System Policies & Procedures · each employee to support safety and health objectives, policies and procedures thoughresponsible actions and thereby prevent injury to themselves,

System Policies & Procedures

Controlled Revision: 01 Sep 2015 HSM Part A – SPP Doc No. 006 Approval: WBF SAFETY MANAGEMENT Page: 1 of 60

6.0 Safety Management

Purpose

o To detail standard operating procedures to ensure safety concerns are correctly and properly managed throughout the organization

Application

o All Offices

o All Vessels

Responsibility

o Shore Management Team

o Shipboard Management Team

o Individual Staff & Crew

6.1 Promotion of HSE

The company recognizes that safety and health is a prime responsibility of senior management. Department heads and Masters have responsibility to make safety and health top priority. Managers, in conjunction with the shipboard management team, must encourage development of a proactive safety culture. It is the responsibility of each employee to support safety and health objectives, policies and procedures though responsible actions and thereby prevent injury to themselves, their colleagues, property and the environment. • The company provides a variety of methods, including training, best

practice sharing and awards, to encourage and promote HSE. Staff are expected to participate to the maximum benefit of the team.

• Suggestions are encouraged and may be submitted via the ShipNet

Marine Information System installed onboard



6.1.1 Hazard Communication The goal of hazard communication is to be sure employees know what hazards exist in the shipboard environment and what they must do to protect themselves. • Hazardous Materials

o Whenever dangerous cargo is carried, printed Material Safety

Data Sheets (MSDS) Sheets must be prominently posted on a central notice board that that all persons on board may easily refer too the standard safety guidance provided.

o Manufacturers MSDS Sheets should be available for all bunkers,

paints, solvents, and chemical stores. A supplier file should be located in each location where the materials are used. MSDS pages should be protected by plastic lamination or other suitable means to prevent page degradation and contamination from handling. MSDS Sheets should normally be provided by suppliers, but if not available, an inventory of most common MSDS Sheets is provided to each ship on the HSQE System CD ROM. Should a needed MSDS Sheet not be included, the HSQE department should be contacted to assist.

o Asbestos, if identified onboard, should be handled in accordance

with procedures in the Code of Safe Working Practices 27.4, and made known by signage in areas where found. Company DPA should be notified if any leakage observed, and the Second Engineer assume responsibility to ensure any damaged areas are promptly sealed

• Physical Hazards

o Hazards should be communicated by prominent signage,

markings and notices. Common hazards to be marked including:

Gangway Notice: Warning – no smoking, no open lights, no visitors; use of mobile telephones or cameras is prohibited; Dangerous Chemicals, if applicable.

No Smoking Signs at the Battery Room, Paint Locker, Oxygen

& Acetylene Store



Tiger striping of pinch points, trip hazards, slip hazards, and low overhead obstructions

High voltage warnings at main electrical panels and other

high voltage areas Posted warnings when dangerous work is being carried out

(e.g. men aloft, divers down, electrical isolation, lock-out tag-out notice)

Posted signage indicating required personal protective gear

work-shops, pump-rooms, engine spaces

Mark Safety Helmets with issue date so 3 year service life can be monitored

• Biological Hazards

o Biological hazards, such as Malaria or Swine Flu, are communicated to the crew by transmission of safety alerts as may be needed to control contamination in a given area of trade.

o Kitchen and garbage areas bacterial hazards are communicated

by signage, cooking and storage instructions, and/or training of ships crew regarding infection prevention

o The ship's hospital is to have a sealed waste bin designated for

disposal of biological waste generated in the course of rendering medical treatment. The designated bin is to be clearly marked for Biological Waste.

• Safety Information Board

o Every vessel should establish a vessel specific safety information board where important safety information may be displayed for visitors and crew. A safety information board should include:

MSDS Sheets for dangerous cargo if carried

On board Smoking Regulations

A description of Fire & General Alarms



Identification of emergency muster points for visitors

An indication of current Security Level

• Departmental Morning Meetings

o A brief morning meeting is required of each department to review work to be done that day, communicate hazards to be encountered, and methods required to adequately control the hazards. The morning meeting is the time to, if required, conduct or review an applicable Risk Assessment and/or Job Safety Analysis, if dangerous work is scheduled to ensure all personnel are aware of hazards and the controls required

o Ideally the morning meeting should include all hands so that deck and engine personnel are jointly aware of the maintenance activities carried out by the other departments. When not possible, the Chief Officer and Chief Engineer are to review activities jointly and advise their staff of any potential hazards to be avoided.

o No minutes of morning meetings are required.

6.1.2 Department Head Supervision The Department head is responsible to ensure each job is adequately supervised to confirm safe working practices are followed. Whenever work requires Lock Out Tag Out of systems, the department head is personally responsible to confirm that controls are properly established prior to commencement of work. • The Department head is responsible to ensure each individual

worker has access to and uses required PPE. • The Department head is responsible to call stop unsafe acts, and

call for Time Out and Step Back 5X5 until conditions or practices are corrected.

• The Department Head is responsible to ensure that all equipment to

be used during the day is operated as per design and within safe operation limits and loads.



6.2 Monitoring Safety Onboard

Safety on board is monitored by the Shipboard Management Team, the nominated Safety Committee and the assigned Safety Officer. Office monitoring is the responsibility of the HSQE Department who will arrange regular on-board visits to audit safety and training standards and communicate with the ship on safety matters. HSQE monitoring will include confirmation, concurrence, and/or corrective action and close-out of HSQE issues, including: • Hot Work • Any Risk categorized as “Intolerable” in a Risk Assessment • Monthly Safety Reports • Audits and Inspections • Incidents

• The Technical Superintendent is responsible monitor

recommendations made during shipboard visits and highlight any need for improvement to senior management, track progress, and close reports when complete

• Formal safety meetings are to be conducted by visiting managers and superintendents as a standard conclusion to each visit

• All onboard inspections are to be recorded in the ShipNet database for monitoring and tracking

6.2.1 Safety Committee The vessel shall have an established Safety Committee that will meet on a monthly basis to review, discuss, report, analyze and evaluate hazards. The Safety Committee is to be made up of: • Master – As Chairman • Chief Mate (Safety Officer) • 3rd Mate



• 2nd Engineer • Bosun • Chief Cook • At least one senior rating from deck department • At least one senior rating from engine department • Any other members needed to comply with flag requirements

o The committee will meet monthly to discuss and record actions

related to:

Any reported incidents or unsafe conditions that have occurred, the results of investigations and recurrence prevention

On board procedures regarding health, safety &

environmental matters that require attention Accident, incident & pollution prevention procedures Safe working practices Correct use of safety and personnel protective equipment Safety suggestions or concerns from crew Any new safety related information received from the

company Safety training exercises held during the month and plans for

the upcoming month Status of safety equipment maintenance and records are

updated

A meeting of safety committee should be held as soon a practicable after any lost time accident or serious incident. The Minutes of monthly Safety Committee Meetings are to be recorded. An electronic copy of each monthly report is to be forwarded to the HSQE Department



• The Master is responsible for:

o Calling the meeting to order

o Ensuring all members attend

o Designating one officer to act as meeting secretary

o Ensuring minutes are recorded

o Transmission of minutes to the HSQE Department with cc to the

assigned Technical Superintendent

6.2.2 Safety Officer The Chief Officer is assigned the collateral duty of Ship Safety Officer, although some responsibilities such as equipment maintenance, is normally delegated to the Third Officer. The Safety Officers responsibilities include: • Inspection, testing, maintenance and readiness of the safety,

lifesaving, emergency and fire fighting equipment, including oversight of personnel assigned to carry out such maintenance

• Ensuring all crew and any riding crew, supernumeraries, etc.

receive the following instructions:

o Their duties in emergency situations

o The vessels alarms signals

o The location of muster points

o The use of equipment required during an emergency (e.g. life jackets, fire extinguishers, life boats, life rafts, etc.)

o Reporting hazards immediately for the attention of the Master,

senior onboard management and the company

o Assisting with the planning and coordination of drills, musters, training etc.



• Duties

o The Safety Officer has a duty to stop any work which he reasonably believes may cause a serious accident, and immediately to inform the master who is responsible for deciding when work can safely be resumed.

o The safety officer’s role should be a positive one, seeking to

initiate or develop safety measures before an incident occurs rather than afterwards.

o He should be on the lookout for any potential hazards and

means of preventing incidents.

o Try to develop and sustain a high level of safety consciousness among the crew so that individuals work and react instinctively in a safe manner and have full regard to the safety not only of themselves but also of others.

o The objective is to become the ship’s adviser on safety to whom

the master, officers and all personnel will naturally turn for advice or help on safe working procedures. As such the Safety Officer, must always lead by setting a good example!

o Where unsafe practice is observed, approach the individual or

responsible officer concerned to suggest improvements in his method of working or use the safety committee to discuss examples of dangerous or unsafe practices in a particular area.

o Where possible, ensure new staffs are assigned to work with a

crew member who is himself adequately familiar with safe working practices and is safety conscious.

o Greet experienced seamen joining the ship for the first time to

stress the importance of a high level of safety consciousness and of setting a good example to less experienced personnel.

• The safety officer should also promote safety on board, subject to

the agreement of the master, by

o Arranging the distribution of booklets, leaflets and other advisory material on safety matters



o Supervising the display of posters and notices, replacing and renewing them regularly.

o Arranging for the showing of films of safety publicity and, where

appropriate, organise subsequent discussions on the subjects depicted.

o Encouraging members of the crew to submit ideas and

suggestions for improving safety and enlist their support for any proposed safety measures which may affect them

o Effective communication of new requirements or advice in

relevant shipping legislation, Marine Notices and Company and ship’s rules and instructions relating to safety at work about the ship.

• Investigation of accidents and dangerous occurrences

o The safety officer has a duty to investigate notifiable accidents

or dangerous occurrences affecting persons on board ship or during access, as well as potential hazards to health and safety and any reasonable complaints made by any personnel, and to make recommendations to the master. All investigations are to be documented in company standard format, the extent of which is governed by the seriousness of the incident.

• Quarterly Safety Inspections

o The safety officer is required to carry out health and safety

inspections of each accessible part of the ship at least once every three months, or more frequently if there have been substantial changes in the conditions of work. “Accessible” should be taken as meaning all those parts of the ship to which any member of the crew has access without prior authority. Deciding whether “substantial changes in the conditions of work” have taken place is a matter of judgment. Changes are not limited to physical matters such as new machinery but can also include changes in working practices or the presence of possible new hazards. A record should be kept of all inspections.

o It is not necessary to complete an inspection of the whole ship

at one time, as long as each accessible part of the ship is inspected every 3 months. It may be easier to get quick and effective action on recommendations arising out of an inspection, if one section is dealt with at a time. When



inspecting a section the safety officer should be accompanied by the officer or petty officer responsible for it.

o Before beginning any inspection, previous reports of inspections

of the particular section should be read, together with the recommendations made and the subsequent action taken. The control measures identified in any relevant risk assessment should also be read, and compliance with them checked during the inspection. Any recurring problems should be noted and, in particular, recommendations for action which have not been put into place. It is important, however, not to allow the findings of previous inspections to prejudice any new recommendations.

• Quarterly Safety Officer Check Points

o Every three months, the Safety Officer is to personally inspect

the ship to identify and eliminate hazards utilizing the UK Code of Safe Working Practices, Annex 3.1 - Checklist for Safety Officer Inspection, as a Guide

o Defects and Non-Conformities are to be reported and recorded

in the ShipNet Database or by reporting forms if ShipNet is not functionally replicating

6.3 Safe Working Practices The company adopts the UK MCA Code of Safe Working Practices for Merchant Seamen for establishment of safe working practices onboard

• All working practices listed are incorporated by reference except for

those areas where the HSQE System provides specific alternative guidance

• Shipboard Management Teams are required to know and understand the Code of Safe Working Practices and ensure on board working practices are conducted in accordance with the code

6.3.1 Safety Stations

The company requires safety stations to be strategically located throughout the ship to ensure ready availability when needed



o Eye Wash Stations are to be placed at each location where paints, chemicals, or batteries are stored or stationed

o Chemical Protective Clothing, including gloves, goggles, and aprons is to be stationed at each location where batteries or chemicals are stored or stationed

o Lock-Out/Tag-Out Stations, including locks and tags, are to be prominently stationed in both deck and engine department work areas

o Decontamination showers and complete set of safety station for

Chemical Tankers as per approved plans

6.3.2 Time Out / Step Back 5 X 5 Each individual has a role to play in ensuring that activities are carried out in such a way as to avoid harm to persons, property or the environment. A call for Time Out is method of accident prevention that is basic safety expectation of all staff. • A Time Out is an individual’s right and obligation to “Stop the Job”

whenever they see imminent and pressing danger. A Time Out requires the courage to speak-up even when senior personnel are present.

• Once a time out is called, all persons involved in the job should

“step back for five minutes”, more commonly referred too in oil industry as “Step Back 5 X 5”. This 5 minute break is to allow evaluation of the danger observed so that hazard controls can be put in place before the job is resumed.

6.3.3 Tool Box Talks Tool box talks should be conducted every morning by both deck and engine departments. Tool box talks are to be used to distribute the day’s work assignments and discuss required precautions. These talks are informal and need not be recorded unless new or dangerous work is involved and a Job Hazard Analysis or Risk Assessment is needed for the job. • A library of Tool Box Topics is provided for a variety of safety

concerns. Tool Box Topics may be used in conjunction with tool



box talks, as corrective action for related incidents, or for posting on bulletin boards for general awareness as deemed appropriate by the safety officer.

6.3.4 CARE Card System

o In order to facilitate awarding individual effort, a CARE Card Reporting System has been established and to promote greater near miss reporting

o CARE is an acronym that provides a means of correcting unsafe behaviors in a positive manner. CARE means to: C = Control - Control safety by observing fellow crew

members

A = Act - Take action if unsafe behavior or conditions are observed

R = Restore - Restore safe behavior or conditions

E = Express - Express concern for the well being of the

individual o CARE Cards have been printed in tear-off tablet form and are

distributed together with the Safety Winner incentive cards. CARE Cards provide a simple and straightforward reporting system that focuses on the correction of unsafe acts or conditions on the spot. The CARE Card system gives credit to the crew member, regardless of rank or position, who reports a danger or an accident intervention. The person, who submits the report, is the person whose name is on the card, and the person who is to be credited for having taken action.

o CARE cards are to be collected by the Safety Officer in a public

"suggestion box" type receptacle. The Safety Officer is responsible to monitor onboard use of CARE Cards and ensure all hands are aware of the process and the company's expectation to participate. At the end of each month, the contents of the box are reviewed and closed-out by the safety committee each month by reviewing contents and highlighting corrective or preventive actions during all hands meeting. Brief details of the content the CARE Card are to be entered in ShipNet as a Near Miss. All minor Near Miss occurrences are to



be "Closed-Out" in ShipNet by the Master and moved to the "Closed" Folder.

• A CARE Card should be issued to document the reason any time-out

is taken for safety reasons

6.3.5 Personal Protective Equipment (PPE)

All persons embarking company vessels are required to strictly adhere to personal protective equipment requirements where and when conditions warrant.

• Figure 6.3-1 Provides basic guidance for conditions and situations

where PPE is required

• The cost of this PPE shall be borne by the company. The following items are to be issued to each crew member:

o Safety Helmet with chin strap o Safety Shoes

o Chipping Goggles

o Boiler Suits x 2 for each man

o Hearing Protection (ear defenders or ear plugs)

o Gloves

• Any damaged safety equipment or protective clothing is to be reported to the Chief Officer for assessment

• All PPE that has been discarded due to poor condition is to be

destroyed or removed from the vessel o Only PPE that is of a good quality, correct for the purpose it is to

be used for and properly fitting is to be ordered and supplied



Figure 6.3-1 Personal Protective Equipment Requirements

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On Deck Machinery Space Mooring Operations Anchoring Operations Cargo Operations Crane Operations Wire Handling Lifeboats / Rescue Boat Ship Side Height > 1.8M De-scaling Painting Cleaning Equipment Chemicals Welding Power Tools Electrical Hydraulic Pressure Steam Mandatory As Required

• SAM Master List 012 - Ship Protective Clothing, provides the

minimum inventory of PPE to be maintained onboard

• The Department Head is responsible for issuance of individual PPE, monitoring it’s use and condition, and retirement for service when conditions dictate

• Personnel are required to wear flotation whenever embarking from sea-side by boats or when working over the side, or rigging the gangway outboard of the maindeck



6.4 Dangerous Work All jobs listed below require the issuance of a Permit to Work. Permits ensure that workers are briefed on dangers or hazardous work and provide checks to ensure that energy sources are locked out, controls are marked to identify and isolate hazards (Lock Out - Tag Out), and/or flammable ignition sources. • A permit to work is required for the following:

o Working aloft with elevated height greater than 1.8 meters

o Work with Asbestos

o High Pressure Systems, Steam, Hydraulics or Compressed Air

o Electrical Work o Diver and Underwater Operations

o Confined Space Entry

o Hot Work

o Other Cold Work on Tankers

o Grit Blasting

o Elevator Maintenance

• Dangerous Work Permit Form HSQE 004 is provided as a general

work permit for hazardous work • Enclosed Space Entry Permit Form HSQE 007 is provided for use

during confined space entry

• Hot Work Form HSQE 008 is provided for use for all hot work outside the designated workshop

• In case of electrical work, a signed and dated Electrical Isolation Tag is specifically required.

• For Helicopter Operations, the checklist in the ICS Guide to Ship / Helicopter Operations is to be used



• For tankers, the company adopts the safe practices for management of dangerous work as specified in the International Safety Guide for Tankers and Terminals (ISGOTT)

o The company requires all hot work, confined space entry, and

tanker safety procedures to be carried out strictly in accordance with ISGOTT Guidelines which is incorporated by reference

o Shipboard Management Teams are required to know and

understand the requirements of ISGOTT and ensure on board practices are conducted in accordance with the guidance contained therein

6.4.1 Hot Work Hot work is defined as any work requiring use of welding, burning, soldering equipment, blow torches, or work with power driven tools or portable electrical equipment that is not intrinsically safe, and internal combustion engines. Any work involving sources of ignition that might cause ignition of flammable gas mixtures. • Hot work may only be carried out outside the designated and

approved work shop, if a Hot Work Permit has been issued and no other viable means of repair exists. Alternatives to be considered include cold work or removal of the piece for repair in the main machinery space work-shop. o For any hot work outside designated and approved welding and

cutting work shop , the Master is to submit to the HSQE Department a written request with full details of the work proposed and a risk assessment detailing the expected hazards and controls to be established. HSQE concurrence is required prior to commencement of planned works and before the Hot Work Permit may be approved.

• On tankers that carry petroleum or chemical cargoes all enclosed

spaces including the cargo and ballast tanks, void spaces, duct keels and pipelines must always be considered to contain residual pockets of hydrocarbon or other explosive or flammable gases

• On bulk carriers the dust from cargoes of coal, wheat, etc. may

have an explosive mix



• All ships present risks in the vicinity of fuel tanks, hydrogen emission from catholically protected ballast tanks, ignition of flammable materials or vapours (e.g. paint), and the use of welding and burning equipment may cause the conduction of heat through steel from safe to unsafe areas. The Master is responsible for ensuring hot work is conducted safely and is to ensure that the correct hot work procedures are planned, understood and will be followed, after which a hot work permit may be issued.

• Hot work shall always be treated with extreme cautions especially when it is to be performed outside the designated workshop. Following requirement shall be met prior commencing hot work

• A Hot Work Permit is required to be completed for any hot work

outside the designated Machinery Space Workshop,

• Risk Assessment to be completed and concurrence from HSQE Department necessary before job commences

• Within Machinery Space Workshop, Permit is not necessary - this is

a designated area for hot work. • Prior to starting any hot work:

o Designate the person in charge of the hot work

o A safety meeting is to be held with all those involved in the hot work. Briefing on the hot work procedures, communications procedures and any related safety precautions and contingency plans must be given

o The Chief Officer will assess the hot work area and carry out the

necessary checks and tests after which a written hot work permit with a duration that does not exceed 12 hours may be issued by the Master for each intended task

o In the case of the engine room and engine room workshops the

Chief Engineer may assess the hot work area • The procedures and precautions with all incorporated checks and

tests are to be carried out: o After a permit time has expired and before continuing with hot

work



o After hot work has been suspended, and prior to starting hot work again

6.4.1.1 General Precautions The following precautions must be observed on every occasion when hot work is intended: • On board tankers ISGOTT / Tanker Safety Manual (Chemical)

procedures are to be strictly followed at all times.

• All operations involving the cargo or ballast system including tank cleaning, gas freeing, purging or inerting are to be stopped before and throughout the duration of the work

• Suitable and adequate firefighting equipment is to be made ready

for immediate use. Where hot work is to be carried out at a compartment boundary then firefighting equipment is to be readied on both sides of the boundary.

• A fire watchmen with radio contact to the bridge is to be posted and fully briefed

• The hot work area is to be cleared of all combustible material

including any combustible material on the adjacent side of any boundary. Adjacent tanks, holds, pipelines, etc. must be confirmed free of any dangers posed by hot work.

• The work area is to be adequately ventilated. The frequency of atmosphere monitoring is to be established and recorded in "Hot Work Permit". Atmospheres should be re-tested after each break in work periods and at regular intervals as defined in the Form. The results of these checks are also to be recorded on the Form. Checks are to be made continuously to ensure there is no ingress of flammable vapours or liquids, toxic gases or inert gas from adjacent or connected spaces.

• Hydrocarbon gas is generally heavier than air and may be present in pockets in compartments that have been ventilated for some time. However, methane gas which may be emitted from coal cargoes is lighter than air and therefore hatch covers must be tested. It is therefore most important that tests should be made throughout any compartment and at different levels.



• Hot work on pipelines and valves is permitted when the item has been detached from the system by cold work and the remaining system blanked off. The item to be worked on should be cleaned and gas freed to be safe for hot work regardless of whether or not it is removed from the hazardous cargo area.

• Check the work area and adjacent compartments and tanks are gas free with properly calibrated instruments

6.4.1.2 Precautions in Enclosed Spaces Where hot work is to be carried out within an enclosed space, all Enclosed Space Entry Procedure procedures detailed in this document must be completed, and the following precautions taken:

• The compartment is to be cleaned and ventilated until tests of the

atmosphere indicate 21% oxygen content by volume and not more than 1% LEL

• Arrange for continuous ventilation during hot work

• Adjacent cargo tanks, including diagonally positioned cargo tanks, should either be:

o Cleaned and gas freed, with hydrocarbon vapour content

reduced to not more than 1% LFL and maintained at that level; or

o Emptied, purged and the hydrocarbon vapour content reduced to less than 2% by volume and inerted; or

o Completely filled with water

o All other cargo tanks should be inerted and their deck openings

closed.

o Slops are to be placed in a tank as far away as possible (at least 30 metres) from the hot work area and that tank kept closed

o All interconnecting pipelines to other compartments should be

flushed through with water, drained, vented and isolated from the compartment where hot work will take place



o All sludge, scale, sediment or other material likely to give off flammable vapour is to be removed from an area of at least 10 meters around the area of hot work. Special attention must be given to the reverse sides of frames and bulkheads. Other areas that may be affected by the hot work, such as areas immediately below are to be cleaned.

• For Bunker Tanks

o Fuel oil bunker tank may be considered safe if tests using a

combustible gas indicator give a reading of not more than 1% LEL in the ullage space of the bunker tank however, no heat transfer through the bulkhead of the bunker tank is to be caused by any hot work

o No hot work should be carried out on bulkheads of bunker tanks containing bunkers or within 0.5 meter of such bulkheads

6.4.1.3 Welding, Burning and Cutting Equipment Company Poster STP 011 is to be posted to provide instruction for the safe working practices and the safe operation of all welding, burning and cutting equipment to be used. This sign would normally be posted in the engine room workshop adjacent to the equipment and at the storage site of any oxygen and acetylene bottles. • The Chief Engineer has the responsibility of assessing and

designating those onboard who may operate the ships welding, burning and cutting equipment to Adequate ventilation must be provided in all spaces where welding is undertaken to eliminate the gases, fumes and dust caused by the welding operation.

• Noxious and toxic fumes may be produced during welding or burning operations and the burning process may result in depletion of oxygen therefore adequate ventilation must be arranged and respiratory protective masks provided if necessary.

• Welding and burning equipment is to be carefully inspected before use to ensure it is in good condition and operating normally. Special attention must be paid when using electric-arc equipment ensuring:



o That electrical supply connections are made in a gas free areas and the cable route to the work site is the safest possible and passing over gas free or inerted spaces

o Cable connectors are to be insulated and designed that live

terminals are not exposed on disconnection and electrode holders should be fully insulated so that no live part of the holder is exposed to touch

o That existing supply wiring is adequate to carry the electrical current demanded without overloading and causing heating. Therefore, the cables should be inspected before use; if the insulation is impaired or conductivity is reduced, they should not be used

o The insulation of flexible electric cables laid across the deck is in good condition

o The earth connection is made adjacent to the work site and the

earth return cable leads directly back to the welding machine o Compressed gas cylinders are to be handled with care, properly

secured and kept upright with valves up and have valve covers in place during transport

o Flash Back suppressors are fitted at the inlet to the cutting torch

and at the Oxygen & Acetylene tank outlets

• Operator’s of welding and burning equipment are to:

o Be protected by clothing, leather gloves, non-conductive safety footwear and a welding helmet or suitable alternate (e.g. Eye goggles or a hand-held shield) Eye injuries are serious and may lead to permanent loss or impairment of vision

o Have an assistant in attendance ready to assist in case of

accidental electric shock or other injury

o Be protected from contact with the ships structure by the provision of dry insulating mats or boards

o Take extra care when welding operations are undertaken in hot

or humid conditions when body sweat and damp clothing increase the risk of electric shock



o Under no circumstances to work while standing in water or with any part of his body immersed

o Have completed training in welding competencies

6.4.1.4 Concurrence It is Master's Responsibility to obtain concurrence for the HSQE Department that the controls described in the Risk Assessment are adequate. Each request must be made in writing and submitted 48 hours prior to the commencement of the planned hotwork. Each request should: • Be specific as to the exact location

• Provide the Work Scope and Detail of all action

• Describe the Reason as to why it is critical to conduct this hot work

at this particular time

• Detail the Planned Safety Precautions including preparations such as line flushing and water plugs (where deemed appropriate)

• Be sent to the technical superintendent responsible for the vessel with a copy (cc) to the HSQE email address - [email protected]

• Technical Superintendents duty upon receipt

o It is the responsibility of the dedicated Technical Superintendent to view the initial request and ascertain if this hot work is justified and in line with his own plans for the vessel. In turn he will add his own comments and recommendations to the request documentation (as received from the vessel).

o The superintendent will then forward comments to HSQE Department for final review, from a safety perspective.

• HSQE duty upon receipt

o Upon receipt from the HSQE Department they will add their comments. It would be the responsibility of HSQE to review the Hot Work Concurrence request in its entirety and ensure all



safety aspects have been identified both in the initial part of the request from the vessel and technical departments' suggestion. Upon the completion of review, he should be satisfied all safety measures are in place, if not he should supply details of any additional measures to be considered. The Concurrence request is then transmitted back to the vessel detailing agreement or restricting conduct of the hot work.

• Close out notes on Hot Work

o Upon receipt of the Hot Work concurrence from the Head Office, the usual practice for the ship to carry out the Hot Work on board will be to have a Tag-in and Tag-out notes. This will ensure that all equipment used on board for Hot Work are properly checked and cleared from the Hot Work area at the end of the Hot Work. By doing so will ensure nothing is left about in the tanks or at the work place. All future Hot Work completion messages must contain the phrase "Hot Work completed and properly closed-out" to indicate that all equipment used for the hot work are cleared item by item in a tag-in tag-out fashion

• Close-out of Request

o It is the responsibility of every Master to ensure proper close-out

of all hot work operations. When you notify the office of the completion of the hot work, the work area is deemed to be safe, area cleared and vessel returned to normal safe operation (such as cargo tanks re-inerted).

6.4.2 Enclosed Spaces

Often a question on board will be what constitutes an enclosed space? The IMO defines an enclosed space as being one which has any of the following characteristics: • Limited openings for entry and exit;

• Inadequate ventilation; and

• Is not designed for continuous worker occupancy The definition includes, but is not limited to, the following compartments: Cargo spaces , Double bottoms, Fuel tanks , Ballast tanks, Cargo pump-rooms, Cargo compressor rooms, Cofferdams ,



Chain lockers, Void spaces, Duct keels, Inter-barrier spaces, Boilers , Engine crankcases, Engine scavenge air receivers, Sewage tanks . • The Safety Officer is to conduct and keep records of a Risk

Assessment to identify ALL Enclosed Spaces onboard, as well as related hazards and controls needed to ensure safe entry. A master-list of confined spaces should be signed by the Master and kept in the cargo office for easy reference, together with confined space entry permits

• The Safety Officer is to ensure confined space rescue drills are being carried out at least once every six months (as required by HSQE 021 - Record of Drills, Trainings & LSA Maintenance).

• The Safety Officer is to ensure training in the use of the gas instruments carried onboard has been carried out and recorded in HSQE 021 when scheduled; training should include: o Identification of the hazards likely to be faced during entry into

enclosed spaces;

o Recognition of the signs of adverse health effects caused by exposure to hazards during entry; and

o Knowledge of personal protective equipment required for entry

• Entrances to enclosed spaces should be secured at all times when entry is not required.

• When opened, an attendant should be posted at the entrance, or a suitable mechanical barrier should be placed across the opening together with a warning sign to prevent accidental entry.

• All gas and oxygen detectors used are to be function tested and if necessary calibrated. Only personnel familiar with the gas and oxygen testing equipment are to carry out testing of the enclosed space atmosphere

• In some cases it may be difficult to test the atmosphere throughout the enclosed space without entering the space (e.g., the bottom landing of a stairway) and this should be taken into account when assessing the risk to personnel entering the space. The use of flexible hoses or fixed sampling lines which reach remote areas within the enclosed space, may allow for safe testing without having to enter the space.



• Steady readings of "not more than 50% of the Occupational

Exposure Limit (OEL) of any toxic vapours and gases" should be obtained prior to entry along with a remark that "It should be noted that the term Occupation Exposure Limit (OEL) includes the Permissible Exposure Limit (PEL). Maximum Admissible Concentration (MAC) and Threshold Limit Value (TLV) or any other internationally recognised terms.

• It should be emphasized that the internal structure of the space, cargo, cargo residues and tank coatings may also present situations where oxygen-deficient areas may exist, and should always be suspected, even when an enclosed space has been satisfactorily tested as being suitable for entry, this is particularly the case for spaces where the path of the supply and outlet ventilation is obstructed by structural members or cargo.

• If it is unclear whether or not a particular compartment is an enclosed space, a risk assessment should be carried out in accordance with IMO recommendations to overcome any doubts. The process of carrying out a risk assessment to identify enclosed spaces should be repeated at regular intervals as circumstances may change.

6.4.2.1 Entry Entry into enclosed spaces is only permitted when: • A Risk Assessment has been completed or reviewed

• Entry requirements specified on SeaTeam Form No. HSQE 007-

Enclosed Space Entry Permit have been verified and the results recorded on the permit by hand in pen and ink o Enclosed Space Entry Permits are valid during the normal

working day, and not to exceed 12 hours

• A pre-entry safety meeting has been conducted to review the Risk Assessment and Entry Permit to reiterate hazards and required controls

• The Permit has been signed by the personnel entering the space, the safety "Attendant", and it has approved by signature of the Master or Safety Officer.



• The atmosphere is continuously monitored with portable gas

monitors with audible alarm where applicable if personnel leave the space for more than 30 minutes, the atmosphere must be re-tested at the lowest point

• Simultaneous tank entry.

o Where simultaneous entry is required in different locations, separate permits must be issued. When issuing more than one permit, due consideration must be given to having sufficient resources available for emergency including personnel and safety equipment.

o A detailed risk assessment is to be carried out, detailing safety precautions to be put in place to minimize risks posed by simultaneous entries. Except for periods when the vessel is gas free (e.g. during dry docking), copy of the risk assessment is to be forwarded to the HSQE/Marine Superintendent for review and concurrence prior to commencement of simultaneous entry of multiple spaces.

6.4.2.2 Atmospheric Tests Prior to entry into a confined space, atmospheric testing must be conducted at least three levels, including the lowest point, with properly calibrated gas detection instruments for the space to be considered safe for entry. Testing is to be conducted based upon known hazards associated with specific types of enclosed spaces: • Cargo holds, ballast tanks, and voids

o Oxygen content must be 21% by volume

• Cargo, fuel tanks and other enclosed spaces on tank deck area

o Oxygen Content must be 21% by volume

o Hydrocarbons must be less than 1% LEL

o Toxicity - Is measured to be less than the Threshold Limit Value

(TLV) for all known or suspected toxins. The previous cargo and bunkers provides an indicator of toxins that should be suspected



Lack of Oxygen Lack of oxygen is to be suspected in any enclosed space. The following situations require risk evaluation of oxygen levels: • Tanks and other compartments that have been closed for a period

of time particularly if they have contained water, have been subjected to damp or humid conditions or have signs of heavy corrosion

• Oxidation of cargoes. Logs, sawn lumber, iron ore, coal, grain,

vegetable oils and tapioca are among the numerous cargos known to consume oxygen in the atmosphere or to displace it by the evolution of other gases (such as Carbon Monoxide)

• If an adjacent space has been inerted Flammable or Toxic Gases Flammable or toxic gases should be suspected in all of the following: • In the cargo tanks, pump-rooms, pipe-ducts, sewage tanks, bilge

tanks, slops tanks, paint storage rooms, and other adjacent spaces in oil and chemical tankers

• If sludge, scale and cargo residue is disturbed or subjected to a rise in temperature then gas free spaces or tanks may evolve or produce dangerous concentrations of flammable or toxic gas

Carbon Monoxide Carbon Monoxide is a colorless odorless and tasteless gas that can be fatal in high concentrations, Atmospheric testing and use of portable alarms is required when conditions for production exist • Ships Discharging Vegetable Oils

o Prior to entry into cargo tanks with vegetable oil or vegetable oil residues,



• Combustion Driven Engines o Whenever combustion driven equipment such as pumps or

tractors, are operated in a confined space, hold or pump-room

6.4.2.3 Ventilation Should any atmospheric test reveal an unsafe atmosphere, the space should be continuously ventilated with portable power ventilation fans until the space is safe for entry. To avoid short circuiting, where ventilated air exits the space without reaching the lowest points, extendable air ducts should be fitted to fans and lowered to the lowest point, as far diagonally opposite the tank hatch as possible. • Ventilation should be maintained continuously throughout entry

• For vapours heavier than air (most clean products) the fan should

take suction through the duct from the low point and exhaust vapours from the tank while bringing in fresh air from the hatch

• For vapours lighter than air, the fan should blow air through the duct at the low point and force vapours from the tank through the hatch

6.4.2.4 Pre-Entry Safety Meeting The crew entering and those on standby outside the space are to be briefed on: • Work instructions, expected duration of entry and the dangers and

hazards that may be encountered

• Working and safety equipment requirements

• Use of personal oxygen or gas alarms

• Contingency and emergency plans

• Additionally, those on standby outside the space are to receive instruction on:

o Raising the alarm by radioing the duty officer should agreed

signals fail



o The duty officer will use the General Alarm to alert the crew of

any emergency

o Enclosed space atmosphere re-testing requirements o Rescue procedures. In relation to this, experienced personnel

should be used 6.4.2.5 Emergency Standby Equipment The following equipment must ready for use and put on standby outside the enclosed space: • 2 SCBA -Self Contained Breathing Apparatus

• EEBD - Emergency Escape Breathing Device

• Tripod with block and tackle, lifelines and rescue harness

• Remote gas detection instruments with hoses long enough for

deepest space

• UHF two-way Radio The list of standby equipment is for guidance and is not exhaustive. Ship's crew may add whatever extra equipment is deemed necessary for safe entry. Where practical a trolley cart should be used to consolidate standby equipment and to transport the items around the deck area, which is especially helpful when more than one enclosed space is to be entered. 6.4.2.6 Communication The Duty Officer is to be advised of each enclosed space entry and must understand the system of communication between those entering the enclosed space and those on standby outside the space. Suggested forms of communication include:

Verbal via UHF Radio • Are you ok / I'm ok



Clicking of Torch Light beam

• Two clicks - are you ok / three clicks - I'm ok

Tapping with a Hammer • Two taps - are you ok / three taps - I'm ok

6.4.2.7 Work on Pipelines and Valves Particular care should be exhibited when working on pipelines and valves within the space. If conditions change during the work, increased frequency of testing of the atmosphere should be performed. Changing conditions that may occur include increasing ambient temperatures, the use of oxygen-fuel torches, mobile plant, work activities in the enclosed space that could evolve vapours, work breaks, or if the ship is ballasted or trimmed during the work", and that "In the event of an emergency, under no circumstances should the attending crew member 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. Only properly trained and equipped personnel should perform rescue operations in enclosed spaces." Where equipment, valves or pipelines are to be opened within an enclosed space and there is a risk that a flammable and or toxic liquid or vapour may be released: • the equipment, valves or pipelines are to be thoroughly flushed

through with water and properly ventilated prior to opening

• Breathing apparatus are to be available at the work site

• Continuous gas monitoring is to be conducted while opening up the equipment, valves or pipelines

6.4.2.8 Spaces that are not Gas Free Spaces that have not been tested should be considered unsafe for persons to enter", and that "Persons entering enclosed spaces should be provided with calibrated and tested multi-gas detectors that monitor the levels of oxygen, carbon monoxide and other gases as appropriate". Entry into a space that is not gas free or does not contain 21% oxygen is only to be permitted on emergency basis when



there is absolutely no other alternative. The following restrictions apply: • Prior to entry, the Marine Department must be advised of the

reasons for the restricted entry

• All crew involved are to be fully briefed on the hazards and extra safety procedures to be followed

• The number of persons entering is to be kept to a minimum however; no less than two persons are to enter the space

• Those entering are to wear either a compressed air breathing apparatus or an airline mask with an external air supply connected to the belt

• An emergency rescue team fully equipped with breathing apparatus

and rescue equipment to be on stand by

• Completion of the 'Restricted Entry Addendum' to the enclosed Space Entry Permit (SeaTeam Form No. HSQE 007) where all conditions must be satisfactorily met

• Where needed, selection of Chemical Protective Clothing (suits,

boots and gloves) is to be made, based on the knowledge of the process for determining chemical resistance and personal exposure limits

• Personnel (Master or Chief Officer) deciding upon a restricted entry

must have been trained on the following topics: o How to determine the permissible exposure limits as expressed

by a specific chemical's TLV-TWA, TLV-STEL and TLV-C o Location and understanding of Material Safety Data Sheets

o How to operate and calibrate a toxic gas detector and determine

results on a direct reading detector tube

o How to use the "Quick Selection Guide to Chemical Protective Clothing" to properly determine chemical resistance requirements



o The fully equipped rescue team that will be on standby at the tank entrance for the duration of the restricted entry must be briefed

o In all cases, the HSQE Department shall be contacted in advance

to review the prepared risk assessment and provide concurrence regarding the adequacy of controls

6.4.2.9 Painting The company considers spray painting and the use of two (2) component paints, such as Epoxy, in enclosed spaces to be extremely dangerous. Any painting in an enclosed space may lead to an atmosphere that is explosive, flammable, and, or toxic. Painting in enclosed spaces may only be carried out after risk analysis has been carried out. The following safety guidelines apply when painting in enclosed spaces: • A Restricted Entry Addendum to the confined Space Entry Permit

has been completed and all safety checks are satisfactorily complied with

• Adequate forced ventilation to ensure the atmosphere does not become explosive or flammable must be provided

• The crew assigned to the space has been specifically instructed with

regard to hazards expected

• Air line masks must be worn by personnel painting in the tank

• Filter masks are prohibited

• Lights and power tools must be pneumatic air driven type

• Electric lights are prohibited when painting in confined spaces 6.4.2.10 Personal Gas Detectors The use of personal type gas detectors is intended for monitoring of ambient conditions in the work place. The detectors are designed to be carried in gas free spaces where unsafe conditions may occur



rapidly (e.g. petroleum cargo leak in a pump-room) and to give the wearer some notice and alarm of an oncoming danger. The use of personal type gas detectors in enclosed spaces is for a person entering the space after it has been previously checked by remote sensing devices and found safe for entry. The personal gas detectors are to be set to alarm when atmospheric conditions deteriorate to unsafe levels warning the wearer to leave the space. The detectors are to be calibrated according to the manufacturer's instruction and prior to entry, the alarm is to be tested. Whenever pump-rooms or confined spaces are entered, at least one person must wear a personal gas detector that will alarm if low levels of Oxygen (less than 19% by volume) or high levels of hydrocarbons (more than 10% of lower explosive limits) are encountered. When wearing personal gas detectors: • Keep away from the effects of own exhaled air • Carry so the sensor is not covered or blocked

• Keep away from UHF radio as this may cause a false alarm

• Refer to manufacturers instructions when in doubt 6.4.2.11 Marking of Entry or Access Hatches All vessels must assume that confined spaces, including cargo tanks and holds, ballast tanks and similar spaces are unsafe until proven otherwise. • All access points are to be marked with the following warnings on a

yellow background with black writing

o DANGER - LACK OF OXYGEN

o DANGER – FLAMMABLE/TOXIC GAS (cargo tanks)

o DO NOT ENTER WITHOUT PERMISSION OF CHIEF OFFICER • Access to holds and hatches are to be pad locked at all times and

the keys are to be held by the Chief Mate. Therefore, the holds and hatches can only be entered with the Chief Mate's consent and knowledge



• Prior to entry into cargo holds, the atmosphere is to be checked for Oxygen, unless forced ventilation is permanently fitted

• Prior to arrival, hold atmospheres should be checked and ventilated a short time before berthing

6.5 Hydrogen Sulfide (H2S) To ensure safety in tanker and terminal operations, all personnel involved should be familiar with the following precautions when handling all cargoes and bunker fuels likely to contain hazardous concentrations of Hydrogen Sulphide. Precautions are also be observed during ballasting of cargo tanks, tank cleaning and gas freeing operations associated with the carriage of previous cargoes having a Hydrogen Sulphide content. • Exposure levels in all work locations should be monitored by using

suitable instrumentation for detecting and measuring the concentration of the gas. Detector tubes should be used if it becomes necessary to monitor a known high concentration. High concentrations and the corrosive nature of the gas can have a damaging effect on many electronic instruments.

• Bunker fuel tanks should be monitored prior to, during and after

bunkering. If H2S has been detected, the bunker tank should be periodically tested. Although the concentration in the vapour space can be successfully lowered by forced air ventilation, it often increases again when the bunker fuel is heated, transferred or agitated by other means. Bridge, control room, accommodation and engine spaces should be monitored if H2S may be present. Ventilation systems should be operated as far as possible to prevent H2S vapours entering the accommodation and engine spaces. A low concentration of H2S over time can cause discomfort to personnel.

• The use of personal H2S gas monitoring instruments for personnel

engaged in cargo operations is required. Warning alarm which should be set at a value not exceeding 5 ppm or the latest TLV which ever is less. Personnel should always carry personal monitors when working in enclosed spaces, gauging, sampling, entering a pump room, connecting and disconnecting loading lines, cleaning filters, draining to open containments and mopping up spills.



• In addition to being a health hazard, the H2S odour is also considered a public nuisance. Most local environmental regulations limit or ban the release of H2S concentrations to the atmosphere and this is, in any case, good practice. It is therefore necessary to maintain cargo tank pressures within acceptably low limits. The tank vapour pressure will rapidly increase if vapour space is exposed to heat or the product is agitated. Crude oil washing may rapidly increase the vapour pressure and should begin at a relatively low pressure and, preferably, while maintaining a relatively high discharge rate.

• Respiratory Protective Equipment

o Whenever high concentrations of H2S are likely to be present, Emergency Escape Breathing Devices (EEBD) should be made available to all personnel working in hazardous areas. They should be used in conjunction with a personal H2S gas monitoring/alarm instrument.

o Personnel should be instructed to don their EEBD should their

alarm activate and immediately leave the area to an upwind location. They should advise the central control location of the presence of a high gas concentration in order that appropriate procedures can be initiated.

o Self-contained breathing apparatus should always be worn if it is

considered necessary to breach the integrity of the cargo system and a vapour free atmosphere cannot be guaranteed. This would include the following activities:

Open gauging and sampling;

Removing blanks for connecting the cargo hose or

loading arm;

Cleaning filters;

Draining lines to open containment; and

Mopping up spills.

o Chemical cartridge respirators should not be used for protection against H2S vapours, as the vapour concentrations in the



atmosphere may exceed the operational capability of the respirator being used.

• Training is to be periodically conducted for crewmembers to highlight the hazards associated with H2S and the precautions to be taken to reduce the risks to an acceptable level. Daily Tool Box talks and MSDS sheets should be utilized to convey:

o Safe operating procedures for all operations;

o Gas testing/atmosphere monitoring procedures;

o Maintenance procedures for cargo related systems;

o PPE requirements;

o Contingency planning; o Emergency response measures; o Measures to protect visitors from exposure.

6.6 Winning with Safety Incentive Program Incentives are provided by the company as a means of encouraging and rewarding safe practices.

• To provide crew with an incentive for safe operation and behavior

based safety, SeaTeam has established a "Winning with Safety" Incentive Program to reward those who promote safety and maintain superior safety records.

• The company will provide each vessel with a quantity of Safety Winner "scratch and win" type incentive cards to reward safe practices.

• Each Safety Winner "scratch card" provides two chances to win cash prizes. Each card has an "Instant Winner" scratch box and a "2nd Chance for Safety" scratch box. The "Instant Win" scratch box provides opportunities for recipients to win CASH awards of $10, $20, $50, $100, $300, or $500 as an incentive for safe behavior. Winners are to be paid in cash by the Master after reporting the winning numbers to the HSQE Department.



• The "2nd Chance for Safety" scratch box which provides a second opportunity for recipients to earn $500 for the ship's welfare fund. Each 2nd Chance block when scratched will reveal one letter in the company name, S.E.A.T.E.A.M. Working together, the crew onboard may collect and compare cards with the objective to correctly spell SEATEAM. Each ship who manages to spell the company name will be awarded a $500 contribution to the welfare fund as a collective safety incentive.

• Game cards will be distributed in bulk to all vessels in the fleet and periodically topped up as need be to maintain availability onboard. The HSQE Department is responsible to monitor game play and as onboard inventories of game cards are depleted over a 3-6 month period.

• Each Vessel will be provided an inventory of scratch cards to be maintained and controlled by the Master. Cards are randomly shuffled and distributed by the company so that awards are completely random. Cash award distribution is controlled so that each vessel will have an equitable mix of winning cards.

• Earning Incentive Cards - Cards will be awarded to crew members

on the basis of both vessel and individual performance.

o Vessel Performance - If the vessel has not experienced any LTI's in the previous 2 months every crew member serving onboard is awarded 1 Card

o For Tankers, If the vessel has undergone a vetting inspection in the previous month with 4 or less observations and no high risk, every crew member serving onboard is awarded 1 card

o For Bulk Carriers, If the vessel has completed a PSC with

inspection in the previous month with 2 or less observations, and no detention, every crew member serving onboard is awarded 1 card

o Individual Performance - Each Safety Committee, as chaired

and guided by the Master, will select two (2) crew members, who have, in the previous month demonstrated superior commitment to safe working practices and has exhibited Behavior Based Safety on the job. Each "Safest Crew" nominee will be awarded 2 cards each as Safety Incentive. No winner may be a repeat winner in consecutive month and the two winners can not come from the same department.



o Each Safety Committee, as chaired and guided by the Master, will select the best "CARE Card" and the best “Non-Conformity Report” submitted for the month. The crew members who raised the selected reports will be awarded 2 cards each as Safety Incentive. No winner may be a repeat winner in consecutive month.

• Issuance and Control of Incentive Cards - The Master shall issue

cards to winners during monthly safety meetings. All winning cards and corresponding serial numbers are then to be reported to the company HSQE Department for control verification prior paying out the award values from cash onboard.

o Incentive cards are to be publicly drawn during safety meetings o All cards in stock are placed in a plain cardboard box and the

box shaken to mix the cards so that winning cards are randomly distributed throughout the box

o Crew select cards one at a time while the box is held overhead

by a senior officer o Winning values are individual awards and are not to shared

among the crew

6.7 HSQE / Quality Safety Campaigns • Safety Posters

o Produced by the company to motivate achievement of the goals

and targets established in the 5 year HSQE Plan. • Quality / Safety Campaign

o Produced by owners to instill culture of safety awareness and

understanding of “human factor” and its role in safety culture. 6.7.1 Organizational Improvement Incentive

The company will an annual basis, review and consider suggestions for improvement submitted by staff, at sea or ashore, for awards of up to USD 1000 monetary incentive, for practical suggestions that result in:

• Improved efficiency in operations or cost reduction;



• A measurable decrease in trends in incidents, break-downs, or non-

conformances, or; • Significant improvement in customer satisfaction

At the end of each calendar year, management will review suggestions submitted for award eligibility. The best suggestions will be short-listed based upon the above criteria, and awards granted, depending upon the benefit of the suggestions as judged by the management team. The resulting incentive awards (if any) will be mentioned in the first management review and news letter of each new calendar year. 6.8 Safety Signage The company provides a standard set of safety signs and posters for display aboard ship to highlight common hazards and promote safe practices. Safety sign inventory is specified on Master List 011. It is a company requirement for safety signs to be posted in locations and quantities listed. 6.9 House Keeping Cleanliness and organization are essential elements in promoting safety and health must be maintained in all spaces onboard. This includes: • Laundry must never be hung out to dry on hand rails or on

makeshift lines rigged in the passages. If sufficient dryers are not available, designated drying rooms are to be established until additional dryers can be supplied

• Toilet areas must be kept clean, sanitized, and well stocked • The bridge, engine control, cargo control rooms must be kept well

organized with systematic labeling and filing. Instruction manuals and publications should be inventoried and indexed

• Galley and work-shop waste cans should be fitted with lids at all

times

o Waste paper bins in the accommodation bins must either have self closing lids or be of the self extinguishing type.



o All waste bins must be constructed of non-combustible materials

• Infestations of roaches and rats must be prevented through good

hygienic practices

o Use of poisons for infestation control must be in accordance with manufacturers instructions and safety data

o No poison may be kept in food or medicine storage areas

• Store rooms and workshops must be kept clean and well organized • Cabins and common spaces must be maintained in a sanitary

condition, clean and tidy

o Masters must ensure a weekly cabin inspection is carried out to ensure that cabins are clean and well maintained

o Showers shall have nozzles and kept operational o Toilets shall always be fitted with seats; broken seats are to be

replaced as soon as possible o For safety reasons, squatting with feet on toilet seats is

prohibited

6.10 Identification & Sharing of Best Practices Many times our crews may develop a new approach to a particular task that results in the development of best practices in the way work is accomplished, either with a higher degree of safety or with greater efficiency. Sources of best practices include employee ideas, and the hard lessons learned from painful and costly incidents. • The sharing of ‘best practices’ is the interchange of ideas between

companies and individuals who may jointly benefit from smarter strategies. Ideas may be generated by clever crewmen who develop a better way of doing things or from incidents where the need to control hazards are highlighted to prevent recurrence. Industry forums provide a platform for sharing lessons learned as do safety alerts and bulletins distributed by the company or received from other sources outside the Company. The HSQE Department is responsible to filter information so that content is



appropriate for dissemination within the company and/or for distribution externally to industry partners.

• The intent of the company is to share information as far as

possible, to progress safety, health and environmental protection throughout the maritime industry.

• Sharing will be accomplished via Safety Alerts, Fleet Circulars,

Seminars, and News Letters. 6.11 Incident Reporting, Investigation and Analysis

An Incident is defined as an uncontrolled or unplanned event, or sequence of events, that results in fatality or injury to Seafarers onboard, damage to property, loss of process or damage to the environment. Incidents involve People, Property, Process or Pollution. Response actions required for a particular incident depend upon its significance. • The Master is responsible to ensure all incidents are reported to the

company in a timely manner with accurate details entered in ShipNet

• The Master and Safety Officer are responsible to ensure all incidents are investigated by appropriate staff, and that adequate evidence is collected

• The Master and Safety Officer are responsible to recommend recurrence preventive measures

• The HSQE Department is responsible to accept or recommend additional recurrence preventive measures, track progress, and close reports when complete

• Anonymous Reports may be submitted to the DPA by via private email: [email protected]

6.11.1 Classification of Incidents Incidents are classified by severity so that appropriate managerial focus is placed on mitigating events with the greatest impact. Severity of consequence is rated on a scale from zero to five (0 – 5) with zero meaning no consequence (a near miss) and five meaning massive effect with cost more than USD 10 Million



• Minor Incidents

o Minor incidents are defined as those small injuries that may require first-aid but do not result in more that 24 hours of lost time, non-polluting environmental incidents such as leaks, material failures or break-downs that do not result in operational stoppage, and routine near miss incidents such as stopping unsafe acts

o Except for navigational incidents, minor incidents are typically investigated by trained personnel serving onboard

Minor incidents are to be investigated by the ship's Safety

Officer, with the supervision, oversight and concurrence of the Master.

Minor navigational incidents are to be investigated by shore

based office investigators as if significant and will be subject to oversight by the management office and shore based investigators

o Minor Incidents are those Rated 0 – 2 on the consequence scale,

with zero being a no consequence near miss

• Significant Incidents

o A Significant incident is one that may not be classified as minor and requires a more extensive investigation.

o A Significant incident is one where there is actual physical

damage to in excess of US$100,000, or those incidents where material damage affects the seaworthiness or efficiency of a vessel, fire, grounding, collision with fixed or floating object, loss of life, Injury hospitalized or repatriated include environmental incident resulting in pollution

o Significant incidents merit the direct involvement and will be

subject to oversight by the management office and shore based investigators

o Significant Incidents are those Rated 3 – 5 on the consequence

scale



• Sub-Classification of Personnel Incidents

o The company subscribes to the Oil Company Marine International Forum's (OCIMF) Marine Injury Reporting Guidelines, and sub-classifies all work related injuries accordingly

o The OCIMF Marine Injury Reporting Guidelines are incorporated

by reference and included in the ShipNet Incident Reporting Module for easy classification

o Shipboard Management Teams are required to know and

understand the sub-classification of work injuries, lost work cases, restricted work cases, medical treatment cases, first aid cases and ensure incident reports are properly classed

o Incident statistics are monitored in line with the OCIMF

guidelines so that safety awareness and training program can be evaluated by comparison of data to others in the shipping industry

• Near Miss Occurrences

o A Near Miss is an event, or sequence of events, which did not lead to an injury or any lost time but which, under slightly different circumstances, could have done so. A near miss is an incident, or occurrence that has no consequence. On the Severity Scale Zero (0) and designated “Minor

Near Miss”

o A "High Potential" Near Miss is an event where only by extremely good luck was a serious accident avoided. High potential near miss incidents are treated and investigated the same as a significant incident with consequences

On the Severity Scale Zero (0) but designated “High

Potential Near Miss”

High Potential Near Miss Occurrences are investigated as if a Significant Incident



o Statistically, there are supposed be 600 near miss incidents for every actual accident, but over reporting of insignificant matters can dilute important trends and is therefore not encourage.

o A near miss report should detail an occurrence that is worthy of

sharing of the lessons learned. o The company promotes the reporting of near misses as a means

accident prevention and process improvement. o It is expected that each main department, deck and engine,

should document a minimum of one near miss per month in line with industry averages

o Near miss occurrences should be a standard discussion point

during departmental and all hands meetings

6.11.2 Reporting The assigned Technical Superintendent is the first point of contact for all incident notifications and should be made verbally by telephone immediately or otherwise as soon as possible. Written follow-up notification must follow within 24 hours of any significant accident, lost time injury, or high-potential near miss • Within 24 hours, or as soon as crisis response in under control, the

HSQE Department will evaluated and determine if any urgent safety-related information should be transmitted and disseminated to the fleet.

• It is important that all necessary information is passed on and thus an IMO Format written report should follow as soon as possible.

o All Officers are required to know how to report incidents in

accordance with the company' Emergency Contingency Plan o The written report should be submitted with details of the

incident and any remedial action taken up to that point. o In all cases, Vessels' assigned office email is primary addressee

of all Incident Reports.



6.11.3 Investigation Incident investigation reports should be completed by responsible officers with no direct involvement in the incident and submitted to the Master for review, corrections where/if needed, and forwarded to the HSQE Department via the ShipNet Database. • The investigation report should include a detailed narrative and

chronology of the incident. All relevant supporting evidence should be attached, including, where applicable:

o Statement(s) of Fact (SOF) - are statutory requirements in the

event of a significant accident and should include all details with relevant times, position, consequences, names of witnesses, etc. SOF’s should contain verifiable facts and no speculation.

o Note(s) of Protest (NOP) - A ‘Note of Protest’ should normally be

made to a third party to protect the interests of Principals. Notes of Protest should not apportion any blame but simply identify a point of concern. The NOP should mention that it is made “without prejudice” and that it is possible that there will be a reference back to this issue at a future date.

o Copies of Log Book entries related to the incident o Copies of the following are required for all significant incidents

as applicable to the events prior to and during the incident data event:

Deck Log book

ER log book

Movement books (Deck and ER)

Standing Orders (Bridge and ER)

Course Recorder

Echo Sounder (if appropriate)

Port Log (cargo operations)

Weather forecasts – Navtex or other as appropriate.



Daily ‘log abstracts’

ER log printout from central logging system.

Photographs

Voyage Data Recorder (VDR) / Simplified Voyage Data recorder (SVDR) inclusive of the incident o Individual Statements. Statements from all involved personnel

shall be taken as soon as practicable after the event. Ideally these statements should be made in isolation so that they represent the actual thoughts of the individual concerned as these statements are of great importance when trying to establish / verify ‘time lines’ after an incident occurs.

o Individual statements should be handwritten and signed by the

author. • Only trained investigators may conduct an investigation; the

company will schedule other appropriate staff, where possible, to assist, so that practical experience in incident investigation is obtained

• Investigations of minor incidents should be completed by the Safety

Officer (if not involved) within 72 hours of occurrence • Investigations of significant incidents and high potential near miss

occurrences should normally be completed within 2 weeks, although severe incidents may require more time for evidence gathering and analysis

The Senior Manager HSQE is responsible to monitor completion of investigations and may authorize more time if and when circumstances dictate

• The investigation must determine: o What happened? o Who was involved either directly or indirectly? o What equipment, tools, materials were involved? o Who should provide witness statements?



o Has anything been moved since the accident took place? o Damage and the injuries o Substandard acts or conditions o Job and personal factors o Immediate, basic, and root causes o If there was any violation of procedures and requirements o Any immediate action necessary to re-establish safe condition o Propose recurrence preventive measures to prevent the accident

from happening again

• Investigation reports should be reviewed by members of the Shipboard Management Team who are not directly in the incident

o The SMT should verify the facts are correctly reported, causes

fully identified, and that adequate preventive measures air proposed.

o The ShipNet System is configured to require specific causation input for each incident

• In the event of a significant incident, an HSEQ Department

Investigator will take responsibility to verify findings, complete the investigation and submit the final report to senior management. o The company maintains at least two externally trained

investigators on staff at all times so that appropriate personnel may be assigned

o The shore investigation team will evaluate: Fundamental operating practices Adherence to the HSQE procedures

Compliance with international standards

The level of supervision and control provided



Adequacy of training and familiarisation

The suitability and reliability of any equipment involved

o Near Miss Incidents

Are investigated of the safety officer or master and, with the

exception of high potential near miss incident, may be closed by the Master once the near miss incident has been discussed with the crew in a safety meeting

High Potential near miss incidents are to be reviewed by the HSQE department to determine is a further more detailed investigation is required

All CARE Cards submitted by the crew are to be recorded in

the ShipNet database as a near miss



Figure 6-11-1 Incident Response and Investigation Process

Incident

Conduct Investigation

What Happened

Persons Involved,

Equipment / Area

Environmental

Conditions

Compliance with Procedures & Requirements

Determine

Immediate & Basic Causes

Recommend Preventative

Measures

Provide Documentation

Investigation

Report

Statements of Witnesses

Supporting

Documents / Photos

HSQE Department

Review

Additional Action or Investigation

Confirm

Preventive Measures

Close Report

Significant Severity 3-5

Minor Severity 1-2

Emergency Response Actions

Immediate Action to Correct Unsafe

Conditions

Attend Priorities

Safety of Life

Safety of Ship

Protection of the Environment

Request

Emergency Assistance

Complete

Notifications

Continuously Update Office Crisis Team at

Agreed Intervals

Confirmation when Emergency is Under Control

Near Miss Severity 0

Investigated by Safety Officer

High Potential NM closed only by

HSQE



6.11.4 Analysis When the report to senior management has been completed, details of the incident shall be circulated to the fleet so that personnel may learn from the incident so that lessons learned may help prevent recurrence. • Analysis of immediate, basic and root causes is a function carried

out by the investigator during the investigation process; assignment of causes is verified by HSQE staff with approval authority.

• All incident reports are entered into the company ShipNet database

for statistical monitoring • Analysis of trends is undertaken on quarterly basis in conjunction

with the quarterly management review. • Spikes in incident statistics will be monitored by the HSQE

Department • Amendments to safety campaigns, audit focal points, or training

programs may be highlighted when appropriate and needed to counter the impact of identified trends

• The minutes or the management review and the incident trend

analysis will be circulated to the fleet for review and action where appropriate.

6.11.5 Close-out The HSQE Department is responsible to ensure incident investigations are completed properly, corrective and preventive actions completed, and the incident report closed out • Incidents will have closure indicated in the ShipNet database after

approval of findings and actions

6.11.6 Post Incident Drug & Alcohol Testing The Master is responsible to conduct post incident testing of involved crew whenever a significant incident has occurred. If the Master is involved, a non-involved officer, preferably the Chief Engineer, is to



serve as a witness to the test. Testing should be conducted whenever there is: • Serious injuries to crew resulting in death or disability

• Collision or Grounding

• Assault with bodily harm

• An incident where behavior indicates possible substance abuse

Vessels are to maintain post incident test equipment for both alcohol and drugs for use in such circumstances. If a positive reading is noted, the affected crew should be the scheduled for confirmation testing by a shore based laboratory. 6.12 Emergency Drills and Training It is the responsibility of the Shipboard Management Team to ensure the crew is properly familiar with basic emergency procedures and have the ability to operate emergency equipment as follows: • Emergency stations when the emergency alarms are sounded

• Individual assigned duties

• The procedures for raising the alarm

• The action to be taken upon discovery of a fire or other emergency

• The function of the emergency organization

• Pollution prevention/mitigation equipment

• The use of safety equipment (e.g. preparation and lowering of

lifeboats, use of emergency fire pump and generator, etc.)

• Closing down procedures (e.g. ventilation, fuel, etc.) • Rescue procedures (e.g. from enclosed spaces)

• Ensure that officers are familiar with and can operate:

o The emergency generator



o Emergency steering

o The emergency fire pump

o The lifeboat engines

o Emergency Communications

o Line throwing apparatus

o Emergency towing arrangements

6.12.1 Conduct & Recording Regular emergency training and drills are designed to ensure that: • The crew is ready to react to contingencies and emergencies should

they occur, to preserve their own lives and the safety of the vessel, environment and cargo

• Emergency or contingency equipment that is ineffective or faulty is

identified • The crew are able to demonstrate to PSC, Flag or company

inspectors:

o That all statutory training has been undertaken

o Satisfactory response to emergency situations

HSQE Booklet 021 - Record of Drills, Training, Life Saving Appliances & Fire Fighting Appliances Maintenance, provides an annual schedule for required drills and trainings. This record is to be maintained and kept up-to-date by the 3rd Officer and should be periodically reviewed by the Safety Officer and Master to ensure drills & Trainings are planned and carried out as required. It is the Masters responsibility to ensure any additional Flag or other statutory requirements not indicated therein, are carried out and recorded • The HSQE 021 LSA/FFA Maintenance Log has a Drill Schedule which

should be used for planning purposes

• It is the responsibility of the Safety Officer to ensure that the vessel is in compliance and conducts all required drills.



• The planning and conduct of emergency drills and training should

be a topic of each monthly safety committee meeting.

• Fire & Boat Drills should be photographed for objective evidence, and uploaded with month Safety Minutes in ShipNet

6.12.2 Types of Training and Drills As long as specific drills fulfill statutory requirements, training and drills may include: • Video training followed by discussion

• Table Top Discussion with review of contingency plans and

procedures • Demonstration of emergency equipment operation

• Physical deployment of equipment

• Full scale drills with simulated response

o Equipment should be activated as far as possible

o Crew should respond as if the emergency were real

6.12.3 Planning When planning drills and exercises the senior onboard management teams are to ensure the requirements of the following are always considered and incorporated where needed: • Flag State requirements

• SOLAS Training Manual

• SOPEP / SMPEP

• Fire Training Manual

• Ship Security Plan



• OPA 90 Vessel Response Plan

• Individual U.S. State Vessel Response Plans

• Drills are to alternate between exercising the emergency organization procedures in simulated emergency conditions and training in the use and operation of Systems and equipment. Training is to be comprehensive, for those who carry out key contingency tasks and the use of substitutes and reserves.

• Any equipment or machinery used during drills shall immediately be

brought back to a fully operational condition with any faults and defects discovered rectified as soon as possible

• After the completion of each training session or drill, a de-brief review should be conducted with all participating officers and crew to evaluate the effectiveness of the training and assess if crew are properly trained

o Any resulting suggestions should be forwarded to the company

in conjunction with the Master’s Review and marked as a Suggestion for Improvement

• Every training session is to be recorded with all participants listed by name on the Training Record o The form should be signed by the Safety Officer or Instructor

6.12.4 Life Boat Drills

• Safety of Life is the first and foremost overriding consideration during boat drills

• Each abandon ship / lifeboat drill is to include: o Summoning of passengers and crew to muster stations with the

ships alarms and by drill announcement on the public address or other communication System

o Reporting to stations and preparing for the duties described in the muster list

o Checking that passengers and crew are suitably dressed and that lifejackets are correctly donned



o Lowering of at least one lifeboat after any necessary preparation for launching

o Different lifeboats are to be lowered at successive drills if

practicable

o For the purpose of drills, the vessel must be stopped in water, anchored, moored, etc. before lifeboats and rescue boats are swung out over the water

o Starting and operating the lifeboat engine

o Operation of davits used for launching life rafts (if fitted)

o Instruction and the use of radio life-saving appliances

o Testing of the emergency lighting used for mustering and

abandonment

• Rescue boat crews must train to be able to prepare, launch and operate the rescue craft in an efficient and timely manner to effect retrieval of survivors

• No dedicated seating positions are to be allocated onboard a

lifeboat

o During an operational life boat drill:

The Master must personally supervise boat dills to ensure safe conduct

The life boat must first be swung-out and lowered without

any crew onboard

The lifeboat is then to be raised to the embarkation deck for boarding by a minimum operating crew and lowered to the water to demonstrate engine and sprinkler operation

In the interest of safety, manning during swing out should be avoided by all possible means

If the ship design is such that it is not possible to embark

crew from other than the cradled position, the safety committee must devise alternate methods and procedures that allow the crew to embark the boat at a point where minimum stresses on lifting tackle will be incurred



If the embarkation deck is at a level where the boat will

swing out and place maximum stress on the rigging, the operating crew should attempt to board either while waterborne via the embarkation ladder or if the curvature of the hull is too great, a boarding platform or other arrangement should be made to allow the crew to board from the davit deck after swing-out

The ‘assigned operating crew’ are to use suitable safety

harnesses secured to a safe external location on the lifeboat (if practicable)

The use of "fall preventer" device is compulsory during

lowering and hoisting with the crew on board. 6.12.4.1 Davit Launched Life Boats JSA Builder on-line risk assessment tool is to be used to account for specific hazards and applicable controls required for each drill. The following sequence is suggested safe practice: • Step 1

o Boat is prepared with locks and harbour pins removed, gripes removed, painter run, etc. Fall Preventers fitted

• Step 2 o Boat is lowered full speed (brake “wide” open) from stowed

position until waterborne – NO CREW ONBOARD • Step 3

o Boat is heaved back to stowed position (or until limit switch is

engaged)

• Step 4 o Boat is lowered again full speed (brake “wide” open) from

stowed position until about 3 metres above the water and brake closed “fast” to place as much force on the equipment as is possible – THIS IS A “CRASH” STOP TEST WITH NO CREW ONBOARD



• Step 5

o Boat is heaved to boat deck where crew board

• Step 6 o Boat is lowered from inside the boat using the lowering wire

until waterborne

• Step 7 o Once the boat is waterborne with crew inside then “weight” is

taken on the falls and the boat heaved approximately 150mm (6 inches) so it is “just” suspended from the falls and not completely floating

• Step 8

o On-load quick release is activated

o If only one end lets go then the boat will come to rest floating at

one end and suspended at the other and no crew will be injured • Step 9

o Boat is then tested waterborne

o All officers, engineers and petty officers are aware if the cam

setting for the quick release and one who is experienced is given the task of resetting the cam

• Step 10

o Boat is re-attached to falls and lifted 1 metre where cam setting

is re-checked and boat with crew are then lifted back onboard 6.12.5 Fire Drills Fire drills are to be planned in such a way that due consideration is given to practice in various emergencies that may occur depending on the type of ships and the cargo. Each fire drill is to include: • Reporting to stations and preparing for the duties described in the

muster list



• Starting of a fire pump and using at least the two required jets of

water to show that the System is in proper working order

o Different fire pumps are to be exercised at successive drills • Checking of fireman’s outfit and other personal rescue equipment • Checking of relevant communication equipment • Checking the operation of watertight doors, fire doors, fire dampers

and main inlets and outlets of the ventilation Systems in the drill area

o Chief Engineers are to personally inspect all fire dampers and

confirm proper operation, the results of which, is to be recorded in the engine log

o Junior Engineers are to be closely monitored in the weekly

testing of fire dampers which should always be supervised

6.13 LSA & FFA Maintenance The Third Officer is responsible for LSA/FFA Maintenance and must ensure that the intervals and maintenance routines specified in HSQE Booklet 021 - Record of Drills, Training, Life Saving Appliances & Fire Fighting Appliances Maintenance, are properly completed. • Maintenance should be performed according to manufacturers

instructions, the SOLAS Training Manual, and the Fire Safety Operations & Training Manual

6.13.1 Lifeboat Maintenance For safety reasons, the following recommendations for lifeboat maintenance and drills are to be complied with: • The maintenance of lifeboat Systems is to be carried out by

documented qualified personnel at dry-docks (or more frequently as prescribed by flag authorities)

• During maintenance, the lifeboat is to be secured by Fall Preventers

in accordance with flag requirements



• Painting of moving parts on LSA Systems should never be done • Corroding parts should be replaced as necessary and, or at

specified lifetime intervals

• Limit switches to be verified to be operating properly • Fuel tanks to be kept in a topped up condition • After any maintenance, life boat rigging must be tested • Testing or launching of the lifeboat should be performed always

without personnel • The difference between mustering (no embarkation) and launching

of lifeboat must be recognized and adhered to • To prevent parting of lifeboat falls or tackle, Chief Officers are

instructed to personally verify the operation of all limit switches and to add checking to the weekly routine. Crews must be constantly reminded to use care when painting so as not to seize the roller or other moving parts



Documentation & Filing

o ShipNet Database

o MSDS Sheets

o SeaTeam Form No. HSQE 007 - "Enclosed Space Entry Permit"

o HSQE Booklet 021 - Record of Drills, Training, Life Saving Appliances & Fire Fighting Appliances Maintenance

o HSQE 030 - CARE Card

o HSQE 008 - Hot Work Permit

o HSQE 004 - Dangerous Work Permit

o SOLAS Training Manual

o Fire Safety Operations & Training Manual

Distribution

o All Offices

o All Vessels References

o OCIMF ISGOTT o Tanker Safety Guide (Chemicals)

o MCA Code of Safe Working Practices for Merchant Seamen

o OHSAS 18001 Health and Safety Standards

o OCIMF TMSA

o Flag State Regulations