06 FEB 2020 

Thanks very much to The Maritime Executive for your kind invitation to rethink our maritime industry’s programs for safe confined space entry and repairs.

My name is Don Sly, and during these last 45 years I have tested the safety of some 200,000 maritime confined spaces. After the testing (when I find the space “Safe for Workers”) I testify thus on a Marine Chemist Certificate so that workers will know the space has been responsibly tested and will perhaps take some hints on strategies to keep the space “Safe” as repairs proceed.

I am moved to a “rethink” of our industry’s “safe-work-in-confined-spaces” strategy by three articles I have recently seen.   

The first was the “…Shocking Spike in Confined Space Deaths” as reported by the International Transport Workers Federation. The “shocking spike” involved three crewmembers killed while de-watering a drill-rig’s leg with a trash pump. Carbon monoxide, of course.

And I have at hand two offerings in The Maritime Executive on the same topic: confined space safety.

The first is by ex-tanker man John Ratcliffe who detailed confined space testing in the “old days.”

The second author is my friend and fellow Marine Chemist Don Raffo. Don recommended Marine Chemists as premier candidates to accomplish timely, documented analysis of confined space hazards in ship repair.

Mr. Ratcliffe and Mr. Raffo wrote in support of the maritime industrial world’s present regulatory approach to confined space hazards. That is, the traditional ship repair confined space testing protocol.

This approach, enshrined in the legal structures of OSHA and the insurance industry, demands electronic analysis of airborne contaminants as the gateway strategy for dealing with confined space dangers.

First, let’s review that rule: Before allowing entry, says OSHA’s chapter (Subpart B) on Confined Spaces, “The Employer shall ensure that atmospheric testing is performed in the following sequence: oxygen content, flammability, and then toxicity.” 

Note that since the regs are written in numerical detail, testing to demonstrate compliance must also provide documented test results in percentages and parts per million.  

And how is that done? By chromatographic, thermal-conductivity, infrared, electrochemical, and/or platinum-bead-based electronic test gear. It is very expensive. Then, this gear must be maintained and repaired. Expensive. Gear-calibration must be checked each day used. Expensive. Workers must be trained to use and interpret the gear. Expensive. And the time taken from production to do proper sampling, testing and analysis: very costly.

My re-thinking mode reinforces what I have observed: that in less organized, less supportive, less safety-committed workplaces, electronic testing of confined space air is hit/miss or unavailable, as noted by ex-tankerman Mr. Ratcliffe. It is not a big reach, therefore, to suppose that high costs play a role.

I fear, therefore, that when we Safety Professionals assume universal compliance and neglect real-life training to deal with substantial noncompliance, we may be shorting the more underserved workers.  

In other words, training maritime workers and supervisors in the benefits of confined space air-testing is just half the story.

We should follow that sermon with an emphasis on the positive role of routine, forced ventilation in making confined spaces safe… I am talking about the routine use of blowers and ducts.    

And after many years’ hands-on experience with both confined spaces and the regulations that govern them, it is my considered opinion that a worker who does not appreciate the importance of ventilation in confined space safety has not been properly trained to deal with the expected dangers.  

In workplaces where air testing may be neglected, ventilation fans and ducts should be set up and ready to go before the bolts are off the manhole cover. Also, this ventilation should be expected to run for an hour minimum before workers enter, and may be continued as the work goes on.

Why do I recommend routine forced air movement? Because the most acute dangers of confined spaces are airborne. Thus, routine air changes always benefit workers. Moreover, such baseline ventilation does not replace, but actually complements, the electronic analysis of a space’s air. In fact, ventilation must be set up anyway when contaminants are found. Plus, ventilation must always accompany “hot work” repairs.  

Considering costs, ventilators are a lot cheaper than electronic test gear; are probably already at hand; and don’t need a lot of training to make them work.

Because my re-thinking has me worried about the cost of testing confined spaces, our discussion would be incomplete without considering the cost of the Marine Chemist. Since safety gear is by nature expensive, and Chemist’s do not work for the minimum wage, I acknowledge that I my invoice may add to the cost of evaluating a vessel’s confined spaces. But I consider that my expertise and enthusiasm make the toll worthwhile.  

My ventilation “re-think” has just scratched the surface of proper worker confined space training.   OSHA, for instance, demands, in addition to a pre-entry meter survey of confined space air, a “visual inspection” of the tank interior. OSHA wants us thereby to control physical hazards such as unexpected energy (“Lock-Out-Tag-Out,) unsecured piping, defective staging, slippery and unguarded work surfaces. While such dangers are unrelated to air quality (and hence are not discovered by electronic test methods) their control is nonetheless absolutely essential to safe entry. And don’t forget the Employer’s duty to have spaces re-inspected “as often as necessary” as long as entry and repairs continue.

My “re-think” is somewhat touchy and political because it involves descent to observed detail, as opposed to simply reporting from a world of ideal regulatory compliance. I propose stop-gap ventilation training in response to the “shocking spike.” I hope that a more complete worker awareness will both save some lives and also will support those essential confined space regulations that keep our industry viable.


Don Sly is a Marine Chemist.


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