA
Dolphin Maritime Software Ltd
626 Alston House
Captain Paul Drouin, MNI Canada
White Cross Mr Peter Hinchliffe, OBE FNI UK
LANCASTER LA14XF, ENGLAND. Captain John Menezes, FNI India
Tel 01524 841946. Fax 01524 841946.
E-Mail: sales@dolphinmaritime.com
Mr Andrew Mitchell, MNI UK
Web Site: www.dolphinmaritime.com Captain Alex Sagaydak, FNI Ukraine

Seaways February 2010

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