As you progress through a long career associated with superyachts, there are risks that stand the test of time and measure. None more so than the ultimate risk of entering an enclosed space – a highly hazardous activity which, unless it is taken seriously and using well assessed measures, can result in multiple fatalities.
Sadly, the constant drip of fatal accident reports is testament to this. But for you as yacht crew, entering such spaces is at times a necessary evil for the safety of the ship and the effectiveness of the yacht’s operation.
When it comes to safety and specifically the identification of risk, especially risk that just won’t go away, it’s easy to divide the yachting industry from the commercial shipping industry. But risk stalks every seafarer. The oxygen in the chain locker of a superyacht could be much lower than the oxygen in a tanker’s space. The chances of fatality are equal when entering the fresh water tank of a superyacht than that of a massive cruise ship.
In fact, one might say that tanks, especially on smaller vessels such as yachts, carry a higher risk of atmospheric danger due to the more ‘confined’ size (less air in there in the first place).
Risk knows no boundaries when it comes to private vs commercial.
In the bad old days: My first experience
I first stepped aboard a ship as cadet in November 1985. The 300-metre (984-foot) container vessel ‘Benavon’ was my induction into the industry. With no ISM code in those days, procedures were contained in basic ‘fleet regulations’, which were largely driven by the experience of the officers involved with the operation. The lack of ISM code meant these fleet regulations were taken very much as guidance and very little compliance was enforced.
The 1974 Health and Safety at Work act prompted the MCA (formerly the Marine Safety Branch of the Department of Transport) to publish the Code of Safe Working Practices (COSWP), which formed the basis of later fleet regulations. In those heady days senior officers would ‘instruct’ you how to stay safe, only pointing you towards COSWP when you asked a tricky question.
I first entered an enclosed space on my second ship – a rather aged 80,000t bulk carrier in 1986. Wearing a basic oxygen analyser alarm, we entered a wing tank that was damaged by a rather severe grounding in the river Orinoco (South America). I remember the alarm on my meter going off and as I looked down it read 17%. The chief officer, with no such alarm set of his own, instructed me to leave the space. He remained in there for some time emerging breathless, announcing he had accomplished the task of assessing the damage! Although I can vaguely remember ventilating the space, I have no recollection of the chief officer testing the atmosphere that day.
So where are we now?
So here we are, some 36 years down the line and we are still seeing new legislation with regards to entering an enclosed space. Recent re-writes of the COSWP and subsequent amendments have created stringent requirements on both testing of the atmosphere and the resultant required readings, having identified those spaces considered to be either enclosed or dangerous. As I always say, every enclosed space is a dangerous space, but not every dangerous space is enclosed. These spaces should be identified within an effective SMS, but if not then you must take time to create a list of such spaces on your yacht.
On top of existing COSWP advice and the general duties of an employer, the new 2022 enclosed space entry regulations make some very important statements and straighten out some unnecessarily misconstrued requirements:
- EVERY yacht that has enclosed or dangerous spaces must carry atmosphere testing equipment, whether such spaces are intended to be entered or not.
- The regulations apply to every yacht, commercial or other, SOLAS or Non-SOLAS, that employs workers on ships.
- It upholds the requirement for enclosed space rescue drills to be held AT LEAST every two months. This is a minimum not a maximum – practice them as often as you like.
- Personal monitoring equipment (such as the O2 alarm that I wore 36 years ago) are designed to alert the wearer to deviations from the safe atmospheric composition. They are not the testing equipment required by the regulations, nor should they be used as such. Prior to entry the atmosphere must be tested using the proper equipment. No test – no entry.
- Risk assessment of the most task-specific nature must be conducted prior to entry. It’s no use using generic assessments. Every enclosed or dangerous space on a yacht has its own lethal idiosyncrasies.
- The 2022 regulations drop ‘not normally occupied by workers’ from the definition of an enclosed space.
But is this enough?
Despite the straightforward requirements of the above regulations, COSWP and indeed IMO Resolution 1050, I feel there is one simple piece of advice that is missing. A definitive and ultimately effective requirement of the Merchant Shipping 1997 Health and Safety at Work regulations; is that you must make all seafarers aware of the risks associated with their work. A general duty of every owner, employer and master of a yacht.
It is essential that you simply make the time to take your crew aside and educate them on the risks of entering an enclosed space without conducting all the safety measures and without issuing a permit to work. You must convey that if the stringent entry procedures are not followed then the crew are at a high risk of dying. You must emphasise that this risk is even more lethal if someone has already succumbed in the space. You must stress that the risk exists on a private yacht as much as on a commercial vessel.
Laying it out as simply, and bluntly, to all will surely make every seafarer think twice before they enter.
‘You will die if you don’t follow these procedures’ – the 2022 regulations legislate this. But they cannot replace the firm/ friendly warning to a fellow seafarer, backed up by effective training and drills. Every employee on a yacht, be it the master or the deckhand, has a duty to highlight risk and to stop and report dangerous practices.
I’m lucky. As a cadet, I got away with the chief mate’s lax procedures. But as history and report after report demonstrate, getting away with it is just not good enough. Too many have died in these operations. We need to educate our workers, not just about the procedures, but about the real risk of dying if the measures required are not taken. We must ensure that our crew understand that just because one works on a superyacht, this does not eliminate the risk of enclosed space accidents.
The new regulations and other documents including a new MGN can be found on the government website.
Regardless of rank, you have the opportunity as a superyacht crew to make a huge difference by highlighting these risks, following the correct procedures and stopping fellow crew members from taking unnecessary risks with their and your life.
See the hazard, Assess the risk, Follow the correct procedure and use the appropriate Equipment.