Man going down a ladder of an enclosed space on a ship

Safety in enclosed spaces: An update from the IMO CCC 10

Published: 06 November 2024

The International Maritime Organization (IMO) continues its unwavering commitment to enhancing safety standards for maritime personnel. At the recent 10th session of the Sub-Committee on Carriage of Cargoes and Containers (CCC), significant progress was made in revising resolution A.1050(27) to ensure the safety of personnel entering enclosed spaces on board ships. During the session, a working group meticulously reviewed the draft revised recommendations for entering enclosed spaces aboard ships. They incorporated various comments and proposals, resulting in a comprehensive and updated set of guidelines. 

Important revisions and recommendations 

The revised recommendations emphasise several vital areas to enhance safety during enclosed space entry: 

Organisational Leadership and Safety Management: 

  • Organisational Leadership: The importance of safety leadership is further emphasised and the need for strong leadership from ashore, which empowers shipboard staff to make informed decisions regarding safety procedures is emphasised. 
  • Safety Management System: Although the previous version required ships to produce a list of enclosed spaces on a ship-by-ship basis, this was not seen implemented widely on all ship as there was a lack of clarity of this recommendation.  This meant that not all ships had a ship-specific list of enclosed space, and there was confusion on which is an enclosed space and which is not. The new revised recommendations make a clear encouragement on companies and ships to adopt a robust safety management system, including maintaining an Enclosed Space Register tailored to each vessel. This is one of the most important additions to the previous version of the recommendations.  

Enclosed Space Hazards and Mitigation: 

  • Risk Assessment: Enclosed spaces present unique challenges due to their complex structures, ventilation, illumination, and potential for oxygen depletion or toxic gas accumulation. This also means that there are pockets of gas that can be trapped within a seemingly safe space.  The revised recommendations clearly define and differentiate between an adjacent space and connected space and gives guidance on how to treat each space in connection with enclosed space entries.  
  • Cargo Safety: Specific safety information about the cargo being carried should be readily available, as hazards can extend beyond the immediate enclosed space. While the earlier version mentioned specific cargo related hazards are present in IMDG and related codes, the revised recommendations put a clear emphasis on obtaining the specific cargo related hazards from the shipper and that the ship master or his representative have all the hazard related information of the particular cargo in question.  
  • Oxygen Depletion and Toxic Atmospheres: In contrast to popular belief, Oxygen depletion occurs more rapidly than previously thought, and the risk of toxic atmospheres developing within enclosed spaces is significant. Carbon dioxide plays a significant role in oxygen depletion and more information on this is included. Emphasis is put on measuring carbon di oxide along with other toxic and relevant gases.  
  • Space Security and Signage: It was noted that workers, especially port workers were oblivious to the dangers present in cargo holds and entered it without any precaution leading to casualties. In these revised recommendations, more emphasis is put on proper identification of safe and unsafe spaces and the use of proper signs to guide port workers is further recommended.  
  • Crew Training: Comprehensive training for crew members is essential, especially considering the ongoing revision of the STCW Convention and Code. The revised recommendations mention what kind of training is needed for the relevant crew members. Training should address specific hazards, such as carbon dioxide and other toxic gases, as well as cargo-related risks and oxygen-depleting cargoes. 

Emergency Preparedness: 

  • Rescue Planning: A number of investigation reports pointed out the fact that rescue was carried out in haste and in an unplanned manner leading to further casualties. A well-planned rescue operation, including training of appropriate staff, is crucial for effective emergency response, this is further emphasized in the revised recommendations and is also mentioned in the training recommendations. Clear and well-practiced emergency response plans are essential for mitigating incidents. 

By addressing these key areas, organisations can significantly enhance safety measures and reduce the risks associated with entering enclosed spaces on board ships. 

Approval and Next Steps 

The draft revised recommendations have been approved at sub-committee level and will be submitted to MSC 110 for adoption. Additionally, necessary consequential amendments to relevant IMO instruments will be made to ensure comprehensive compliance and implementation. 

Conclusion 

The revised recommendations for entering enclosed spaces aboard ships represent a significant improvement in maritime safety. By following these guidelines, lives of personnel can be safeguarded and safer working environment fostered in the maritime industry. 

As we move forward, it is imperative that all stakeholders—shipowners, operators, and port authorities—collaborate to enforce these recommendations effectively. For more detailed information, refer to the official IMO documents and the complete report of the 10th session of the CCC Sub-Committee.

 

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Ashok Srinivasan

CONTACT BIMCO

Ashok Srinivasan

Manager, Maritime Safety & Security

Singapore, Singapore