Solid bulk aboard of bulk carriers - the connected dangers with life threatened or lethal accidents in enclosed spaces

On March 3, 2019, Abacus Marine Consultants published a post on LinkedIn related to the article "Another Five Fatalities with Solid Bulk Cargo" at www.maritime-executive.com.

Two sides of one medal

Side one

Basically, I share the opinion of the author of this article. The recent casualties on bulk carriers caused by lack of oxygen in loaded holds and fumigated holds and adjacent areas show us that there are significant deficiencies which by IMO, its safety committees, shipping companies, surveyors, fumigation companies, shippers and port authorities must worked up. That's the one side of the medal.

But it would be too easy to have to turn only on the screws of administrative regulations to tighten existing safety regulations again and again. How would it be if, before the loud shouting for tightening of existing provisions, first of all the existing international and national regulations were consistently and effectively implemented and enforced. We would then quickly realize that the number of serious accidents involving in cargo holds can be drastically reduced on bulk carriers with injured or fatalities.

That this must be revised and adapted over and over again is beyond question. Finally, over the time become:

? gained new insights, also gained through the evaluation of tragic accidents,

? new technical innovations which ensure a considerable improvement in the analysis methods of the cargo space atmosphere, inaugurated

? Analyzing systems, constantly improved and their handling simplified

? New chemical compounds for fumigating of cargo holds utilized.

? Innovative new respirators/ Breathing systems and more effective and refined filtration systems being developed

Side two

But the other side of the coin should not be hidden!

The vast majority of fatal accidents on bulk carriers are not caused by tank inspections, they are based on careless handling of existing safety regulations during cargo hold inspections or careless entering of cargo compartments, ignoring all associated hazards. This has shown the evaluation of numerous investigation reports. The so-called human error must therefore not be trivialized

The consistent observance and enforcement of the applicable safety regulations for the entry of closed, loaded and fumigated spaces by the crews is subject to the particular responsibility of the captains and officers.

Most accidents are due to:

• Failure to comply the criteria of effective and maximum-safety existing Risk Assessment.
• Another chapter is the inadequate adherence to ship management and safety management systems and their on-board enforcement, their ongoing review to promptly identify and eliminate identified shortcomings.
• A faulty, inadequate risk management is carried out.
• Enormous practized external time pressure on the crews, which lead to such fatal accidents. What good doing bloated news about record loading/ discharging times of ships, if the so canonized safety management stays by the wayside and serves only as a paper tiger for PSC inspections and audits?
• Inadequate technical and scientific knowledge of the key personnel, ie the captains and officers, just about the course of chemical processes in loaded closed holds and their negative effects at e.g. Grain (enrichment of the cargo hold atmosphere with CO2 and concomitant reduction of the O2 content) or steel bars (reduction of the O2 content by oxidation processes on the steel), to name only two, with life-threatening potential
• Inadequate information of the crew about the related chemicals for the fumigation of holds, their potential hazards and risks, the mandatory safety regulations with clear indication that entering these spaces is strictly prohibited and only in exceptional circumstances with the express permission of the Captain. Under compliance with all to executing necessary safety measures and procedures preceded. I have handled it in the manner that the crew got before arrival an extensive safety instruction. In all the corridors of the deckhouse, on the bridge, in the mess rooms and in the ECR appropriate data sheets with warnings and with the corresponding first aid measures in the event of an emergency were posted. All hatch covers and cargo hold accesses were clearly marked with warnings for everyone and locked. The keys to this were in the care of the CO
• What about the nautical officers' knowledge of using gas detectors to analyze the cargo hold / enclosed space (tank) atmosphere and the right evaluation?
• Which deeper mediated knowledge in all questions of correct conclusions on the basis of existing well-founded scientific knowledge are available?
• What qualitative and quantitative technical equipment level is available with circulating-air-dependent respiratory protection equipment and the associated filters to be used and knowledge of their proper use? I would like to refer as an aid an:

www.berner-safety.de/filter_selection_guide_for_draeger_respiratory_masks_en_1078.html.

Please note: These systems may only be used if the oxygen content of the breathing air is at least 17% by volume

• What level of equipment of gas testing equipment is on board and are the manufacturer's calibration periods and specified periods of use complied with?
• How is the replacement of filter stocks on board secured to prevent overlay beyond the expiry time (particle filter / gas filter /combination filter)? I did find while stock checks aboard always a lot of expired unused filters in stock. What showed that they were not with care checked. They have no business there, are to be weeded out and disposed of. And have to be replaced. 
• What is the level of knowledge of the crew in testing, operation and application of SCBA?

      Note: Approximate determination of breathing air consumption Q [l / min]:

"Extensive tests have shown that the respirator wearer of a compressed air respirator (PA) consumes  approximately:

              - light work (unhindered walking under PA) Q ~ 30 l / min

              - medium work (firefighting) Q ~ 40 l / min

              - heavy work (climb ladder, wearing a Chemical protective suit) Q ~ 50 l / min

              Calculation of breathing air consumption Q [l / min]:

                                  Q=(V1*Dp)/(p1*t*V)                                 

              V1... output volume or respiratory air supply in liters

              p1... initial pressure, z. B. Air pressure (pB) in bar

              Dp... pressure difference in bar

              p2... pressure in the compressed air cylinder at the start of the operation,

                            e.g. filling pressure in bar

                             D p = p2 - pEnd

              pEnd...Pressure in the compressed air cylinder at the end of the application in bar"

(source: https://typo3.p116282.mittwaldserver.info/lexikon/a/atemluftverbrauch/), the source is unfortunately only in German language, but I translated it for interested reader

• How tight and consequent is the on-board organization to ensure maximum enforcement of existing safety policies without being influenced by the time pressure from the outside?
• Which qualified knowledgeable training on all very specific aspects of the cargo hold climatology and cargo hold atmosphere for the various cargo forms, the strict safety guidelines to be respected, the handling of respiratory protection systems and different filter categories are carried out for the crews? What qualification level do the trainers, i.e. the officers, have? Monthly safety meetings are not enough. It requires qualified briefings.
• What and how are crew trainings and safety instruction of the crews are conducted beforehand about rescue from enclosed spaces, under the condition of holds under fumigation/ low oxygen areas?
• Safety takes time. It has to take into account of all the required aspects and can only be guaranteed in reliable timeframes, thus minimizing accidents. Safety comes always first, not only as slogan in papers or on deck houses

As a matter of principle, it must be clearly stated that access to enclosed spaces requires explicit ship-authorizations by Captain, which may only be granted if ALL measures have been taken in the Risk Assessment and the Guidelines for Entering Enclosed Spaces. All steps taken in preparation for entering closed rooms must be recorded accordingly. Only if ALL the required criteria are met is a permit to enter issued.

Sea shipping should definitely take its time and also look beyond one's own nose. The existing IMO guidelines applicable to maritime shipping, such as:

? MSC.1 / Circ. 1477 - 09 June 2014, GUIDELINES TO FACILITATE THE SELECTION OF PORTABLE ATMOSPHERE TESTING INSTRUMENTS FOR ENCLOSED SPACES AS REQUIRED BY SOLAS REGULATION XI-1/7

? MSC.350 (92) - 21.June 2013, AMENDMENTS TO THE INTERNATIONAL CONVENTION FOR THE SOLAS 74, AS AMENDED CHAPTER III LIFE-SAVING APPLIANCES AND ARRANGEMENTS Part B Requirements for life-saving appliances Regulation 19 - Emergency training and drills

? IMO Resolution 1050 (27) - November 30, 2011, REVISED RECOMMENDATION FOR ENTERING CLOSED SPACES

? IMSBC Section 3 - Safety of personnel and ship

and publications in specialist maritime panels such as "The Nautical Institute" and Maritime Insurers on this topic are helpfool. 

www.nautinst.org/filemanager/root/site_assets/forums/enclosed_spaces/a-masters-guide-to-enclosed-space-entry.pdf

But there are also very good recommendations for "Enclosed Spaces" in other areas of Shipping business, such as inland navigation.

It is interesting to note that inland navigation takes at "Enclosed Spaces" in Chapter 10 of ISGINTT, First Edition, 2010 ("International Safety Guide for Inland Navigation Tank-barges and terminals") a very detailed look. And provides an excellent guide to action, what meets every safety requirement in its details.

www.cbrb.nl/nieuws/documenten/doc_download/984-isgintt-en

Futhermore I want urgent for all cases of required fumigation in cargo holds on bulk carriers refer to the:

 Code of Practice - On Safety and Efficacy for Marine Fumigation - by the International Maritime Fumigation Organisation (IMFO).

This Code should be taken under consideration for company safety staff and crew training in preparation of fumigation practice and all therewith connected urgent safety procedure. It is a good guide about required emergency procedures with helpful checklists.

www.imfo.com/IMFO_Code_of_Practice.pdf

Additional I want recommend for all QHSSE Departments in Bulk carrier companies the home page of IMFO in World Wide Web:

www.imfo.com/standards.html

Here are IMO, US and Canadian Fumigation standards, revisions, updates and new information in all matters of fumigation and safety procedures retrievable.

By this documents, the IMO could certainly get some suggestions to implement in SOLAS 74, Chapter 3, Part B, Regulation 19 and in IMSBC Section 3 some specifications to "Enclosed Spaces". The International Chamber of Shipping (ICS) too could borrow aspects and develop general rules for maritime shipping to "enclosed spaces" together with the IMO. The in tank shipping fleets valid standard procedures, can also be readily adapted for bulk carrier and for all other specialized maritime shipping sectors. Loaded, fumigated, sealed holds definitely meet the criteria of "Enclosed Spaces". And require the utmost caution.

Of course, it is possible and, if necessary, essential to introduce shipbuilding modifications to improve safety standards on board.

But the main problem of the sensitization are:

? Crews,

? Inspections,

? Management,

? Auditors,

? Classification societies

? Flag States authorities

? Port authorities,

? Surveyors and

? PSC

a)     consistently and effectively enforcing the applicable safety provision,

b)     identifying and clearly naming deficiencies,

c)     demanding of elimination and monitoring their consistent elimination

Conclusion

This can only achieved with extensive specialist training, intensive training for emergency situations, the sense of responsibility by management personnel aboard and ashore, and with consequent deep going inspections by PSC in their entirety be mastered.

I even go so far and plead for unannounced controls and Vettings of experienced superintendents, QM employees. Only then we get an actual picture of the real conditions on board and only then is it possible to counteract consistently, in order to eliminate discovered deficiencies and to control their elimination. It also creates the effect of a high sensitivity in all safety issues is awakened, because no one on board knows when the next safety inspection is in the house. I already hear the critical voices from all camps. But the critics should explain to me how they want to deal with the loss of human lifes that are based on substantial proof of the non-compliance with existing security standards. Extraordinary circumstances require extraordinary measures. With good talking and raised forefinger, we come no one step further. Here, assertiveness, consistency and discipline are required. This can only be achieved by unpopular steps. Occasionally you have to force people to their happiness.

Those who save in high-quality safety equipment, saves in the wrong place. It does not even have to be expensive. It must be available and above all fully functional. Analyze devices for analyzing the room atmosphere must be able to be used in a multifunctional manner for the different gas types in different room heights. Because only that gives meaningful results.

The protective equipment on board must be in perfect technical and maintenance condition, its handling must be intensively trained in order to be prepared for emergencies.

And the ship's command should not accept to be forced to unjustified hurry, by agents, surveyors, port authorities, charterers, shippers. On the other hand, you have the opportunity to intervene and put safety first. Anyone who thinks they have to ignore this must then live with the consequence that the Captain will SOLAS XI-2 Regulation 8 (1) applies. That is their right and their duty. Be consistent and insist as captains on compliance with all safety aspects, as they have a duty to their crews to protect their health and lifes. In German there is the saying: what lasts long, lasts well. And it's true. Prudence and thoughtful action is the key to a safe working environment and avoiding accidents. If the ship's command team refer that and put it in practice, the crew will act accordingly.

In this respect, we are again talking about Human Error, what is not limited to crews, but refers to all parties involved, including superordinate authorities/ managers ashore involved in the enforcement and compliance with applicable safety standards, cargo operations, cargo securing, Vessel Operational Management and Vessel Management, refers. So it's a very complex issue.

? Copyright 2019 Capt. Gunter Schütze. Replication or redistribution in whole or in part is expressly prohibited without the prior written consent by Capt. M.Eng. Gunter Schütze