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A recent fatality as a result of a fall inside a ship’s cargo tank illustrates the need for better risk assessment before work begins and more safeguards to prevent a fall occurring.

A young seafarer died recently from injuries sustained in a fall during work inside a ship’s cargo tank. He was entering the tank and had just descended the first ladder when he stepped into an open maintenance access in the stringer plate and fell almost 20 meters onto the tank top. A thorough investigation was carried out and concluded that the accident could have been prevented if the open maintenance access had been identified as a hazard and properly secured before the work began.

The investigation also highlighted other contributory factors common for this type of accidents, such as poor planning and supervision. A permit to work (PTW) had been issued for the specific tank and the open maintenance access was mentioned during the crew’s morning safety meeting, but no order was given to secure the opening. No proper ‘Tool-box Talk’ was carried out by the assigned work team and the unsecured opening was therefore not discussed as a hazard before the work began. In addition, the tank area was poorly lit and the work team had to use their flashlights to move around.

The most obvious risk is not always the cause of the accident
Falling from a height onboard ships continue to be a cause of death and injury to seafarers despite the maritime industry’s efforts to ensure safe working conditions for the crew. Gard’s case database contains many examples of similar accidents, often with the primary cause of the accident identified as “not following safety management procedures” or “failure of the PTW system”. Cases illustrate that the procedure for hazard identification and the implementation of safeguards to control risks are not always taken seriously and are looked upon merely as a paper exercise.

Onboard a ship, the term working at height is normally associated with working aloft, e.g. in a ship’s mast or crane, or outboard where the most obvious risk to somebody is that of falling. But when planning work inside ships’ tanks or other enclosed spaces, most of the focus is on the risks associated with the tank’s atmosphere upon entry.1 Less attention is therefore paid to safeguards that can prevent or reduce the possibility of a fall, when in reality the risk of falling in such spaces can be much higher than when working on or above deck. Enclosed spaces may have hatchways that are difficult to squeeze through, vertical ladders for ascending and descending, slippery decks/surfaces and rungs of the ladders, structural arrangements and pipework acting as trip hazards as well as a work environment that may be humid and uncomfortable.

Rules and regulations
It is a general health and safety requirement that risks associated with all work tasks onboard a ship must be assessed beforehand. This requirement is regulated internationally by the International Safety Management (ISM) Code and the Maritime Labour Convention (MLC) and enforced through the legislation of each flag State. But international maritime regulations contain few ‘hands-on’ design requirements aimed at preventing falls from a height during activities on board. SOLAS Reg.II-1/3.6 sets out some requirements related to the arrangement of accesses and protection of walkways during close-up inspections of tanks and holds – but only for oil tankers and bulk carriers. The IMO’s “Revised recommendations for entering enclosed spaces aboard ships” does not mention the risk of falling at all.

To ensure a practical approach and uniform enforcement of regulations governing health and safety risks, flag States publish useful codes of working practice (or similar documents). One such example is the UK “Code of Safe Working Practices for Merchant Seamen” (COSWP). Its aim is to provide guidance to shipowners and seafarers on how to fulfil their statutory obligations. The ILO’s “Code of practice for accident prevention on board ship at sea and in port” provides similar practical recommendations and guidance - much of which have been taken from national codes of practice and other safety-related publications.2

How to prevent falls from a height
Members and clients should ensure work tasks are properly planned, supervised and carried out by competent personnel. Occupational health and safety requirements enforced through flag States’ laws and guidance documents should be carefully adhered to when deciding upon the type of equipment and safeguards to be used for each work task. The following is particularly important to prevent falls from a height:

  • Assess the risks when planning a work task. Obtain an overview of all dangers and hazards associated with the task. For simple routine jobs, a risk assessment could be carried out in a more informal manner, e.g. through a verbal discussion like a ‘Take 5’ or ‘Tool-box Talk.’ For more complex, non-routine, or new tasks, the assessment should follow a prescribed set of steps and a well-defined risk assessment form.PWT checklists for entry into enclosed spaces should clearly emphasise the need for safeguards to reduce any risk of falling.
  • Prioritise collective protection measures over personal protection measures. Collective protection measures to prevent falls when working in tanks and other enclosed spaces will typically include permanent or temporary guard rails, proper lighting, marking of trip hazards etc. Personal protection measures will depend on the task at hand but could include use of a safety harness as well as appropriate clothing.
  • Familiarise yourself with the layout of a tank or enclosed space before entry. Persons assigned to the task must be aware of the layout before entering. No risk assessment can be completed unless the layout of the space is known. When an exposed height is identified as a potential hazard for the task being planned, and if practicable possible and compatible with the work in progress, fitting of guard rails or other physical barriers to prevent a fall should always be the prioritised safeguard.
  • Consider each individual person’s experience. Only persons with sufficient skill, knowledge and experience should be allowed to work at heights, also when the work is performed below deck.
  • Maintain high standards of safety also when the ship is at a yard. A close co-operation with the shipyard is beneficial as a yard is likely to equip the ship with higher standards of shore lighting into enclosed spaces, better ventilating ducts, scaffoldings, etc. The ship’s crew should follow the shipyard’s safety procedures as far as practicably possible but continue to apply normal seafaring practises and comply with their company’s safety standards.
  • Take into account the possibility of emergencies occurring when planning a task. Any person may need to be rescued from where they are working at height.

Although shipowners and operators have a duty to put regulations for the reduction of occupational health and safety risks into practice - each crew member has an obligation to comply with the specific standards and policies applicable on board their ship. Crew members must take reasonable care of their own safety and that of others on board that may be affected by their activities.

2 We also refer to ILO’s recently agreed set of guidelines for implementing the occupational safety and health (OSH) provisions of the MLC. Although the guidelines still need to pass through the March session of the ILO’s Governing Body, Members and clients are strongly encouraged to review these guidelines and see how they may be best implemented on their ships.