COSWP - 14. PTW & 15. Enclosed Space Entry PDF

Particulars of interviewer Name: ………………………………………………………………………………………………… ………………………………… Rank: ………………………………………………………………………………………………… ………………………………….. 14 PERMIT TO WORK SYSTEMS 14.1 Introduction 14.1.1 Based on the findings of the risk assessment, appropriate control measures should be put in place to p...

Particulars of interviewer Name: ………………………………………………………………………………………………… ………………………………… Rank: ………………………………………………………………………………………………… ………………………………….. 14 PERMIT TO WORK SYSTEMS 14.1 Introduction 14.1.1 Based on the findings of the risk assessment, appropriate control measures should be put in place to protect those who may be affected. This chapter covers permits to work, which are formal records to confirm that control measures are in place when particular operations are being carried out. 14.1.2 In this chapter and its annexes, any reference to a ‘competent person’ means a person designated and authorised for the task covered by a permit to work under the safety management system, and ‘authorised officer’ means a person designated and authorised for the purposes of issuing and closing permits to work under the safety management system. 14.2 Permit to work systems 14.2.1 There are many types of operation on board ship when the routine actions of one person may inadvertently endanger another, or when a series of action steps needs to be taken to ensure the safety of those engaged in a specific operation. In all instances, it is necessary, before the work is done, to identify the hazards and then to ensure that they are eliminated or effectively controlled. Ultimate responsibility rests with the Company to see that this is done. 14.2.2 The permit to work system consists of an organised and predefined safety procedure. A permit to work does not in itself make the job safe, but contributes to measures for safe working. 14.2.3 The safety management system for individual ships will determine when permit to work systems should be used, and the form of the permit to work. In using a permit to work, the following principles apply: ⚫ The permit should be relevant and as accurate as possible. It should state the location and details of the work to be done, the nature and results of any preliminary tests undertaken, the measures undertaken to make the job safe and the safeguards that need to be taken during the operation. ⚫ The permit should specify the period of its validity (which should not exceed 24 hours) and any time limits applicable to the work that it authorises. ⚫ Only the work specified on the permit should be undertaken. ⚫ Before signing the permit, the authorised officer should ensure that all measures specified as necessary have in fact been taken, or procedures are in place. ⚫ The authorised officer retains responsibility for the work until they have either closed the permit or formally transferred it to another authorised officer who should be made fully conversant with the situation. Anyone who takes over from the authorised officer, either as a matter of routine or in an emergency, should sign the permit to indicate transfer of full responsibility. ⚫ The competent person responsible for carrying out the specified work should countersign the permit to indicate their understanding of the safety precautions to be observed. ⚫ On completion of the work, the competent person should notify the authorised officer and get the permit closed. ⚫ The competent person carrying out the specified work should not be the same person as the authorised officer. 14.2.4 Annex 14.1 gives examples of permits to work for various types of activity. The examples in this annex show different approaches: sections 14.1.1 and 14.1.2 show permits to work which record that safety measures have been put in place before the work commences (dangerous (enclosed) spaces and work at height); section 14.1.3 hands the site over to the competent person carrying out the work, and sets out the safety measures that need to be put in place. This second type should only be used when alternative safety procedures are in place to ensure that measures have been carried out before work begins. These examples may be adapted to the circumstances of the individual ship or the particular job to be carried out, in the light of the risk assessment. 14.3 Sanction to test systems 14.3.1 A sanction to test may be required when additional controls are needed for the testing of high-risk systems, such as high-voltage systems. Where required, a sanction to test should be issued in an identical manner to a permit to work. A sanction to test should not be issued on any apparatus on which a permit to work is still in force, or on which another sanction to test is in force. 14.3.2 A sanction to test should be issued when testing operations require the removal of the circuit main earth. Note: maintenance and repair cannot be carried out under a sanction to test. 14.3.3 Annex 14.2 gives an example of a sanction to test for testing work carried out on electrical high-voltage systems over 1000 volts. The example shows the headings for each section and each section’s requirements. These should be adapted to the circumstances of the individual ship or ship’s electrical high-voltage system, or the particular job to be carried out, in light of the risk assessment. ANNEX 14.1 PERMITS TO WORK Permits to work would normally be required for the following categories of work: ⚫ entry into dangerous (enclosed) space; ⚫ any work requiring use of gas testing/equipment; ⚫ hot work; ⚫ working at height/over the side; ⚫ general electrical (under 1000 volts); ⚫ electrical high voltage (over 1000 volts); ⚫ working on deck during adverse weather; and ⚫ lifts, lift trunks and machinery. This list is not exhaustive. Permits to work, following a similar format, may be required and developed for other categories of work. ANNEX 14.1 PERMITS TO WORK Annex 14.1.1 PERMIT TO WORK: ENTRY INTO ENCLOSED SPACES Note (i): The authorised officer should insert the appropriate details when the sections for other work or additional precautions are used. Note (ii): The competent person should tick each applicable box as they make their check. Note (iii): This permit to work contains five sections. SECTION A – Scope of work Location (name of space) ………………………………………………………………………………….……………… ……………….. Plant apparatus/identification (designation of machinery/equipment) ………………………………………………………………………………………………… …………………………………………………………. Work to be done (reason for entry) ………………………………………………………………………………………………… …………………………………………………………. Permit issued to (name of competent person carrying out work or in charge of the work party) ………………………………………………………………………………………………… …………………………………………………………. This permit is valid: from ……………………. hours Date ………………………………………………. to ………………………… hours SECTION B – Checklists Has a risk assessment been carried out for the proposed work? Y/N Has a toolbox talk been carried out? Y/N No conflict with any other permit to work in force? Y/N B1 – Pre-entry preparation To be completed by the authorised officer Checklist 1. Space thoroughly ventilated. If not, ensure that section B3 is also completed. 2. Atmosphere tested and found safe. If safe atmosphere not tested, ensure that section B3 is also completed. 3. Space secured for entry (verified all isolations, lock outs and tag outs are in place for safe entry and work). 4. Testing equipment available for regular checks while space is occupied and after breaks. Checked 5. Arrangements for ventilation for duration of permit to work. If ventilation not possible, ensure section B3 is also completed. 6. Adequate access and lighting. 7. Rescue and resuscitation equipment available at entrance. 8. Competent person in attendance at entrance. 9. Relevant officer of the watch advised of planned entry. 10. Appropriate communication arrangements agreed between attendant and those entering, including emergency signals. 11. Emergency and evacuation procedures agreed and in place. 12. All equipment to be used of appropriate type. 13. Personal protective equipment to be used: safety helmet, safety harness as necessary. B2 – Pre-entry checklist To be completed by each person entering the space Names of persons entering the space I have received instructions and authorisation from the authorised officer to enter the enclosed space. Section 1 of this permit has been completed by the authorised person. I have agreed and understand the communication procedures. I have agreed upon a reporting interval of …….. minutes. Emergency and evacuation procedures have been agreed and are understood. I have witnessed the testing of the atmosphere within the space and am satisfied it is safe to enter. I am aware that the space must be vacated immediately in the event of ventilation failure or if the atmosphere test shows a change from agreed safe criteria. Signatures of persons entering the space B3 – Breathing apparatus and other equipment To be completed by the competent person Breathing apparatus should only be used to enter unsafe spaces in cases of emergency or for the purpose of atmosphere testing. Checklist Checked 1. Those entering the space familiar with any breathing apparatus to be used 2. Breathing apparatus tested and found satisfactory 3. Means of communication tested and found satisfactory 4. Those entering wearing rescue harnesses and lifelines where practicable 5. Although the enclosed space is potentially unsafe, the adequate breathing apparatus and relevant procedures will be used to mitigate risk, and the reason for entry into the unsafe space is due to an emergency, or for essential atmosphere testing. B4 – Other work/additional precautions To be completed by the authorised officer Checklist Checked SECTION C – Certificate of checks I confirm that I am satisfied that all precautions have been taken and that safety arrangements will be maintained for the duration of the work. Competent person Name ..................................................................... Signature ................................................................ Time ................................................. Date ..................................................... I am satisfied that all precautions set out in B1 to B4 have been taken and that safety arrangements will be maintained for the duration of the work. Authorised officer Name .......................................................... Signature ...................................................................... Time ............................................................. Date ............................................................................. Note: After signing the receipt, this permit to work should be retained by the competent person in charge at the place where the work is being carried out until the work is complete and the clearance section signed. SECTION D – Personnel entry Names Time in Time out SECTION E – Cancellation of certificate The work has been completed*/cancelled* and all persons under my supervision, materials and equipment have been withdrawn. Competent person Name ........................................................ Signature .................................................................... Time ........................................................... Date ….......................................................................... * Delete words not applicable and where appropriate state: The work is complete*/incomplete* as follows: [description] ....................................................................................................................................................... ....................................................................................................................................................... ....................................................................................................................................................... ....................................................................................................................................................... ............................................ The worksite has been inspected; I accept that all persons, material and equipment have been withdrawn, and the site is secured against entry*/safe for entry*. Authorised officer Name ........................................................ .................................................................... Signature Time ........................................................... Date ............................................................................. *Delete words not applicable. Annex 14.1.2 PERMIT TO WORK: WORKING AT HEIGHT/OVER THE SIDE Note (i): The authorised officer should indicate the sections applicable by ticks in the lefthand boxes next to headings, deleting any subheading not applicable. Note (ii): The authorised officer should insert the appropriate details when the sections for other work or additional precautions are used. Note (iii): The competent person should tick each applicable right-hand box as they make their check. Note (iv): This permit to work contains four sections. SECTION A – Scope of work Location (name of space) ………………………………………………………………………………………………… …………………………………………………………. Plant apparatus/identification (designation of machinery/equipment) ………………………………………………………………………………………………… …………………………………………………………. Work to be done [description] ………………………………………………………………………………………………… …………………………………………………………. Permit issued to (name of competent person carrying out work or in charge of the work party) ………………………………………………………………………………………………… …………………………………………………………. This permit is valid: from ……………………. hours Date……………………………………………… to ………………………… hours NOTE: The validity of this permit to work should not exceed 24 hours. SECTION B – Checklists To be completed by the authorised officer (AO) and competent person (CP) B1 – Preliminary checklist Checklist Checked Checked (AO) (CP) Checked Checked (AO) (CP) Has a risk assessment been carried out for the proposed work? Has a toolbox talk been carried out? No conflict with any other permit to work in force? B2 – Preparation checklist Checklist 1. Duty officer informed 2. Warning notices posted 3. On-deck supervisor identified 4. Equipment in good order 5. Work on funnel: • • advise duty engineer; isolate whistle. 6. Work near radar scanners/radio aerials: • • isolate radar and scanner/radio room notified; notices placed to stop the use of radar/radio. 7. Work over the side: • • advise duty officer/engineer; lifebuoy and lifeline ready. 8. Personal protective equipment to be used: • • • • safety helmet; safety harness and line attached to a strong point; lifejacket; other (please list). 9. All tools to be raised and lowered secured on a lanyard/belt or in a bag. 10. Has a plan been agreed and necessary equipment been put in place to achieve an effective rescue? SECTION C – Certificate of checks I confirm that I am satisfied that all precautions have been taken and that safety arrangements will be maintained for the duration of the work and no attempt will be made by me or people under my charge to work on any other apparatus or in any other area. Competent person Name ..................................................................... Signature ................................................................ Time ...................................... ................................ Date ....................................................................... I am satisfied that all precautions have been taken and that safety arrangements will be maintained for the duration of the work and no attempt will be made by me or people under my charge to work on any other apparatus or in any other area. Authorised officer Name .............................................................. Signature ........................................................................ Time ................................................................ Date ............................................................................... Note: After signing the receipt, this permit to work should be retained by the competent person in charge at the place where the work is being carried out until work is complete and the clearance section signed. SECTION D – Cancellation of certificate The work has been completed*/cancelled* and all persons under my supervision, materials and equipment have been withdrawn and warned that it is no longer safe to work on the apparatus detailed in this permit to work. Competent person Name ............................................................ Signature ........................................................................ Time .............................................................. Date ................................................................................. * Delete words not applicable and where appropriate state: The work is complete*/incomplete* as follows: [description] (*Delete words not applicable) ....................................................................................................................................................... ....................................................................................................................................................... ....................................................................................................................................................... ....................................................................................................................................................... ............................................ The worksite has been inspected; I accept that all persons, material and equipment have been withdrawn and all persons warned that it is no longer safe to work on the apparatus detailed in this permit to work. Authorised officer Name ........................................................ Signature .................................................................... Time ........................................................... ........................................................................ Date Annex 14.1.3 PERMIT TO WORK: GENERAL VESSEL: PTW No: AREA OF VESSEL: / a 1. AUTHORISED OFFICER (AO): TIME: 1.1 WORK DESCRIPTION (Please use BLOCK CAPITALS at all times except for signatures) Category of work (delete as required): HOT WORK/DANGEROUS SPACE WORK/WORK AT HEIGHT/OVERSIDE WORK/GAS TESTING/EQUIPMENT Equipment to be worked on: COMPETENT Proposed work description: 4 PERSONS (CPs) Requested by (AO): 1 5 2 6 3 7 Signature: Company: HAS RISK ASSESSMENT OF THIS TASK BEEN CONDUCTED? YES/NO – If no, STOP THE JOB until one is provided. HAS TOOLBOX TALK BEEN CONDUCTED? HAS LOLER LIFTING PLAN BEEN CONDUCTED? YES/NO YES/NO 2. PRECAUTIONS: Delete as required. Leave applicable item clear. 2.1 GENERAL (a) Inform other personnel who may be affected YES/NO (d) Rope off area YES/NO (b) Provide additional access, lighting, ventilation YES/NO (e) Post warning signs YES/NO (c) Visit to work site required YES/NO (f) Provide radio communications YES/NO 2.2 PERSONAL PROTECTIVE EQUIPMENT REQUIRED Safety helmet Coveralls YES/NO Safety boots YES/NO Safety goggles YES/NO Gloves Other (list) YES/NO Safety harness YES/NO 2.3 HOT WORK YES/NO 2.4 ENTRY INTO DANGEROUS (ENCLOSED) SPACES (a) Fire watch required YES/NO (a) Isolate from systems YES/NO (b) Safety watch during breaks YES/NO (b) Risk of oxygen deficiency YES/NO (c) Portable extinguisher to be at site YES/NO (c) Need to wear breathing apparatus/mask YES/NO (d) Shielding to prevent spread of sparks YES/NO (d) Provide additional ventilation YES/NO 2.5 ISOLATION/ENERGY RELEASE PROTECTION (e) Provide additional lighting YES/NO If isolation is required, lock down to be confirmed by chief (f) Rescue plan provided *required* YES/NO engineer. Certificate to be provided and attached to permit to work. (g) Portable monitor in use by entry team *required* YES/NO (h) Appoint crew standby person YES/NO If third-party action, crew standby person must be additional to contractor Certificate number: ________________________ standby person. 2.6 WORKING AT HEIGHT/OVER THE SIDE Have alternative means for task been explored? YES/NO Rescue plan provided *required* Work crew at least two people *required* YES/NO Suitable bridge equipment to be locked YES/NO out Continuous comms est. with bridge YES/NO Life ring with line readily available Warning notices posted YES/NO YES/NO 2.7 CONTRACTOR CONTROL OF WORK SITE I hereby sign that I agree to take complete control of [insert work site] _____________________________ at the time of issuance of this permit to work and have satisfied myself that all required isolations are in place to secure this site. – NO CREW IS NOW TO ENTER THIS SITE. AO TO SIGN TO TAKE CONTROL OF SITE Signed (AO): __________________________________ 2.8 GAS TESTING/EQUIPMENT Vessels: Serial no. ______________ Calib. date:______________ Gas testing result: ________________________________________ If outside contractor, certificate must be attached. 2.9 ENSURE NO CONFLICT WITH ANY OTHER Completed by (AO signature): PERMIT 3. AUTHORISATION BY AO (as named in Part 1) Authority is hereby given for the work detailed in Part 1.1 to be carried out, provided the precautions in Part 2 are strictly observed. AUTHORISED BY (AO): SIGNATURE: TIME: DATE: PERMIT IS VALID FOR A PERIOD OF 12 HOURS FROM THE TIME AUTHORISED, UNLESS EXTENDED UNDER SECTION 5 4. ACCEPTANCE We accept the conditions of the permit as stated above and will inform all competent persons involved in the work of the precautions to be taken. We will display a copy of the permit at the work site at all times during the task. ACCEPTED BY CP: SIGNATURE: ACCEPTED BY AO: SIGNATURE: TIME: DATE: 5. EXTENSION (Site should be inspected prior to extension being granted) Permit must not exceed 24 hrs Signature First extension granted at: 6hrs on: Second extension granted at: 6hrs on: Ti D m at e e 6. COMPLETION (Delete as required for 6.1) 6.1 Work is complete YES/NO All tools/apparatus have been removed and secured YES/NO Site is in a safe condition YES/NO Normal operations may be resumed YES/NO Name (AO): Signature: Date: Time: 6.2 The worksite has been inspected; I accept that all equipment is operational, the site is safe, and that I take back full control of this site. CLOSED BY (AO): Signature: Date: Time: ANNEX 14.2 SANCTION TO TEST: ELECTRICAL HIGH VOLTAGE (OVER 1000 VOLTS) Note (i): The authorised officer should indicate the sections applicable by ticks in the lefthand boxes, deleting any subheading not applicable. Note (ii): The authorised officer should insert the appropriate details when the sections for other work or additional precautions are used. Note (iii): The competent person should tick each applicable right-hand box as they make their check. Note (iv): This sanction to test contains six sections. SECTION A – Scope of work Location (name of space) ………………………………………………………………………………………………… ………………… Plant apparatus/identification (designation of machinery/equipment) ………………………………………………………………………………………………… …………………………………………………………. Work to be done [description] ………………………………………………………………………………………………… …………………………………………………………. Sanction to test issued to (name of competent person carrying out work or in charge of the work party) ………………………………………………………………………………………………… …………………………………………………………. This sanction to test is valid: from ……………………. hours ………………………………… to ………………………… hours Date NOTE: The validity of this sanction to test should not exceed 24 hours. SECTION B – Checklists To be completed by the authorised officer (AO) and competent person (CP) B1 – Preliminary checklist Checklist Checked Checke (AO) d (CP) Has a risk assessment been carried out for the proposed work? Has a toolbox talk been carried out? No conflict with any other permit to work already in force? B2 – Isolation data checklist Checklist 1. The above apparatus is dead and has been isolated from the system at the following points: [description] 2. Circuit main earths have been applied to the equipment at the following points. These earths may be removed and replaced to your instructions. [description] Checked Checked (AO) (CP) 3. Safety locks [detail location fitted and identify lock set] 4. Additional precautions to avoid danger have been taken by: [description] 5. Caution/danger notices have been applied at all points of isolation as listed above and safety signs positioned as follows: 6. Presence of other hazards including list of other relevant permits to work/sanctions to test: 7. Treat all other apparatus and areas as dangerous. Further precautions: SECTION C – Certificate of checks I accept responsibility for carrying out the work on the apparatus detailed in this sanction to test and no attempt will be made by me or by persons under my charge to work on any other apparatus or in any other area. I confirm that the above equipment is dead and isolated from all live conductors and connected to earth. I am satisfied that all precautions set out in Section B have been taken and that safety arrangements will be maintained for the duration of the work. Safety key no. ………………………………………………… Received/applied* (*Delete word not applicable) Competent person Name ................................................................... Signature ................................................................. Time ............................................................... Date .............................................................................. I confirm that the above equipment is dead and isolated from all live conductors and connected to earth. I am satisfied that all precautions set out in Section B have been taken and that safety arrangements will be maintained for the duration of the work. Safety key no. ……………………………………………………….. Received/applied* (*Delete word not applicable) Authorised officer Name ................................................................... Signature ................................................................. Time ............................................................... Date .............................................................................. Note: After signing the confirmation, this sanction to test should be retained by the competent person in charge at the place where the work is being carried out until the work is complete and the clearance section signed. SECTION D – Clearance of sanction to test The work for which this sanction to test has been completed*/cancelled* and all persons under my supervision have been withdrawn and warned that it is no longer safe to work on the apparatus detailed in this sanction to test. All work materials and equipment have been removed. Competent person Name ............................................................. Signature ........................................................................ Time ............................................................... Date …............................................................................. Safety key no. ………………………………………. Received/applied* The worksite has been inspected; I accept that all persons, material and equipment have been withdrawn, and the site is secured against entry*/safe for entry*. (* Delete words not applicable.) SECTION E – Cancellation of sanction to test This sanction to test is cancelled. Authorised officer Name ............................................................ Signature ....................................................................... Time .............................................................. Date ................................................................................ Safety key no. …………………………………………………………… Received/applied* * Delete words not applicable and where appropriate state: The work is complete*/incomplete* as follows: [description] ....................................................................................................................................................... ....................................................................................................................................................... ....................................................................................................................................................... ....................................................................................................................................................... ............................................ 15 ENTERING ENCLOSED SPACES 15.1 Introduction 15.1.1 An enclosed space is one that is not designed for continuous worker occupancy and has either or both of the following characteristics: ⚫ limited openings for entry and exit; ⚫ inadequate ventilation. S.I. 2022/96 15.1.2 Any enclosed space deprived of regular and constant ventilation may become dangerous. The atmosphere in any enclosed space 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. Gases are often invisible to the human eye. 15.1.3 Some spaces may be a dangerous enclosed space only intermittently, perhaps due to the type of cargo carried or work to be undertaken, e.g. a compartment during spray painting. 15.1.4 Any enclosed space is potentially life threatening and every precaution should be taken both prior to entry and while inside. The dangers may not be readily apparent and, following testing, atmospheres can change. In addition, isolated areas with very low oxygen content or small concentrations of toxic gases may exist. N.B.: A single inhalation with a 5% oxygen content may result in instantaneous loss of consciousness and subsequent death. Similarly, small concentrations of a toxic substance may result in loss of consciousness and subsequent death. Therefore, it is essential that all necessary precautions are taken, including a risk assessment, the completion of a permit to work and frequent testing of the atmosphere when the space is entered, according to the schedule set out in the risk assessment. 15.1.5 Awareness of any risks is necessary for all spaces on board ship. If in doubt, any such space should be regarded as enclosed and appropriate action taken based on the findings of the risk assessment and appropriate control measures should be put in place to protect anyone who may enter an enclosed space. Procedures (such as systems of work, permits to work and emergency procedures) should be part of a ship’s safety management system. 15.1.6 An enclosed space may not necessarily be enclosed on all sides, e.g. ships’ holds may have open tops but the nature of the cargo makes the atmosphere in the lower hold dangerous. Such places are not usually considered to be enclosed spaces but the atmosphere may become dangerous because of a change in the condition inside or in the degree of enclosure or confinement, which may occur intermittently, e.g. in diving bells or saturation chambers. Personnel need to exercise caution before entering any space on board a ship that has not been opened for some time. Examples of such spaces include: ⚫ cargo spaces; ⚫ double bottoms; ⚫ fuel tanks; ⚫ ballast tanks; ⚫ cargo pump rooms; ⚫ cargo compressor rooms; ⚫ cofferdams; ⚫ chain lockers; ⚫ void spaces; ⚫ duct keels; ⚫ inter-barrier spaces; ⚫ sewage tanks; ⚫ boilers; ⚫ engine crankcases; ⚫ engine scavenge air receivers; ⚫ CO2 rooms; ⚫ battery lockers; ⚫ certain hold ladders enclosed in trunks; and ⚫ any spaces adjacent or connected to an enclosed space, e.g. cargo space access ways. This is not an exhaustive list, and awareness of potential risks is necessary for all spaces on board ship. If in any doubt, any such space should be regarded as potentially enclosed and appropriate action taken. 15.1.7 Enclosed spaces can change over time. Risk assessments should consider how works undertaken may change the atmosphere. Spaces connected in any way to an enclosed space can become dangerous due to the migration of gases from the enclosed space. Migration of gases from another space can also cause the enclosed space to become dangerous. Precautions must be taken where this is a possibility. 15.1.8 The possibility of leaks from one space to another should be considered in risk assessments of any space. 15.1.9 Incidents involving fumigants are likely to occur outside of the enclosed space due to gas migration. 15.1.10 Any enclosed spaces on the ship should be identified using risk assessment (carried out in accordance with Annex 1.2). A register should be made of any enclosed spaces that seafarers may enter. Throughout the assessment process, there should be an assumption that the space to be entered is hazardous until proved positively to be safe for entry. Spaces where the risk of a change in atmosphere is significant should be included on this register. 15.1.11 The register should record: ⚫ the characteristics of the space, including physical layout of the space and access and egress points; ⚫ any potential hazards; ⚫ measures to prevent entry, including locking and signage arrangements; ⚫ procedures to follow when entering, including details such as estimated time needed to ventilate the area; ⚫ information related to ventilation, including equipment and where the equipment is stored; ⚫ lighting and requirements for temporary lighting; and ⚫ requirements for atmospheric testing. Any difficulties inherent in rescue from the space should also be considered, and solutions identified, so that in the event of an emergency, the crew is in the best position to respond quickly. 15.1.12 The register should be reviewed regularly and should be available to any seafarer that may need to enter the space. The register should also be available to those ashore – for reference when considering time required for entry and repairs. 15.1.13 In addition: ⚫ if there is any unexpected reduction in or loss of the means of ventilating spaces that are usually continuously or adequately ventilated, such spaces should also be dealt with as enclosed spaces; and ⚫ when it is suspected that there could be a deficiency of oxygen in any space, or that toxic gases, vapours or fumes could be present, then such a space should be treated as enclosed. 15.1.14 Entrances to all unattended enclosed spaces on a ship should be kept locked or secured against entry. Any hatches to readily accessible enclosed spaces should be marked as the entrance to a dangerous space. When the space is open for work to be carried out, an attendant should be posted or a barrier and warning sign put in place. As far as possible, work should be arranged in such a way that no one has to enter the space. 15.1.15 Some hold ladders are enclosed in trunks that are open at the top and bottom. These are connected to the hold space and will share any hazardous atmosphere within the parent space. Hazardous atmosphere can be trapped in these spaces, which may not be adequately ventilated when hatches are opened. Such spaces should remain secured until atmosphere testing of the space has taken place. 15.1.16 All crew should be given on-board training and familiarisation with the risks of entry into dangerous spaces on board. Training should include as a minimum: ⚫ the vessel’s register of enclosed spaces; ⚫ identification of the hazards likely to be faced during entry into enclosed spaces; ⚫ any steps taken to reduce those hazards to an acceptable level; ⚫ knowledge of the procedures for assessment of the space; ⚫ knowledge of how to test the atmosphere of an enclosed space (where responsibilities require this); ⚫ knowledge of the procedures for safe entry; and ⚫ recognition of the signs of adverse health effects caused by exposure to hazards during entry. 15.2 Duties and responsibilities of a competent person and an authorised officer 15.2.1 A competent person means a person with sufficient theoretical knowledge and practical experience to make an informed assessment of the likelihood of a dangerous atmosphere being present or subsequently arising in the space, including taking measurements of the atmosphere. IMO Resolution A.1050(27) 15.2.2 An authorised officer means a person authorised to permit entry into an enclosed space and with sufficient knowledge of control and elimination of hazards, and of the procedures to be established and complied with on board, to be able to ensure that the space is safe for entry. (For further details on the role of an authorised officer, see Chapter 14, in which International Maritime Organization (IMO) Resolution A.1050(27) refers to this person as the ‘responsible person’.) 15.2.3 On the basis of their risk assessment, the authorised officer should decide the procedures to be followed for entry into a potentially dangerous space. These will depend on whether the assessment shows that: ⚫ there is minimal risk to the life or health of a person entering the space then or at any future time; ⚫ there is no immediate risk to health and life but a risk could arise during the course of work in the space; or ⚫ the risk to life or health is immediate. 15.2.4 Where the assessment shows that there is no immediate risk to health or life but that a risk could arise during the course of the work in the space, the precautions described in sections 15.3 to 15.10 should be taken as appropriate. 15.2.5 Where the risk to health or life is immediate, then the additional requirements specified in section 15.11 are necessary. 15.2.6 On vessels where seafarers are never expected to enter an enclosed space, or no accessible enclosed spaces exist, some of the recommendations of this chapter may not apply; e.g. the requirement to have atmosphere-testing equipment on board the ship at all times, and the requirement for entry drills. However, all seafarers should have on-board training to help them recognise the risks from enclosed spaces and to familiarise them with any applicable procedures. When the competent person and authorised officer are shore-based personnel, no entry into a potentially dangerous space should be permitted until such suitably competent persons are present. 15.2.7 When non-ship staff (i.e. shore-side personnel)are contracted to enter an enclosed space on a ship in a UK port, the requirements of the Confined Spaces Regulations 1997 apply. While the master retains overall authority for any activity on board their ship, the employer of the shore-side team is responsible to ensure compliance with the Confined Spaces Regulations 1997. The Company should satisfy themselves that the shore-side personnel have sufficient training, equipment and arrangements for rescue in accordance with the Confined Spaces Regulations 1997, Approved Code of Practice, or suitable equivalent arrangements. Once a permit to work has been issued, the shore-side personnel should take responsibility for the operation and for rescue arrangements. It is not sufficient to rely on emergency services for rescue arrangements, although they should still be notified in the event of any such emergency; nor should the ship’s crew be designated to provide back-up support. 15.3 Precautions before entering an enclosed space 15.3.1 The following precautions should be taken, before any potentially enclosed space is entered, so as to make the space safe for entry without breathing apparatus and to ensure it remains safe whilst persons are within the space. ⚫ A competent person should review the ship’s register of enclosed spaces. If the register needs to be amended, the designated person ashore (DPA) should be informed. ⚫ A competent person should make an assessment of the space and an authorised officer to take charge of the operation should be appointed, see section 15.2. ⚫ The potential hazards should be identified – see section 15.4. ⚫ The space should be prepared, vented and secured for entry – see section 15.5. ⚫ The atmosphere of the space should be tested – see section 15.6. ⚫ A permit to work system that includes a record of the gas measurements should be used. ⚫ Procedures for preparation and entry should be agreed– see sections 15.8 and 15.9. ⚫ Emergency procedures should be in place. 15.3.2 When the procedures listed in the previous paragraph have been followed and it has been established that the atmosphere in the space is or could be unsafe, then the additional requirements (including the use of breathing apparatus appropriate to the type and size of the space), as specified in section 15.11 should also be followed. 15.3.3 In addition to pre-entry testing of the atmosphere, it is recommended that any person entering a potentially enclosed space should wear a personal atmosphere-monitoring device (‘multimeter’) capable of detecting oxygen deficiency, carbon monoxide, toxic gases and explosive atmospheres. It is important to recognise that carrying a personal atmosphere monitor is no substitute for pre-entry testing. 15.4 Identifying potential hazards 15.4.1 In carrying out their assessment, the competent person must take into account any cargo previously carried in the space, ventilation, the coating of the space, the degree of corrosion and any other relevant factors. The factors affecting adjacent spaces may be different from those affecting the space to be entered, but may affect the atmosphere in the space to be entered. Oxygen deficiency 15.4.2 If an empty tank or other confined space has been closed for a time, the oxygen content may have been reduced for a number of reasons. 15.4.3 The following are examples only: ⚫ Rusting may have occurred due to oxygen combining with steel. ⚫ Oxygen-absorbing chemicals may have been present. ⚫ Oxygen-absorbing cargoes may have been carried, including: – grain, grain products and residues from grain processing (such as bran, crushed grain, crushed malt or meal) hops, malt husks and spent malt; – oilseeds, products from oil seeds (such as seed expellers, seed cake, oil cake and meal); – copra; – wood in such forms as packaged timber, round wood logs, pulpwood, props (pit props and other prop-wood) woodchips, wood-shavings, wood pellets and sawdust; – jute, hemp, flax, sisal, kapok, cotton and other vegetable fibres, empty bags, cotton waste, animal fibres, animal and vegetable fabric, wool waste and rags; – fish, fishmeal and fish-scrap; – guano; – sulphidic ores and ore concentrates; – charcoal, coal lignite and coal products; – direct reduced iron (DRI); – dry ice; – metal wastes and chops, iron swarf, steel and other turnings, borings, drillings, shavings, filings and cuttings; and – scrap metal. ⚫ Gases from volatile cargoes may have displaced the oxygen in tanks. ⚫ Hydrogen may have been produced in a cathodically protected cargo tank used for ballast. ⚫ Oxygen may have been displaced by the use of carbon dioxide or other fire-extinguishing or preventing media, or inert gas in the tanks or inter-barrier spaces of tankers or gas carriers. ⚫ Nitrogen or another inert gas may have been used to purge tanks. Oxygen-enriched atmosphere 15.4.4 This may arise from: ⚫ leaks from damaged or poorly maintained hoses, pipes and valves; ⚫ leaks from poor connections; ⚫ opening valves deliberately or accidentally; ⚫ not closing valves properly after use; ⚫ using an excess of oxygen in welding, flame cutting or a similar process; or ⚫ poor ventilation where oxygen is being used. Because oxygen is odourless, colourless and tasteless, an oxygen-enhanced atmosphere cannot be easily detected by human senses. However, because oxygen aids combustion, even a small increase in the concentration of oxygen in the air produces an increased risk of fire – including spontaneous combustion – or explosion. Toxicity of oil 15.4.5 Hydrocarbon gases are flammable as well as toxic and may be present in fuel or cargo tanks that have contained crude oil or its products. 15.4.6 Hydrocarbon gases or vapours may also be present in pump rooms and cofferdams, duct keels or other spaces adjacent to cargo tanks due to the leakage of cargo. 15.4.7 The components in the vapour of some bunker oils and oil cargoes, such as benzene and hydrogen sulphide, are very toxic. Toxicity of other substances 15.4.8 As appropriate, seafarers should understand the properties and hazards of relevant gases and the mitigation measures required. 15.4.9 Some of the cargoes carried in bulk, liquid, gas or packaged form may be toxic or liable to emit toxic gas; appropriate testing for toxic gas should be carried out as per 15.6.12. 15.4.10 There is the possibility of leakage from drums of chemicals or other packages of dangerous goods where there has been mishandling, incorrect stowage, or damage due to heavy weather. 15.4.11 Inert gas does not support life. In addition, trace components that are often present in the inert gas, such as carbon monoxide, sulphur dioxide, nitric oxide and nitrogen dioxide, are very toxic. 15.4.12 The interaction of vegetable or animal oils, sewage or slops from drilling operations with sea water may lead to the release of hydrogen sulphide, which is very toxic. 15.4.13 Hydrogen sulphide or other toxic gases may be generated where the residue of grain or similar cargoes permeates into or chokes bilge-pumping systems. 15.4.14 The chemical cleaning, painting or repair of tank coatings may involve the release of solvent vapours. 15.4.15 Fumigants may have been used on cargoes in the space (see section 21.7). Flammability 15.4.16 Flammable vapours may still be present in any tanks that have contained oil products or chemical or gas cargoes. 15.4.17 Cofferdams, fuel treatment and processing rooms, and other spaces that are adjacent to tanks, may contain flammable vapours, should there have been leakage into the space. Other hazards 15.4.18 Although the inhalation of contaminated air is the most likely route through which harmful substances enter the body, some chemicals can be absorbed through the skin. 15.4.19 Some of the cargoes in bulk, liquid, gas or packaged form are irritants or corrosive if permitted to come into contact with skin; appropriate testing should be carried out as per 15.6.11. 15.4.20 Disturbance of rust, scale or sludge residues of cargoes of animal, vegetable or mineral origin, or of water that could be covering such substances, may lead to the release of toxic or flammable gases. 15.5 Preparing and securing the space for entry 15.5.1 Prior to opening the entrance to an enclosed space, the space should be depressurised. Precautions should be taken in case pressurised or unpressurised vapour or gases are released from it. The space should be thoroughly ventilated, preferably by mechanical means or by natural means, and then tested (see section 15.6) to ensure that all harmful gases have been removed and no pockets of oxygen-deficient atmosphere remain. Any vented gases should be discharged away from the area, thereby not contaminating the immediate area of the entry point to the space or other spaces. 15.5.2 The space should be isolated and secured against the ingress of dangerous substances by blanking off pipelines or other openings and by closing and securing valves, in accordance with the risk assessment and on-board procedures. The valves should be secured in the closed position, or some other means used to indicate that they are not to be opened. Remoteoperated valves should, where practicable, have their remote actuators inhibited with notices placed locally and on the relevant controls. The officer on watch should be informed. 15.5.3 Where necessary, any sludge, scale or other deposit liable to give off fumes should be cleaned out. This may in itself lead to the release of gases, and precautions should be taken (see section 15.11). 15.5.4 Compressed oxygen should not be used to ventilate any space. 15.5.5 When appropriate, pumping operations or cargo movements should be suspended when entry is being made into an enclosed space. 15.6 Testing the atmosphere of the space 15.6.1 From May 2022, ships to which The Merchant Shipping and Fishing Vessels (Entry into Enclosed Spaces) Regulations 2022 apply are required to carry atmosphere-testing equipment. This must be capable of measuring concentrations of oxygen, flammable gases or vapours, hydrogen sulphide and carbon monoxide before any person enters the space. S.I. 2022/96 15.6.2 Atmosphere testing equipment should have clearly defined calibration procedures included within the manufacturer’s instructions. Where the operation of the ship permits access more frequently than the manufacturer’s recommended calibration renewal period (e.g. ferry services), the calibration equipment may be kept ashore, and arrangements for calibration should be clear from the ship’s SMS. Otherwise, calibration equipment should be carried on board. MSC.1/Circ.1477 15.6.3 Testing should be carried out by remote means before entry and at regular intervals thereafter. Testing of a space should be carried out using properly calibrated and maintained equipment, and only by competent persons trained in the use of the equipment. 15.6.4 If testing by remote means is not possible (e.g. where remote double-bottom tanks have to be entered), it should be assumed that the atmosphere is hazardous until proven otherwise. The person selected to enter the space to test the atmosphere should only do so in accordance with the additional precautions specified in section 15.11, which include the wearing of breathing apparatus. Testing of any space should be carried out at different levels. 15.6.5 Personal monitoring equipment is designed for personal use only and to provide a warning against oxygen deficiency, toxic gases and explosive atmospheres whilst the wearer is in the space. This equipment should not be used as a means of determining whether an enclosed space is safe prior to entry, unless the specific equipment has the necessary certified/approved additional capability to conduct remote readings (i.e. pumped capability). 15.6.6 Personal monitoring equipment that has been designed and has the certified/approved capability to remote sense, by the addition of a length of sample hose and provision of either an electronic external or internal air pump to draw a sample of the atmosphere over the sensors, is acceptable as long as it is used with the additional equipment for remote sensing. The risk assessment should take account of the size and shape of the space, the reach of the remote sensor and the ability to thoroughly test the atmosphere throughout the space. Testing for oxygen deficiency 15.6.7 The normal level of oxygen in the atmosphere is 20.8%. Any variation from that may indicate a problem and should be investigated further. For example, when the oxygen reading is 20%, consideration should be given to further testing for toxic gases, where appropriate, because toxic gases may have displaced some oxygen (see section 15.6.12). Once other risks are discounted, a steady reading of at least 20% oxygen by volume should be obtained before entry is permitted. Minor changes in temperature, pressure, condition of the cargo used and other conditions can influence the speed of oxygen depletion, so the atmosphere should be tested regularly when enclosed spaces are opened. 15.6.8 A combustible gas indicator cannot be used to detect oxygen deficiency. Testing for flammable gases and vapours 15.6.9 The combustible gas element of the detector detects the amount of flammable gas or vapour in the air. An instrument capable of providing an accurate reading at low concentrations should be used to judge whether the atmosphere is safe for entry. 15.6.10 The combustible gas element of the detector is calibrated on a standard gas. When testing for other gases and vapours, reference should be made to the calibration curves supplied with the instrument. Particular care is required should accumulations of hydrogen and methane be suspected, because high levels may affect the accuracy of the device. 15.6.11 In deciding whether the atmosphere is safe to work in, a ‘nil’ reading on a suitably sensitive combustible gas indicator is desirable but, where the readings have been steady for some time, up to 1% of the lower flammable limit may be accepted, e.g. for hydrocarbons in conjunction with an oxygen reading of at least 20% by volume. Testing for toxic gases 15.6.12 The presence of certain gases and vapours requires specialised equipment and trained personnel to undertake accurate and reliable testing. If this equipment is not available for use, the period of gas freeing should be considerably extended. Where measurement can be carried out, the readings obtained by this equipment should be compared with the workplace exposure limit (WEL) for the contaminant given in the latest edition of the Health and Safety Executive (HSE) Guidance Note EH40, which can be found on the HSE website. (Workplace exposure limits are sometimes known as occupational exposure limits (OELs) and are given in international industry safety guides.) Workplace exposure limits provide guidance for the level of exposure to toxic substances. Entry should not be authorised if the atmosphere measures over 50% of the WEL. However, it is necessary to know for which chemical a test is being made in order to use the equipment correctly, and it is important to note that not all chemicals may be tested by these means. Tests for specific toxic contaminants, such as benzene or hydrogen sulphide, should be undertaken depending on the nature of the previous contents of the space. The safety data sheets for previous cargoes or fuel carried should be referred to. IMO Resolution A.1050(27) Summary 15.6.13 In all spaces, the following conditions should be tested as a minimum. Entry should not be permitted, and personnel should not remain in an enclosed space (unless in an emergency, see section 15.11), until the following readings are obtained. The following four conditions should be tested as a minimum in all spaces. Oxygen (O2) content At least 20% by volume Flammable gas content Nil NB: where readings have been steady for some time, up to 1% of the lower flammable limit (LFL) may be acceptable in conjunction with a 20% oxygen level Carbon monoxide (CO) Content is less than: 100 ppm short-term exposure limit (STEL): maximum exposure is 15 minutes* 20 ppm time weighted: maximum exposure is 8 hours* Hydrogen sulphide Content is less than: 10 ppm STEL: maximum exposure is 15 minutes* 5 ppm time weighted: maximum exposure is 8 hours* Toxic gases Less than 50% of the WEL* * Current limits within EH40 as of August 2020. 15.6.14 When a toxic chemical is encountered for which there is no means of testing, then the additional requirements specified in section 15.11 should also be followed. 15.6.15 If a separate combustible gas indicator is used, this is not suitable for measuring levels of gas at or around its workplace exposure limit, where there is solely a toxic, rather than a flammable, risk. This level will be much lower than the flammable limit, and the indicator may not be sufficiently sensitive to give accurate readings. 15.7 Use of control systems 15.7.1 Entry into an enclosed space should be planned in advance and use should be made of a permit to work system. Details of the arrangements to be followed in a permit to work system are described in Chapter 14, Permit to work systems (a sample permit to work can be found in Annex 14.1). 15.7.2 For situations for which a well-established safe system of work exists, a checklist may exceptionally be accepted as an alternative to a full permit to work, provided that the principles of the permit to work system are covered and the risks arising in the enclosed space are low. 15.7.3 No person should enter an enclosed space unless authorised to do so by an authorised officer. Only the minimum number of trained personnel required to do the work should be authorised to enter. Those entering must be wearing appropriate clothing. All equipment used must be in good working condition and inspected before use. 15.8 Safety precautions before entry 15.8.1 The space and its access areas should be adequately illuminated. 15.8.2 No source of ignition should be taken or put into the space unless the authorised officer is satisfied that it is safe to do so. 15.8.3 A rescue plan should be in place (see section 15.14). In all cases, rescue and resuscitation equipment should be positioned ready for use at the entrance to the space. A risk assessment should identify what rescue equipment may be required for the particular circumstances but, as a minimum, this should include: ⚫ appropriate breathing apparatus, with fully charged spare cylinders of air; ⚫ lifelines and rescue harnesses; ⚫ torches or a lamp (approved for use in a flammable atmosphere, if appropriate); and ⚫ a means of hoisting an incapacitated person from the confined space, if appropriate. 15.8.4 Breathing equipment may be bulky and limit movement in the space. Before entry is permitted, it should be established that entry with breathing apparatus is possible. Any difficulty of movement within any part of the space, or any problems if any incapacitated person had to be removed from the space (as a result of breathing apparatus or lifelines or rescue harnesses being used), should be considered