Enclosed Space Entry
The seemingly simplest operation that continues to cause fatalities on board: why the bi-monthly drill mandatory since 2015 exists, and how to make it genuinely useful.
Operational Explanation
Confined spaces (cargo holds, tanks, cofferdams, double-bottom spaces) present a specific and recurring risk: an atmosphere deficient in oxygen or containing toxic/flammable gases, often not detectable without instrumentation, even in spaces that appear ventilated or have already been inspected previously.
Fatal accidents in confined spaces frequently follow the same pattern: a first victim enters without checking the atmosphere, a second crew member enters to rescue them without adequate protection, increasing the number of casualties. This is why the periodic drill focuses as much on prevention as on the correct rescue procedure.
Regulatory Reference
SOLAS Chapter III, Regulation 19.3.5 (in force since 1 January 2015): all personnel involved in enclosed space entry and/or rescue operations must take part in an enclosed space entry and rescue drill at intervals not exceeding 2 months, covering the use of PPE, atmosphere-testing instruments, communication and rescue equipment, and basic first aid.
Scope of Application
Every ship with spaces classifiable as confined (cargo holds, tanks, double-bottom cofferdams, pump rooms), for all personnel involved in entries or rescue operations.
Procedure / How to Complete It
- Never enter a confined space without a formal authorisation (permit to work) and a prior atmosphere check.
- Test the atmosphere with calibrated instruments (oxygen, flammable gases, toxic gases) before entry and periodically throughout the time spent inside.
- Ensure adequate ventilation of the space before and during entry.
- Keep an outside attendant in constant communication with those inside.
- Conduct the enclosed space entry and rescue drill at least every 2 months, with participation of all personnel involved.
- In an emergency, never enter to rescue someone without breathing apparatus and support, to avoid adding further casualties.
Practical Example
Example drill: simulation of a crew member falling ill inside a double-bottom cofferdam, with recovery using a harness and tripod, use of breathing apparatus by the rescue team, and verification of communication with the outside throughout the operation.
Real Cases
Common Mistakes Mistake Library
| Mistake | Consequence | How to avoid it |
|---|---|---|
| Entry without instrumental verification of the atmosphere, relying only on the visual appearance of the space | An oxygen-deficient or toxic atmosphere goes undetected, a mortal risk | Always test the atmosphere with calibrated instruments before every entry, without exception |
| Immediate rescue attempt without breathing apparatus when the person inside falls ill | The rescuer becomes a second victim | Train the crew never to enter to rescue without adequate protection, even in an emergency |
| Bi-monthly drill skipped or reduced to mere theory without practical exercise | The crew fails to gain real familiarity with using the equipment in an emergency | Always conduct the drill with hands-on use of PPE, instruments and rescue equipment |
PSC Observations
Operational Tips
- Never make exceptions to the instrumental atmosphere check, even for spaces considered 'safe' based on past experience.
- Constantly repeat the most important rule to the crew: never rescue without breathing apparatus.
- Use the bi-monthly drill as a genuine practical test, not as a theoretical formality.
Checklist
- Formal permit to work issued before every entry
- Atmosphere tested instrumentally before and during the time spent inside
- Adequate ventilation ensured before and during entry
- Outside attendant present and in constant communication
- Entry and rescue drill conducted at least every 2 months