The Maritime & Coastguard Agency (MCA) introduced in February the merchant shipping and fishing vessels (entry into enclosed spaces) regulations 2022 (“the 2022 regulations”). The new rules come into force for ships to which the SOLAS Convention 1974 applies, on the 14 May 2022 and for other ships, including fishing vessels, on the 14 May 2023 and revoke the 1988 regulations. With a focus on industry developments and typical cases of enclosed space incidents, the Association strongly recommends Members to follow guidance of the regulations and develop suitable procedures of entry to ensure safe working practices.

I. Background

Entry into enclosed spaces is a dangerous but necessary work activity onboard ships. As such spaces exist in different areas of a vessel and the risks arising from the entry are not that tangible, incidents in enclosed spaces have been a serious problem for many years. Statistics show that if procedures not followed properly, rescue persons are also to be victims, resulting in increased fatalities. The new regulations were hence made to address industry concerns regarding the risks of enclosed space entry.

The 2022 regulations implement an amendment to the SOLAS Convention, and provide information on identification of enclosed spaces, procedures, drills, carriage of atmosphere testing equipment, use of PPE and training of seafarers for their safety awareness.

II. Identifying enclosed spaces

“Enclosed space” means a space which is not designed for continuous worker occupancy and has either or both of the following characteristics – (a) limited openings for entry and exit; (b) inadequate ventilation.

Any space on a ship can potentially be an enclosed space. The 2022 regulations provide a non-exhaustive list of enclosed space: cargo spaces, double bottoms, fuel tanks, ballast tanks, ballast water treatment rooms, cargo pump rooms, cargo compressor rooms, cofferdams, chain lockers, void spaces, duct keels, inter-barrier spaces, sewage tanks, refrigerated sea water and vivier tanks, engine crankcases, engine scavenge air receivers, CO₂ rooms, battery lockers, bait stores, fish rooms, net stores, enclosed lifeboats, slop tanks, bilges, boilers, adjacent connected spaces (e.g. cargo space, access ways, forecastle spaces, windlass switch rooms and bosun’s workshops/stores).

Awareness of potential risks is necessary for all spaces on board ship. If in any doubt, any such space should be regarded as enclosed and appropriate action taken. An enclosed space may not necessarily be enclosed on all sides, e.g., a ship hold may have open tops but the nature of the cargo makes the atmosphere in the lower hold toxic. Such places are not usually considered to be enclosed spaces, but the atmosphere may become toxic because of a change in the condition inside or in the degree of enclosure or confinement, which may occur intermittently. Personnel should also exercise caution before entering any space on board a ship that has not been opened for some time.

III. Crew awareness

The shipowner or company should provide any necessary training, instruction and information to seafarers to allow the 2022 regulations to be complied with, including but not limited to:

• recognition of the circumstances and activities likely to lead to the presence of a dangerous atmosphere;
• the hazards associated with entry into enclosed spaces, and the precautions to be taken;
• the use and maintenance of equipment and clothing required for entry into enclosed spaces; and
• instruction and drills in rescue from enclosed spaces.

The 2022 regulations require all seafarers to attend a dedicated course for entry into enclosed spaces. Even on ships where normal procedures do not require seafarers to enter into enclosed spaces, it is important that everyone onboard has the appropriate awareness of the risks and to understand the necessary precautions if entry does need to be undertaken.

IV. Systems of work

Safe systems of work should be in place for enclosed space entry, according to the new regulations, and the master of a ship must ensure that all entrances to unattended enclosed spaces on the vessel are either kept closed or otherwise secured against entry. Members are recommended to clearly assign duties and responsibilities to competent officers and establish complete systems of work.

V. Risk assessments

A risk assessment should not be limited only to entry into the enclosed space but also consider the environment and activity as a whole and any other potential safety hazards, including but not limited to low lighting and reduced visibility, trip hazards, low ceilings and narrow walkways. Any activity which may cause a change in atmosphere such as hot work and use of paints, glues and coatings poses a particular risk. An authorised officer or competent person should follow company procedures to assess the risks of enclosed spaces. The ship’s safety management system (SMS) should be referred to and a permit to work issued.

VI. Testing

The shipowner and the employer must each ensure that the ship carries appropriate portable atmosphere testing equipment that enables a seafarer to measure any concentration within that space of oxygen, flammable gases or vapours, hydrogen sulphide and carbon monoxide before any seafarer enters that space. The equipment should be maintained in good working order; and where applicable, regularly serviced and calibrated according to the manufacturer’s recommendations. Where a test is carried out, the following should be considered to ensure safety of all personnel.

• Tests should be taken at varying levels and locations within deep tanks or large spaces. Some gases and vapours are heavier than air and therefore settle at the bottom of an enclosed space, some are lighter than air and so collect at the top of the enclosed space.
• Testing must be for all the gases, not just oxygen content, and should also consider other relevant gases.
• Atmospheres can change and therefore regular testing should be undertaken throughout entry.
• Only testing can establish the air environment for what cannot be seen, tasted or smelt.
• Refer to manufacturers’ instructions for the calibration of portable testing equipment.

Additional atmosphere testing equipment should be provided where any other toxic gas is likely to be present in an enclosed space. A risk assessment should identify any gases that may be harmful that may occur in that space. Of notable risk are carbon dioxide, hydrofluorocarbons and ammonia, which are commonly used in refrigeration, and can be harmful if a leak occurs, particularly in an enclosed space.

VII. Conclusion

Despite many proactive measures taken by the shipping industry, including the guidelines and circulars issued by IMO and other organizations, injuries and fatalities continue to occur in enclosed spaces. Even with many details covered in the new rules, it is the seafarers who need to raise safe awareness and strictly implement safe working practices to ensure standard entry into enclosed spaces.

For more information, please contact Managers of the Association.