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Article: Guidelines for topping-up of fumigant by crew during the voyage

17 November 2020

The club is witnessing an increasing number of cases where ships that are typically engaged in carriage of logs are being asked to carry out topping up of fumigation by the crew during the sea passage. Generally, this procedure is supposed to be carried out by a qualified fumigator; however, due to the pandemic and with travel restrictions in place, the fumigators are unable to sail with the vessel. Essentially this means that ship operators and crew, who do not have the necessary expertise to handle toxic materials, are exposed to a new and risky operational environment.
Recently while doing the fumigant topping-up, there has been a crew fatality on one of the Hong Kong flagged vessel entered with the club, following which the Flag State has issued the attached circular highlighting the risk of performing topping up of fumigant in a cargo hold.

IMO Guidelines

IMO guidance contained in circulars MSC.1/Circ.1264 (Recommendations on the safe use of pesticides in ships applicable to the fumigation of cargo holds) and MSC.1/Circ.1358 (Revised Recommendations on the safe use of pesticides in ships), states that the crew should not handle fumigants and requires fumigation to be conducted by qualified operators.

MSC.1/Circ.1358, paragraph 3.1.3.2 states that “Since fumigant gases are poisonous to humans and require special equipment and skills in application, they should only be used by specialists and not by the ship's crew.”
and
MSC.1/Circ.1264, paragraph 5.1.1 states that "Ship’s personnel should not handle fumigants and such operations should be carried out only by qualified operators…"

Additionally, as per IMO circular 1264, section 3.3.2.1 – “Fumigation in transit should only be carried out at the discretion of the master.”

“The master should be aware of the regulations of the flag State Administration with regard to in-transit fumigation. The application of the process should be with the agreement of the port State Administration. The process may be considered under two headings:

  1. fumigation in which treatment is intentionally continued in a sealed space during a voyage and in which no aeration has taken place before sailing; and
  2. in-port cargo fumigation where some aeration is carried out before sailing, but where a clearance certificate for the cargo hold(s) cannot be issued because of residual gas and the cargo hold(s) has been re-sealed before sailing.”

Section 3.3.2.3 states that “Before a decision is made as to whether a fumigation treatment planned to be commenced in port and continued at sea should be carried out, special precautions are necessary. These include the following:

  1. at least two members of the crew (including one officer) who have received appropriate training (see 3.3.2.6) should be designated as the trained representatives of the master responsible for ensuring that safe conditions in accommodation, engine-room and other working spaces are maintained after the fumigator-in-charge has handed over that responsibility to the master (see 3.3.2.12); and
  2. the trained representatives of the master should brief the crew before a fumigation takes place and satisfy the fumigator-in-charge that this has been done.”

Section 3.3.2.6 mentions that “The trained representatives of the master designated in 3.3.2.3 should be provided and be familiar with:

  1. the information in the relevant Safety Data Sheet; and
  2. the instructions for use, e.g., on the fumigant label or package itself, such as the recommendations of the fumigant manufacturer concerning methods of detection of the fumigant in air, its behaviour and hazardous properties, symptoms of poisoning, relevant first aid and special medical treatment and emergency procedures.”

As mentioned in our A Master’s Guide to Enclosed Space Entry publication, the appropriate safety and rescue equipment for entering an enclosed space varies depending upon the space, ship type and work involved. As a minimum, it should include following:

  • SCBA (self-contained breathing apparatus) with a spare cylinder
  • life-line and rescue harnesses
  • lighting, including torches
  • a stretcher
  • means of raising stretcher, ie tripod type arrangement
  • communication equipment
  • appropriate atmosphere testing equipment and personal gas meters.

IMO MSC. 1/Circ.1477 (Guidelines to facilitate the selection of portable atmosphere testing instruments for enclosed spaces as required by SOLAS Regulation XI-1/7) mentions that ‘given a ship’s specific characteristics and operations, additional atmospheric hazards in enclosed spaces may be present that may not be detected by the instruments recommended’. As such, in addition to proper personal protective equipment (PPE), suitable gas detector tubes for measuring concentrations of the toxic fumigant gas need to be provided in cases where cargo is fumigated.

Club's Guidance

Given the exceptional circumstances and in view of the stated IMO requirements, it is recommended that the ship operator and the fumigation company should develop a plan including:

  • How the topping-up operation will be conducted.
  • The training that will be given to the crew on the risks involved in handling toxic fumigant materials.
  • A risk assessment for the fumigation operation (before proceeding to sea).
  • Procedures to mitigate the risks identified.

Based on this plan, approval needs to be obtained from the ship’s Flag State and the relevant Port States.

Members are recommended to engage with the club to obtain assistance with the letter of indemnity (LOI) against any consequences arising out of this procedure.

The topping-up is generally the same as the procedure followed by the 'qualified operator' during the initial fumigation at the load port. The crew should be aware of which fumigant is used, the information provided in the relevant safety data sheet (MSDS) and its handling requirements. Additionally, they need to be trained on the step-by-step procedure before they conduct the fumigation themselves. 

All relevant local regulations and guidelines provided by the authority at the loading port, the fumigation company, IMO circulars MSC.1/Circ.1264 and MSC.1/Circ.1358 should be observed.

The ship should be provided with suitable gas detector tubes for measuring the concentration of toxic fumigant gases; and the fumigation company should always be available to offer any additional guidance if the crew encounter any issues during the operation or subsequent monitoring during the voyage.