NL 307/25 | China MSA 2025 Inspection Campaign on Enclosed Space Safety
In recent years, the number of accidents caused by the act of illegally entering enclosed spaces has been increasing, and such illegal acts have pose serious threats to the safety of personnel and ships.
In view of this, China Maritime Safety Administration (China MSA) has launched a special inspection campaign on enclosed space safety onboard ships, aiming to standardize the behavior of personnel entering enclosed places onboard ships and prevent and curb the occurrence of such accidents.
Viewing from an organizational perspective, the special inspection campaign is similar to the Concentrated Inspection Campaign (CIC) held annually by some PSC Memorandum of Understanding organizations (MoUs), e.g. Paris, Tokyo MoUs, but the inspection period of this campaign is much longer than the PSC CIC (usually 3 months).
According to the requirements of the special inspection campaign, it will be conducted in combination with the daily supervision and management of shipping companies, safety management system audits, ship safety inspections and on-site supervision, etc. The targets of this special campaign are the ships entering Chinese ports, regardless of their nationality.
Therefore, this NL is made in the frames to provide insights on the special campaign and provide relevant suggestions to ship-owners, ship-managers/operators for the preparation of their ships if destined for Chinese ports about the ongoing special campaign being carried out by China MSA during this period so that crew members have sufficient time to prepare for the onboard inspections and pass them smoothly.
The period of the Campaign started on January 15 and will end by October 14, 2025.
The Campaign applies to ships and waterborne facilities equipped with enclosed spaces that meet the following definitions.
Enclosed space means a space which has any of the following characteristics:
limited openings for entry and exit;
inadequate ventilation; and
is not designed for continuous worker occupancy.
Enclosed spaces include, but are not limited to, 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, and the adjacent connected spaces which are normally unventilated and not used for cargo storage but which may share the same atmospheric characteristics with the enclosed spaces.
In principle, only one inspection shall be carried out onboard the same ship during the special inspection campaign period, except for the following situations:
Where an accident or dangerous situation is triggered due to illegal entry into the enclosed space onboard a ship.
Where serious deficiencies or potential risks in the management of entering enclosed spaces onboard the ship are identified during on-site ship supervision.
Where a ship is reported for severe problems or potential risks in enclosed space entry management.
Where special inspections are required by the MSA of the Ministry of Transport.
The special campaign action plan provides an inspection checklist with the following contents:
Are crew members responsible for enclosed space entry aware of the associated risks?
Are the measures in place to permit to work for visitors and crew members for enclosed space entry?
Is there a list of enclosed space identified?
Are the enclosed spaces marked and for authorized personnel only?
Are the atmosphere testing devices regularly checked and calibrated?
Are the emergency rescue equipment for enclosed space entry in good condition?
Are the personnel familiar with the safe entry and risk assessment procedures for enclosed space?
Are the personnel familiar with the operation of safety protective equipment and devices?
Is the enclosed space entry and rescue drill in accordance with SOLAS Chapter III, Regulation 19.3.3?
Is the SMS related to enclosed space operations effectively implemented on board?
Suggestions
In order to effectively respond to this special campaign and avoid the identification of deficiencies related to illegal entry into enclosed spaces during the PSC inspection, we suggest that whilst conducting self-inspection in accordance with the items listed in the above mentioned inspection checklist, the Shipowners, Managers / Operators and ships should also draw their particular attention on the following aspects in order to pass the inspection smoothly:
Self-check the relevant procedures in the SMS documents: Check and confirm that the ship’s SMS documents contain the safety operation procedure for guiding the personnel entering enclosed spaces, the emergency response and rescue plan and the maintenance procedure/plan for the safety equipment, communication devices, rescue and first aid tools which are necessary for entering enclosed spaces by way of a thorough self-inspection. The SMS documents should be modified and improved in accordance with appropriate procedures if the aforementioned procedures / plans are found to be absent.
Establish and strictly comply with the risk assessment and entry permit system: Ensure that crew members possess the ability to determine the various types of hazards and risk levels that may exist in the enclosed spaces by comprehensively analyze on the various factual conditions such as cargo type, ventilation status, operation type, gas composition, tank coating, adjacent area conditions, etc., and able to propose reasonable measures to reduce the corresponding risks to an acceptable level and keep proper records. After sufficient risk assessment, an authorized entry permit from the master or the designated person in charge shall be obtained before entering. Furthermore, the entry permit should be kept on board along with the risk assessment documents for inspection.
Inspection of enclosed spaces and the related equipment: Ships should regularly identify and establish a list of enclosed spaces on board. Through regular inspections, ships shall confirm that the entrances or passageways to the enclosed space are in good maintenance condition, free from obstacles that could affect the safe entry of personnel and rescue operations; the internal structures within the enclosed spaces are complete, safe and reliable; the connecting ventilation systems are working properly; and the interior equipment such as lighting, fixed gas monitoring equipment, water level detectors (if any), etc. are in good working condition. In addition, regular inspection should also be carried out to ensure the personal protective equipment, rescue tools, communication devices etc. are in good order.
Training and Emergency Drills: Provide regular training to crew members, conduct drills for entering enclosed spaces strictly in accordance with the requirements of SOLAS Regulation III/19 (every two months) and keep the training and drill records. Through adequate training and drills, ensure that crew members are familiar with their emergency responsibilities, aware of the dangers of enclosed spaces, understand the correct procedures for entering enclosed spaces and familiar with emergency evacuation and the rescue procedures. Ensure that the responsible personnel can correctly inspect, use, and maintain the protective and rescue equipment, and is proficient in the operating, inspection, testing, and calibration of the fixed and portable gas detection instruments.
Should you have any inquiries, please feel free to contact PhRS Head office or any of our local branch offices.
