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Going Down the Rabbit-hole of Enclosed Space Entry

Confined Space Photo

Steel surrounded me on all sides with barely a half-meter clearance in any direction, concentrating the hot, humid Indian Ocean air that had been forced in over the previous day. Twenty-five minutes and I was only halfway across the after peak water ballast tank that was twenty meters wide. As the sweat rolled down my back, I thought about the International Maritime Organization’s (IMO) and P&I Clubs’ increased emphasis on enclosed space safety. Perhaps they had a point; because, if I had a problem, it would be a long time before anyone got to me.

 Much like Alice chasing the rabbit down its hole and winding up in Wonderland, once we dive into enclosed space entry, there’s a whole ’nother world. From regulations, drills and training to rescue equipment, risk analysis and atmosphere testing, there is enough information and skills on which to base an entire career. Unfortunately, as mariners, it’s only part of the job. A job that must be done safely, as the consequences can be dire.

 Between 1998 and 2009, nearly 200 {enclosed space} casualties, including 96 fatalities – the majority of which were attributable to procedures not being followed!

 According to Steve Clinch of the United Kingdom’s Marine Accident Investigation Branch (MAIB), this may be the tip of the iceberg. Since 2009, there have been a further 12 enclosed space accidents resulting in 10 fatalities and 7 injuries – in the MAIB database alone. Worldwide, the number of reported and unreported incidents is expected to be far greater.

 Virtually all the casualties of enclosed space accidents are the result of atmosphere deficiencies. Whether due to a lack of oxygen or toxicity due to carbon monoxide, hydrocarbons, hydrogen sulfide or other substance, it is apparent the correct precautions are not being taken. Many enclosed space incidents continue to have multiple casualties due to rescuers not exercising due care before attempting the rescue.

SOLAS regulation III/19 (amended) : …on emergency training and drills, to mandate enclosed-space entry and rescue drills, which will require crew members with enclosed-space entry or rescue responsibilities to participate in an enclosed-space entry and rescue drill at least once every two months.  – Adopted by IMO’s Maritime Safety Committee in June 2013

 Fortunately, there are a lot of stakeholders in the enclosed space entry arena, ranging from the lofty IMO to flag states to insurance companies to shipping companies and all the way down to the deck plates on the ship. While their stakes differ greatly, from the very personal life and limb of the seaman to the more nebulous reputation of a shipping company or flag state, the goal is the same – no incidents.

 IMO’s Secretary General Koji Sekimizu has initiated an “Accident Zero” campaign with the initial goal of reducing all maritime casualties by half by 2015. Directly addressing enclosed space entry was IMO Resolution A.1050(27) Revised Recommendations for Entering Enclosed Spaces Aboard Ships, adopted in November 2011. On its own, this resolution provides a robust base for an enclosed space safety program.

 Some of the other stakeholders aren’t so surprising, with shipping companies providing their crews guidance through their safety management systems (SMS). Other stakeholders are a little more surprising, with insurance companies or protection and indemnity (P&I) clubs providing excellent guidance on enclosed space safety (and a multitude of other subjects) through their Loss Prevention programs. One such resource is The Standard Club’s A Master’s Guide To : Enclosed Space Entry.

 Squeezing my body through the web frame openings to get to this spot had required careful coordination of all limbs, hardhat and the gas meter slung over my shoulder. Not infrequently when performing these contortions, my exhaled breath triggered the low oxygen alarm on my multi-gas meter. The momentary rush of adrenaline when this happens is, I’m sure, only a taste of how a real emergency would feel.

 An informal poll of senior merchant mariners recently revealed a lack of formal training in either Enclosed/Confined Space Entry and Rescue or Gas Free Engineering. While most companies provide training on their permit-to-work program or the use of gas meters, more specialized training is lacking.

 Gas free engineering is a term more normally associated with the military. While certainly not training people to the level of a marine chemist, it does promote a feeling of confidence in equipment and procedures. Unfortunately, while some in the maritime industry do have this training, it is only those with specific military backgrounds.

 Enclosed (or confined) space entry training is not uncommon, but as yet is not mandated. With the amendment to SOLAS III/19 requiring bi-monthly rescue drills, perhaps mandatory training is down the road? Until then, it is less likely that it will be taken voluntarily.

 Additional training in these areas will certainly improve the abilities of seafarers in enclosed space entry. However, it is not only the knowledge of the matter, but the ability to consistently and properly apply that knowledge that will reduce the casualties associated with enclosed space entry.

Additional Reading and Links

MAIB, Steve Clinch, Chief Inspector of Marine Accidents, Entry Into Enclosed Spaces – An Overview.

International Maritime Organization (IMO), Resolution A.1050(27) Revised Recommendations for Entering Enclosed Spaces Aboard Ships

 The Standard Club,  A Master’s Guide To : Enclosed Space Entry.

MED-PIC Moment : Unconscious, But No Trauma?

As the medical person-in-charge (MED-PIC) onboard ships, there are any number of scenarios with which one could be faced.  Cuts, scrapes, bumps, bruises, broken bones and other assorted trauma injuries can reasonably be expected.  Mariners do live and work in an industrial environment, after all.  Normally, a mechanism of injury (MOI) is obvious – the seaman fell from the ladder, was struck by a parted mooring line, was snagged in a moving part, was burned by chemicals, had something caught in their eye, or any of a myriad of job-related hazards.  To a certain extent, the MED-PIC will be challenged by any of these situations, but can also be comforted by the fact that they are not unexpected.  Circulation, airway, breathing – plug the holes and keep the red stuff (blood) inside – treat for shock and, hey, life is good, right?  But, mariners all know to…..

Expect the unexpected.

 Medical emergencies happen – crewmembers have pre-existing conditions, mariners are aging and develop problems and sometimes, someone takes a substance into their body that creates issues. These emergencies can be a MED-PIC nightmare – trying to diagnose a condition that may be life-threatening with a mere fraction of the training given first responders, nurses or doctors. So, where do we turn? Medical advisory services? Textbooks or medical guides? For some emergencies, though, having an idea of the appropriate protocol from the get-go is a good idea.

One such scenario is the unconscious victim/patient. A rapid trauma assessment or survey of any witnesses may offer a MOI. However, if no trauma is obvious and there are no witnesses, then the MED-PIC is truly challenged. The patient can’t offer any help and, aside from the vital signs taken, the MED-PIC has little information on which to act. So…… 

The following is excerpted from the World Health Organization (WHO) Medical Guide for Ships, 3rd Edition (pg. 122-123) (formatting added for clarity) :

Finding an unconscious person

Common causes of unconsciousness include:

- alcohol intoxication: remember that alcohol and trauma often go together, so be wary of singling out alcohol as the only cause of unconsciousness;

 -epileptic seizures;

- hypoglycaemia (low level of sugar in the blood), usually caused by insulin treatment;

- overdose of a narcotic drug, usually heroin, or a benzodiazepine (drugs with names ending in – azepam);

- compression of the brainstem by high pressure in the skull forcing part of the brain through the hole at the base of the skull through which the spinal cord leaves the skull: a common cause of this compression is bleeding in the skull caused by trauma or intracerebral haemorrhage (see Chapter 4, Head injuries).

What to do on finding an unconscious patient

If there is no evidence of major head injury, immediately give:

- glucagon at once, 1 mg intramuscularly; AND

- naloxone, 0.8 mg intramuscularly or intravenously, repeated twice if there is no response.

If the patient remains unconscious, seek medical advice.

 That could be pretty important information! However, to act on it quickly, the MED-PIC may need a few things; One, knowing whether this is a protocol that can be used independently or for which they need to get permission from their medical advisors. And if permission is necessary, being able to quickly contact those advisors; Two, knowledge of where in the ship’s hospital / medicine chest the appropriate drugs are located; and three, the knowledge and ability to properly administer those drugs.

Mariners are the first-responders in the maritime industry. They are the EMTs, firefighters, paramedics and emergency room personnel while on the water – and sometimes it’s all they have. Yes, there is help out there from Coast Guards and military vessels, but that help might be hours or days away. Check out the links below – take some time to read the medical guides – and expect the unexpected.

 Additional Reading and Links

International Medical Guide for Ships – 3rd Ed – World Health Organization

UK MCA – The Ship Captain’s Medical Guide

Naloxone Training Program – State of Connecticut, Dept of Public Health

Near Misses: Saving Ourselves One Miss at a Time……

Courtesy British Columbia Public Service

 “Near-miss : A sequence of events and/or conditions that could have resulted in loss.  This loss was prevented only by a fortuitous break in the chain of events and/or conditions.  The potential loss could have been human injury, environmental damage or negative business impact (e.g., repair or replacement costs, scheduling delays, contract violations, loss of reputation).” – International Maritime Organization

 Near-miss reporting and investigating is something that mariners have been doing for many years now.  Initially, many viewed them as a passing fad – the latest gimmick rolled out by the newest consultant.  Unfortunately, the rationale behind near-miss reporting and investigation wasn’t and probably hasn’t been explained to many.  That’s an opportunity that was certainly lost, as this is all much more than a passing fad or gimmick.

Whether it is the data gathered by Frank E. Bird, Jr. in 1969 – represented above in the graphic – or the more recent studies conducted by Conoco-Phillips Marine in 2003, there’s solid evidence that looking at and understanding the root causes of near-misses will reduce injuries and fatalities.  Why?  Because we’ve caught the situation before it produced that injury or damage and now, we have the opportunity to learn.  It doesn’t matter if it was equipment failure, personnel error or an inadequate procedure, something has been identified as a problem.  Once that root cause is identified, those lessons learned can be used to prevent further incidents of the same sort: future incidents that might not be caught and might lead to equipment damage, human injury or fatality

“The safety management system should include procedures ensuring that non-conformities, accidents and hazardous situations are reported to the Company, investigated and analysed with the objective of improving safety and pollution prevention.” – ISM Code 9.1

 So, there is a system whereby a vessel is creating a library of near-misses and lessons learned.  But, wouldn’t it something if those near-misses and lessons learned were shared across a fleet or a whole company?  Does someone within your company compile a newsletter that contains some lessons learned?  Very frequently, there will be similar near-misses from many vessels which could indicate a systemic problem.  Sometimes it is a slew of trips, slips and falls or possibly equipment that fails, such as gratings or handrails that leads to near-miss observations.  If so, a concentrated safety campaign in that area might be warranted.  At a minimum, if this information is passed around, other vessels get the opportunity to learn from the mistakes or observations of others.  Designated Persons Ashore (DPA), safety departments or loss prevention groups’ buy-in would be crucial to making this happen on a company-wide basis.

Going to the next level, what would happen if these near-misses were passed around the whole industry?  Wouldn’t it be great to stop a problem onboard your vessel before it became an issue by hearing about lessons learned from another company or possibly, another segment of the maritime industry entirely?  Oddly enough, there are already some systems set up for doing just that.  One of the most notable is the Nautical Institute’s Mariners’ Alerting and Reporting Scheme (MARS).  Drawing near-misses from across a wide swath of the maritime industry, their database goes back over 20 years.  That’s no small amount of lessons learned!  In the UK, there is CHIRP, which gathers near-misses from both the aviation and maritime industries.  The Confidential Hazardous Incident Reporting Programme (CHIRP) compiles near-misses received into a quarterly report which is quite interesting to read.  Not only do they report on information received, but they follow-up on it to see what best practices companies might have implemented in response to the near-miss.

CHIRP is definitely European-centric, whereas MARS is more international.  On the U.S. side of the Atlantic, the U.S. Coast Guard publishes lessons learned under their Incident Reports.  These lessons learned come more from inspection observations and incident investigations, rather than from within the maritime industry itself.  Perhaps, the U.S. Maritime Administration should establish its own database of near-misses – all the better for passing along lessons learned and making the industry – and mariners! – safer.

Does it take effort to pass along near-misses, especially outside the company?  Absolutely it does!  But, remember how onerous it seemed to fill out those near-misses onboard your vessel a few years ago?  And now, it’s just how you do business.   Perhaps, in a few more years, it might be just as natural to send a report into one of the national or international databases.  In the meantime, mariners, DPAs and companies should continue to look at lessons learned inside and outside their organizations to ensure best practices are used and mariners are safe!


Additional Reading and Links

U.S. Coast Guard Investigations – Investigations

MARS (Mariners’ Alerting and Reporting Scheme)

CHIRP for Maritime (Confidential Hazardous Incident Reporting Programme)

IMO MSC /Circ. 1015 “Reporting Near Misses”

IMO MSC-MEPC.7/Circ.7 “Guidance on Near-Miss Reporting”


Seamanship : Alive and Well or Dead and Gone?

What contributes more to safety?  Seamanship and common sense or the regulations and management systems that we currently use?  Captain Charis Kanellopoulos argues that seamanship onboard modern merchant vessels is almost extinct, leading to an increase in incidents across the industry.  You can read his op/ed at :

Seamanship : the Forgotten Factor

There is certainly some truth in what he says.  Does the additional administrative workload onboard contribute to fatigue?   Absolutely.  Unfortunately, the majority of regulations have been brought about by disasters or incidents where seaman have NOT used common sense and good seamanship.  Regulations are written for the lowest common denominator – the person that is not applying common sense and is prone to contributing to or causing incidents.  Is that fair to those who feel they are not that lowest common denominator?  Possibly not.  Then again, should they also feel relieved that there is some safety net that will catch an unsafe act before it becomes an incident?

So, I ask again.  What contributes more to safety?  Seamanship and common sense or the regulations and management systems that we currently use?  Perhaps, it’s a combination of all these factors…….