Few yacht crew will be overly concerned with enclosed space entry in normal daily operations, but when the rare circumstances do arise, particularly in refit, appropriate safety measures should be taken. Management companies of larger boats, where this is more likely to apply, are likely to have this in hand.
“Port State Control Officers (PSCOs) will use a list of 10 selected questions to establish that crewmembers with enclosed space duties are familiar with relevant equipment and have received training to carry out their duties and identify and understand the hazards associated with entry into enclosed spaces,” a press release issued by the Paris MoU explains.
“Additionally there are questions aimed at gathering information about the existence of measures in place to test the atmosphere of an enclosed space to confirm it is safe to enter and remains safe whilst persons are within the space. If deficiencies are found, actions by the Port State may vary from recording a deficiency and instructing the master to rectify it within a certain period of time to detaining the ship until serious deficiencies have been rectified.” It is expected that the Tokyo and Paris MoUs will carry out approximately 10,000 inspections during the CIC.
Since the announcement, the International Chamber of Shipping (ICS) has issued a guidance note to its members, which has been prepared to ‘assist owners and operators to prepare for Port State Control (PSC) inspections’. Adrian McCourt, managing director of Watkins Superyachts, has picked up on this wording and asks: “Shouldn’t ICS be more concerned that some of their members may not actually be complying with the many useful published procedures and guidelines that are already in place to protect seafarers from asphyxiation?”
"It cannot have escaped anyone’s notice that the maritime world has spawned a culture of tick-box managers whose aim is to ensure bureaucratic compliance without a thought to the end user: the at-risk seafarer."
Many seafarers and especially those involved with the commercial industry will have horror stories of the dangers involved with entry into enclosed spaces. “Amongst the hundreds of tragedies were the three officers who broke off for lunch with their wives during a refit, then re-entered the space where a change in hazard was not recognised and all three perished,” recalls McCourt.
“The CIC must be welcomed by anyone with an interest in safety as sea. Warning the maritime world is, I assume, a necessity to publicise the good work of Port State Control, but for ICS to publish a guide to handling the PSC inspection is madness. It cannot have escaped anyone’s notice that the maritime world has spawned a culture of tick-box managers whose aim is to ensure bureaucratic compliance without a thought to the end user: the at-risk seafarer. It is worth remembering that a seafarer entering an enclosed space may not understand the subtle nuances between ‘equipment available’ or ‘equipment ready’, but would respond to a strict go/no go culture on board.”
McCourt argues that, for a respected organisation to issue guidelines on how best to survive a PSC inspection is misguided. “We have very few instances where we need to carry out enclosed space entry on large yachts, but … if there is an inherent failure in our enclosed space entry system waiting to bite us, let’s find it,” he concludes.