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A06
Working Safely

Version 05 - Issue Date: 01.10.2024

DONT WAIT FOR SOMEONE TO TELL YOU HOW TO WORK SAFELY

If you're not sure, it's probably not safe - stop and ask.
Let's all get home safely.

The majority of accidents on board ship can be avoided by following correct procedures and using appropriate tools, equipment and clothing. Before you start work, think about how to keep yourself and everyone around you safe.

There are a number of excellent external guides about working safely, one of which is the Code of Safe Working Practices for Merchant Seafarers (COSWAP). Every ship is provided with one of these, and everyone should be familiar with its guidance.

Crew members will be advised of the dangerous nature and possible hazards of any work to be carried out. They will also be instructed as to any necessary precautions to be taken including the use of protective clothing and equipment. Always follow these instructions!

There may be times when deck crew will have to help in the engine room, or engine crew have to help on deck. The different working environment can mean that the personnel involved may not be familiar with the tasks or the risks involved. It is therefore essential that in these cases a briefing and risk assessment are carried out by a senior officer beforehand to make sure everyone is familiar with what is needed and that they know the risks and precautions.

Keeping everyone safe is our first priority, and it also needs to be yours. 

Always use proper PPE, always look after your PPE!

Personal Protective Equipment will not in itself prevent an accident from happening but if used appropriately and correctly it will help prevent or minimise injury in an accident.

Remember, if PPE is not used correctly, does not fit properly or is not in good condition, it can actually make things worse!

The Company will provide the right PPE for the job. It is your job to look after it, to make sure it is working properly before using it, and to tell the Company if replacement equipment is needed.

Never start work if the PPE is wrong, damaged or not working!

No work is to start unless:
- Everyone involved has the right PPE
- The PPE is in good condition, tested as required
- The PPE is being used properly

If you see work being done by people not using proper PPE, stop the work immediately.

Everyone has the right to stop a task if proper PPE is not being used.

Requirements for wearing PPE apply, without exception, to everyone onboard. This means that all crew must use proper PPE, but also anyone else who comes onboard our ships.
Any person required to use protective clothing and equipment is to be properly trained or instructed in its use and advised of its limitations.

Instructions for proper use or maintenance of equipment or clothing are to be kept with the item or in a safe place near where it is stored.

Visitors to working areas must observe the Company's safety regulations and wear the appropriate protective clothing. If stevedores or other shore-workers do not use or have not been provided with suitable PPE, this must be brought to the attention of their foreman or manager.

If you see equipment being used or maintained incorrectly, say something! 

Protective clothing and equipment is issued to each employee or is kept in an easily accessible and clearly marked location. PPE must be stored in a way that stops it being damaged or from deteriorating due to the conditions. It must always be kept separately from harmful substances!

PPE issued to an individual must be stored safely, and looked after properly. Always follow the instructions on the PPE itself. If your PPE is damaged or has passed its expiry date, it must be replaced. If you have a query about your PPE, ask your head of department or the Master.

Never, ever use PPE in a way that it isn't designed for.

All other equipment is to be maintained in accordance with the manufacturer’s instructions, regularly inspected and its operation checked before use where possible, or at the interval required by the manufacturer.

The equipment is to be cleaned thoroughly, repaired or replaced as necessary. The Safety Officer and Heads of Department are to ensure that stocks of protective equipment are maintained to an appropriate level. 

Appropriate PPE is to be worn for all tasks carried out onboard. The Master must ensure that risk assessments carried out prior to the commencement of work include a section on the required PPE. The person in charge must ensure that the required PPE is being worn at all times during the task.

For tasks carried out on a routine basis, the Master should ensure that the responsible person completes a list detailing what PPE is to be worn every time the operation is carried out. Even where this list is available, the risk assessment is where the correct PPE is identified.

1. Ear Defenders (Ear-Muffs)
In areas where high noise levels exist, ear defenders are to be worn by all personnel. A standard sign is to be displayed at each entrance to a space which routinely has high noise levels, but it is the responsibility of each individual person to ensure that ear defenders are worn anywhere that noise levels are high, even temporarily. Don't put your hearing at risk. Use ear defenders whenever it is loud.

2. Eye Protection

Goggles are available on board and offer protection against the risk of foreign bodies entering the eyes when carrying out operations such as grinding and chipping and also when handling chemicals. Signs are to be displayed in workshop areas to warn of the need to use eye protection. .

During welding and burning operations, suitably approved goggles/visors must be worn to prevent eye damage from Ultra-violet light.

3. Body Protection
Protective overalls or other safety clothing is to be worn as appropriate to give adequate protection against foreseeable risks within the relevant work area. Your working clothing must fit you, if it doesn't request replacement.

Work clothing must be kept as clean as possible for health and hygiene, particularly when handling food. You need to be aware of the risk of dermatitis or skin cancer from prolonged contact with various oils or other hazardous substances.

Overalls or other working clothes must be correctly closed (i.e. zips/buttons fastened) to give maximum protection to the body during work.

4. Respiratory (Breathing) Protection
There are various types of respiratory protection equipment available, it is essential that the correct equipment is worn for the specific task to be carried out.

Respirators do not protect you from a space with low oxygen, or a space which contains harmful gases. Whenever entering an enclosed space, use the proper procedure, it could save your life.

Some types of respirator (filter canister type masks) are designed to protect from specific chemicals and are sometimes used in the petrochemical industry. However, these are not suitable for shipboard use.

The only sure way that you can guarantee the air you are breathing is safe in a harmful or oxygen-poor space, is to use a compressed air breathing apparatus.

Always follow the procedure for entering an enclosed space, even (maybe especially) if you are not sure if the space is actually enclosed.


5. Safety Harnesses
Safety harnesses are to be used any time that work is to be carried out at height. All work at height is to be carried out only after a proper risk assessment has been carried out.

A safety harness is completely ineffective if it is not properly secured or if it is secured to an unsuitable point. 

The Master is responsible for ensuring that there is a safe means of access between the vessel and the shore or between the ship and any other ship.

Equipment used for this purpose must be well maintained, in proper working condition, rigged correctly and promptly, adjusted correctly, and monitored and kept safe throughout the ship’s stay.

All access points and equipment providing access are to be well lit.

Appropriate safety and warning signs are to be posted at the access to the ship.

Access equipment is to be kept free of snow, ice, cargo, oil, and grease residues at all times.
In the interests of security, wherever possible, access to the ship is to be limited to one point at the gangway or accommodation ladder.

Each Access point is to be manned at all times by a crew member with a means of contacting the Officer of the Watch. The crew member assigned to this duty is not to leave their post at any time without being properly relieved.

Under no circumstances is this watchman to escort visitors throughout the vessel unless a relief watchman is in place at the access point they are assigned to.

The requirement for access points to be properly manned applies whether the means of access is by gangway, ladder, or by any other means.

All personnel, whether ship staff, visitors, stevedores, contractors, authorities or anyone else, are to use properly designated access points and proper means of access. Incidents where individuals are observed accessing the vessel by any other means are to be reported immediately as “incidents”, additionally the Master is to notify the Ship Management Team at the earliest opportunity. In the case of a crew member, such action will be considered serious misconduct and may result in serious disciplinary consequences.

The following additional notes are made to ensure safe means of access can be maintained:

1. Rigging Gangways
Gangways must not be rigged at an angle of more than 30° and accommodation ladders no more than 55° from below the horizontal unless specifically designed for greater angles.

Where a gangway or accommodation ladder rests on top of a bulwark or strengthened handrails, a bulwark ladder must be provided. Any gap between the gangway or accommodation ladder and bulwark ladder is to be fenced to a height of at least 1 metre. Handrails are to be fitted to at least one side of the bulwark ladder to ensure safe passage to and from the gangway.

After the means of access has been rigged, it must be checked to ensure that it is safe to use. Regular checks are to be made during the period of use and any adjustments made as required. Stanchions are to be securely rigged and guard ropes or chains kept taught at all times.

The access point should be located away from any area where a suspended load is expected to pass, such as a cargo working area on a general cargo vessel.

A gangway or accommodation ladder must never be allowed to drop between the ship and the quay or other structure in such a way that it may be crushed or damaged.

If the gangway is fitted with wheels or rollers, it must be fitted or protected in such a way to prevent feet from being caught and is to be placed in a position that does not restrict the free movement of the wheels. If the landing surface is rough suitable material is to be placed under the wheels to ensure free movement.

When a bulwark ladder is used in conjunction with a gangway it must be fitted in such a way that it is properly and safely secured.

Ship’s handrails are not to be used to support gangways unless the rail has been specially reinforced for that purpose.

Gangways and accommodation ladders are normally the main types of accesses used, however some vessels may have other access methods that require special handling and precautions. The Master must ensure that they and their crew understand and adhere to these specific requirements.
Rope ladders must only be used as a means of access if there is no other safe alternative available as a result of the port in which the vessel is operating. Where a rope ladder is used as a means of access it must be rigged to the same standard as a pilot ladder and must be manned at all times like any other (conventional) means of access.


2. Gangway Safety Nets
The purpose of a safety net is to minimise the risk of injury arising from falling between the ship and quayside, between two ships, or falling onto a quay or jetty.

Safety nets of suitable strength, dimensions, mesh size and strength must be rigged using available securing points on the ship and on the shore. Where practicable, the whole length of the access is to be covered with such a net.

The method of rigging the net so it passes underneath and up the sides of the gangway, securing it to the top rope and thus enclosing the spaces between and under the hand-ropes is incorrect. This protects a person from falling through the ropes, however it does not offer any protection for the person falling off the gangway over the top hand-ropes.

For a standard accommodation ladder parallel to the ship’s side, the net should be rigged so it will prevent someone falling between the ship and quay. Rigging the net so it also encloses the outboard and top rails will also enhance safety.

For an athwartships brow gangway, safety nets must be rigged so that the safety net extends on both sides of the brow for a distance of 1.8m, and the net is to be kept taut at all times. To achieve this it will be necessary to attach the nets to the shipside rails on either side of the gangway. On most brow gangways the critical part is the transfer at the top from brow to bulwark ladder and it is essential that this area is properly protected.


3. Other Equipment at Access Points
A lifebuoy fitted with a self-activating light and a separate buoyant line attached to a quoit, or similar device, is to be provided ready for use at the point of access to the vessel. Note that for tankers and other vessels carrying dangerous cargoes, the lifebuoy lights must be intrinsically safe.


4. Maintenance of Access Equipment
All ship’s access equipment must be maintained according to the manufacturer’s instructions and the vessel’s planned maintenance system. It must be visually inspected prior to each use and subjected to a thorough inspection by a Deck Officer on at least an annual basis.

All moving parts and wire falls are to be adequately lubricated with the correct oil or grease. Any damages to wires or ropes are to be investigated carefully and, if deemed necessary, replaced or renewed. A careful check is to be made for any signs of cracking or corrosion.

The majority of gangways and accommodation ladders are constructed of aluminium alloys which can corrode easily when in contact with other metals. Care must therefore be taken to ensure that joints of rubber or neoprene are used between steel fittings (e.g. stowage points, washers etc.) and aluminium. Any repairs using steel doublers or bolts made from steel or brass are to be considered only temporary. Permanent repairs must be undertaken as soon as possible.

5. Shore-Supplied Access Equipment
When the access equipment is provided by the port authorities or another shore-party, it remains the responsibility of the Master to ensure as far as practicable that the equipment is suitable for the needs of the vessel, that it is properly rigged, safe for use and adequately illuminated.

Should defects or deficiencies in shore-supplied access equipment be noted, they must be reported to the shore authority who supplied the equipment immediately for repair or replacement. An unsafe means of access must not be used under any circumstances. In the event that the port authority is unwilling to act on the noted defect or deficiency, the Master is to advise the Ship Management Team immediately.  

Irrespective of anything contained in this section, at all times the requirements of the International Maritime Pilots’ Association with respect to boarding arrangements for pilots are to be complied with, and in addition all personnel involved should exercise good seamanship and the norms of common sense.

Pilot transfers are risky operations. The pilot is there to get you safely into and out of port, it is our responsibility to get them safely on and off our ship.

Regulations regarding maintenance and pilot transfer arrangements entered into force on the 1st July 2012. Any new ladder or associated equipment purchased after this date must be certified by the manufacturer as per MSC.308 (88) SOLAS Regulation V/23.

All ladders used for pilot transfer shall be clearly identified with tags or other permanent marking so as to enable identification of each appliance for the purposes of survey, inspection and record keeping.

A record shall be kept on the ship as to the date the identified ladder is placed into service and any repairs effected.

01 Position and Construction
The securing points, shackles and securing ropes should be at least as strong as the side ropes specified below.

Ropes
The side ropes of the pilot ladder should consist of two uncovered ropes not less than 18mm in diameter on each side and should be continuous, with no joints and have a breaking strength of at least 24KN per side rope. The two side ropes should consist of one continuous length of rope, the midpoint half-length being located on a thimble large enough to accommodate at least two passes of side rope.

Side ropes should be made of manila or other material of equivalent strength, durability, elongation characteristics and grip which has been protected against actinic degradation and is satisfactory to the Administration.

Each pair of side ropes should be secured together both above and below each step with a mechanical clamping device properly designed for this purpose, or seizing method with step fixtures (chocks or widgets) which holds each step level when the ladder is hanging freely. The preferred method is seizing.

Steps
The steps of the pilot ladders should comply with the following requirements:

1. If made of hardwood, they should be made in one piece, free of knots
2. If made of other than hardwood, they should be of equivalent strength, stiffness and durability to the satisfaction of the Administration.
3. The four lowest steps may be of rubber of sufficient strength and stiffness or other material to the satisfaction of the Administration.
4. They should have an efficient non-slip surface.
5. They should not beless than 400mm between the side ropes, 115mm wide and 25mm in depth, excluding any non-slip device or grooving:
6. They should be equally spaced not less than 310mm or more than 350mm apart
7. They should be secured in such a manner that each will remain horizontal.

Replacement Steps
No pilot ladder should have more than two replacement steps which are secured in position by a different method from that used in the original construction of the ladder, and any steps so secured should be replaced as soon as is reasonably practicable by steps secured in position by the method used in the original construction of the pilot ladder. When any replacement step is secured to the side ropes of the pilot ladder by means of grooves in the sides of the step, such grooves should be in the longer sides of the step. Any repairs affected should be logged in the maintenance log.

Spreaders
Pilot ladders with more than five steps should have spreader steps not less than 1.8 metres long provided at such intervals as will prevent the pilot ladder from twisting. The lowest spreader step should be the fifth step from the bottom of the ladder and the interval between any spreader step and the next should not exceed nine steps.

Retrieval Lines
When a retrieval line is considered necessary to ensure the safe rigging of a pilot ladder, the line should be fastened at or above the last spreader step and should lead forward. The retrieval line should not hinder the pilot nor obstruct the safe approach of the pilot boat.

Permanent Markings
A permanent marking should be provided at intervals of 1 metre throughout the length of the ladder consistent with ladder design, use and maintenance in order to facilitate the rigging of the ladder to the required height.

02 Access to Deck
Means should be provided to ensure safe, convenient and unobstructed passage for any person embarking on, or disembarking from, the ship between the head of the pilot ladder. Where such a passage is by means of

1. A gateway in the rails or bulwark, adequate handholds should be provided at the point of embarking on or disembarking from, the ship on each side which should not be less than 0.7 metres or more than 0.8 metres apart. Each handhold should be rigidly secured to the ships structure at or near its base and also at a higher point, not less than 32 mm in diameter and extend not less than 1.2 metres above the top of the bulwarks. Stanchions or handrails should not be attached to the bulwark ladder.
2. A bulwark ladder should be securely attached to the ship to prevent overturning. Two handhold stanchions should be fitted at the point of embarking on or disembarking from the ship on each side which should be not less than 0.7 metres or more than 0.8 metres apart. Each stanchion should be rigidly secured to the ships structure at or near its base and also at a higher point, should not be less than 32mm in diameter and should extend not less than 1.2 metres above the top of the bulwarks. Stanchions or handrails should not be attached to the bulwark ladder.

03 Stowage of Pilot Ladders
When not in use ladders should be stowed in a sheltered location on gratings to ensure air flow and covered by a tarpaulin.

04 Maintenance
A Pilot ladder maintenance log is to be maintained and recorded each month, a copy of this form FM04 being attached to this system. The Chief Officer is to initial each month that an inspection has been carried out and record any maintenance or repairs carried out to the ladder. 

A pilot is not required to climb more than 9 metres on a vertical ladder. In cases where the distance between the water and the ship’s point of access is more than 9 metres, the pilot ladder is to be used in conjunction with an aft facing accommodation ladder.

The pilot ladder must be rigged adjacent to the lower platform of the accommodation ladder and is to extend at least 2 metres above the lower platform. The lower platform is to be in a horizontal position when in use. All stanchions and hand-ropes are to be secure and taught.

Lighting is to be provided so that the full length of the accommodation ladder as well as the pilot ladder is adequately illuminated at night. 

Any access to the ship must be safe.

Gangway rigging is covered above in Section 05 Safe Access.

In principle, when in port a gangway should be used to access the vessel. It is strictly prohibited to access the vessel by "jumping" from the wharf onto the ship - even if this appears easy to do at any point.

Whenever crew or others are to embark or disembark while the vessel is at sea, the same arrangements should be used as for Pilots (refer section 06, 07, 08). The Master has the final decision on whether conditions are suitable for transferring people at sea. In making that decision they should also consider that most people have less experience than pilots in using pilot ladders.

The following are general practices that if followed can reduce the risk of harm to those onboard the ship. In addition, these practices serve to give the best possible impression of the working of the ship to visitors, inspectors, auditors or management.

The ship must be kept clean and tidy at all times.

Improperly stores spares or stores can move in bad weather and cause damage or hurt people. Oil spills can be a fire hazard. In an emergency, if spare parts aren't properly stowed and inventoried, you may not be able to find what you need quickly.

The ship is your home and your workspace, treat it with the same care you would ashore.

The following simple rules regarding housekeeping will reduce the risk of accidents onboard and ensure that the ship working environment remains clean and healthy:

• Keep all areas clean, dry and free of rubbish, slipping and tripping hazards
• Stow materials, spares and other supplies securely and correctly
• Ensure that electrical items are properly connected and no unauthorised equipment is in use
• Keep tools, fittings and equipment in good order. After a job is finished put the tools back in their correct place
• Look out for and remove any fire hazards
• Ensure lighting is sufficient
• Secure all moveable items
• Ensure escape routes and emergency exits are not obstructed
• Ensure that the access lids (e.g. manholes) and walkway areas that have been removed for maintenance or repair are fenced off to avoid danger of falling.
• Ensure that there are no leaking pipes or fittings
• Keep paint and other flammable materials stowed correctly
• Dispose oil soaked rags and other flammable materials in fire proof receptacles 

If you see something out of place, put it away properly.

If you see something dirty, tidy it up.

If you aren't sure, ask the Master or the Chief Engineer.

Tools are designed for a specific purpose and under no circumstances is a tool to be used for a job for which it is not designed. Moreover, all personnel using tools must be trained in their correct use.

Prior to use, tools are to be inspected for defects prior to use and if there is any doubt as to their condition or operation they must not be used.

Where tools are fitted with safety guards or other protection devices, these must be in place and operational before at all times. If these devices are not in place, then the tool is not to be used and the defect must be reported for immediate rectification.

Appropriate safety clothing and equipment is to be used and in particular proper eye protection is to be worn.

When planning to use tools or equipment, the following points are to be considered:

• Identify the correct tool for the job
• Identify personal protective equipment required by the user and personnel nearby
• Identify any Permits-to-Work required (especially hot-work)
• Do not use damaged or badly worn tools
• Ensure safety guards are in place
• When finished, stow tools correctly in a tool rack or suitable box 

It is essential that all personnel who use oxygen/acetylene cutting equipment and/or electric arc welding equipment are fully aware of the potential risks and hazards. The UK Code of Safe Working Practices for Merchant Seafarers provides details on the safety precautions to be taken when using this equipment. Staff involved in the use of this equipment, are to be familiar with the relevant parts of the code.

A hot work permit must be obtained prior to use of this equipment outside the engine-room workshop. Particular attention is to be paid to monitoring spaces adjacent to the work area for spread of fire.
Local Port procedures and regulations must be followed, and permission obtained if welding/cutting is planned to take place when in port.

Safety warning signs and instructions are to be posted adjacent to all equipment. Appropriate PPE must be used at all times.

All equipment must be inspected for defects prior to use and must not be used if there is any doubt as to its satisfactory condition. Hoses, regulators and cables are to be subject to close inspection and must be designed for the purpose and be properly connected. 

Many of the substances and materials used onboard for various purposes can be dangerous and/or hazardous to the health of those using them. This section describes some of the hazards which may be encountered on board and the requirements for the safe handling and use of these materials.

In addition to the contents of this section, the UK Code of Safe Working Practices for Merchant Seafarers is to be consulted for detailed guidance. For every dangerous or hazardous material,substance or product handled on board, a MATERIAL SAFETY DATA SHEET (MSDS) is to be provided and available to all personnel working with the material. These data sheets must be clearly posted in all areas where the materials in question are stored and used. For example inchemical store(s) and paint lockers, along with any other place the items are regularly stored.Refer to A07 “ Preventing HSQE Events". All dangerous materials are only to be used in accordance with the manufacturer instructions.


Dangerous, hazardous or irritating substances are to be handled only under instruction from a responsible officer. The responsible officer is to instruct, inform and train crew, so that they understand the risks arising from their work with dangerous or hazardous materials and are fully aware of the precautions that must be taken.

As with all parts of this system, where a dangerous or hazardous materials or substance is not specifically mentioned here, the requirements of good seamanship and common sense should be applied and the course of action that best protects the health and safety of all involved should be followed.


1. Use and Storage of Chemicals
A properly ventilated and secure storage area is to be used to store all chemicals, and materials must only leave this area under the clear instruction of a responsible officer. Materials having different properties and safety concerns, are to be properly segregated and the storage area is to provide protection and security from accidental spillage or damage to containers from the vessel’s motion in a seaway. There must be no possibility of other important equipment such as mooring lines becoming damaged by chemical spills.

Original containers are always to be used to identify the contents and avoid confusion. Chemicals must never be used from unlabeled containers and containers are to be properly sealed and secured after use. MSDS are to be posted up adjacent to each type of chemical and the particular dangers of each are to be highlighted.

Chemicals must always be handled with great care and appropriate personal protective equipment must be used. This equipment is to consist of eye protection, rubber gloves, apron and other PPE as dictated by the MSDS and manufacturer instructions . Care is to be taken not to breathe in chemical vapours. Eye wash liquid is to be available as a first aid measure to remove chemicals from the eyes and skin.

2. Detergents and Cleaning Materials
Detergents are commonly used throughout the ship for a variety of reasons including laundry, galley and general cleaning purposes. They do not normally present serious hazards in handling, Care must be taken when handling strong or concentrated detergents and in cases where there may be prolonged contact with the skin. This can cause a degreasing effect of the skin and subsequent skin irritation.

It is therefore recommended that gloves are to be worn in such circumstances. Where gloves are not practical, a good quality barrier cream is to be used. Splashes of neat detergent onto the skin are to be washed with plenty of water followed by, if necessary, a moisturising cream or similar substance. If contact is made with the eyes, then again water is to be used in copious amounts to flush the eyes clear.
MSDS and manufacture instructions must always be consulted before using detergents and cleaning products, and appropriate PPE must be worn according to recommendations.


3. Use and Storage of Paints and Thinners

Paints and thinners present significant fire and explosion hazards due to their volatile nature. They also have toxic properties if vapours are inhaled. They must only be stored in the designated fire protected locker which is to be kept well ventilated. Drums of paint and thinners must be kept closed to reduce vapour release to a minimum. No type of hot work is to be carried out in or near the paint locker unless suitable precautions are taken, including removal of all paint drums. MSDS must be available and posted up at the locker for all types of paint stored.

Enclosed areas where painting is being carried out are to be kept well ventilated and appropriate fire precautions taken. Smoking is not permitted in any internal space during painting and until paint has fully dried.

Paint spraying equipment must only be operated in accordance with the manufacturer’s instructions and with great care. During paint spraying, the body is to be kept fully covered to prevent accidental penetration of the skin. Eye protection and respirator masks are also to be used.


4. Oils
Health hazards may exist from contact with some oils used for fuel, lubrication and hydraulic systems. Certain materials such as residual fuel oil or used engine lubricating oils contain polyaromatic hydrocarbons (PAH’s) which are known to be carcinogenic. In addition to any carcinogenic effects, a range of skin diseases ranging from irritation to severe oil acne may occur.

When handling oil or waste oil, direct contact with the skin must be avoided by the use of protective gloves and / or barrier creams.
Additionally, further protection is to be utilised as appropriate, i.e. use of aprons and eye protection. This is particularly the case with degraded oils that may have undergone chemical changes during use, and therefore may exhibit different characteristics from their MSDS.


5. Adhesives
Adhesives, in many cases emit fumes that are highly flammable and toxic if inhaled. Additionally, some “super glues” are very powerful and bond materials on contact. In all cases adhesives must only be used for their intended purposes in accordance with the maker’s instructions. They must only be stored in a sealed manner and if possible in a well ventilated room. During use, appropriate ventilation must be provided in order to prevent build-up of toxic or explosive vapours and fire precautions and equipment must be observed and available. Handlers are to wear appropriate respiratory protection where appropriate.

A careful watch should be kept on any signs of a crew member suspected of solvent abuse such as inhaling the vapours of adhesives. If this is suspected, then the seafarer is to be reported to the Master who will report the occurrence to the office for follow-up action. The abuse of solvents is a breach of the Company Drug and Alcohol Policy.


6. Asbestos
The risks posed to health by asbestos are well recognised by the Company, and to this end every ship has been provided with an Asbestos Management Plan.

In addition, all equipment or stores purchases must be 100% asbestos free.


7. Pesticides and Fumigants
Pesticides used on board ships may be classed as dangerous goods. Some of the gases used for fumigation are flammable and may create a fire hazard. All fumigants are highly toxic and exposure to fumigants must be kept to the minimum practical level.

A number of accidents have occurred from fumigation processes.

Fumigation in port must only be carried out under the supervision of a specialist company, usually involving the evacuation of the crew to a hotel or other location. Fumigation during a voyage is to be carried out under the supervision of the Master however, must only be carried out if absolutely essential, with the Ships Management Teams written approval, the approval of the vessel’s flag state and the approval of the administration of the state where the vessel will call next.

Where there is any doubt that the fumigant tablets have fully decomposed prior to arrival at the discharge port, self-contained breathing apparatus must be worn until all fumigant residues have been removed and the cargo spaces have been thoroughly ventilated.

The Master must ensure that personnel involved in the fumigation process are trained in its use and are provided with all the information and protective equipment required. The fumigant must only be used in accordance with the manufacturer’s instructions with which the trained personnel are to be thoroughly familiar. This is to include knowledge concerning the methods of detection of the fumigant in air, its behaviour and hazardous properties, symptoms of poisoning, relevant first aid and special medical treatment and emergency procedures. A comprehensive risk assessment is to be undertaken.

If fumigant tablets are applied in a retrievable form, their residues are to be removed immediately on arrival at the discharge port. In cases where no means of retrieval are provided, a vessel must not discharge her cargo until safe working conditions have been established both on board and ashore.


8. New Chemicals, Detergents and Cleaning Products
When a new substance is to be used onboard, the Company is to ensure that the supplier provides the correct MSDS for the substance at the time it is delivered. The MSDS is to be stored in SMMS. Every consumable item has the option to store documents against its record, and this is to be used for MSD Sheets.
Whenever a new substance is to be used onboard, a proper risk assessment must be conducted.


9. Forbidden Chemicals and Cleaning Products
The Company is to apply the law of the European Union when determining which chemicals and cleaning substances may be used onboard the vessel. Any substance banned for use in the European Union by any of the following regulations, may not be sourced for the ship:
- REACH Registration, Evaluation, Authorisation, and Restriction of Chemicals Regulation
- RoHS Restriction of Hazardous Substances Directive
- SRR Ship Recycling Regulation

In addition, any substance prohibited by the following United States legislation may not be sourced or supplied for the ship:
- TSCA Toxic Substances Control Act 

Mooring and unmooring operations, including the handling of tugs lines and anchoring, are highly hazardous operations. For further guidance, crew should refer to the UK Code of Safe Working Practices for Merchant Seafarers.

Proper precautions must be observed at all times to prevent accidents. The following are some guidelines to ensure safety during these operations:

• Always use appropriate Personal Protective Equipment including safety helmets, safety shoes and gloves.
• Stand well clear of all lines when under load.
• Watch your feet. Do not step into a coil or loop.
• Always ensure that the winch operator can see the person in charge.
• Ensure all equipment is operational and well maintained.
• Report all defects and ensure that action is taken to address them.
• Mooring areas are to be free from obstructions and must be adequately illuminated at night.
• Ensure that all safety devices for mooring power supplies are in place and operational.
The relevant publications in the Reference Publications Index are to be consulted for more comprehensive guidance on safe mooring.

1. Maintenance of Mooring Equipment
The Master is responsible for ensuring that regular, thorough inspections are conducted and that maintenance is carried out on all mooring equipment. This should be in accordance with the planned maintenance system in place and at more frequent intervals should the Master deem this to be necessary. A record of all inspections and work is to be maintained.

Wire ropes are to be lubricated regularly using a recognised wire rope lubricant. On no account are home-made lubricants to be used as these can lead to pollution claims against the vessel. Particular attention must be made to ensure that lubricants are penetrating to the inner layers to prevent internal corrosion that could result in failure of the wire.

Care must be taken to ensure that the brakes are kept in good condition and clean. Oil, moisture or heavy rust on the brake linings or brake drum can reduce the holding capacity by up to 75%.

2. Certification
All mooring lines, wires, tails, links and other such equipment must have a proper certificate and this must be retained on file. The Master must ensure that the date that any particular item enters into service is either recorded in an equipment register or is clearly marked on the certificate. 

Refer to section “B02 Navigation” and the UK Code of Safe Working Practices for Merchant Seafarers.

It must be remembered that towing operations may place excessive loads on ropes, leads and connections. The safe working load of all equipment must be known and clearly marked on all equipment.

Prior to commencing any emergency tow, the Master must make reference to the Ship’s emergency towing booklet and a suitable plan must be agreed between the vessels.

Once the tow is in place, all personnel must keep well clear of the towing area unless essential work must be carried out to ensure the safety of those aboard the ship. In such a circumstance the Master must weigh up the risk associated with not carrying out the work and must be absolutely satisfied that that risk is greater than the risk of having personnel in an operational towing area. 

Enclosed spaces are dangerous! Only enter enclosed spaces after following this procedure fully, and taking all steps to ensure the atmosphere is safe!

Too many seafarers have died as a result of entering enclosed spaces without taking the proper and necessary precautions. The danger of these spaces cannot be underestimated, where a lack of oxygen or a toxic atmosphere can lead to death in extremely short periods of time.

Any enclosed space is dangerous, store rooms, cargo holds, tanks, voids. Some “active” spaces which aren't properly ventilated can become dangerous very quickly too.

There are various reasons that enclosed spaces can have dangerous atmospheres:

• Rust in ballast tanks will remove the oxygen from the atmosphere
• Cargoes can deplete oxygen or generate poisonous gases or fumes in their own right, eg:
o Coal will give off methane and carbon dioxide
o Some organic cargoes may generate toxic gases
• Void spaces, access trunkings can be filled with gases which can remain after the cargo has been discharged
• Leaking exhaust gases could fill a space with carbon monoxide
• Paint thinners or chemicals can give off gases which result in a dangerous atmosphere

1. Precautions
Nobody is to enter an enclosed space without the permission of the Master, the Chief Engineer, the Chief Officer or the Second Engineer.

Nobody is to enter an enclosed space unless the enclosed space entry procedure described below has been followed fully and properly and a record of this being done has been made.

“Enclosed Space” includes all tanks, but will also include other spaces. The Master and the Chief Engineer are required to regularly inspect the vessel to identify spaces which through the nature of their use or through lack of regular use or which for any other reason could potentially be considered enclosed spaces. It is sufficient for there to be a “potential” risk that the space could be dangerous for it to be considered an enclosed space. Enclosed spaces should be clearly marked as such.

2. Enclosed Space Entry
There are only two types of enclosed space entry, “normal” and “emergency”. Emergency entries are only carried out to rescue people who have made a “normal” entry or in the case of extreme emergency.

i. Normal Entry
Normal access to an enclosed space may only occur when all of the following steps have been taken. In the event that any step cannot be fully completed or if the result of any check does not meet the requirements then the enclosed space entry must not be carried out.

• The Master must ensure that sufficient personnel have been made available to safely carry out the enclosed space entry and to monitor progress throughout the period that personnel are in the space.
• The space should, wherever possible, be well ventilated prior to commencing this entry procedure. In any case ventilation to the space is to be continuous throughout the entry. Should the ventilation fail at any time, those personnel in the space must leave immediately.
• As many openings into the space as possible/practical should be opened to provide additional ventilation and other means of escape.
• At least two fully charged SCBAs must be positioned immediately next to the entry point. They must remain there throughout the entry.
• The space to be entered must be suitably illuminated for entry or all personnel making the entry must carry torches of sufficient power to light their way. At least one torch must also be placed at the point of access for use in the event that an emergency entry is required.
• A system of communication must be in place between the person/people monitoring from outside the space and those making the entry. It must be tested before the entry and should it fail at any time, those in the space must leave immediately. A set “check-in” interval must be agreed.
• A means of communication must be in place between the person monitoring the entrance to the space and the OOW. It must be tested and remain active throughout the entry.
• Nobody is to enter the space until an Enclosed Space Entry Permit has been completed and the space has been determined to be “safe for entry” by a responsible officer.
• Nobody is to enter the space until the atmosphere has been tested and found safe by the responsible officer.
• At least one person in the team entering the space must have an atmosphere monitor (multi-meter) on their person and it must be switched on and remain switched on throughout the entry. If the battery runs out during the entry, all personnel in the space must leave immediately.

ii. Enclosed Space Entry Permit
No entry into an enclosed space is to occur until an Enclosed Space Entry Permit has been fully completed.

Entry is only to take place if all of the answers on the Enclosed Space Entry Permit form are “YES”.

However, there are certain questions that allow for “N/A” as a response on the basis that the requirement may not always be possible (such as cleaning of a space). In the event that the answer to a question is “N/A” the permit must be co-signed by the Master or Chief Engineer who must ensure that the fact that the item in question has not been carried out does not in any way compromise the safety of the entry.

If an item does not have “N/A” as a possible result, then that item must be carried out before an entry may take place.

A copy of the completed permit must be posted at the entrance to the space, and a further copy must be placed on the Bridge. Enclosed Space Permit forms are to be retained onboard and filed sequentially.

The responsible officer must inform the OOW of the planned entry into the enclosed space and must also inform him when all persons are clear of the space. A record of each enclosed space entry is to be made in the deck log book.

iii. Emergency Entry
Of those deaths that have occurred in enclosed spaces, a large number have been as a result of individuals entering a space to try and rescue their colleagues without taking proper precautions.

Take a moment and follow the necessary steps before making an emergency entry, or you may become another casualty who needs to be rescued.

An emergency entry into an enclosed space is only to be carried out to rescue people in trouble in the space. Any emergency entry into an enclosed space is a major emergency and the General Alarm should be sounded.

All equipment required for an emergency entry should be ready at the entrance to the enclosed space.

Emergency entries are only to be made by a team of at least two persons wearing full SCBA and monitored by another person at the entrance. There must be a means of communicating with those making the emergency entry.

Those entering and the person monitoring their entrance must know how long their BA air will last.

Once the initial rescue team makes their emergency entry, a relief team should begin to prepare at the entrance.

A detailed report of any emergency entry into an enclosed space is to be made to the Ship Management Team. Additionally any reports that are required by the flag state or the port state must be made. 

Divers provide essential underwater assistance to the ship, and their job is dangerous. We need to do all we can to protect them and make sure they make it home safely.

If it is necessary to utilise divers to carry out essential repairs or to carry out underwater surveys, there are several steps that must be taken:

• All requests for diving services are to be made in the first instance to the Ship Management Team;


• Once such a request is approved, the Master is to make sure they are precisely clear about what services the diving company have been engaged to perform and what is to be achieved;


• Permission to carry out diving operations is to be sought from the port authorities;


• Upon the arrival of the diving contractors:     
o A meeting is to be held with the Master and Chief Engineer to discuss the scope of work and to point out the location of all overboard discharges and sea suctions that will remain in use during the dive;
o Safety requirements are to be discussed and agreed between the ship and the diving company;


• An Underwater Work Permit is to be completed.


At all times divers are in the water, all moving underwater machinery is to be tagged out and clear notices to the effect that divers are in the water should be displayed in the engine room and on the Bridge.

Signal flag “A” is to be displayed. 

“Lifting equipment” means any mobile or stationary equipment which is used anywhere onboard ship for the purpose of suspending, raising or lowering loads or moving them from one position to another whilst suspended. Lifting equipment includes, but is not limited to, cargo cranes, stores cranes, engine room cranes, chain blocks, forklift and container handling vehicles.

No one is allowed to operate lifting equipment without adequate training and familiarisation with the operating instructions. No lifting appliance is to be operated in a manner other than that described in the operating instructions. Persons who are permitted to operate equipment or assist in the operation of lifting equipment are to be fully conversant with the appropriate sections of the UK Code of Safe Working Practices for Merchant Seafarers.

All lifting appliances are subject to load testing every 5 years with annual examinations. A register of lifting appliances and items of loose gear is to be maintained up to date and ready for inspection by any authority. A record of all ropes and wires must be maintained along with certificates for the same and it is essential that this record is updated whenever a new rope or wire is brought into service.

Lifting appliances must not be operated outside their design limits regarding safe working load, wire speed, list, trim or dynamic movement of the vessel. All these limitations are to be clearly marked on the appliance.

The SWL of any lifting appliance should be stencilled onto the equipment or immediate structure.

Controls are to be permanently and clearly marked with their function with operating directions and instructions. Where special instructions are applicable to securing and unsecuring of the equipment these shall be detailed clearly. Controls must not be modified in any way from their original specification. Any locking devices fitted to controls must be kept in good condition.

All fitted safety devices limit switches, cut-offs or pawls are to be kept in good working order and tested regularly. Safety devices must never be isolated or overridden. Should a safety device be found to have been overridden or isolated, this is to be reported as an appropriate incident (either a near-miss or an incident).

Lifting appliances must always be attended when they are ‘on’, i.e. when there is power to them. When work is completed the appliance is to be secured as applicable and the power turned off.

Personnel operating lifting equipment shall have no other duties at the time of operation and must have a clear view of the operation. Where this is not possible a trained signaller is to be used to give directional instructions to the operator. The signals used are to comply with those found in the Code of Safe Working Practices for Merchant Seafarers.

No one should allow a load to pass over their head!

Lifting appliances must never be used to drag heavy loads, or to pull loads from underdeck where the fall wire has to pass round edges. Wire ropes must be regularly inspected for damage and kept properly lubricated. Care must be taken to ensure that effective internal lubrication is applied so that the rope is not allowed to dry out.

In the case of crane wires, the safe handling of loads by a correctly operated crane depends upon regular maintenance and examination of the wire rope, with removal of the wire rope from service before problems arise. 

Health and hygiene are critical to the wellbeing and comfort of all onboard. The company requires that all personnel maintain the highest standards of health and hygiene at all times when on our ships. This includes personal hygiene, cleanliness and hygiene of the workplace, the accommodation and especially when dealing with foodstuffs. Any symptoms of illness or cause for concern relating to health and hygiene are to be reported to the Master or a senior officer as soon as they arise. The Master is responsible to the Company for ensuring that these standards are maintained and is required to conduct weekly inspections of the ship for this purpose.

Illness or disease can rapidly spread if clean, healthy and effective working practices are not adopted when handling and working with food and provisions. The galley is also a place of work associated with various hazards such as sharp utensils and boiling liquids. The UK Code of Safe Working Practices for Merchant Seafarers contains good advice and guidance and should be read in conjunction with this section.

1. Galley Safety & Hygiene
All equipment such as stoves, ovens, mixers, deep fat fryers and other electrical equipment must be operated in strict accordance with the manufacturers’ instructions and safety guidance. Whenever practical such instructions are to be posted beside each piece of equipment. Galley equipment is to only be used by experienced personnel or under their supervision. No personnel are to be allowed in the galley without the permission of the Chief Cook or the Master.

Care must be exercised when handling hot equipment and utensils. In heavy weather it is essential that guard rails are used around the galley range and that pots and pans are not overfilled to the extent that they may spill when the ship rolls.

Sharp utensils, such as knives and choppers, must be handled with care at all times and are to be kept in secure racks or other suitable storage when not in use. They must not be left lying around where persons may accidentally cut themselves. When washing utensils, knives must be washed individually and not mixed up with other items and must not be left lying at the bottom of a sink.

All galley areas, particularly those where food is prepared must be kept clean at all times. Any damaged surfaces, especially tiled surfaces including decks and splash panels, are to be repaired with the minimum of delay. All surfaces, cookware, crockery and utensils must be thoroughly cleaned after use and correctly stowed.

In order to avoid cross-contamination between uncooked meats and other foods, separate cutting/chopping boards and preparation surfaces are to be used. Likewise utensils such as knives are to be designated for uncooked meats and kept separate from other utensils. Colour coding or other types of identification are to be used. Foods should be handled as little as possible and hands washed thoroughly after handling raw produce.

High-risk foods include the following that are media for the reproduction of bacteria:

• Meat, game, meat products and poultry;
• Fish, shellfish and fish products;
• Confectioner’s ready-made custards, cream and other dairy products including cheese;
• Cracked eggs, egg products, dressings and salads.
Perishable foods must not be exposed to the temperature danger zones (4.5°C to 65°C). If food is left at an improper temperature for more than 30 minutes, persons consuming that food may suffer food poisoning within one to six hours. Bacteria is dormant below 4.5°C and most is destroyed if the poultry is cooked at temperatures of 70°C throughout the meat.

Food obtained for raw consumption (for example fruit and salad vegetables) must be carefully selected, inspected and thoroughly washed before use.

Foodstuffs and provisions are to be kept in sealed containers when not in use.

Waste, particularly food scraps must be kept in sealed containers and away from foodstuffs. Galley waste must not be allowed to build up in the galley and is to be transferred to the vessel’s designated garbage stowage area as soon as practicable. Garbage must be properly segregated at the storage area (please refer to Ship's Sanitation Manual for further details including disposal).
The ventilation system is to be used in order to keep the galley free of smoke, steam and odours. The ventilation grids are to be cleaned regularly in order to keep them free of oil and grease.

2. Personal Hygiene
All persons handling food must pay the utmost attention to the cleanliness of both themselves and to their clothing. They are to wear clothing designated for working in food preparation and service areas when working in these spaces, and must not remain in these clothes when working in other areas or during their free time.

Hand washing facilities are to be made available and are to be used frequently especially after handling uncooked meats and visits to the toilet. Manufacturer’s instructions are to be followed when using cleaning materials.

Persons who are suffering from a disease or ailment capable of being transmitted via food or water must not be allowed to work in food preparation or service areas.

All cuts, no matter how small, must be reported for first aid attention. An open cut, small burn or abrasion is to be covered with a suitable, distinctively coloured, waterproof dressing. Anyone with a septic cut, wound, boil etc. must not be involved in handling foods.

3. Provisions
The Master and Chief Cook must ensure that the food received on board should be of sufficient quality to ensure that nutritious healthy meals can be produced. Sufficient means enough for the planned voyage, and an additional 14 days.

Food received should be clean, wholesome, free from spoilage and safe for human consumption. Packaging must be intact and undamaged. Any food that is suspect should be returned to the supplier and the Ship Management Team must be notified.

Milk and milk products must be stored in a refrigerator until used. Canned or packaged milk, other than dry milk powders, must be refrigerated for storage after the container has been opened.

4. Disposal of Cooking Oil
Once cooking oil has been deemed unsuitable for re-use, it must be disposed of properly. The oil is to be transferred to a metal container for disposal ashore. This transfer is to be noted in the Garbage Record Book and categorised as Garbage category “D”, per Marpol Annex V.

5. Cockroaches and Other Infestations
Insects such as Cockroaches can damage food and are capable of transmitting serious diseases such as dysentery. They must be guarded against at all times.

To eliminate these pests, food and waste must not be left lying around and must be stored or disposed of correctly. All areas associated with storing or handling of foods must be meticulously cleaned, with cracks or damages repaired promptly to prevent breeding areas.

Upon discovering cockroaches or other pests, suitable elimination products such as sprays, baits and traps should be promptly acquired and used, strictly in compliance with the manufacturer’s instructions, particularly regarding their utilization in proximity to food. 

This section is a guide which is to be supplemented by the requirements of the UK Code of Safe Working Practices for Merchant Seafarers (COSWP).

It is a requirement of the Company, and is essential to the safety of the ship, that safety meetings are held at least monthly. The meeting is to involve all crew, and can be chaired by anyone onboard who is willing to do so.

It is strongly recommended that crew, other than the Master, are able to chair this meeting.

The Chair is to encourage all members of the crew to actively raise safety relevant questions during this meeting. As a minimum, this meeting must cover the points listed in Form FA03A Minutes of Occupational Health and Safety Committee Meeting. The minutes are to be completed after every meeting and sent to the Company, who must respond to any points raised within one week of receiving the minutes.

While it is a requirement that the meeting is held at least monthly, a Safety Meeting can be held as often as required. Crew members are encouraged to request one be held if they have topics that should be discussed by all onboard. If the matter is urgent, the Master should not refuse such a request, but otherwise they can propose the topic be held until the next scheduled meeting.

Every request to hold a safety meeting, whether granted or not, must be reported to the Company. 

The Master is the Ship Safety Officer.

However, the Master can request, and the Managing Director can agree in writing, to delegate the duties of Ship Safety Officer to any other onboard Officer who meets the requirements to fulfil this role. The Company delegation, if granted, applies only to a single person for a single contract onboard, and if not renewed the responsibility reverts to the Master.

The Ship Safety Officer is responsible for overall safety of the vessel, and must take steps to actively ensure a safe working environment for all personnel. Amongst other things, their duties include:

• Look into all the potential hazards to the health and safety of the vessel and its crew
• Ensure that the crew maintains high standard of safety consciousness and is familiar with all of the important aspects of the ISM code related to safety
• Ensure that the provisions of the code of safe working practices and safety instructions, rules and guidance for the ship’s safety and health are complied with.
• Ensure that safety inspection of the vessel is carried out at least every three months or more frequently if required
• Help ship safety committee to take substantial steps for enhancing the safety of the ship
• To look into crew complaints related to health and safety
• Make recommendations to the master to remove a potential hazard which might lead to an accident or harm to the crew
• Help in making/maintaining an efficient safety management system (SMS)
• Provide information to the ship’s master regarding deficiencies related to ship’s health, safety, and security
• Properly investigate any accident involving death of a crew and major or minor accident
• Inform the master when someone from the crew fails to work according to the regulations mention in the ISM code
• Recommend important aspects related to safety in ship’s maintenance plan
• Maintain a record of all the accidents taking place on the ship, including death, major or minor injury, and near death experiences. Also, make this information available to the ship’s master, safety representative, or any official of the company
• Stop any vessel operation, which might cause damage to the vessel or harm to any of the crew and inform the Master so the necessary steps are taken. 

Amendments

DATE DETAILS
01.11.2023New header section added.
Amendment table inserted.
Language improved for clarity.
04.02.2024Section A06.20 Safety Committee added.
This section requires a safety committee meeting to be held at least monthly and minutes recorded on Form A03A.

Section A06.21 Ship Safety Officer added.
This section makes clear that the Master is the Ship Safety Officer, unless this role is expressly delegated by the Company.
01.10.2024Wording improved for clarity.
A06.05.1 Rigging Gangways amended to clarify safe access requirements.
A06.10 restructured to make it easier to find relevant information. Now split into lettered sub sections (A06.10A, A06.10B etc.)
A06.10A Housekeeping amended to clarify requirements.
A06.10C Welding and Cutting requirement to follow local port procedures added.
A06.11.2 Detergents and Cleaning materials adds specific requirements for use and documentation required for cleaning materials and detergents onboard.
A06.11.8 New Chemicals, Detergents and Cleaning Products adds requirement for a risk assessment for any new chemical and requirement for supplier to provide MSDS 
A06.11.9 Forbidden Chemical and Cleaning Products described which regulations are to be applied in determining whether a cleaning product may be used onboard a Company ship.
A06.18.4 Disposal of Cooking Oil amended to clarify record keeping requirement.