LP 88/2016 Enclosed space entry permits still not being implemented correctly

In 2016, the SOLAS convention on enclosed space entry was amended requiring all ships to carry portable atmosphere testing equipment on board. The regulation aimed at protecting seafarers who need to enter enclosed spaces entered into force on 1st July 2016. The revised regulation requires ships to carry an appropriate portable atmosphere testing instrument or instruments, capable, as a minimum, of measuring concentrations of oxygen, flammable gases or vapours, hydrogen sulphide and carbon monoxide, prior to entering enclosed spaces.

Enclosed spaces are spaces that have limited openings for entry and exit, inadequate ventilation and are not designed to be continuously occupied. The atmosphere in any enclosed space may potentially pose a risk to life. However, despite the dangers of entering enclosed spaces, the UK Club’s Risk Assessors still find instances where proper precautions are not followed. 

The checklist for the Permit to Work should contain at a minimum the following precautions:

1. Is the Multi-gas detector supplied with tubing long enough to reach all areas of the space to be entered?

During one ship visit a Chief Officer indicated he had no tubing or pump and so lowered the detector into the compartment and listened in case an alarm sounded  - a totally unsafe practice!

2. Has the enclosed space been ventilated for at least 24 hours prior to entry? Refiling and emptying the space in the case of a ballast tank is not ventilation!

3. Has ventilation been stopped at least 10 minutes prior to initial gas testing?

4. Has an adequate risk assessment been undertaken and a pre work safety meeting been held involving all personnel?

5. Is the Self Contained Breathing Apparatus set, and a qualified stand-by person designated to be at the       entrance during entry, with adequate communication to the personnel inside the space?

6. Are all personnel to enter the space issued with a personal multi-gas alarm unit?

7. Is there proper through ventilation continuous during entry?

8.  Is there an adequate atmosphere re-testing regime during the entry period?

9.  Have all personnel involved signed the Permit to Work?

Only when all proper safety precautions have been taken should any personnel be allowed to enter an enclosed space on board.