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Confined Space Entry Update And Safety Management

The Maritime Authorities of the Tokyo and the Paris Memorandum of Understanding (MoU) on Port state control will be launching a joint Concentrated Inspection Campaign (CIC) on Crew Familiarization for Enclosed Space Entry. The campaign will be held for three months, commencing 1 September 2015. Port state control inspectors will be using a checklist to ascertain whether crewmembers are familiar with equipment, training and whether they can identify and understand the hazards associated with entry into enclosed spaces.

Poor training, lacklustre approaches to risk assessment and broken safety management systems result in poor practice. Safety management systems should have in place a permit to work for various operations on board that present more risk than most; hot work, working aloft, working over the side of the vessel and so on. Included in this list of prepared permits to work is ‘entry into enclosed spaces’. A permit to work is not a risk assessment.

There is guidance available of how to undertake a risk assessment, but often this is misinterpreted or the person lacks a thorough understanding. ‘ALARP’ is in most cases met with blank faces. But ‘As Low As Reasonably Practicable’ is a way of conducting a good risk assessment.

The Risk Assessment guidance as stated by COSWP and Ocean Time Marine here is worth taking a look at. Entering a confined space Once the assessments have been created, covering every aspect of risk to human life and the environment; from preparation to testing, training, use of equipment, number of crew, lighting, entering, monitoring and exit and not forgetting rescue, the permit should be drawn up detailing the procedures that mitigate all perceived risks to ALARP.

A permit to work should be regarded as a live document and should be subject to scrutiny on a regular basis. They should be an agenda item for your safety meetings. Risk assessments aside, information about enclosed space entry and rescue can be disseminated in many ways around your vessel – it does not only have to be in the safety management system or Mini ISM safety management system.

Update your vessel specific SOLAS training manual with a section dedicated to entry and rescue from an enclosed space Detail the equipment that is carried for testing atmospheric conditions State where the equipment is stowed for rescue, the equipment used for safe extraction etc. Update the crew familiarisation checklist cover enclosed space entry Update the Muster list, detail certain crewmembers for enclosed space rescue Update the annual training and drill matrix / log to incorporate the frequency of drills as required by SOLAS Chapter III Reg.19

Flag administrations are acutely aware of the dangers of enclosed space entry and through the announcement of this concentrated inspection campaign some flag states are looking to include non-SOLAS yachts i.e. yachts less than 500GT that hold a mini-ISM to follow, the requirements and procedures required for SOLAS/Code compliant yachts. The Republic of the Marshall Islands Administration, for example, has released Marine Notice 7-041-1 detailing their requirements.

If you need to know more about the requirements needed for maintaining safety aboard your vessel, feel free to contact Ocean Time Marine to discuss their interactive, do-it-yourself Safety Management templates.

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