Entry into enclosed spaces onboard vessels is sometimes necessary, but it is a dangerous activity. However, new regulations designed to reduce the danger could have impacts on the operations of fishing vessels.
Any enclosed space deprived of regular and constant ventilation may become a ‘dangerous space’. Lack of oxygen or build-up of other gases means that anyone entering the space can be severely injured, and tragically, fatalities occur. Sadly, sometimes multiple fatalities occur, as other crew members rush in to save someone who has become unconscious, not realising just how dangerous the space is.
The Maritime and Coastguard Agency (MCA) is consulting on proposed regulations that would protect seafarers entering dangerous spaces onboard. Under the proposed regulations, if a fishing vessel has an enclosed space, the vessel owner would have to secure entrances to it, carry out drills and provide atmosphere-testing equipment. These are new requirements for fishers, so the MCA is asking for their views.
Entry into enclosed spaces has killed fishers, and the MCA believes that extending the regulations to fishers will provide real safety benefits. However, these regulations will also have direct and indirect costs to owners, operators and employers. Financial and/or time costs may arise from securing entry to enclosed spaces, conducting emergency drills and entering details into official logbooks, changes to onboard safety procedures and the provision of testing equipment. In order to maintain competency in using atmosphere-testing and other relevant equipment, training may also be needed.
The MCA believes that any costs are offset by the safety benefits provided, but it welcomes comments on this via the consultation.
What are enclosed spaces?
The definition in the proposed regulations of an ‘enclosed space’ means a space with any of the following characteristics:
- Has limited openings for entry and exit
- Has inadequate ventilation
- Is not designed for continuous worker occupancy.
These factors mean that this space may contain a dangerous atmosphere. Most commonly, unsafe atmospheres would have oxygen deficiency, but they could otherwise contain inert gas including nitrogen, toxic and/or flammable gases, or excess oxygen.
In addition to risks associated with the atmosphere in an enclosed space, more general health and safety risks (e.g. slips, trips and falls) can also be present. Rescuing or helping an individual whilst they are in an enclosed space can pose risks for the rescuer, which is why careful planning and the provision of appropriate equipment is especially important.
How do the proposed regulations affect fishing vessels?
The proposed Entry into Enclosed Spaces Regulations (2021) would require that:
- The vessel owner or skipper ensures that all entrances to unattended enclosed spaces are either kept closed or otherwise secured against entry, except when entry is necessary. This is to prevent entry into potentially dangerous spaces without knowing or planning accordingly.
- The vessel owner ensures that procedures for safe entry into and working in enclosed spaces are clearly laid down.
- Drills must be held on entry into enclosed spaces, and should cover the checking and use of personal protective equipment required for entry, communication equipment and procedures, atmosphere-testing equipment, rescue equipment and procedures, and instructions in first aid and resuscitation technique.
- Drills must be held at least every two months and recorded in an official logbook. Enclosed space entry incidents can be particularly tragic, as there is a risk of multiple fatalities, caused by crew members who find a casualty in an enclosed space entering that space to help without taking the proper precautions, and falling victim to the same hazard. These fatalities could perhaps be avoided if those attempting to rescue colleagues from an enclosed space were better trained and aware of the need to follow best practice and the use of atmosphere-testing equipment.
- The vessel owner must ensure that the vessel carries appropriate portable atmosphere-testing equipment which is maintained in good working order. The atmosphere-testing equipment must be capable of measuring any concentration within any enclosed space of oxygen, flammable gases or vapours, hydrogen sulphide and carbon monoxide before any seafarer enters that space. The carriage of atmosphere-testing equipment meeting international standards would ensure that seafarers were able to adequately test any enclosed space before entry, and plan their operations accordingly.
- Small vessels that have no spaces big enough for crew members to enter would not need to do anything to comply, and there is provision for exemption where this can be applied without reducing the level of safety – for example, where access to enclosed spaces is restricted to specialist shore-based personnel and/or takes place when the vessel is in drydock.
Why is the MCA tackling this issue?
The MCA must implement the International Convention for the Safety of Life at Sea (SOLAS) amendments that require ships to carry atmosphere-testing equipment and run regular enclosed spaces drills. The proposed enclosed spaces regulations therefore ensure that the UK is meeting its international obligations.
This gives the UK an opportunity to address the safety concerns, raised by the industry, relating to accidents involving entry into enclosed spaces. This is why the MCA is proposing to apply the regulations to non-SOLAS ships and fishing vessels.
According to MAIB statistics, there have been six fatalities since 2009 relating to enclosed space/confined space incidents, on both UK vessels and non-UK-flagged vessels in a UK port, with one of those fatalities onboard a UK fishing vessel. The aim of the proposed regulations is to prevent fatalities and serious injuries from occurring due to entry into enclosed spaces.
In addition to updating the regulations, the MCA is developing guidance to support safe enclosed spaces entry. Chapter 15 of the Code of Safe Working Practices for Seafarers has already been updated to reflect best practice.
The MCA hopes that the new regulations will reduce the number of lives lost to enclosed spaces entry, and looks forward to hearing the views of fishers in developing these regulations, including on any financial and/or time costs that may arise from applying them. For further information, or to respond to the consultation, go to: bit.ly/2Sqd8Dk
The consultation is open until 19 July.
Following the consultation period, the MCA will take into consideration the views put forward before implementing the regulations this autumn.
This story was taken from the latest issue of Fishing News. For more up-to-date and in-depth reports on the UK and Irish commercial fishing sector, subscribe to Fishing News here or buy the latest single issue for just £3.30 here.