Worked an LPG tanker in dock recently. Company insisted the tanks had been cleaned and safe for entry. I insisted on Chemist. His meter started alarming due to high VOC’s even as he approached the tank. Needless to say took several additoinal days of heavy duty ventilating before it could be safely entered. As Reagan said: “Trust but verify!”
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Based on an old Russian proverb.
But I know our SMS very well.
I just wanted to find out what it looks like with you.
Perhaps, I should precede my question with such an explanation.
I am interested in chemical tanker procedures where washing and entering the cargo tanks for mopping and/or inspection is almost a routine activity. Checking the atmosphere in the tank and preparing the appropriate permits is the responsibility of the crew and not the external inspectors.
So far we have been able to place six cargo tanks on one permit and the time interval for gas re-checking has been set to two hours, permit valid for 8hrs.
Currently, to meet the “high safety standards”, whatever that means, it is planned to reduce the number of cargo tanks to four and the recheck time interval to 30 minutes. In my opinion, this is an unnecessary complication having no real basis. Therefore I would like to know the sources of these high safety standards.
Just to make sure.
Does it apply to cargo tanks or are these general requirements for all other enclosed spaces?
Do you know about any exclusions for benzene.
I like sea stories but maybe not this time.
All enclosed spaces should be treated the same. Doesn’t matter what it is or what was, or was not, in it.
I don’t know about @Mmamate, but 6 tanks on a permit is 5 too many for me. Each tank should have an individual permit with its own atmospheric readings. I think 30 minutes is too short an interval, personally.
Totally agree. That has been my guiding light. That is why I’m still alive.
I was of the impression Reagan was an actor, not a seaman??
Yeah, every space gets its own permit. Doesn’t matter if it’s a cargo tank or any number of other enclosed spaces.
It’s a lot of paperwork if you’re inspecting several tanks or voids in one day, but more than one space on a permit sounds like checking a box for having a permit but taking a big shortcut in protecting those entering the spaces.
I am a retired Shipyard Competent Persson.
Trained by a Marine Chemist.
Commercial/US Navy ships.
42 years in the ship repair industry.
All Entry certs for tanks and spaces are inspected at least once a day. If conditions change, re-check the space /tank. Always check the log (Form 74) at the space/tank and gangway with the copy of the Marine Chemist Certs before entering. If in doubt, call the SPC or the Marine Chemist.
I have seen a lot of near misses because the workers just want to get the job done. Always keep SAFETY IN MIND. The job will get done and we want all want to go back home to our families in one piece.
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I don’t think there is one.
Captain. It is listed in the CFR for the Shipbuilding/Shiprepair.
O2- 20.8
Lel- <5
Toxic Gases- 0
H2S- 0
The allowable levels weren’t the question.
Do you know what exactly “Toxic Gases - 0” means? In my opinion it cannot be written like that. In fact, it is very difficult to reliably measure toxic gases but that is another problem.
Then on what basis were the relevant SMS developed, maybe there is something about the OSHA regulations?
This is how it looks in our SMS.
3.5.1 Cargo Tanks
A single permit may be issued for entry into a maximum of 4 (four) cargo tanks, provided that
the individual cargo tanks are clearly marked to indicate which cargo tanks are safe for entry.
3.5.2 All other Enclosed Spaces
A single permit must be issued for each individual compartment it is intended to enter.
3.7 Records of Atmosphere Re-ChecksThe atmosphere of the compartments must be rechecked
at intervals not exceeding 30 minutes when persons are in the tanks (this can also be
done by Attendant at the top) and prior the space is re-entered after any interruption or
occupancy or break in the work. The results of the atmosphere re-checks must be recorded in
“Table 2 – Record of Atmosphere Re-Checks” of the Enclosed Space Entry Permit.
The Document of Compliance (DoC) and ISM Certificate is issued by one of well-known European maritime country.
I quoted wrongly, but you consciously interpret even worse.
Anyway, let’s not go into that now, please. It would be better if you wrote how the number of cargo tanks on a single permit is specified by the Sjofartsdirektoratet or quoted the relevant entries from SMS of such well-known shipowners as Stolt, Odfjell, Utkilen or Seatrans.
My meter would go through the various gases it could sense If there were no evidence of a particular gas or vapor in the tank it would read zero for that gas. I presume that was what was meant.
My meter would read zero for CO but if there was a welder on deck that was gasoline driven CO entered the tank through the open hatch the meter would alarm and the gas in ppm would be indicated
Very common occurrence
I don’t know the SMS of individual Norwegian shipping companies as I haven’t sailed on Norwegian flag ships since 1970.
.
As for the Chemical tanker companies you mention I would assume they follow IMO Recommendations for this (and other subject):
Since they have ships under many different flags the SMS for individual vessels MAY have to differ to comply with flag state rules though.
PS> I couldn’t find any specific rules, regulations or guidelines from NMA re: confined space entry on NOR or NIS registered ships. (IMO recommendation apply)
Check CFR 29
The toxic gases are measured in PEL-Person Exposure Limits.
My bad. Been retired for a while in this fast changing world.
Keep in mind, when opening a tank or hatch please have your 4 gas calerbrated meter with you.
OSHA regulations are set forth on the CFR and I saw nothing in there that would specifically answer your question.
If so, it must be true;
8.1 The relevant sections of the Tank Entry Permit (see appendix) should be filled in
upon completion of preparations for tank entry. Entry permits may be made for multiple tank
entries, however tanks which are not immediately entered should be re-tested and a new
permit issued. At no time should a permit be granted for entry into more than six tanks.
Then on what basis your colleagues say what they say?
If I had to guess I would say one or both of the following:
- Their own personal opinion on the safety of the matter via experience on tankers.
- Their company’s SMS.
Most of us are alive now. Due to our own knowledge, common sense and intuition
Sorry to say, but it is the worst possible approach.
All procedures, including the more risky activities, are based on the experience of the entire industry sector and not on the intuition, common sense or even knowledge of a single person.
Much more would have survived if they had simply followed the proper procedures.
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Why is being more careful than the proper procedures require the “worst possible approach”?