The best safety management systems on ships
Safe practices on ships are a matter for both individuals and operators to consider. The best safety management systems are only as good as the least safety conscious crew member and when cavalier attitudes to safety combine with a poorly run safety system the result is usually tragic or catastrophic.
It is probably true that the advent of the International Safety Management Code or ISM has improved the culture around safety onboard but as official investigations show, even the best systems break down occasionally and for a variety of reasons.
As the ISM Code and the safety management systems needed to comply with it have been mandatory for many years, usually the only time a new system is needed is when a new shipowning or managing company is formed. Existing fleets will already have a system in place.
If a safety system is in place but not functioning as well as it might across a fleet of vessels, there is a good case for the shipowner or manager responsible for the vessel to carry out a complete overhaul of the system. Most failures are because the system is unnecessarily complicated with individuals interpreting parts of it in very different ways. There is some evidence that simpler systems are more effective. Working practices are at the heart of every effective safety system and improvements are rarely necessary if the way work is carried out has been thoroughly thought through.
How crew work and interact and how effective the safety management system is not set in stone and poor working practices can be improved by employing best practices. Regular reviews should be made and training needs identified. For a system to work effectively all those involved in operating with it need to have a common purpose. Involving sea staff in the development of systems has been shown to improve the sense of ‘ownership’ of the system making departures from it less likely.
Most of the regular training in the form of drills is regulated but a good system builds upon those basic exercises and takes into account reports and investigations of incidents and accidents across the fleet and further afield. Making use of specialist training films can help crew understand how safety can be improved. The fact that such films are made in several languages is very useful as English is not the first language of most seafarers.
Leaving aside the matter of navigation errors, there are four areas that regularly feature as the causes of accidents on board ships that have led to an official investigation. These are mooring and unmooring, working at height, hot work and entry into enclosed spaces.
Every port call involves at least two operations involving the ship’s ropes and winches. Accidents usually involve crew getting crushed in machinery or caught in ropes. Safety begins with ensuring the ropes, wires and machinery are well maintained and rigged properly. The mooring area should be kept free of equipment not needed for the immediate operation as this often causes trips and falls as crew attempt to work in and around obstacles.
Crew involved should be properly trained and supervised with the supervisor not being required to perform any task that prevents him from observing the actions of others. Mooring can be heavy work and should not be entrusted to crew unable to meet the physical demands of the task.
Crew engaged in operations should be wearing appropriate PPE especially, hard hats, safety boots or shoes and gloves. The snap back zone – the area likely to be most affected if a mooring rope under tension parts – should be well marked and crew trained to stay out of it. The crew should also be aware of the dangers of being trapped in a bight. Trapped crew can be pulled over the side, into the winch or against bitts.
Working at height could involve tasks such as painting or cleaning the hull of the ship, cleaning holds, work on cranes, derricks and masts and other similar jobs. When working at height crew should be issued with hard hats and most importantly a safety harness. If the work involves paints or chemicals, then a facemask to prevent inhalation of substances and safety glass or goggles to protect the eyes.
Hot work such as welding or cutting will need appropriate gloves and a welding mask to protect the face and eyes especially from the condition known as arc eye or welder’s flash. Hot work should never be carried out without a prior risk assessment and a permit to work system should be operating.
Several incidents have been recorded where, although a risk assessment was carried out taking into account factors in the immediate vicinity, no thought was given to adjacent spaces on the other side of the structure being worked on. Particular attention should be paid to pipes and cabling that may be affected by any hot work.
Possibly one of the most dangerous aspects of work on ships is when a crew member must enter an enclosed space to carry out work. This is now regulated under SOLAS and the use of detection instruments is also now mandatory. Whether a ballast tank, a void space, or even a cargo hold, enclosed places can generate or contain toxic gases leaked in from elsewhere. In a cargo hold, the use of bobcats and forklifts can lead to poisonous fume build up as can some of the fumigants used to kill pests in cargoes such as grain.
Every vessel should have a procedure that is followed closely before a crew member enters an enclosed space. A risk assessment should be done and as with hot work, any work being done in neighbouring spaces must be taken into account. The following are points to consider when preparing for such work.
- A permit to work will be required and should be checked and approved by a competent officer.
- The space should be well ventilated before entering.
- A check for oxygen and other gas content using a properly calibrated and tested portable gas detector. Under no circumstances should an entry be attempted if oxygen levels are below 20% by volume.
- Lighting should be adequate for the work and the crew member should carry a torch. A time period for the work should be agreed and if it looks to be exceeded a further risk assessment and permit may be needed.
- Sign boards should be provided at required places warning other persons not to start any equipment, machinery or any operation in the confined space that could endanger those working there.
- Recovery and resuscitation equipment should be on hand before the space is entered and a second crewman should remain on standby while the person working is in the enclosed space.
- In the event of an accident or incident the standby crew should raise the alarm and not attempt rescue alone.
- The person entering the space should be equipped with appropriate PPE including an oxygen analyser and gas detector. * Consideration should be given to a life line being carried.
Although intended for more day-to-day matters, medical facilities and specialist skills are also likely to be needed when an emergency occurs.
Provision of medical facilities on board ships was touched upon in Chapter 1 but in many instances the level will be set by flag states above those required under IMO and ILO regulations. Ships are obliged to carry limited stocks of medicines and equipment and some form of medical guide that can be used for advice in emergencies. The exact details of what must be carried are at the discretion of the flag state. Flag states that do not have national requirements for the contents of the medical chest have in the past relied on a list that has been provided by the World Health Organisation (WHO) in the International Medical Guide for Ships (IMGS). It is not a formal international instrument but the Guide is noted as a source of information in the non-statutory part of the relevant ILO Convention. Port State Control Inspectors frequently use the IMGS list as the minimum requirement for medical supplies.
In 2010, WHO published Quantification Addendum: International Medical Guide for Ships, Third Edition as an updated list of medications and for the first time included non-prescription medicines and treatments for common conditions that are not covered in IMGS. The list does not take precedence over flag state rules but as before, ships of flag states that do not regulate the quantities and types of medicines should consider it as a minimum in order to avoid PSC complications. The list is also used as a reference by specialist marine pharmacists who supply medicines and equipment for ships.
A companion publication to IMGS entitled MEDICAL FIRST AID GUIDE FOR USE IN ACCIDENTS INVOLVING DANGEROUS GOODS (MFAG) is published by the IMO and gives specialist advice for substances considered dangerous goods and included in the IMO’s IMDG Code. The guide contains information on symptoms, treatment and care and is considered an essential requirement on most ships.
Almost every flag will either make mandatory or recommend a general medical guide that should be carried onboard but it is most important that the crew member who is appointed to carry out any medical procedures is able to understand the terminology used in the guide and the language it is written in. For this reason, blind adherence to recommendations of a particular guide that is not available in the appropriate language may satisfy PSC but could prove dangerous in a medical emergency.
Except on passenger vessels and a very few merchant ships, access to a qualified medical practitioner will be very limited. The first aid and limited medical training that is needed under STCW for various ranks is all that most sick and injured crew can expect unless or until the ship is in port or close enough to land for more expert medical assistance to be given. With the advance in marine communications, it is now possible to subscribe to a handful of specialist telemedicine services that give access at any time to the expertise of trained doctors.
These possibilities exist now but few cargo ships are able to make use of them. Services that some shipping companies may find useful are those offered by specialists such as Norway’s Medi 3. Its ShipMed Safety System software takes full control of the ship’s medicine chest and monitors expiry dates, distribution and purchase of medicines and medical equipment, as well as reports for stock, consumption and purchase. The software also provides a guide to use of medicines and medical equipment, a quick reference for medical equipment for different injuries and video clips showing various medical procedures. An enhanced version also gives access to telemedicine facilities and services.
The potential for cargoes to create hazardous situations for the ship either because of inherent properties or because of deliberate acts by shippers to circumvent rules is something that has long been recognised.
Understanding that certain cargoes have characteristics that can endanger lives or pose a threat to the ship is something that is both taught and learned through experience. Experience of the threats need not mean having been exposed to them directly but having worked with people that have explained what precautions they are taking and why. Unfortunately, the rapid career progress of many seafarers means that their opportunity to learn through experience can be somewhat limited.
The matter is one that has been recognised by the IMO which has established the Sub-Committee on Carriage of Cargoes and Containers (CCC) which operates under instructions from both the MSC and the MEPC and which has produced several guides and codes many of which are mandatory to follow.
All seagoing personnel with responsibility for cargoes are expected to be aware of the relevant codes, publications and sources of advice and to follow them when carrying such cargoes. Clearly some of the rules and advice will not apply to all ship types. Also of use is the special advice promulgated to members by P&I Clubs and other industry bodies.
Because both the SOLAS and MARPOL Conventions are involved, some of the regulations are concerned more with environmental matters than safety but most of the documents will contain a mix of both and are therefore essential sources of safety advice. The subject of cargo safety is extremely wide and to cover it comprehensively is beyond the scope of this guide.
Cargoes can cause loss of life and ships in many ways. Shifting cargo is cited in many ship losses and while the problems of certain cargoes as regards angles of repose and propensity to shift are well known it seems that in recent years an inordinate number of lives have been lost due to ships capsizing following liquefaction of nickel ore and other similar cargoes.
Another seemingly innocuous cargo that has proved extremely dangerous over time is grain. It is less its shifting potential – although that can be high – but the hazards associated with fumigation needed to kill any insects present in the cargo. The most common fumigant is hydrogen phosphide (PH3) usually referred to as phosphine. Phosphine is manufactured in a solid formulation of either magnesium or aluminium phosphide in the shape of tablets.
The tablets react and break down in contact with water or in an atmosphere containing moisture when they release phosphine. The most favourable conditions for complete release of phosphine from the tablets are in tropical and subtropical climates, where four to five days are sufficient. In temperatures below 15°C, or in a very dry atmosphere, much more time would be needed. If the tablets are only spread on top of the cargo, it will also take time for the gas to spread through the full depth of the cargo, although the gas is heavier than air. Tablets may therefore be placed in tubes penetrating the cargo depth and the gas spread by a fan or pushed into the cargo by probes to speed up the process. While pure phosphine gas is odourless the tablets sometimes contain an ingredient that smells of garlic.
Phosphine is a powerful irritant but not normally fatal although it has caused the death of several seafarers including in one case where the victim’s cabin was located near to the bulkhead of the hold which had corroded allowing the gas to leak continually into the cabin. Phosphine is also highly flammable under certain conditions. It has a lower flammable limit of 1.8% volume by volume (v/v) in air. If an air/phosphine mixture in which the phosphine concentration exceeds this level is ignited in an enclosed space, then an explosion is likely to occur. The auto-ignition temperature for phosphine is reported by some sources to be as low as 38°C, although other sources state higher temperatures of about 85°C are required.
In 2015 the North of England P&I Club reported two explosions on bulk carriers loading wheat at Rio Grande Do Sul, Brazil. It is believed that the explosions are linked to the use of phosphine fumigants. The IMO has issued guidance on the use of fumigants in a circular: IMO MSC.1/Circ.1264
Container fires and weights
Containerisation has been responsible for a revolution in cargo handling and rapid port turnrounds but the use of containers also has safety implications. Often this is due to shippers deliberately declaring hazardous cargoes as something harmless to avoid paying premium freight rates. In such cases this may mean containers are stowed in inappropriate slots on board. There are several cases of hazardous cargoes catching fire or exploding and resulting in the loss of ships and lives.
There is an onus on shore staff when booking cargoes to be more vigilant and indeed there is a requirement under IMDG for staff responsible for accepting hazardous cargoes to have undergone training to understand the requirements with regard to packing and separation of such cargoes. Well trained staff can often identify some cargoes as being hazardous even when the shipper is not aware of the particular hazard involved. For example swimming pool cleaners can contain some highly flammable components and the booking staff must be able to recognise proprietary names for some of the more hazardous types. However, dealing with the issue of deliberate concealment is difficult because inspecting cargoes inside containers is not easy to achieve.
Another issue with containers is the mis-declaration of weights which has resulted in stowage and stability problems. It is a matter that ship operators have complained about for many years and the IMO has finally taken action and adopted amendments to SOLAS Chapter VI Regulation 2. These have been published as MSC.1/Circ. 1475.
Since 1st July 2016, all packed containers are required to have a verified gross weight (VGW) declared by shippers. The VGW is the certified gross cargo weight (including weight of all packing material) plus container tare weight. The measure has not proved popular with shippers but under the rules containers cannot be loaded onto a vessel unless a certified VGW is provided.