CHIEF ENGINEER Unit 10 Code of Safe Working Practice Q2

The Code of Safe Working Practices for Merchant Seafarers (COSWP) provides comprehensive guidance on dangerous (enclosed) spaces. According to the COSWP, a dangerous enclosed space is any enclosed or partially enclosed space onboard a ship that:

• Has limited openings for entry and exit.
• Is not designed for continuous human occupancy.
• May have a dangerous atmosphere due to:
  • Oxygen deficiency (less than 21% oxygen by volume)
  • Presence of toxic gases, fumes, or vapors
  • Flammable atmosphere

Examples of dangerous enclosed spaces found on merchant vessels include:

• Cargo holds: Particularly when carrying certain types of cargo like wood chips, fertilizers, or chemicals that may release hazardous gases.
• Tanks:
  • Ballast tanks
  • Fuel tanks
  • Cargo tanks (especially for liquid or gas cargoes)
  • Sewage tanks
  • Fresh water tanks
• Cofferdams: Spaces between two bulkheads or tanks, often used for ballast or void spaces.
• Void spaces: Empty spaces within the ship’s structure, such as double bottoms or spaces between bulkheads.
• Pump rooms: Spaces housing pumps and associated machinery.
• Pipe tunnels: Enclosed passages for pipes and cables running through the ship.
• Duct keels: Enclosed spaces along the ship’s keel used for ballast or structural purposes.
• Chain lockers: Spaces used for storing anchor chains.
• Battery lockers: Enclosed spaces for storing batteries, which can release hydrogen gas.
• Paint and chemical lockers: Storage areas for paints, solvents, and other chemicals that may emit hazardous fumes.
• CO2 rooms: Spaces used for storing carbon dioxide for firefighting systems.
• Engine crankcases: Enclosed spaces within the engine structure.
• Boiler furnaces: The enclosed chambers within boilers where fuel is burned.

It’s crucial to remember that some spaces may not seem obviously enclosed but can still pose serious risks due to their limited ventilation or potential for hazardous atmospheres. Even spaces with weathertight or shipboard doors, like paint lockers or battery rooms, can become dangerous if not properly ventilated.

Therefore, it is vital to follow the COSWP guidelines for identifying, assessing, and safely entering enclosed spaces to prevent accidents and protect the health and safety of seafarers.

Before entering a dangerous (enclosed) space, the Code of Safe Working Practices for Merchant Seafarers (COSWP) outlines several crucial requirements that must be satisfied to ensure the safety of those entering and those involved in the operation:

1. Risk Assessment and Permit to Work:

• Thorough Risk Assessment: A comprehensive risk assessment must be conducted to identify all potential hazards associated with the enclosed space, such as oxygen deficiency, toxic gases, flammable atmospheres, or physical hazards like confined space or limited access.
• Permit to Work: A Permit to Work, specific to enclosed space entry, must be issued and signed by authorized personnel. This permit outlines the identified hazards, control measures, emergency procedures, and the individuals responsible for the task.

2. Preparation of the Space:

• Ventilation: The space must be thoroughly ventilated using mechanical means, such as fans or blowers, to remove any stagnant or potentially hazardous atmospheres.
• Isolation: Where applicable, isolate the space from any pipelines, valves, or other sources that could introduce hazardous substances or create dangerous conditions.
• Cleaning: Remove any debris, sludge, or other materials that could pose a hazard or obstruct movement within the space.

3. Atmospheric Testing:

• Gas Testing: The atmosphere inside the space must be tested using calibrated gas detection equipment to ensure safe oxygen levels (typically between 19.5% and 23.5%) and the absence of toxic or flammable gases.
• Continuous Monitoring: If the atmosphere is deemed safe for entry, continuous monitoring should be maintained throughout the duration of the work to detect any changes in the atmosphere.

4. Communication and Rescue Arrangements:

• Clear Communication: Establish reliable communication between the personnel inside the enclosed space and a designated person outside who can monitor their progress and raise the alarm in case of an emergency.
• Rescue Equipment: Suitable rescue equipment, including breathing apparatus, harnesses, lifelines, and retrieval systems, must be readily available and in good working order.
• Trained Personnel: At least one person outside the enclosed space must be trained in enclosed space rescue procedures and capable of initiating and coordinating a rescue operation if necessary.

5. Additional Precautions:

• Lighting: Provide adequate lighting within the enclosed space for visibility and safety.
• Personal Protective Equipment (PPE): Ensure all personnel entering the space are wearing appropriate PPE, including protective clothing, gloves, safety footwear, and, if necessary, respiratory protection.
• Limited Entry Time: Limit the time spent inside the enclosed space to minimize exposure to potential hazards and fatigue.

Important Considerations:

• Never Enter Alone: No one should enter an enclosed space alone. Always have at least one person stationed outside as a lookout and to provide assistance in case of an emergency.
• Continuous Monitoring: The atmosphere inside the enclosed space must be continuously monitored, even if the initial tests show a safe environment, as conditions can change rapidly.
• Emergency Preparedness: Ensure all personnel involved are familiar with the emergency procedures and rescue plan, and conduct regular drills to practice these procedures.

By strictly adhering to these requirements and following the guidance in the COSWP, the risks associated with entering enclosed spaces can be significantly minimized, ensuring the safety and well-being of seafarers.