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Confined Space Entry - understanding the facts

Don't get yourself into a hole!

In 2007 the Marine Accident Investigators International Forum (MAIIF) identified that a large number of fatalities in the shipping industry worldwide were related to confined space or enclosed space entry and that accidents were increasing. At the same time the Marine Accident Investigation Board (MAIB) commenced investigations into three separate accidents that had resulted in six seafarers dying. Consequently the MAIIF began researching incidence of this type and to date has identified 120 fatalities and 123 injuries since 1991 resulting from entry into a confined space.

The Confined Space Regulations 1997 define a confined space as: “Any chamber, tank, vat, silo, pit, trench, pipe, sewer, flue, well or other similar space that presents a foreseeable specified risk by virtue of its enclosed nature” and the Health and Safety Executive (HSE) defines it as: “a place which is substantially enclosed (though not always entirely) and where serious injury can occur from hazardous substances or conditions within the space or nearby (e.g. lack of oxygen)”

So what are the dangers from confined spaces?

The HSE identifies that dangers can arise because of: a lack of oxygen; poisonous gas, fume or vapour building up or entering the space unexpectedly; liquids and solids that can suddenly fill the space or release gases; fire and explosions; residues left in tanks or vessels; high concentrations of dust; and hot conditions. The incident that took place on the Viking Islay on 23 September 2007 resulted in three experienced seamen dying when, one by one, they entered the chain locker in an attempt to tie off an anchor chain to prevent it from rattling in the spurling pipe. Unfortunately as a result of ongoing corrosion of the steel structure and anchor chain the space had become oxygen deficient and all three men were asphyxiated. Two other cases in 2008 that are still being investigated by the MAIB also involved entering a confined space. In one incidence two men entered a store and the other incidence one man entered an empty ballast tank. All three men died from asphyxiation because of low levels of oxygen in the atmosphere.

The ports and shipping industry in the UK employs around 490,000 people which is equivalent to 1.7% of all UK employment and the industry has a combined estimated contribution to GDP of £23.4 billion. And according to the Department for Transport, 95% of the UK international trade arrives or leaves by sea. The MAIB has determined that the number of accidents happening because of seafarers entering oxygen deficient confined spaces is unacceptable and that although clear procedures have been developed for people to follow, it is clear from the numbers of fatalities and injuries that these procedures are failing.

Chris Nix , Sales Manager with Equipment Status Management company Scafftag, explains “many of our clients are operating in the shipping and marine industry and ask our advice regarding managing entry into a potentially hazardous or dangerous environments and also isolating or securing equipment associated with entry to confined spaces. For example, during entry into an enclosed space (such as a ballast tank or boiler drum) it may be necessary to close and isolate valves on pipelines connected to the space to ensure ingress prevention of gases or liquids. Obviously there are strict criteria that should be followed in order to plan confined space entry and we can recommend visual and physical systems that could be implemented to ensure safe access control.”

Planning for a confined space entry should include the following:

• Confined space hazard identification and risk assessment
• Safe Work permit, Confined Space Entry permit, Hot Work permit, Lockout/Lockoff procedure, and/or any other permit or procedure that may be applicable
• Atmospheric testing and confined space inspection
• Defining the criteria for confined space entry
• Visual warnings systems as appropriate
• Procedures for the control of safe systems of work
• Training and information
• Emergency response arrangements
• Recording detail on all of the above

Chris explains “any confined space that has been opened or fails inspection must have a suitable warning system with ‘Do Not Enter’ displayed and the confined space isolated to ensure that entry cannot take place. Actions to correct the situation and satisfactory retesting of the confined space need to be implemented before the entry procedure can continue.”

Most systems available to shipping and marine businesses to ensure safe entry to a confined space take the form of an ‘Entry Tag’ Systems, ‘Lock out/Tag out’ Systems and ‘Man in Tank’ systems and all are designed to help prevent accidents happening and efficiently manage ongoing inspection procedures. “Regular inspections should be taking place to ensure that there is no significant changes to the atmospheric conditions which could result in potentially hazardous working conditions for those involved”, Chris goes on to explain, the systems in place should enable those working in the area to know instantly whether access is safe or is denied and also when someone has physically entered and is working in the confined space. An entry tag and insert should be attached in a conspicuous place at the entrance to the enclosed space and should clearly inform everyone of the minimum requirements for entry, the type of work being undertaken and all other salient details. This system can also prohibit entry entirely by clearly displaying a ‘Do Not Enter’ message. Isolation tags or ‘Lock out/Tag out’ systems are designed to ensure that physical entry to a hazardous or dangerous area cannot be granted until identified related equipment or supplies are isolated and made safe. For example during entry to an enclosed or confined space it may be necessary to close and isolate valves on pipelines connected to the space in order to prevent inadvertent ingress of gases or liquids. And when a person or persons has accessed and is working in a confined space, his personal ‘Man in Tank’ tag system identifies that this is the case and confirms exactly how many people are there by the number of Man In Tank tags being displayed.”

The Merchant Shipping (Entry into Dangerous Spaces) Regulations 1988 impose strict duties on employers to ensure that procedures for entering and working in dangerous spaces are laid down and that the Master ensures those procedures are observed. The regulations also state that dangerous spaces should be identified and kept closed, wherever possible. The Master of tankers or gas carriers of 500 tons and over or any other ship of 1,000 tons or over should conduct regular drills simulating the rescue of a crew member from a dangerous space and employers should ensure that an oxygen meter or other testing devices are available and in good working order.

Both the Merchant Shipping (Entry into Dangerous Spaces) Regulations 1988 and the Maritime Accident Investigation Board recommend ship owners and managers and other related industries to identify and implement measures that are aimed at improving the identification of all dangerous and potentially dangerous spaces. Compliance with the safe working practices required when working in such compartments should be increased and that all employers and those working in these areas have a responsibility to raise awareness of the continuing high incidence of fatalities of seafarers working in enclosed spaces in an attempt to drive these statistics down.