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  • MARSHALL ISLANDS: Marine Notice No. 7-041-1
TO:

ALL SHIPOWNERS, OPERATORS, MASTERS AND OFFICERS OF MERCHANT SHIPS, AND RECOGNIZED ORGANIZATIONS

 

SUBJECT: Entering Enclosed Spaces – Safety Precautions

 

References:

International Convention for the Safety of Life at Sea (SOLAS) Consolidated Edition 2014

IMO Resolution MSC.380(94), Amendments to the International Convention for the Safety of Life at Sea (SOLAS), 1974, as Amended (Chapters II-2, VI and XI-1 and Appendix), adopted 21 November 2014

IMO Resolution MSC.350(92), Amendments to the International Convention for the Safety of Life at Sea, 1974, as Amended, adopted 21 June 2013

IMO Circular MSC.1/Circ.1485, Early Implementation of SOLAS

Regulation XI-1/7 on Atmospheric Testing Instrument for Enclosed

Spaces, issued 14 January 2015

RMI Maritime Regulations (MI-108), Section 7.41.7

IMO Resolution A.1050(27), Revised Recommendations for Entering

Enclosed Spaces Aboard Ships, adopted 30 November 2011

IMO Circular MSC.1/Circ.1477, Guidelines to Facilitate the Selection

of Portable Atmospheric Testing Instruments for Enclosed Spaces as

Required by SOLAS Regulation XI-1/7, issued 9 June 2014

IMO Circular MSC.1/Circ.1401, Guidelines for Tank Entry for

Tankers Using Nitrogen as an Inerting Medium, issued 9 June 2011

RMI Marine Notice 2-011-14, Maintenance and Inspection of Fire

Protection Systems and Appliances

 

PURPOSE:

This Notice establishes requirements and elaborates on safety standards which are to be followed by personnel entering enclosed spaces on board ships. These requirements are necessary because of the continued loss of life resulting from personnel entering shipboard spaces in which the atmosphere is oxygen-depleted, oxygen-enriched, toxic or flammable.

This Notice supersedes Rev. 8/12 and reflects the incorporation of requirements for enclosed space entry and rescue drills under Chapter III/Regulation 19.3 of the International Convention for the Safety at Life at Sea (SOLAS), 1974, as amended. It further reflects the requirement on the carriage of instruments for measuring the atmosphere in enclosed spaces pursuant to new SOLAS Chapter XI-I/Regulation 7.

APPLICABILITY:

This Notice is applicable to all vessels registered in the Republic of the Marshall Islands (RMI) to which SOLAS applies, including Commercial Yachts of 500 gross tons and over, and to Private Yachts Limited Charter (PYLC) of 500 gross tons and over.

Drills – 1 January 2015: The new requirements under SOLAS Chapter III/Regulations 19.3.3 and 19.3.6 (Resolution MSC.350(92)) for crew member participation in onboard enclosed space entry and rescue drills once every two (2) months shall apply beginning 1 January 2015, except for with respect to 19.3.6.2.3.

Carriage of Atmosphere Testing Instruments – By 1 July 2016 (see RMI Maritime Administrator’s Application below): Paragraph 3.6.2.3 of Regulation 19 requires that each enclosed space entry and rescue drill requirement includes: “checking and use of instruments for measuring the atmosphere in enclosed spaces’‘ However, the International Maritime Organization (IMO) did not mandate the carriage of portable atmospheric testing instrument(s) until after it established the requirement for drills. See SOLAS Chapter XI-I/Regulation 7 as provided in Resolution MSC.380(94). As a result, the entry into force dates of these two (2) new regulations are not aligned – the equipment carriage requirement enters into force later (1 July 2016) than the requirement for utilization of the equipment in drills (1 January 2015)—and the IMO is inviting early implementation of the carriage requirement.

RMI Maritime Administrator’s Application: The RMI Maritime Administrator (the “Administrator”), therefore, is applying these requirements as follows:

1 January 2015: Atmospheric testing equipment currently being carried onboard shall be used in accordance with SOLAS Chapter III, Regulation 19 paragraph 3.6.2.3 and shall comply as far as practicable with Regulation 7 of SOLAS Chapter XI-1.1

1 July 2016: All vessels shall carry a portable atmosphere testing instrument in accordance with SOLAS Chapter XI-1/Regulation 7. These instrument(s) shall be checked and used during drills in accordance with SOLAS Chapter III/Regulation 19, paragraph 3.6.2.3.

REQUIREMENTS:

1.0              Safety Strategy (Instruction, Training and Drills)

  • The importance of regular instruction, training and drills in the proper methods of enclosed space entry and rescue operations cannot be over emphasized. In order that personnel safety measures are maintained at a high level on RMI flagged vessels, shipowners and/or ship operators shall adopt a comprehensive safety strategy to prevent accidents while entering into enclosed spaces.
  • The strategy shall give full consideration to the IMO’s recommendations for entering enclosed spaces aboard ships contained in Resolution A.1050(27) and shall be incorporated into the Safety Management System (SMS), as appropriate. Tankers using nitrogen as an inerting medium shall also give full consideration to the guidelines of MSC.1/Circ.1401 while developing their SMS.
    • In particular, the strategy shall be ship-specific, and shall establish safety instructions and training initiatives to emphasize proper utilization of personal safety equipment and procedures. Safety instructions and training shall consider and include a review and briefing of the following primary mistakes made by personnel that have led to casualties:

.1 entering an enclosed space without advising other persons of intent;

.2 entering an enclosed space without ensuring the space is adequately ventilated; and

.3 attempting to enter an enclosed space to give aid to a person or persons inside the space without first taking the necessary safety precautions.

  • The safety strategy shall also require crew members with enclosed space entry or rescue responsibilities to participate in periodic enclosed space entry and rescue drills to be held on board at least once every two (2) months (see MI-108, section 7.41.7). Such drills shall be planned and conducted in a safe manner, taking into account, as appropriate, the guidance provided in Resolution A. 1050(27) and shall include the following exercises:

.1 checking and use of personal protective equipment required for entry;

.2 checking the use of communication equipment and procedures;

.3 checking and use of instruments for measuring the atmosphere in enclosed spaces;

.4 checking the suitability, including the length, of sampling hoses of portable detectors for gas measurement at all levels in double bottom spaces;

.5 checking and use of rescue equipment and procedures; and

.6 instructions in first aid and resuscitation techniques.

  • The Master and Safety Officer shall review periodically the safety instructions which have been issued by the shipowner and which shall be available on board in sufficient numbers for all personnel to have their own copy.

Every crew member, upon joining the vessel, shall be given instructions which shall include but not necessarily be limited to the risks associated with enclosed spaces and the onboard procedures for safe entry into such spaces which should take into account, as appropriate, the guidance contained in Resolution A.1050(27).

2.0 Authorization of Entry

No person shall open or enter an enclosed space unless authorized by the master or the nominated responsible person and unless the appropriate safety procedures laid down for the particular ship have been followed. See Attachment 1 of this Notice for an example of an enclosed space entry permit as extracted from IMO Resolution A.1050(27).

3.0 Ventilation of Spaces

Enclosed spaces shall be assumed to be incapable of supporting life and shall be well ventilated for a minimum of at least 24 hours, or if mechanical venting is used, for a minimum of at least four (4) hours before entry. Testing of the atmosphere of the space shall be carried out before any person enters the space and at regular intervals thereafter until all work is completed. Only if the test results indicate acceptable levels of oxygen and acceptable levels of flammable or toxic vapors, shall entry be permitted.

4.0              Cargo Pumprooms

  • In tankers, the officers and pump technicians shall be alerted to the danger which will arise if liquid cargo leaks from defective pumps or cargo piping systems and floods the pumproom bilges to a height which could obstruct the inlets of the air exhaust ducts, thus making the pumproom ventilating system ineffective and permitting heavy accumulation of cargo vapors within the compartment.

Constant vigilance shall be exercised by personnel on board tankers regarding the asphyxiation and toxic hazards associated with cargo pumprooms if there is any leakage of cargo into the pumproom bilges. Such spaces shall be entered only by personnel properly trained and equipped with suitable breathing apparatus for the product involved and the individual shall be secured to a lifeline. Under no circumstances shall the breathing apparatus be removed while within a space containing atmosphere fouled by noxious vapors or gases.

5.0              Breathing Apparatus

  • A breathing apparatus of an approved type shall be carried in all ships in accordance with SOLAS Chapter II-2, Regulation 10.2. Breathing apparatus for chemical carriers and liquefied gas carriers is prescribed by the Chemical Code and Gas Code respectively and shall be carried accordingly. See also Section 10.0 of RMI Marine Notice 2-011-14which addresses Self-Contained Breathing Apparatus (SCBAs).
    • In all cases where the atmosphere of a space is known or suspected to be unsafe, persons entering such spaces shall only do so while wearing an approved SCBA, and all such persons shall be trained in its use.
      • Under no circumstances shall an Emergency Escape Breathing Device (EEBD) be used to enter an enclosed space in which the atmosphere is known or suspected to be oxygen- depleted, oxygen-enriched, toxic or flammable.

6.0 Records

The date when enclosed space entry and rescue drills and on board training shall be recorded in the vessel’s log book. If a drill or training session is not held at the appointed time, an entry shall be made stating the circumstances and the extent of the drill or training session held.

Attachment 1

EXAMPLE OF AN ENCLOSED SPACE ENTRY PERMIT

This permit relates to entry into any enclosed space and should be completed by the master or responsible person and by any persons entering the space, e.g. a competent person and attendant.

General
Location/Name of enclosed space
Reason for entry
This permit is valid From hrs. Date
To hrs. Date
(See Note 1)
Section 1 – Pre-entry preparation

(To be checked by the master or nominated responsible person)

Yes No
• Has the space been thoroughly ventilated by mechanical means?
• Has the space been segregated by blanking off or isolating all connecting pipelines or valves and electrical power/equipment?
• Has the space been cleaned where necessary?
• Has the space been tested and found safe for entry? (See Note 2)
• Pre-entry atmosphere test readings:
–  oxygen % vol (21%)*

–  hydrocarbon % LFL (less than 1%)

–  toxic gases ppm (less than 50% OEL of the specific gas)

By: Time:
(See Note 3)
• Have arrangements been made for frequent atmosphere checks to be made while the space is occupied and after work breaks?
• Have arrangements been made for the space to be continuously ventilated throughout the period of occupation and during work breaks?
• Are access and illumination adequate?
• Is rescue and resuscitation equipment available for immediate use by
the entrance to the space?
• Has an attendant been designated to be in constant attendance at the entrance to the space?
• Has the officer of the watch (bridge, engine room, cargo control room) been advised of the planned entry?
• Has a system of communication between all parties been tested and
emergency signals agreed?
• Are emergency and evacuation procedures established and understood by all personnel involved with the enclosed space entry?
• Is all equipment used in good working condition and inspected prior to entry?
• Are personnel properly clothed and equipped?
* Note that national requirements may determine the safe atmosphere range.

 

 

Section 2 – Pre-entry checks

(To be checked by the person entering the space or authorized team leader)

Yes No
I have received instructions or permission from the master or nominated responsible person to enter the enclosed space.
Section 1 of this permit has been satisfactorily completed by the master or nominated responsible 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 am aware that the space must be vacated immediately in the event of ventilation failure or if atmosphere tests show a change from agreed safe criteria.

 

 

 

Section 3 – Breathing apparatus and other equipment

(To be checked jointly by the master or nominated responsible person and the person who is to enter the space)

  • Those entering the space are familiar with any breathing apparatus to be used
  • The breathing apparatus has been tested as follows:
  • gauge and capacity of air supply
  • low pressure audible alarm if fitted
  • face mask – under positive pressure and not leaking
  • The means of communication has been tested and emergency signals agreed
  • All personnel entering the space have been provided with rescue harnesses and, where practicable, lifelines.
Yes No

 

 

 

Signed upon completion of sections 1, 2 and 3 by

Master or nominated responsible person

Date: _______ Time:

Date: _______ Time:

Date:                       Time:

Attendant __________________________

Person entering the space

 

 

Section 5 – Completion of job

(To be completed by the responsible person supervising entry)

  • Job completed                                                                            Date: _____________ Time:
  • Space secured against entry                                                     Date: _____________ Time:
  • The officer of the watch has been duly informed               Date: _____________ Time:Responsible person supervising entry                                                      Date:                             Time:
  • Signed upon completion of sections 4 and 5 by:

THIS PERMIT IS RENDERED INVALID SHOULD VENTILATION OF THE SPACE STOP OR IF ANY OF THE CONDITIONS NOTED IN THE CHECKLIST CHANGE.

Notes:

    1. The permit should contain a clear indication as to its maximum period of validity.
    2. In order to obtain a representative cross-section of the space’s atmosphere, samples should be taken from several levels and through as many openings as possible. Ventilation should be stopped for about 10 minutes before the pre-entry atmosphere tests are taken.
    3. 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.

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