ENTRY INTO DANGEROUS/ ENCLOSED SPACES Changes to UK regulations Julie Carlton Seafarer Safety and Health Manager February 2016

This presentation Current UK requirements SOLAS amendments Consultation on proposed implementation –Non-SOLAS ships

Current UK requirements Merchant Shipping (Entry into Dangerous Spaces) Regulations 1988 Code of Safe Working Practices for Merchant Seafarers Ch 15

1988 regulations Apply to all UK ships except –Fishing vessels –Pleasure craft –Offshore installations –Ships on which there is for the time being no master or crew

1988 regulations “dangerous space” means any enclosed or confined space in which it is foreseeable that the atmosphere may at some stage contain toxic or flammable gases or vapours, or be deficient in oxygen, to the extent that it may endanger the life or health of any person entering that space.”

1988 regulations All entrances to unattended dangerous spaces are secured against entry Procedures for safe entry to be laid down and observed Duties on employer, master and individuals Take full account of the principles and guidance in the CSWP

1988 regulations Drills for rescue from a dangerous space at least every 2 months Recorded in OLB –Any tanker of 500 tons and over –Any ship of 1000 tons and over

1988 regulations Where entry may be necessary, each ship must carry an oxygen meter and other suitable testing devices. Maintained in good working order, regularly serviced and calibrated according to manufacturer’s recommendations.

UK requirements - CSWP Before entry –Competent person to make an assessment –Person in charge to be appointed –Potential hazards to be identified –Space to be prepared and secured for entry –Atmosphere to be tested –Permit to work to be used –Procedures agreed

UK requirements - CSWP –How to identify potentially hazardous spaces –Carriage of O2 meters –Training and drills for safe entry as well as rescue on all ships –Limitations of EEBDs –MNTB training

European legislation Framework directive 89/391/EC –Risk assessment –Dynamic approach: procedures may become invalid over time; review, revise. Marine Equipment Directive (Directives 96/98/EC and 98/85/EC) –Testing standards for portable oxygen analysis and gas detection equipment (Annex A.1/3.30)

SOLAS amendments SOLAS Chapter 1 applies to: –All passenger ships on international voyages –All cargo ships over 500GT on international voyages Does not apply to (i) Ships of war and troopships (ii) Cargo ships of less than 500 gross tonnage (iii) Ships not propelled by mechanical means (iv) Wooden ships of primitive build (v) Pleasure yachts not engaged in trade (vi) Fishing vessels

SOLAS amendments SOLAS Reg III/19 Mandatory drills every 2 months for crew members with enclosed space entry or rescue responsibilities –Checking and use of PPE –Checking and use of communications equipment –Checking and use of atmosphere testing equipment –Checking and use of rescue equipment –First aid/resuscitation techniques

SOLAS amendments SOLAS Chapter XI-1 Reg 7 Mandatory carriage of atmosphere testing instrument(s), capable of measuring at least - –concentrations of oxygen, –flammable gases or vapours, –hydrogen sulphide and –carbon monoxide –prior to entry into enclosed spaces

UK implementation Issues to consider Government policy – no gold-plating of regulation Avoiding burdens on industry MLC obligations Coverage of existing UK regulations –Non-SOLAS ships MGN 423 – published Sept 2010 (withdrawn)

UK implementation Issues for discussion Interface with HSE Confined Spaces regulations Are exemptions from SOLAS requirements ever appropriate? from on board drills from carriage of atmosphere testing instruments? - e.g. for day vessels, equipment held ashore?

UK implementation Possible reasons for exemption [frequent returns to port]and [systems to ensure that no seafarer enters an enclosed space while at sea] [no enclosed spaces which seafarers have a foreseeable reason to enter.] [unusual patterns of operation making on-board drills impracticable]

UK implementation Non-SOLAS ships (1) Provisions for drills: –Currently required on tankers of 500GT; and other ships of 1000GT and over operating exclusively on domestic voyages Carriage of oxygen meter where risk of entry into dangerous space – all vessels

UK implementation Non-SOLAS ships (2) –Under existing legislation, the shipowner must ensure that seafarers are trained in the hazards of entry into enclosed spaces; and the procedures to be followed if entry is in exceptional circumstances required.

UK implementation: Non-SOLAS ships (3) How to proceed? We will need to cost and justify any “gold plating” Please complete Survey monkey questionnaire.

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