AMENDMENTS TO SOLAS TO MANDATE ENCLOSED SPACE ENTRY AND RESCUE DRILLS

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1 E SUB-COMMITTEE ON DANGEROUS GOODS, SOLID CARGOES AND CONTAINERS 15th session Agenda item 17 DSC 15/17 6 July 2010 Original: ENGLISH AMENDMENTS TO SOLAS TO MANDATE ENCLOSED SPACE ENTRY AND RESCUE DRILLS Submitted by the Bahamas, Chile, Iran (Islamic Republic of), Vanuatu, International Association of Classification Societies (IACS) and Oil Companies International Marine Forum (OCIMF) SUMMARY Executive summary: This document proposes amendments to SOLAS for mandatory drills for enclosed space entry and rescue procedures. Two options are presented as to where the possible amendments could be inserted into SOLAS, as set out in annexes 1 and 2. Strategic direction: 5.2 and 5.4 High-level action: and Planned output: and Action to be taken: Paragraph 12 Related documents: Resolution A.864(20), SOLAS regulation III/19, SOLAS chapter XI-1, DSC 14/16/1, DSC 14/INF.9, DSC 14/22, MSC 87/24/3, MSC 87/24/15 and MSC 87 Final Report Introduction 1 This document is submitted in accordance with the provisions of paragraph 4 of MSC-MEPC.1/Circ.2, and proposes mandating shipboard training in enclosed space entry and rescue procedures. The MAIIF Report 2 The Marine Accident Investigators International Forum (MAIIF), in their document DSC 14/INF.9 (re-issued as document DSC 15/10), outlined the number of deaths and injuries reported to them since the introduction of resolution A.864(20) Recommendations for Entering Enclosed Spaces Aboard Ships. The co-sponsors are greatly concerned about this unnecessary loss of life and injuries in enclosed spaces and regard this as an unacceptable situation that demonstrates a compelling need for action. 3 MAIIF list 93 deaths and 96 injuries since 1997 suffered by seafarers entering enclosed spaces. However, it is considered that these numbers represent a significant under reporting of the situation as only the members of MAIIF submitted reports and only then for

2 Page 2 the period under review. After the Bahamas submitted its reports to MAIIF, three seafarers lost their lives after entry into an enclosed space which was assumed to have a safe atmosphere on board Bahamian registered vessels. More lives have been lost on other vessels since this time and will continue to be lost prior to this potentially hazardous situation being adequately addressed. 4 MAIIF, in document DSC 14/INF.9 (re-issued as document DSC 15/10), detailed their analysis of the root causes underpinning the accidents; these were:.1 lack of knowledge, training and understanding of the dangers of entering enclosed spaces;.2 personal Protective Equipment (PPE) or rescue equipment not being used, not available or in disrepair;.3 inadequate or non-existent signage;.4 inadequate or non-existent identification of enclosed spaces on board;.5 inadequacies in Safety Management Systems; and.6 poor management commitment and oversight. 5 As can be seen, MAIIF concluded that seafarers were not following the correct procedures and, as a direct consequence, lives were lost. The co-sponsors believe that this highlights a failure in the safety management system. It is also evidence that the advice on confined space entry contained within circular MSC-MEPC.2/Circ.3 on the basic elements of a shipboard health and safety programme has not achieved the expected level of awareness of the issues. 6 Enclosed space entry is widely believed to be an issue for the tanker industry alone. However, the MAIIF report identifies the fact that while 22 of the 93 deaths occurred on board tankers, the other 71 happened on other ship types. Furthermore, a number of the deaths on tankers occurred in non-cargo tank spaces, illustrating the fact that there is a need to raise awareness throughout the world fleet and not only in the tanker sector. Necessity for further work 7 Taking into account the findings of MAIIF, accident investigations and the discussions at various IMO meetings, it is the opinion of the co-sponsors that seafarers are inadequately prepared in enclosed space entry and rescue procedures. The co-sponsors believe that the issuance of guidance has not achieved the desired effect and, therefore, the only practical approach that can be taken is to mandate drills to ensure that all seafarers properly understand the risks and how to safely manage them. 8 In response to this concern, the Bahamas submitted document DSC 14/16/1, proposing amendments to SOLAS chapter III/19 for mandatory training for enclosed space entry and rescue procedures as a means to address the uneccessary loss of life found in this entirely routine procedure. Following discussions at DSC 14, the Sub-Committee invited the Bahamas and other interested parties to submit a proposal to MSC 87 for a new work programme item on this subject. Subsequently, the Bahamas, Vanuatu, IACS and OCIMF submitted document MSC 87/24/3. An associated document MSC 87/24/15 was also submitted by Chile, Cyprus, Iran (Islamic Republic of), Italy, the Netherlands, Panama and IPTA.

3 Page 3 Scope of the proposal 9 This document proposes amendments to SOLAS for mandatory drills, at regular intervals, in enclosed space entry and rescue procedures. The co-sponsors have set out two options as to where the amendments may be inserted into SOLAS, these are set out in annexes 1 and 2. The objective of such drills is to ensure that seafarers who may be expected to, or decide to, enter enclosed spaces are familiarized with the precautions to be taken prior to entry, and to ensure that effective rescue strategies are available in the event of an accident. Such mandatory drills would cover the following items:.1 identification of all spaces where there may be an oxygen deficient, flammable and/or toxic atmosphere, including any risks associated with the particular ship, cargo or trade;.2 entry permit procedures;.3 checking of communication procedures;.4 ventilation and practising the atmosphere testing procedures;.5 practising the procedures to be followed to effect the rescue of an incapacitated person from the enclosed space; and.6 first aid and resuscitation techniques. 10 One risk in making mandatory drills in enclosed space entry and rescue is that some may interpret this requirement literally and so expose seafarers to the risks through unnecessary enclosed space entry. To avoid such a situation, it should be expressly stated that this is not the intent and that no unnecessary enclosed space entry should be undertaken. Benefits which would accrue from the proposal 11 The co-sponsors have identified five main benefits. These being:.1 through repeated drilling the safety procedures will become ingrained into the seafarer's work culture;.2 only through repeated drilling can we remove the completely natural instinct to enter an enclosed space in order to rescue a fellow seafarer;.3 this repeated drilling will make seafarers think carefully about a space and spend time assessing the risks involved in entering it;.4 such drilling will empower junior seafarers to question unsafe practices; and.5 fewer people will lose their lives on board ship. Action requested of the Sub-Committee 12 The Sub-Committee is invited to review the proposed amendments to SOLAS and decide as appropriate. ***

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5 Annex 1, page 1 ANNEX 1 PROPOSED CHANGES TO CHAPTER III/19 In Regulation 19-3 Drills (deleted text is shown as strikethroughs and new text as underlined): Amend 3.2: Every crew member shall participate in at least one abandon ship drill, and one fire drill and one enclosed space entry drill every month. The abandon ship and fire drills of the crew shall take place within 24 h of the ship leaving port if more than 25% of the crew have not participated in abandon ship and fire drills on board that particular ship in the previous month. When a ship enters service for the first time, after modification of a major character or when a new crew is engaged, these drills shall be held before sailing. The Administration may accept other arrangements that are at least equivalent for those classes of ships for which this is impracticable. Insert new regulation: 3.5 Enclosed Space Entry Drill Enclosed space entry drills should take due account of the recommendations for enclosed space entry in resolution A.864(20) as amended Enclosed space entry drills shall be planned and conducted in a manner to ensure safety of life. There shall be no unnecessary entry into any enclosed space Each enclosed space entry drill shall include:.1 identification of all spaces where there may be an oxygen deficient, flammable and/or toxic atmosphere, including any risks associated with the particular ship, cargo or trade;.2 entry permit procedures;.3 checking of communication procedures;.4 ventilation and practicing the atmosphere testing procedures;.5 practising the procedures to be followed to effect the rescue of an incapacitated person from the enclosed space; and.6 first aid and resuscitation techniques The primary purpose of this drill is to ensure those involved in enclosed space entry receive proper training in the procedures. An Administration may allow companies operating passenger and other vessels carrying large numbers of non-marine crew an exemption from this regulation for non-marine crew, provided that those non-marine crew members are not involved in enclosed space entry. However, non-marine crew shall receive familiarization training related to and upon joining the vessel.

6 Annex 1, page The equipment used during the drills shall immediately be brought back to its fully operational condition and any faults and defects discovered during the drills shall be remedied as soon as possible. ***

7 Annex 2, page 1 ANNEX 2 PROPOSED INSERTION OF NEW REGULATION INTO CHAPTER XI/1 Regulation 6 Enclosed Space Entry Drill 1 Every crew member shall participate in at least one enclosed space entry drill at intervals not exceeding [one] month. When a ship enters service for the first time, or after modification of a major character or when a new crew is engaged, these drills shall be held before sailing. The Administration may accept other arrangements that are at least equivalent for those classes of ships for which this is impracticable. 2 Enclosed space entry drills should take due account of the recommendations for enclosed space entry in resolution A.864(20) as amended. 3 Enclosed space entry drills shall be planned and conducted in a manner to ensure safety of life. There shall be no unnecessary entry into any enclosed space. 4 Each enclosed space entry drill shall include:.1 identification of all spaces where there may be an oxygen deficient, flammable and/or toxic atmosphere, including any risks associated with the particular ship, cargo or trade;.2 entry permit procedures;.3 checking of communication procedures;.4 ventilation and practising the atmosphere testing procedures;.5 practising the procedures to be followed to effect the rescue of an incapacitated person from the enclosed space; and.6 first aid and resuscitation techniques. 5 The primary purpose of this drill is to ensure those involved in enclosed space entry receive proper training in the procedures. An Administration may allow companies operating passenger and other vessels carrying large numbers of non-marine crew an exemption from this regulation for non-marine crew, provided that those non-marine crew members are not involved in enclosed space entry. However, non-marine crew shall receive familiarization training related to 4.1 and 4.2 upon joining the vessel. 6 The equipment used during the drills shall immediately be brought back to its fully operational condition and any faults and defects discovered during the drills shall be remedied as soon as possible.