Confined space entry policies

While taking the personal safety portion of BST last week this subject came up; competent persons,marine chemist etc. Turned out that two of the hands attending, one with a river tug outfit, the other OSV both stated that their company policy is “DO NOT ENTER!! Period!!”. If a confined space needs to be entered, wait until the vessel returns to port and the entry will be handled by a third party. Is this a common practice at this point or limited to outfits that do not want to maintain and support the training programs?

It is more of a liability issue more than anything. Believe it or not, I was sent to school to be a confined space entry supervisor, after getting certified, the same company told me that I would never be able to use the cert because they did not want the liability of me saying a tank was safe, then someone going in and dying, then them get sued over it. We always get an outside chemist to give us a certificate if we have to go inside a tank. No exceptions, a few months ago they even took the oxygen meter off all the boats.

It all varies company to company. Anyone entering, attending or supervising should at the minimum be trained as such. A competent person should be in charge of opening and testing the space. The space should be properly ventilated for at least 24 hours or verify that the air for the space has been exchanged at least three times. Before any hot work takes place the space should be tested and verified by a competent person. Continuous monitoring of the space while inside and during hot work. In the case of hot work inside of a tanks that holds combustible materials a marine chemist should certify the space is safe for hot work. I have only experience this once inside a diesel tank. The smell was so bad you could barely breath and the welder was in there burning rods. I would have never done it, but the chemist tested it as OK. In shipyards all confined spaces are tested at each tower. I have entered many confined spaces. All these rules, guidelines and precautions have been developed over the years from actual accident investigations, so they should not be taken lightly. If you don’t feel that you are properly trained to enter, open or supervise these functions do not take any chances. It is simply not worth dying over.

Their are a lot of companies with that rule. My company allows entry as long as the proper steps are taken (OSV company). What most people don’t understand is that you must have a competent person operating the equipment as well as performing the monthly calibrations and pump tests before every use.

Yes I know the protocol, I was certified “competent person” years back for shipyard ops. Wrote up many a JSA for entries. I just assumed that the CE or CM or another onboard would be certified for such. What if you’re towing a rig across the pond and you need to enter a compartment? I can certainly see the liability as an issue. Without the proper training and precautions, confined space work can be one the most deadly jobs a mariner performs. It just seems odd to take that tool away from a crew.

A confined space by definition does not necessarily mean it has bad air.
It means it’s “confined”.

Only one way in, sharply sloping decks, entrapment hazards or moving machinery without guards could all be reasons to declare a space confined.
A steering gear compartment can easily be a confined space, even if it has natural ventilation.

A Marine Chemist is only concerned with the atmosphere.
A Shipyard Competent Person (that’s the certificate tittle) should recognize these other types of hazards.

Well, as one who used to make his daily living entering confined spaces and also is also Shipyard Competent Person trained, there are many misconceptions regarding entry and responsibilities. The “Competent Person” is not concerned about they types of hazards in a confined space. Both the Marine Chemist AND the Competent Person are concerned with the atmospheres IN the confined spaces.

Here is a quote from the US Department of Labor page regarding the space entry requirements:

“The Shipyard Competent Person or a Marine Chemist may conduct initial tank entry testing and hotwork testing. However, if the space contains flammable or combustible liquids or gases, a Marine Chemist must issue a certificate before hot work begins. If the Shipyard Competent Person finds a toxic atmosphere above the OSHA Permissible Exposure Limit (PEL), additional testing by the certified marine chemist or certified industrial hygienist is required and additional controls must be implemented to prevent excessive exposures. Controls typically include ventilation and personal protective equipment (PPE). [29 CFR 1915.12©(3)]”

I can say that for any certificates issued by the Marine Chemist, periodic testing MUST be carried out by the Shipyard Competent Person to maintain the validity. Should the periodic testing NOT be carried out, the certificate MUST be renewed by the Marine Chemist.

Now, these rules do not necessarily apply on vessels while underway. That is where the vessel operator’s rules come in; most likely they are spelled out in their ISM documentation.

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From the OSHA website:

Confined Spaces

Many workplaces contain spaces that are considered “confined” because their configurations hinder the activities of employees who must enter, work in, and exit them. A confined space has limited or restricted means for entry or exit, and it is not designed for continuous employee occupancy. Confined spaces include, but are not limited to underground vaults, tanks, storage bins, manholes, pits, silos, process vessels, and pipelines. OSHA uses the term “permit-required confined space” (permit space) to describe a confined space that has one or more of the following characteristics: contains or has the potential to contain a hazardous atmosphere; contains a material that has the potential to engulf an entrant; has walls that converge inward or floors that slope downward and taper into a smaller area which could trap or asphyxiate an entrant; or contains any other recognized safety or health hazard, such as unguarded machinery, exposed live wires, or heat stress.

Confined space hazards are addressed in specific standards for the general industry and shipyard employment.

“Well, as one who used to make his daily living entering confined spaces and also is also Shipyard Competent Person trained, there are many misconceptions regarding entry and responsibilities. The “Competent Person” is not concerned about they types of hazards in a confined space. Both the Marine Chemist AND the Competent Person are concerned with the atmospheres IN the confined spaces.”

As I said earlier, a Confined Space does not mean it must have an atmosphere concern.
As a student at a Shipyard Competent Person class many years ago, we were taught to be aware of ALL the hazards when working in confined spaces.

The example you cite is a “tank”. A fuel tank? Atmosphere is of obvious importance.
What about a steering compartment with unguarded machinery, sharply sloping decks and a grating as an overhead.?
Does a Marine Chemist need to verify that this open to the atmosphere space is safe for entry?

Learn to operate MSA meters and learn how to span and zero explosive and O2 meters. If your life is on the line count only on yourself. I’ve had mates suck up water and or oily mixes into meters from tank bottoms and ruin the element that burns the atmosphere in an explosive meter. Carry them with you after you initially check the entry area and lower level atmospheric condition. Hydrocarbon vapors are heavier than air so they settle in low pockets. Any O2 reading lower than 21% or LEL (Lower explosive Limit) above 1% get out until conditions can be changed. I don’t go in with any movement of LEL needle. Follow all company confined space entry procedures. I always have a 5 min escape pack on my shoulder to get out fast if conditions changed suddenly. Personal oxygen meters (crickets are a great tool to back up the meters) clipped on your collar should be worn too.

Your company policy of non-entry is good because you don’t have to endanger yourselves or shipmates. We could not delay a $200 million dollar tanker while we waited for some shore gang to do what we were trained to do. I don’t think any seamen like tank work. Take a tank-ship or tank barge course with inert gas thrown in for good measure.