Enclosed Space Entry: New SOLAS requirement for the carriage of atmosphere testing instruments enters into force

At its ninety third session in May 2013, the Maritime Safety Committee (MSC) of the International Maritime Organisation (IMO) approved the new draft SOLAS regulation XI-1/7 "Atmosphere testing instrument for enclosed spaces", which entered into force on 1 July 2016.

This new regulation makes it mandatory for all ocean going ships to which SOLAS applies to carry on board an appropriate portable atmosphere testing instrument or instruments. As a minimum, these instruments shall be capable of measuring concentrations of oxygen, flammable gases or vapours, hydrogen sulphide and carbon monoxide prior to entry into enclosed spaces. The new regulation also requires that suitable means are to be provided for the calibration of all such instruments.

When considering compliance with the new regulation, Members attention is drawn to

MSC.1/Circ.1477

dated 9th June 2014, which provides guidelines to facilitate the selection of portable atmosphere testing instruments.

The introduction of this SOLAS amendment can be viewed as removing the regulatory ambiguity created in January last year by the entry into force of amendments to SOLAS regulation III/19 requiring mandatory enclosed space entry and rescue drills, which are to include the "checking and use of instruments for measuring the atmosphere in enclosed spaces".

Whilst this new regulation is most welcome, in practice many ships will already be in compliance either due to other regulatory or operational requirements or simply to conform with existing IMO recommendations or industry good practice in this respect. In particular, members should ensure that all persons with enclosed space entry responsibilities are made fully familiar with the content of

IMO Resolution A.1050 (27

) "Revised Recommendations for Entering Enclosed Spaces on Board Ships". The objective of these recommendations is to encourage the adoption of safety procedures aimed at preventing casualties to ships' personnel entering enclosed spaces where there may be an oxygen-deficient, oxygen-enriched, flammable and/or toxic atmosphere. In specific relation to gas testing, the recommendations direct that the atmosphere of an enclosed space should be tested with properly calibrated equipment by persons trained in its use and that the manufacturer's instructions should be strictly followed. Testing of the space should be carried out before any person enters and at regular intervals thereafter until all work is completed.

The loss prevention department aims to reduce Members’ exposure to claims by raising awareness of risk. Co-ordinated by the Loss Prevention team is a dedicated team of Risk Assessors.

The Risk Assessors supervise and co-ordinate the activities of the five ship inspectors and control the condition surveys which are carried out (by independent surveyors) under the Club’s Rules. The Risk Assessors travel worldwide in order to carry out their tasks. Permanent bases are maintained in Rotterdam, Greece and Singapore. All the Ship Inspectors are qualified QA Lead Assessors and are familiar with the requirements of the ISM Code.  For more information on our Loss prevention team please contact lossprevention.ukclub@thomasmiller.com