It seems to vary by company and size of trunk whether multideck escape trunks are fitted with safety nets. I’m trying to research if there are any SOLAS/ CFR requirements that dictate when/ if a safety net needs to be installed in an escape trunk. So far I’ve only turned up the Navy Ships’ Technical Manual (S9086-UF-STM-030) which required Trunk Safety Nets be installed if the vertical ladder is longer than 5.18m (17ft) (600-18.4.5). Does any one have a company policies that require fall prevention gear be used while conducting routine inspections and non-emergency use of multideck (significant fall hazard) trunks?
SOLAS II-2 Reg 13 – Means of Escape 1.3 additional aids for escape shall be provided as necessary to ensure accessibility, clear marking, and adequate design for emergency situations.
This is the only thing in either SOLAS or the FSS Code which discussing anything other than ladders, ladder enclosures, and marking of means of escape. What does “additional aids” mean? Could be a safety net, could be a harness, and could be nothing. All depends on your ship’s specific layout.
46 CFR Subchapter I – Cargo and Miscellaneous Vessels 46 CFR 92.10 – Means of Escape makes no mention of any type of additional aids being required.
I’ve also found in the OSHA Regulations 1926.501(b)(1) “Unprotected sides and edges. Each employee on a walking/working surface (horizontal and vertical surface) with an unprotected side or edge which is 6 feet (1.8 m) or more above a lower level shall be protected from falling by the use of guardrail systems, safety net systems, or personal fall arrest systems.”
That seems to require something be in place but does it apply to ships?
Somebody speak up if I’m wrong about this, but my understanding has always been that OSHA has no authority or relevance in the marine industry outside of shipyards.
I will add my personal opinion to this conversation. Escape trunks are just that and not your typical ingress/egress paths to a workspace. Such things as personal fall arrest systems are problematic when the purpose is to get the hell out. It is a different story if one is working in that space in which case the use of safety belts and the like are warranted.
I do not know if this is federally mandated but 6’ has been company policy at every company ive worked at regarding PPE.
This makes the most sense based off what I can see on a ship, also with most American ships being born in or visiting an American shipyard, it would need to be OSHA compliant
therefore:
If Im understanding the question correctly, what we should be looking for are fixed ladder safety systems? Im seeing 29 CFR 1910.27(D) being cited.
The stuff on these guys website looks like what we have for fixed ladder safety on the post 2017 regulation American vessels ive been on. And what they had on their site about pre-2017 regulations about just having the cage around the ladder makes sense with what Ive seen as well.
In practicality unless you are asking for help on a new build, in most trunks I’ve seen I think the safest move if you’re doing maintenance or something would be a “yoyo” on an i beam clamp or shackle to a padeye at the top of the ladder, definitely justified being 6’ off the deck. Id much rather the yoyo catch me than relying on a body part getting caught on one of those ladder cages.