5.

2 ENCLOSED SPACE ENTRY PROCEDURES

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Purpose
To outline safe procedures for entry and working inside enclosed spaces and other spaces with unsafe
atmospheres.

Enclosed Spaces
Enclosed space means a space that has any of the following characteristics:
➢ Limited openings for entry and exit
➢ Poor natural ventilation
➢ Not designed for continuous worker occupancy
Enclosed spaces include:
➢ Cargo spaces: Holds, tanks, containers
➢ Tanks & double bottoms: ballast, fresh water, fuel / lubricating oil, bilge, sludge,
sewage
➢ Engine room spaces: boilers, pressure vessels, crankcases, scavenge air
receivers, thruster spaces, generator spaces, IG scrubber units
➢ Under-deck spaces: cofferdams, void spaces, inter-barrier spaces, chain lockers,
duct keels
➢ Adjacent connected space: A normally unventilated space which is not used for
cargo but may share the same atmospheric characteristics with the enclosed space
such as, but not limited to, a cargo space access way
Note 1
Identify and list all ‘enclosed spaces’ and ‘other spaces with unsafe atmosphere’ on board. Keep this list
in the Life Saving Appliances Training Manuals (LTM) and make all staff aware of such spaces.

Note 2
Entering enclosed spaces is a controlled task and require implementation of Permit-to- Work (PTW)
system procedures. Compliance with the procedures will establish safeguards against human error.

Caution
The nature of the enclosed space will determine the hazards. Enclosed space incidents occur due to
non-compliance with procedures, poor training, complacency, not checking atmosphere prior entries /
after breaks, improper use of gas measuring instrument, entering without adequate ventilation / without
advising other persons, accidental entries, failure to manage shore workers, poor supervision, improper /
impulsive action in emergencies, slip / trip / falls, nature of work, etc.

Other Spaces with Unsafe Atmosphere

Apart from the enclosed spaces there are other spaces which may not meet the criteria for
an enclosed space but may have an unsafe atmosphere.
These spaces do not require the issue of an enclosed space entry permit but are subject to
controlled entry procedures.
Other spaces with unsafe atmosphere include:
➢ Stores: Forecastle stores, paint store, stores within cargo areas of tankers and gas
carriers, cargo/bunker sample lockers, etc.
➢ Equipment room: Ballast water treatment room, battery lockers, CO2 room,
enclosed gas bottle storage lockers, crane motor trunks, tank cleaning heater
rooms, ballast pump rooms, Fuel Preparation Room on LNG fuel vessels, etc.
➢ Other spaces: Enclosed lifeboats, underdeck tunnel, etc.
Clearly mark the entrance of such spaces with the warning notice as below:
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Prior entry:
➢ Ventilate At Least 10 Minutes
➢ Ensure the space is well lit
➢ Inform Duty Officer / Engineer
➢ Carry personal gas meter, where unsafe atmosphere is suspected.

Note 3
Identify and list all spaces with possibility of unsafe atmosphere on board along with enclosed space list.

Note 4
On tankers and gas carriers, refer the respective cargo operations manual for entry procedures into
cargo pumprooms, IG/N2 rooms, compressor rooms. Maintain records of entry and exit of personnel from
such spaces, including separate ballast water treatment plant rooms.

Training and Familiarisation

Do not allow personnel to enter any enclosed space or perform any other duties related to
enclosed space entries / rescue until they have read, understood and trained as per the
vessel-specific Enclosed Space Entry and Rescue Training Procedure. Refer LTM Annex 3.

Securing of Enclosed Space Entrances

Mark all entrances to the enclosed spaces with the following signage:
➢ Identity of the space served
➢ ‘Caution: Do not enter without permit’
Secure the accesses to enclosed spaces when entry is not required. Where a compartment
can be opened with quick release latches / handles / wing nuts / motorized latches, secure
the hatch / door to prevent accidental entry.
For securing of access to cargo holds on bulk and general cargo vessels, refer BGCM Ch.
‘Cargo Hold Entry Procedures’.
Note 5
Identity of cargo hold on non-tankers should be permanently marked with bead weld on all the entrances.

Caution
To prevent accidental/ unauthorised entries or personnel putting their head/ body into the space, post an
attendant or use mechanical barriers with warning signs when hatches, tank lids or any other openings
are opened for checks/ ventilation.

Roles and Responsibilities

Role Description
A Competent Person with sufficient theoretical knowledge and
practical experience to make an informed assessment of the
Approver: Master likelihood of a dangerous atmosphere being present or subsequently
arising in the space.
Responsible
A person having sufficient knowledge for establishing and complying
Officer: Master //
with the procedures to ensure that the space is safe for entry.
C/E // C/O // 2/E
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Role Description
A person trained in the safe entry procedures designated as an
attendant to keep a watch outside the space and must:
➢ Control access to the enclose space and not leave their post,
unless relieved by another qualified attendant
➢ Maintain communication with those inside the space, the
responsible person and the bridge and engine room as directed
Attendant ➢ Monitor conditions in the space as directed
(Vessel staff) ➢ Keep records of atmosphere tests and personnel entry and exit
times
➢ Not undertake any other activities
➢ Initiates the emergency procedure in the event of an accident
Caution: The attendant must always stay alert and not get
distracted from the task of keeping the watch outside the space.
Team leader,
Task Performer Person in-charge of team and person(s) entering the space.

Note: Undertake the risk assessment, enclosed space entry permits, atmosphere testing
as a team activity. Do not do it in isolation or by a single person-in-charge

Enclosed Space Entry Requirements

Master must review that the entry is necessary and there are no alternatives that may remove
the need for personnel to enter the space. No person must open or enter an enclosed space
unless authorised by Master.
If any space is located in machinery spaces, Chief Engineer to countersign such permits.
Prior to making any such authorisation, Master to ensure the Responsible Officer has
carried out the following:
➢ Risk assessment and implementation of controlling measures
➢ All safety checks and preparation required by the PTW system
➢ Appoint only trained and experienced persons for the task
➢ Any isolation assessed and implemented using the Lockout/ Tagout system
➢ Any additional precautions for entry in ballast tanks using Ballast Water Treatment
System (BWTS). Refer maker’s instructions.
➢ Any additional precautions for entry in ballast tanks used as storage of sewage and
grey water effluents. E.g., flushing the tanks for at least 2 cycles, evacuation of
space if strong smell, burning of eyes, irritation of throat, etc are experienced.
➢ Addressing any concerns raised by the staff
Entry Requirements:
Restrict the entry to 1 enclosed space at a time with a separate permit for each space.
At least 2 persons should enter the space, unless impracticable due to space constraints.
Person entering the space must complete the permit along with Responsible Officer and
ensure compliance with all safeguards prior entering to the space.
All personnel entering the space must wear appropriate PPE, and a calibrated personal
multi-gas detector to monitor the levels of O2, HC, H2S, CO and other gases as
appropriate.
On tankers, as far as possible avoid entering double hull or double bottom tanks with
adjacent cargo tanks loaded.
Where not necessary, avoid entry of 2 senior officers from same department at the same
time in one enclosed space.
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Note 6
If necessary to enter 2 or more spaces simultaneously, seek Office approval, designate a separate
attendant for each enclosed space and ensure availability for sufficient resources – people, emergency
rescue equipment, personal gas meters, lighting arrangements, communication equipment, PPE and
ventilation system. For entry into cargo tanks of Chemical Tankers, comply CTM Ch. - Multiple-Tank
Entry Procedures.

Note 7
On tankers, water wash any cargo tank or space containing hydrocarbons before entry. Company
prohibits use of SCBA/ ELSA/ EEBD as an alternative to properly cleaning and gas freeing a space for
safe entry. In exceptional circumstance, if entry is required without water washing, consider the additional
hazards when carrying out risk assessment, take additional precautions as required for enclosed spaces
with known or suspected atmosphere to be unsafe and seek Office approval.

Caution
Consider all enclosed spaces as unsafe for entry. Only after compliance with the requirements of this
chapter and determining safe atmosphere can the Master authorise any such entry. Do not let time
pressures affect the safe planning and conduct of an enclosed space entry.

Caution
A person entering an enclosed space is responsible for complying with enclosed space entry procedures
and must be fit and well to undertake such task. Everyone has the right to refuse to enter a space they
consider unsafe.

Ventilation
Start ventilating well before entry and continue until space is occupied. Continue ventilation
even during temporary breaks.
Keep as many manholes and doors open as possible, but with appropriate entry control
measures. When using portable fans, ensure fan intake is from fresh air.
In certain spaces, such as double hull and double bottom tanks, the most effective way of
ensuring full ventilation is by filling the tank completely with clean seawater and pumping it
out thus drawing in the fresh air.
Ventilate duct keel for at least 2 hours using the fixed ventilation systems provided.
Note 8
Allow for at least 4 air changes if using mechanical ventilation before allowing any entry. Roughly,
estimate the 4 changes by knowing the blower capacity and the time period blower has been in
operation.

Note 9
Where only natural ventilation is possible, allow the space to ‘breathe’ for at least 24 hours, this is if
sufficient openings are available for natural ventilation.

Caution
In the event of failure of the ventilation system, personnel in the space should leave immediately.

Caution
Regardless of the method, do not allow any entry until atmospheric tests have proven a safe, breathable
atmosphere exists.
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Oxygen-rich / Deficient Environment

Oxygen-rich and oxygen-deficient atmospheres both present serious risks.
Oxygen enrichment (O2 levels above 23.5%) increases the flammability of clothing and
other combustible materials.
A relatively small reduction in the oxygen can lead to impaired mental ability.

Caution
Low oxygen concentrations can lead to unconsciousness and death. The effects are very rapid and
generally, there will be no warning to alert the senses. This can happen even in circumstances where
only the person’s head is inside a confined space.

Occupational Exposure Limits (OEL)

OEL is an upper limit on the acceptable concentration of a hazardous substance in
workplace air for a particular material or class of materials.
The term OEL, is also referred as Permissible Exposure Limit (PEL), Workplace Exposure
Limits (WEL), Maximum Admissible Concentration (MAC) and Threshold Limit Value (TLV).

Types of OEL Description

TWA values are calculated by taking the sum of exposure to a toxic
Time Weighted contaminant in terms of ppm-hours during a working day and dividing by an 8-
Average (TWA) hour period. E.g., TWA of H2S is 5 ppm, TWA of CO is 25 ppm, TWA of
Benzene is 1 ppm, etc
Short-Term A 15-minute time- weighted average exposure that should not be exceeded at
Exposure Limits any time during a workday. E.g., STEL of H2S is 10 ppm, STEL of CO is 100
(STEL) ppm, STEL of Benzene is 5 ppm, etc.
Concentration of an airborne toxic substance that should not be exceeded at
any time during the working day.
Ceiling value Note: On board vessels, to prevent exposure to high concentration of gas, set
the personal gas meters to pre-warn as per alarm setting stated in H&S
Chapter - Gas Measuring Instruments. Personnel must evacuate the space on
hearing of such alarm.
Notes:
1. For enclosed entry purposes, ensure the readings are not more than 50% of OEL (TWA) of
toxic vapours and gases. Max permitted values are stated in enclosed space permit.
2. OEL can be found in Section 8 of Safety Data Sheet (SDS). It is normally based on average
exposure time for 8 hours per day and often referred to as Time Weighted Average - 8h
(TWA-8h) and expressed in units of ppm or mg/m3.

Note 10
The Occupational Exposure Limit (OEL) protects the personnel against harmful exposures to toxic
substances and are not the safe working limits. Ensure the exposure is as low as reasonably practicable
and below the Occupational Exposure Limit (OEL) at all times. For alarm settings of gas meters, refer
H&S Chapter - Gas Measuring Instruments

Atmosphere Checks
Check the space and adjacent connected spaces for:
➢ Oxygen (O 2)
➢ Hydrocarbon (HC)
➢ Hydrogen Sulphide (H 2S)
➢ Carbon Monoxide (CO), and
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➢ Other toxic gases as per the SDS of the previous and current content of space
Whilst making preliminary assessment and during checks, bear in mind that internal
structure of the spaces might inhibit proper ventilation and atmosphere checks of remote
areas. Present and previous cargo residues, condition of protective coatings could give out
hazardous gases, causing pockets of unsafe gases. Leaks from adjacent tanks, lines and
valves may also make the atmosphere unsafe.

Atmosphere
Description
Checks
Prior carrying out the checks, stop the ventilation for about 10 minutes
and check from as many openings as possible and at several levels (at
Pre-Entry
least from top, middle and bottom level) of tank.
Check
Caution: Take all gas measurements from safe areas, without entering or
putting the head or body into the space
Once an entry permit issued and before anybody enters the tank for
work, make an initial entry check with 1 or 2 persons (depending on the
size, nature, and layout of the space) with EEBD and a personal gas
Initial Entry monitor.
Check Check the atmosphere with particular attention to the work location(s)
and places that are inaccessible for testing from the deck
During this entry, keep the ventilation running and frequently check the
tank atmosphere from outside.
Re-check the atmosphere at pre-determined intervals (not exceeding 30
minutes) using portable gas meter from a safe remote location by
Responsible Officer or delegated Certified Officer
Re-Checks
Caution: Do not stop the ventilation with persons inside the enclosed space
and during re-checks. E.g., periodically re-check of atmosphere, check after
each break etc.
Notes:
1. Use adequate length of sampling hose/ fixed sampling lines, which can reach remote
areas, including double bottom spaces. Do not lower the meter into the space for
checking.
2. When checking the representative cross section of the space atmosphere, record the
highest reading obtained for HC and toxic gases and lowest reading for O2
3. If the conditions are not safe for entry, apply additional ventilation and conduct a retest
after a suitable interval.
4. Personal gas detectors carried by personnel within an enclosed space are not suitable
for conducting pre-entry and re-testing atmosphere checks.

Caution
In case of any doubt regarding correctness of the readings, immediately evacuate the space. Restrict the
entry until atmosphere has been rechecked and re-entry has been authorised by Master.

Caution
A space certified safe may not continuously remain so, particularly if hot work is being carried out. Ensure
re-checking of atmosphere is carried at specified intervals.
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Caution
Never trust one’s own senses to determine if the air is safe. Many toxic gases can neither be seen nor
smelled.

Enclosed Spaces with Known or Suspected Unsafe Atmosphere

These precautions are in addition to the other precautions stated in this chapter.
Consider entering any space that has not been proved safe only when no practical alternative
exists and when essential for safety of life/ vessel or for the safe operation of the ship.
Except when there is immediate risk to safety of life or vessel where the Master has ultimate
responsibility, prior entering such spaces:
➢ Master must inform Office and record in the deck logbook stating that there is no
practicable alternative to the proposed method of entering the space and it is
essential for the safe operation of the vessel
➢ Carry out risk assessment
➢ Obtain Office approval
➢ Agree on a safe system of work in agreement with Office
A Responsible Officer must continuously supervise the operation and should ensure the
following:
➢ Comply with all the procedures and requirements of this chapter
➢ Only the minimum number of persons required for the work, are entering the space
and for the shortest time possible. Personnel outside are monitoring and recording
all entries and exits
➢ All persons entering the space are wearing:
• Breathing apparatus in positive pressure mode, trained in its use and warned not to
remove the mask in such atmospheres
• Rescue harness and connected to lifeline, where possible
• Appropriate PPE, particularly where there is any risk of exposure to toxic substances
➢ Provide the persons entering with tested and calibrated personal monitors that are
capable of measuring at least O 2, HC, CO and other gases as appropriate
➢ Provide ventilation, where possible
➢ Maintain continuous communication and establish a system of signals
➢ Spare sets of breathing apparatus, a resuscitator and rescue equipment are
available outside the space; a standby party, with breathing apparatus donned, is
in attendance in case of an emergency
➢ All essential work is carried out in a manner that will avoid creating an ignition
hazard

Caution
Do not use canister and cartridge type respirators within enclosed spaces. Do not use EEBDs as the
primary means for entering spaces or compartments with unsafe atmospheres as they are for emergency
escape only.

Precautions when Working in Enclosed Spaces

Exercise caution from other hazards such as:
➢ Slips trips and falls - for example, slippery surfaces and unguarded openings
➢ Heat exhaustion
➢ Burns from heating coils/ remains of corrosive cargo
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➢ Improper illumination and inadequate communication due structures

➢ Tools and equipment to be carried in bag or bucket to avoid getting caught when
climbing ladders
➢ Dust emitted from the use of power tools, cleaning of holds after carriage of grains,
coal, cement etc.
Any cargo pumps, pipelines, valves or heating coils which may contain flammable liquids or
gases, should be thoroughly flushed with water, prior to opening if possible. Continuously
monitor tank atmosphere near work area.
Do not carry out hammering/ chipping if there is probability of hydrocarbon vapours.
Note 11
As far as possible, remove loose scale, sludge or combustible material from work site. Maintain
continuous effective ventilation, directed towards the work area by using portable ventilation hoses, ducts
or chutes if required.

Caution
Increase the frequency of testing of the atmosphere in case the work conditions change. E.g. increase in
ambient temperatures, carrying out hot work, painting, removal of sludge / scale / sediment or any other
works, which could give off vapours.

Exit and Closure of Jobs

Prior exiting the space, the persons working inside the space must check and remove all
the tools and equipment.
Record the time of exit and attendant to confirm that all persons are out the tank.
Shut and secure the entrances as required and inform Master (Chief Engineer, if work is in
engine room). Remove any Lockout/ Tagout and withdraw other permits issued.
Inform all persons involved about the completion of the job and withdrawal of the permit.
Master to sign the closure of the permit, on completion of the job.

Caution
Once the enclosed space entry permit is withdrawn / cancelled, any other permit, if issued for work within
that space, also gets automatically withdrawn.

Emergency Response Plans

Responsible Officer must discuss the emergency procedures with all personnel involved
prior entry.
Rescue team to involve only trained personnel.
For emergency rescue from enclosed spaces, refer ECM Chapter Emergency - Personnel
Accidents

Caution
Under no circumstances must the attendant or any other person enter the space before help has arrived
and the situation has been evaluated to ensure the safety of those entering the space to undertake
rescue operations.

Working with Shore Contractors

Outside contractors involved in enclosed space tasks must comply with the Company's
enclosed space entry procedures.
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Confirm contractors are aware of the dangers involved and the actions to take in an
emergency.
PPE used by outside contractors, as a minimum, must comply with the vessel's equipment
standards and procedures for use.
For contractor management and safety procedures in shipyard and for afloat repairs, refer
to the H&S manual chapter ‘Contractor Management’.
Note 12
Always designate a vessel staff as an attendant, even when shore contractors are entering the space.

Work Boats
Exercise caution when using workboats inside enclosed spaces - for example, tank repairs
and inspection.
Apart from all precautions required for enclosed space, take the following precautions:
➢ Use a suitable workboat fit for the task
➢ Open all deck apertures, such as tank washing covers, and continuously ventilate
while persons are in the tank
➢ Ensure water surface is calm and contains only clean ballast water
➢ All task performers, including the surveyor/ contractors must wear a buoyancy aid
➢ Post an attendant at the top near tank hatch. If the boat is working remotely away
from tank hatch, attach painters to the work boat and post an additional lookout a
little way down the access ladder with a clear view of the boat

Caution
The water level in the tank must be either stationary or falling. On no account must the level of the water
be rising while the boat is in use.

Hazards Related to Specific Types of Vessels or Cargo

Follow additional procedures as per the individual cargo operations manuals for:
➢ Multiple tank entries on Chemical Tankers
➢ Pump room entry on Oil Tankers
➢ Compressor/ motor rooms entries on Gas Tankers
➢ Cargo hold entries on Dry Vessels
➢ Use of nitrogen as an inert gas

Caution
Nitrogen is a colourless and odourless gas - when used as an inert gas, causes oxygen deficiency in
enclosed spaces and near exhaust openings on deck during purging of tanks, void spaces and in cargo
holds. A single breath of 100% nitrogen gas will be fatal.

Liberian Flagged Vessels

Additional requirements and recommendations for entry into enclosed spaces and enclosed
space entry and rescue drills:
➢ Enter the Competent Persons (Master) record of certification in the Official
Logbook
➢ Maintain records of enclosed space entry drills in the Official Logbook
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➢ On vessels not equipped with BA compressor, carry at least 2 additional fully

charged spare BA cylinders dedicated for drill (in addition to those required under
SOLAS II-2 regulation 10.10).

Forms and checklists: References:

CL: EMRG /17 Training Material #174, 165, 150
RA: DKM 037 QA Poster QA-36
WI: LTM Annex 3
FORM: PTW01