20 December 2018
Applicability: Bulk carriers and ships with similar hold-access arrangements
Entering confined spaces with an unsuitable atmosphere and/or attempting rescue from such spaces without proper precautions still leads to incidents in the marine industry.
Cargo hold access arrangements differ according to the extent that the access arrangements are enclosed. However, many are accessed via the upper stools through separately enclosed spaces that communicate with the holds. As a result, while the atmosphere is shared with the hold, the ventilation rates of the spaces concerned will be different.
Recently, a fatal incident highlighted the importance of robust confined space entry procedures, including atmosphere testing in each location where the atmosphere may have become contaminated by the cargo. The incident was related to a bulk carrier access, designed for trade to and from Australia, with cargo hold access ladders in compliance with AMSA Marine Order 32. The ship was fitted with an enclosed protection arrangement that does not fall within the scope of International Regulations. Plans of such arrangements may be submitted by the yard/designer directly to the relevant authority in Australia; however, different approaches to mechanical protection have been adopted in practice:
Figure: Typical examples of Australian ladders, with different arrangement for protection.
While these spaces are in direct communication with the atmosphere in the cargo holds, clearly they may not be ventilated at the same rate as the holds, even when hatch covers are opened.
SOLAS, as amended, deals with various aspects of maritime safety and contains, in parts A and B of chapter VI and part A-1 of chapter VII, the mandatory provisions governing the carriage of solid bulk cargoes and the carriage of dangerous goods in solid form in bulk, respectively.
These provisions are detailed further in the International Maritime Solid Bulk Cargoes Code (IMSBC Code), including general safety provisions related to poisoning, corrosive and asphyxiation hazards and schedules for typical cargoes shipped in bulk. They provide advice on a cargo’s properties and characteristics, including the precautions to be taken to manage associated safety hazards.
The IMSBC Code Section 3 – Safety of personnel and ship includes:
3.2.4 Prior to entry into an enclosed space aboard a ship, appropriate procedures shall be followed, taking into account the recommendations developed by the Organization (see IMO Resolution A.1050(27)). It is to be noted that, after a cargo space or tank has been tested and generally found to be safe for entry, small areas may exist where oxygen is deficient or toxic fumes are still present.
Operators are reminded that:
Before loading, it is essential to obtain current valid information from the shipper on the physical and chemical properties of the actual cargoes presented for shipment.
Safety Management Systems should consider the actual arrangements and areas of the ship when detailing requirements for ventilation, atmosphere testing, access and evacuation. They should also consider cargo spaces when carrying out the regular enclosed space entry and rescue drills required by SOLAS reg. III/19.3 (see Class News 33/2014 for details).