Solid Bulk and the Connected Dangers in Enclosed Spaces


Published Mar 11, 2019 5:57 PM by Captain Gunter Schütze

On March 2, 2019, The Maritime Executive published an article "Another Five Fatalities with Solid Bulk Cargo."

Basically, I share the opinion of the author of this article. The recent casualties on bulk carriers caused by lack of oxygen in loaded holds, fumigated holds and adjacent areas show us that there are significant deficiencies which the IMO, its safety committees, shipping companies, surveyors, fumigation companies, shippers and port authorities must wake up to. 

But it would be too easy to only turn the screws of administrative regulations to tighten existing safety regulations again and again. How would it be if, before this happened, all the existing international and national regulations were consistently and effectively implemented and enforced? We would then quickly realize that the number of serious accidents involving cargo holds can be drastically reduced.

That regulations must be revised and adapted over time is beyond question as we:

• Gain new insights through the evaluation of tragic accidents,
• Adopt new technical innovations which ensure a considerable improvement in the analysis methods of the cargo space atmosphere
• Improve systems and simplify their handling
• Use new chemicals for fumigation of cargo holds
• Develop new breathing and filtration systems

But the other side of the issue should not be hidden!

The vast majority of fatal accidents on bulk carriers are not caused by tank inspections, they are based on careless handling of existing safety regulations during cargo hold inspections or careless entering of cargo compartments, ignoring all associated hazards. This has been shown in the evaluation of numerous investigation reports. The so-called human error must therefore not be trivialized

The consistent observance and enforcement of the applicable safety regulations for the entry of closed, loaded and fumigated spaces by the crews is subject to the particular responsibility of the captains and officers.

Most accidents are due to:

•  failure to comply the criteria of effective and maximum-safety existing Risk Assessment.

• the inadequate adherence to ship management and safety management systems and their onboard enforcement, as well as their ongoing review to promptly identify and eliminate identified shortcomings.

• a faulty, inadequate risk management is carried out.

• external time pressure on the crews. How tight is the onboard organization to ensure maximum enforcement of existing safety policies without being influenced by the time pressure from the outside?

• inadequate technical and scientific knowledge of key personnel, i.e. the captain and officers. e.g. grain (enrichment of the cargo hold atmosphere with CO2 and concomitant reduction of the O2 content) or steel bars (reduction of the O2 content by oxidation processes on the steel), to name only two, with life-threatening potential

• inadequate information for the crew about the chemicals used for the fumigation of holds, their potential hazards and risks, the mandatory safety regulations with clear indication that entering these spaces is strictly prohibited and only entered in exceptional circumstances with the express permission of the Captain. I have handled it in the manner that the crew got an extensive safety instruction before arrival. In all the corridors of the deckhouse, on the bridge, in the mess rooms and in the ECR appropriate data sheets with warnings and with the corresponding first aid measures in the event of an emergency were posted. All hatch covers and cargo hold accesses were clearly marked with warnings for everyone and locked. The keys to this were in the care of the CO.

• what about the nautical officers' knowledge of using gas detectors to analyze the room atmosphere and the right evaluation?

• What qualitative and quantitative technical equipment level is available with circulating-air-dependent respiratory protection equipment and the associated filters to be used and knowledge of their proper use? I would like to refer as an aid: www.berner-safety.de/filter_selection_guide_for_draeger_respiratory_masks_en_1078.html. Please note: These systems may only be used if the oxygen content of the breathing air is at least 17 percent by volume.

• What level of equipment of gas testing equipment is on board, and are the manufacturer's calibration periods and specified periods of use complied with?

• How is the replacement of filter stocks on board secured to prevent overlay beyond the expiry time (particle filter / gas filter /combination filter)? 

• What is the level of knowledge of the crew in testing, operation and application of self-contained breathing apparatus?

• What training is provided to the crew? What qualification level do the trainers, i.e. the officers, have? Monthly safety meetings are not enough. It requires qualified briefings.

• What training on rescue from enclosed spaces is conducted? Safety takes time. It has to take into account all the required aspects and can only be guaranteed in reliable timeframes.

As a matter of principle, it must be clearly stated that access to enclosed spaces requires explicit ship-authorizations by the Captain which may only be granted if all measures have been taken in the Risk Assessment and the Guidelines for Entering Enclosed Spaces. All steps taken in preparation for entering closed spaces must be recorded accordingly. Only if all the required criteria are met is a permit to enter issued.

Guidelines applicable to maritime shipping include:


• MSC.350 (92) - 21.June 2013, AMENDMENTS TO THE INTERNATIONAL CONVENTION FOR THE SOLAS 74, AS AMENDED CHAPTER III LIFE-SAVING APPLIANCES AND ARRANGEMENTS Part B Requirements for life-saving appliances Regulation 19 - Emergency training and drills


• IMSBC Section 3 - Safety of personnel and ship and publications in specialist maritime panels such as The Nautical Institute and maritime insurers on this topic are helpful: 


There are also very good recommendations for enclosed spaces in other areas of shipping, such as inland navigation. It is interesting to note that inland navigation discusses enclosed spaces in Chapter 10 of ISGINTT, First Edition, 2010 ("International Safety Guide for Inland Navigation Tank-barges and terminals") and provides an excellent guide to action.


Futhermore for all cases of required fumigation in cargo holds on bulk carriers refer to the:

Code of Practice - On Safety and Efficacy for Marine Fumigation - by the International Maritime Fumigation Organisation (IMFO). This Code should be taken under consideration for company safety staff and crew training in preparation of fumigation practice and all therewith connected urgent safety procedure. It is a good guide about required emergency procedures with helpful checklists.


Additional I want recommend for all QHSSE departments in bulk carrier companies the home page of IMFO in World Wide Web: www.imfo.com/standards.html. Here are IMO, U.S. and Canadian Fumigation standards, revisions, updates and new information related to all matters of fumigation and safety procedures.

By this documents, the IMO could certainly get some suggestions to implement in SOLAS 74, Chapter 3, Part B, Regulation 19 and in IMSBC Section 3. The International Chamber of Shipping (ICS) too could borrow aspects and develop general rules. The in tank shipping fleets valid standard procedures can also be readily adapted for bulk carrier and for all other specialized maritime shipping sectors. Loaded, fumigated, sealed holds definitely meet the criteria of enclosed spaces and require the utmost caution.

Of course, it is possible and, if necessary, essential to introduce shipbuilding modifications to improve safety standards on board. The main problem is the sensitization of crews, management, class societies, flag states, surveyors etc.


The issue can only be resolved with extensive specialist training, intensive training for emergency situations, the sense of responsibility by management personnel aboard and ashore and with consequent in-depth inspections by Port State Control.

I even go so far as to plead for unannounced vetting by experienced superintendents. Only then we get an actual picture of the real conditions on board and only then is it possible to counteract deficiencies consistently. It also awakens sensitivity to all safety issues, because no one on board knows when the next safety inspection will be. I already hear the critical voices from all camps. But the critics should explain to me how they want to deal with the loss of human life which is based on substantial proof of the non-compliance with existing security standards. 

Extraordinary circumstances require extraordinary measures. Here, assertiveness, consistency and discipline are required. This can only be achieved by unpopular measures. Occasionally you have to force people to their happiness.

Those who save on high-quality safety equipment, saves in the wrong place. It does not even have to be expensive. It must be available and above all, fully functional. The protective equipment on board must be in perfect technical and maintenance condition; its handling must be intensively trained in order to be prepared for emergencies.

And the ship's command should not allow themselves to be forced into unjustified speed by agents, surveyors, port authorities, charterers or shippers. They should have the opportunity to intervene and put safety first. Anyone who thinks they have to ignore this must then live with the consequence - that the Captain will SOLAS XI-2 Regulation 8 (1) applies. That is their right and their duty. Be consistent and insist as captains on compliance with all safety aspects, as captains have a duty to their crews to protect their health and life. 

In German there is the saying: “what lasts long, lasts well.” And it's true. Prudence and thoughtful action is the key to a safe working environment and avoiding accidents. If the ship's command team refer to that and put it in practice, the crew will act accordingly.

In this respect, we are again talking about human error, what is not limited to crews, but refers to all parties involved, including authorities and managers ashore. So it's a very complex issue.

View the original editorial here.

The opinions expressed herein are the author's and not necessarily those of The Maritime Executive.