Entering Enclosed or Confined Spaces, Cont'd.
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Testing for Toxic Gases
The presence of certain gases and vapours on chemical tankers and gas carriers is detected by fixed or portable gas or vapour detection equipment. The readings obtained by this equipment should be compared with the occupational exposure limits for the contaminant given in international industry safety guides or the latest edition of the Health and Safety Executive Guidance Note EH-40 Occupational Exposure Limits. These occupational exposure limits provide guidance on the levels of exposure to toxic substances which should not be exceeded if the health of persons is to be protected. However, it is necessary to know for which chemical a test is being made in order to use the equipment correctly and it is important to note that not all chemicals may be tested by these means.

When a toxic chemical is encountered for which there is no means of testing then the additional requirements specified in Section "Additional Requirements for Entry into a Space where the Atmosphere is Suspect or known to be Unsafe" should also be followed .

A combustible gas indicator will probably not be suitable for measuring levels of the gas at or around its occupational exposure limit, where there is solely a toxic, rather than a flammable, risk. This level will be much lower than the flammable limit, and the indicator will probably not be sufficienty sensitive to give accurate readings.
 
Use of a Permit-to-Work System
Entry into a dangerous space should be planned in advance and use should preferably be made of a 'permit-to-work' system. If, during the course of the operation, unforeseen difficulties or hazards develop, the work should be stopped and the space evacuated so that the situation can be fully assessed. Permits should be withdrawn and only issued after the situation has been re-assessed. 'Permits-to-work' should be revised as appropriate, Details of the arrangements to be followed in a 'permit-to-work' system are described in Web Page "Permit-to-work Systems" which includes a specimen of a 'permit-to-work'.

For situations for which a well established safe system of work exists a check-list may exceptionally be accepted as an alternative to a full 'permit-to-work ' provided that the principles of the 'permit-to-work' system are covered and the risks arising in the dangerous space are low.

On expiry of the 'permit-to-work', everyone should leave the space and the entrance to the space should be closed or otherwise secured against entry or alternatively, where the space is no longer a dangerous space, declared safe for normal entry.
 
Procedures and Arrangements Before Entry
Access to and within the space should be adequate and well illuminated .

No matches, welding or flame cutting equipment, electrical equipment or other sources of ignition should be taken or put into the space unless the master or responsible officer is satisfied that it is safe to do so.

In all cases rescue and available resuscitation equipment should be positioned ready for use at the entrance to the space. Rescue equipment means breathing apparatus together with fully charged spare cylinders of air, life lines and rescue harnesses, and torches or lamp, approved for use in a flammable atmosphere, if appropriate. A means of hoisting an incapacitated person from the confined space should also be readily available when appropriate.

The number of persons entering the space should be limited to those who actually need to work in the space and who could be rescued should an emergency occur.

At least one attendant should be detailed to remain at the entrance to the space whilst it is occupied.

A system of communication should be agreed and tested by all involved to ensure that any person entering the space can keep in touch with the person stationed at the entrance.

A system of communication should be established between the attendant at the entrance to the space and the officer on watch.

Before entry is permitted it should be established that entry with breathing apparatus is possible. The extent to which the use of breathing apparatus or life lines or rescue harnesses would cause any difficulty of movement within any part of the space, or would cause problems if any incapacitated person had to be removed from the space, should also be examined.

Lifelines of rescue harnesses should be long enough for the purpose and be easily detachable by the wearer should they become entangled, but should not otherwise come away from the rescue harnesses.
 
Procedures and Arrangements During Entry
Ventilation should continue during the period that the space is occupied and during temporary breaks. In the event of a failure of the ventilation system any persons in the space should leave immediately.

The atmosphere should be tested periodically whilst the space is occupied and persons should be instructed to leave the space should there be any deterioration in the conditions.

If unforeseen difficulties or hazards develop, the work in the space should be stopped and the space evacuated so that the situation can be re-assessed.

If a person in a space feels in any way adversely affected he should give the pre-arranged signal to the attendant standing by the entrance and immediately leave the space.

When available a rescue harness should be worn to facilitate recovery in the event of an accident.

Should an emergency occur the general (or crew) alarm should be sounded so that back-up is immediately available to the rescue team.
 
Additional Requirements for Entry into a Space where the Atmosphere is Suspect or Known to be Unsafe
If the atmosphere is considered to be suspect or unsafe to enter without breathing apparatus, then the space should only be entered if it is essential for testing purposes, the working of the ship, for the safety of life or for the safety of the ship. The number of persons entering the space should be the minimum compatible with the work to be performed.

Breathing apparatus should always be worn. Respirators cannot be used as they do not provide a supply of clean air from a source independent of the atmosphere within the space.

Except in the case of emergency, or where impracticable because movement in the space would be seriously impeded, two air supplies as described in Section below should be available to the wearer of the breathing apparatus who is required to work in a dangerous space. The wearer should normally use the continuous supply provided from outside the space and he should immediately make his way out of the space should it be necessary to change over to the self-contained supply.

During occupation of the space, precautions should be taken to safeguard the continuity of the outside source of air to the wearer of breathing apparatus. Special attention should be given to supplies originating from the Engine Room.

Where remote testing of the space (as recommended in Section above) is not reasonably practicable, or where a brief inspection only is required, a single air supply may be acceptable provided prolonged presence in the space is not required and the wearer of the breathing apparatus is so situated that he can be hauled out immediately in case of emergency.

Rescue harnesses should be worn. Wherever practicable lifelines should be used. Lifelines should be attended by a person stationed at the entrance who has been trained how to pull an unconscious person from a dangerous space. Where the dangerous space to be entered requires the possible use of hoisting equipment to effect rescue, arrangements should be made to ensure that persons would be available to operate it as soon as necessary.

When appropriate, portable lights and other electrical equipment should be of a type approved for use in a flammable atmosphere.

Should there be any hazard due to chemicals, whether in liquid, gaseous or vapour form, coming into contact with the skin and/or eyes then protective clothing should be worn.
 
Drills and Rescue
Regular drills simulating the rescue of an incapacitated person from a dangerous space should be conducted to prove the feasibility of the ship's rescue plan under different and difficult circumstances. A real-weight dummy may be used for this purpose. If necessary, the space selected should be made safe for the exercise. Alternatively drill may be held, for operational convenience, in non-dangerous spaces provided that these spaces realistically simulate conditions expected in actual dangerous spaces on the ship. A drill should normally be held soon after signing on a new crew or if there has been a substantial change in crew members. Each drill should be recorded in the official log book.

Any attempt to rescue a person who has collapsed within a space should be based on a pre-arranged plan. Every ship will have its own individual problems each of which may require a different rescue procedure, and the plan should take into account the design of the ship and of the equipment and manpower on board. Allocation of personnel to relieve or back-up those first into the space should also be borne in mind.

If there are indications through the agreed system of communication or otherwise, that the person in the space is being affected by the atmosphere, the person outside the space should immediately raise the alarm. ON NO ACCOUNT SHOULD THE PERSON STATIONED AT THE ENTRANCE TO THE SPACE ATTEMPT TO ENTER IT BEFORE ADDITIONAL HELP HAS ARRIVED. NO ONE SHOULD ATTEMPT A RESCUE WITHOUT WEARING BREATHING APPARATUS AND A RESCUE HARNESS AND, WHENEVER POSSIBLE, USE OF A LIFELINE.

If air is being supplied through an air line to the person who is unwell, a check should be made immediately that his air supply is being maintained at the correct pressure.

On reaching an incapacitated person, unless he is gravely injured, e.g. a broken back, he should be removed from the dangerous space as quickly as possible. It is emphasized, however, that restoration of the casualty's air supply at the earliest possible moment has always to be the first priority.
 
Breathing Apparatus and Resuscitation Equipment
No one should enter a space, even to effect a rescue, where the atmosphere is unsafe or suspect without wearing breathing apparatus.

The two air supplies normally to be available to the wearer of a breathing apparatus working in a dangerous space will usually comprise a continuous supply from outside the space and a self-contained supply to enable the wearer to escape to a safe atmosphere in the event of difficulty with, or failure of, the continuous supply. It should not be necessary to remove any part of the equipment or any protective clothing to change over to the self contained supply.

Equipment for use with two air supplies may consist of:-

(a) a conventional self-contained breathing apparatus of the open circuit compressed air type or

(b) a compressed air line breathing apparatus incorporating an emergency self-contained supply. The compressed air line breathing apparatus should be of the demand valve type.

The capacity of the self-contained supply should be sufficient for the wearer of the breathing apparatus to escape to a safe atmosphere. When determining this capacity it should be recognized that if under stress or in difficult conditions the wearer's breathing rate may be in excess of the nominal breathing rate of 40 litres per minute.

Where the supply of air comes from outside the space, the responsible officer should make sure that it is continuous and is available only to those working in the space. Pipeline or hoses supplying air should be placed so that they are not likely to be so distorted that supply might be interrupted or damaged. If the purpose for which such air lines are used is not immediately apparent to persons not engaged in the entry, then notices should be posted at appropriate positions. When a mechanical driven pump is being used it should frequently be checked carefully to ensure that it continues to operate properly. Any air pumped directly into a pipeline or put into reserve bottles requires to be filtered and should be as fresh as possible. Pipelines or hoses used to supply air should be thoroughly blown through to remove moisture and freshen the air before connection to breathing apparatus and face masks. It is essential that where the air supply is from a compressor sited in a machinery space, the engineer of the watch be informed so that the compressor is not shut-down until the work is completed.

Everyone likely to use breathing apparatus should be instructed by a competent person in its proper use.

The Master, or responsible officer, and the person about to enter the space should undertake the full pre-wearing check and donning procedures recommended in the manufacturer's instructions. In particular they should check:-

1./ that there will be sufficient clean air at the correct pressure;

2./ that low pressure alarms are working properly;

3./ that the facemask fits correctly against the user's face so that, combined with pressure of the air coming into the mask, there will not be an ingress of oxygen deficient air or toxic vapours when the user inhales. It should be noted that facial hair or spectacles may prevent the formation of an air-tight seal between a person's face and the facemask;

4./ that the wearer of the breathing apparatus understands whether or not his air supply may be shared with another person and if so is also aware that such procedures should only be used in an extreme emergency;

5./ that when work is being undertaken in the space the wearer should keep the self-contained supply for use when there is a failure of the continuous supply from outside the space.

When in a dangerous space:-

1./ No one should remove his own breathing apparatus.

2./ Breathing apparatus should not be removed from a person unless it is necessary to save his life.

It is recommended that resuscitators of an appropriate kind should be provided where any person may be required to enter a dangerous space. Where entry is expected to occur at sea the ship should be provided with appropriate equipment. Otherwise entry should be deferred until the ship has docked and use can be made of shore side equipment.
 
Maintenance of Equipment
All breathing apparatus, rescue harnesses, lifelines, resuscitation equipment and any other equipment provided for use in, or in connection with, entry into dangerous spaces, or for use in emergencies, should be properly maintained, inspected periodically and checked for correct operation by a competent person and a record of the inspections and checks should be kept. All items of breathing apparatus should be inspected and checked for correct operation before and after use.

Equipment for testing the atmosphere of dangerous spaces, including oxygen meters, should be kept in good working order and, where applicable, regularly serviced and calibrated. Due regard should be paid to manufacturer's recommendations which should always be kept with the equipment.
 
Training, Instruction and Information
Employers should provide any necessary training, instruction and information to employees in order to ensure that the requirements of the Entry into Dangerous Spaces Regulations are complied with. This should include:-

1./ recognition of the circumstances and activities likely to lead to the presence of a dangerous atmosphere,

2./ the hazards associated with entry into dangerous spaces, and the precautions to be taken,

3./ the use and maintenance of equipment and clothing required for entry into dangerous spaces,

4./ instruction and drills in rescue from dangerous spaces.
 
Statutory Regulations
The Merchant Shipping (Entry into Dangerous Spaces) Regulations 1988 place obligations on the Master of a ship and his employer to ensure that procedures for safe entry and working in dangerous spaces are clearly laid down and observed on board the ship, and on persons entering or remaining in a dangerous space to do so only in accordance with these procedures. In carrying out these duties full account must be taken of the principles and guidance described in this Web Page.
 
Ends
 
 




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