Confined spaces in ports

People are killed or seriously injured in confined spaces each year in the UK. This happens in a wide range of industries, from those involving complex plant to simple storage vessels.

Those involved in these incidents include not just people working in the confined space but also those who try to rescue them without proper training and equipment.

A space can be any space of an enclosed nature where there is a risk of death or serious injury from hazardous substances or dangerous conditions (eg lack of oxygen).

Where a confined space on a ship is involved, co-operation between the shoreside employer and master is essential to ensure that all relevant risks are managed and duties are adequately discharged.

Where can confined spaces be found?

Confined spaces can be found in a variety of places within the port environment including some ships' holds, warehouses, silos and freight containers. In addition some places may only become confined spaces when particular work is carried out eg fumigation. Further guidance on where confined spaces may be found in ports can be found in PSS Safety in Ports Guidance sheet SIP015 Confined Spaces.

MAIB Safety Bulletin 3/2014 - Suntis

Following a recent incident on board a cargo ship that resulted in 3 fatalities, the MAIB have issued a Safety Bulletin that covers procedures for entering confined spaces on board ship and also the need for emergency rescue plans.

Fumigation of freight containers

Fumigants are highly toxic. Cargoes most likely to have been fumigated include foodstuffs, leather goods, handicrafts, textiles, timber or cane furniture, luxury vehicles and cargo in timber cases or on timber pallets from China.

Containers transported under fumigation are required to be labelled and declared in accordance with the International Maritime Dangerous Goods Code. However, absence of marking cannot be taken to mean fumigants are not present. Containers marked as having been ventilated after fumigation may also contain fumigant that was absorbed by the cargo and released during transit.

Any container suspected of containing fumigant should be:

  • carefully opened in the presence of a competent person, such as a pest officer trained in using fumigants
  • tested for the presence of fumigants
  • ventilated if necessary
  • competent person to remove any traces of fumigant
  • competent person to issue a 'gas free' certificate

Wood pellet bio-fuels and confined spaces

The manufacture and carriage of wood pellets has increased in recent years because of their use as a non-fossil heating fuel.

The pellets are produced from sawdust and wood shavings and do not contain any additives or binders. The sawdust and shavings are dried, and milled into particles that are then compressed.

Wood pellets undergo oxidation to produce carbon monoxide and carbon dioxide. In a confined space such as an unventilated ship's hold, this can lead to a dangerous reduction in the oxygen concentration in the hold as well as the development of a dangerous concentration of carbon monoxide which is toxic (and flammable). In a recent case a carbon monoxide concentration of approximately 1% was measured in a sealed cargo hold of a ship containing wood pellets some 18 days after the cargo was loaded. The oxygen concentration at this time was less than 1%. Since the cargo hold was an enclosed space and there was a clear specific risk of oxygen depletion and potential noxious fume, this hold would constitute a confined space.

Since May 2002 there have been reports of fatalities throughout Europe. In Rotterdam one person was killed and two other people were severely injured as a result of exposure to carbon-monoxide when entering one of the cargo holds. In November 2006 in Helsingborg, despite clear instructions on-board and an elaborate system of temperature sensors in the cargo as well as gas sampling tubes at various levels of the cargo hold, one person was killed and several other people were injured, one seriously. In other incidents in Swedish ports, five people were reported killed during a period of 24 months. The main caused appears to be oxygen depletion and to a lesser extent carbon-monoxide.

Accidents have also been reported in Germany, including two fatal incidents and two near fatalities.

What law applies?

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Updated 2022-07-07