Shipyard Safety


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SHIPYARD SAFETY

April 1997

  1. INTRODUCTION

Throughout the working life of a ship, both at sea and in port, nearly all operations on board a ship are carried out by the ship's personnel in accordance with procedures established by the company. Thus, under normal circumstances the safety of the ship and her personnel is directly controlled by ship personnel in accordance with company's safety and environment protection management system and operating procedures.

The situation is very different when the ship is under repair in a shipyard. The repair work is carried out and managed by shipyard personnel. Although the work may be supervised by company ship personnel, the safety of the ship and its personnel is to a large extent dependent upon the shipyard's own safety management system (N.B. it should be born in mind that in some countries, the master of the ship may be held legally responsible for injuries to shipyard workers). The situation is exacerbated by the fact that, during a repair period, the ship takes on an unfamiliar status. The ship and its personnel are thus exposed to unexpected and unfamiliar risks and hazards.

In order to ensure that the safety of both the ship and its personnel is maintained during a shipyard repair period, it is essential that :

The purpose of this paper is to highlight those factors which need to be addressed by company and ship personnel, both prior to, during and after a shipyard repair period, in order to ensure that any risk either to ship's personnel or to the ship itself are minimized.

  1. GENERAL SAFETY CONSIDERATION

On an oil tanker the major safety issue concerns the danger of fire and explosion particularly where hot work (welding, burning, grinding, soldering, heat lamps, electrical work) is involved.

Hot work should always be isolated from :

Where electric arc welding is to be carried out, high humidity and dampness and the generation of toxic fumes due to the welding process may present additional and significant risks to personnel. Procedures relating to gas free certificates and hot work permits are to be strictly maintained.

Other important safety issues include ensuring that :

  1. PRIOR TO ENTRY INTO THE SHIPYARD

    1. Shipyard Selection

Geographical location, size of ship, economics and knowledge of a yard ability are obviously major factors to be taken into account during the selection of a shipyard. However because of the potential impact on company personnel and assets the manner in which a yard manages and controls the safety of repair operations should receive particular attention during the selection process and as part of the tender process.

    1. Contractual Aspects of Safety

The repair contract should clearly define certain key responsibilities in respect of safety. As a minimum it should specify :

    1. Arrival Condition

The Company should arrange for the ship to arrive in the yard with all cargo tanks, ballast tanks, void spaces, pipe tunnels, cofferdams, pumprooms and empty fuel tanks in a clean and gas free "safe for entry" condition. Where hot work is to be carried out, a "safe for hot work" condition is to be achieved in accordance with local regulations. All cargo, vent, inert gas and cow lines together with cargo heating coils and lines should have been flushed and/or ventilated. Fuel lines and associated systems should be similarly cleaned in so far as this is practicable. Any exceptions to these requirements should be clearly identified.

Note: "Safe for entry" criteria are those defined in ISGOTT section 11.3 i.e.:

It is imperative that an independent qualified chemist inspect and certify the vessel to be gas free (see section 3.6 ) at a cleaning station or anchorage prior to the ship's entry into the yard.

    1. Removal of Oily Residues

In tanks where significant hot work is to be carried out, the tank bottom and horizontal stringers and other major surfaces of tank structures should be cleaned of any significant oily residues. Further local cleaning may be required once access is obtained to the work site and the cleanliness of the structure in the vicinity can be assessed.

In tanks where there is only minor hot work, it may be possible to satisfy cleanliness criteria by covering the tank bottom with water, however most chemists do not accept this and it should not be encouraged. If this is done the water surface should be clear of any oil sheen. In such cases it will be necessary to remove residue from structure in the vicinity of the work site.

Even if there is no hot work being carried out in a tank, there may be hot work in adjacent or surrounding tanks. In such cases it will be necessary to remove residue from the structure on the "other side" of the bulkhead, and it may also be necessary to remove residues or put a water bottom in the non-working tank.

In some cases the removal of residues from cargo tanks may be allowed after the ship has entered the yard. In this event, hot work should be prohibited outside the engine room or superstructure until all the requirements for the issue of a hot-work certificate are met.

The disposal of both liquid and solid hydrocarbon residues generated by such cleaning operations must be handled in compliance with MARPOL and any local regulations.

    1. Non Gas-Free Repairs

If in exceptional circumstances, and where no viable alternative exists it is necessary to carry out repairs with the ship in a non gas-free condition the company should arrange for all cargo and slop tanks to be inerted.

Prior to arranging for such repairs, the company should establish that facilities are available for "topping up" inert gas during the repair period.

Repairs involving hot work should not be carried out in cargo or fuel oil pumprooms, within the entire cargo area, or on decks above such spaces, within the inner hull space of a double hull tanker, or to any pipeline system connected to these spaces, or in the vicinity of any such pipeline system connecting these spaces, unless such spaces and pipelines have been cleaned and properly certificated "gas-free" and suitable for hot work in full compliance with the detailed requirements "of the appropriate sections of ISGOTT.

Any tanks or compartments where work is to be carried out should be blanked off from common vent, inert gas and COW lines, and there should be at least two valve segregation from the cargo systems. Valves should be secured and marked accordingly.

    1. Verification of Ship Status

The shipyard should not assume that the ship, its tanks, pumps or piping systems are free from hydrocarbon or toxic gases. Prior to entry into the yard an independent certified chemist should test all lines and tanks. On completion of the tests appropriate certificates should be issued to the company representative and master.

It is important to note that this initial test may only be to verify that the status of the ship is suitable for it to enter the yard. It should not be assumed that any tank or space is safe for entry or safe for hot work until that tank or space has been properly tested and certified.

It is particularly important that any tank which is not certified as being safe for entry or safe for hot work is clearly identified as such. Under normal circumstances the only tanks not certified as such should be bunker and lubricating oil tanks.

The continuing maintenance and verification of the status of any tank or space throughout the repair period is the responsibility of the yard and is addressed later in this paper.

    1. Fuel and Lubricating Oil Tanks

All tanks which contain fuel or lubricating oils should be clearly identified. Their boundaries should be clearly and adequately marked. No hot-work should be carried out on bulkheads of bunker or lubricating oil tanks containing bunkers or lubricating oils or within 0.5 metres from such bulkheads.

All valves on lines to and from such tanks should similarly be clearly marked and should be secured against inadvertent operation. This includes both local (manual, electric, hydraulic or pneumatic) and remote controls in the control room or elsewhere. All vents from such tanks should be clearly identified. These should be covered and clearly marked if they terminate in an area where hot work is likely to be carried out.

  1. IN THE SHIPYARD

    1. Safety Factors

Once the ship arrives in the yard, there are three main areas of concern with respect to safety. They are:

Protection of the environment will also be a prime consideration.

Although the safety of yard personnel and contractors is not normally the direct responsibility of the master or company representative, many of the safety issues involving shipyard workers are the same as those for company personnel. Ship personnel and the company representatives should thus be alert to all unsafe practices or conditions in order to help to safeguard company 'employees and others.

Company or ship personnel should routinely review the repair activity to verify that working practices are in accordance with the procedures detailed in the yard's safety management system.

The ship's officers and yard safety staff should have the clear authority to stop any work which is considered unsafe, regardless of whether yard, ship or contractor personnel are involved.

    1. Initial Safety Information

When the ship arrives in the yard an initial yard/vessel safety meeting should be held and the master and company representatives should be given copies of the yard's safety and security arrangements which apply to the ship whilst in the yard. They must ensure that ship and company personnel and the shipyard comply with these requirements throughout the repair period.

The yard should also supply the master and Company representative with a list of emergency telephone numbers which allow rapid access to emergency services on a 24 hour basis. These should be clearly posted at several different locations around the ship and at the foot of every gangway.

The yard fire and emergency alarms should be demonstrated to ship staff. The evacuation procedures should be given to the master and company representative, and they should be advised of the location of designated muster points.

Where practical a combined ship's personnel and shipyard evacuation muster and drill should be carried out near the commencement of repairs.

Ship's personnel should be advised of the tank rescue procedures in place in the yard.

The master should supply the yard with a list of the ship's crew and any other company staff or company contractors who may be attending the ship. This should be kept up to date as personnel change during the repair period.

    1. Fire Fighting Capability

The yard must ensure that adequate fire fighting facilities are maintained on board the ship throughout the repair period. This equipment should be stored at clearly marked locations around the ship. Ship personnel should be made familiar with the operation of extinguishers and nozzles, which are likely to be of a different type to those with which they are familiar.

Note: Ship personnel should not attempt to use breathing equipment with which they are unfamiliar.

The ship's fire main should be kept pressurised on a 24 hour a day basis either by the ship or by connecting it to the yard fire. line. The yard should demonstrate, and the ship staff should confirm, that the supply is adequate in terms of both pressure and flow rate.

Fixed fire-fighting systems such as CO2 and Halon systems should have their normal operating means disabled so they cannot be inadvertently operated. Additional portable fire extinguishers should be provided in affected spaces. Any period during which fixed fire-fighting systems are disabled should be clearly defined and posted. They should not be disabled during recommissioning of the plant and, whilst disabled, should be capable of being reinstated within a reasonably short period of time.

The yard should have a fire patrol organisation on the ship. The personnel involved in this programme should be readily identifiable to ship staff i.e. by coloured overalls or helmets.

Fire watchers should be stationed in the vicinity of all hot work locations where they have a good view of the work site, this should include other spaces or compartments directly adjacent to the work site, and any place where sparks or molten metal may fall. Fire watchers should be provided with appropriate fire extinguishing media such as a charged hose and/or a portable dry chemical extinguisher and an audible "fire alert" device.

Combustible material should be removed from all hot work locations and areas where sparks may fall so as to eliminate the chance of a fire. The use of fire watchers to extinguish small fires should not be considered an alternative to appropriate cleaning.

    1. Ship Status Board

Prior to the start of work, the yard should establish a protected location where an overall picture of work in progress can be easily determined by means of a status board or diagram posted in this area. This status board should indicate:

    1. Atmosphere Monitoring

There should be a system whereby the atmosphere of all tanks, pumprooms and machinery spaces, regardless of whether or not work is being carried out in them, is monitored at least once a day for oxygen, hydrocarbon gas and any toxic gases which might be present including those generated by the work in hand i.e. welding. This monitoring should be carried out by a competent and qualified person.

The results of these inspections, together with the date and time at which they were carried out, should be clearly marked at each entrance to the space concerned and the central status board.

Ship's staff and company representatives should be alert for changes such as opening of pipelines or valves, introduction of chemicals or paints, leaking fuel gas or oxygen hoses, etc. which could make the atmosphere of a tank or confined space hazardous or unhealthy to work in and thus invalidate the entry/work permit.

    1. Status of Spaces

The status, i.e. safe for entry, safe for hot work, do not enter, etc., of the spaces referred to above must be clearly displayed at each entrance and on the central status board.

    1. Permit to Work Systems

The yard's safety management system should incorporate a permit to work system to control and co-ordinate key repair activities. This should, as a minimum, address:

Permits should clearly identify:

Ship's personnel should be advised of permit systems in use by the yard and the procedures under which such permits are issued. Work carried out by ship's personnel should be subject to the yard permit systems.

Copies of all permits issued by the yard should be given to the master and company representative. Any such copy should also be given to any sub-contractor involved in such work. A copy of all permits should be available in a central location.

    1. Combustible Materials and Solvents

Strict control should be maintained over the introduction of combustible materials into work sites. The introduction of combustible cleaning solvents must also be carefully monitored and controlled.

Where substantial combustible or hazardous material is to be used or brought on board, the company representative should review its product hazard identification bulletin, e.g. a safety data sheet, to confirm that the hazards associated with handling the material, from both a fire and health point of view, are well understood and that proper precautions are taken.

Hot work must not be carried out in any space where combustible liquids or vapours are being used, e.g. painting or chemical cleaning. Entry into such spaces should be strictly controlled. In the case of "in tank" painting or cleaning, connecting pipelines or ducts between tanks should be blanked off . Where access holes have been cut, particularly in bottom areas, sufficient precautions must be taken for the dispersion of solvent vapours, which could otherwise leak into adjacent spaces or come into contact with potential heat sources.

    1. Control of Industrial Gases

A procedure should exist to assure the safety of main supply or bottled gas used for heating and gas welding or burning. Company representatives should assure themselves that all hoses used for acetylene, liquefied flammable gas (LFG) and oxygen are fitted with flashback arrestors and have been pressure tested within the last three months and are checked on a periodic basis. Such hoses should be colour coded to avoid mistakes in identification. Gas welding equipment procedures should include requirements that whenever there is a work break, e.g. meals, shift change, or securing for the day:

Gas cylinders are not to be left free standing or leaning against any structure, but should be secured from accidental falling. Protective caps should be placed on gas cylinders when not in use.

At all times care must be taken to ensure" that hoses are deployed in a manner where they are not liable to physical damage and do not obstruct walkways, tank hatches or other means of escape.

    1. Safety Inspections

The yard should have a system of regular inspections in place to ensure that safe working conditions are maintained. These should include:

    1. Staging and Scaffolding

The yard should have procedures which establish scaffolding and staging standards including:

    1. Personnel Lifting Equipment

Personnel may gain access to elevated work locations by means of mobile elevating work platforms (MEWP's) such as scissor lifts, elevating platforms, cherry pickers, etc., and personnel carriers suspended from cranes. The yard should be ready to present evidence to the master and company representatives that any equipment utilised by company personnel or contractors:

Cranes used to hoist personnel carriers should be fitted with brakes or equivalent devices to arrest or prevent movement of the hoist or slewing mechanism when the drive motor is disengaged or in case of a power failure. These devices should be automatic and be fail-safe. Hydraulic cranes should be fitted with equivalent devices in the hydraulic circuitry. Crane fail-safe devices and limit switches should be regularly tested.

    1. Lifting Equipment

The yard should have procedures which address:

    1. Smoking Regulations

Smoking should be prohibited except in specifically identified areas. Ship's personnel should observe these restrictions. The use of cigarette lighters should be prohibited.

    1. Ventilation and lighting

A large proportion of ship repair work is carried out in confined or enclosed spaces. It is essential that adequate ventilation and safe lighting be provided and maintained to all work sites. The recommended method for ventilation of an enclosed space where hot-work {especially welding and gas cutting) is being carried out, is by means of a properly designed local exhaust {extraction) system.

    1. Sub-Contractors

It is likely that both yard and ship will employ specialist sub-contractors to carry out certain repair activities. The yard safety management system should include procedures to ensure that such contract personnel comply at all times with the yard requirements.

The master and company representative should ensure that any contractors appointed on behalf of the ship comply at all times with the yard requirements. The master and company representative should advise the yard where work is to be carried out by contract personnel.

    1. Transfer of Liquids

It is often necessary, for operational and/or repair purposes, to transfer liquids {ballast, fuel, lubricants) within the ship or to load these into storage tanks. In order to avoid the inadvertent spillage or release of such liquids it is essential that both ship and yard personnel are aware of the operation and co-ordinate their activities so that it can be carried out safely and without spillage. The loading of fuel and lubricating oils represents a significant change in the shipyard environment and should not be allowed to take place until a complete review of all systems is made by the responsible parties and proper notification is given to any potentially affected work activities.

Wherever possible the bulk loading of fuel or lubricating oil should be deferred until the completion of repairs. Where this is impractical, all hot work in, on, or around the tank or system{s) used for loading should cease. Dependent on local circumstances this may involve additional hot working restrictions elsewhere on the vessel including the cessation of all hot work activity on board and, as required, on any adjacent or double banked vessels.

    1. Testing Equipment and Systems

As equipment and systems are repaired it is obviously necessary to test them prior to reactivation. In order to avoid potentially dangerous conflicts between tests and other repair activities, it is essential that both ship and yard personnel are aware of all tests which are to be carried out and co-ordinate their activities so that they can be carried out without incident.

All systems should be visually inspected by ship's personnel prior to commencement of the test.

Steam, fuel and lubricating systems should be tested during periods when there is no repair activity in their immediate vicinity.

    1. Earthing of Welding Equipment

The shipyard must ensure when using arc-welding equipment that transformers are adequately earthed, especially when the ship is on the blocks in a dry-dock.

    1. Access to the Ship

In order to provide adequate emergency access to and from the ship, there should always be a minimum of two separate points of access. These should be located as far apart as is practicable and where possible on opposite sides and ends of the ship. Clear passage ways to these access points should be maintained at all times. Where gangways are used a properly rigged safety net should be positioned beneath each gangway unless the gangway is fully enclosed.

Where there is a large work force in a confined space such as an engine room or pumproom, consideration should be given to cutting an access/exit point into the hull in way of such a space, subject always to classification society approval. In any event, a safe clear way should always be maintained from the lower engine room to the main deck level. Escape routes should always be well sign posted and consideration should be given to providing supplementary battery powered "rope" lighting on ladders and platforms leading to escape exits.

    1. Moorings

The ship should be securely moored throughout the repair period. The ship will usually be unable to provide power during the repair period and the yard should thus have a system which allows for mooring lines to be tightened as required. Both ship and yard

personnel should monitor the moorings on a regular basis.

The prevailing weather should be monitored and early action should be taken to increase the moorings in order to meet any adverse weather conditions.

    1. Double Banking

Although the double banking of ships is not desirable, it will occur on occasions. In such a situation the yard should ensure that the master and company representative are advised of any repair activities on the other ship which might effect the safety of their own ship or personnel.

Where crossing one vessel to gain access to another a clear way should be marked across the deck of the vessel being crossed so as to prevent personnel getting lost/wandering around a vessel they are unfamiliar with.

Ship's personnel should be alert at all times to repair activity on the other ship which might effect

their own safety e.g. lifts to and from the other ship.

  1. COMMUNICATIONS

    1. Managing Communications

The company representative must ensure that clear lines of communication/authority between the

yard staff, ship's personnel and company contractors are established and maintained throughout the repair period. There are so many simultaneous activities going on that unless all parties are aware of what others are doing there is a high probability of conflict between jobs which could compromise the safety of the ship and those on board.

Where used, and as far as possible, ship's personnel and yard managers should utilize a common radio frequency on their portable radios.

    1. Monitoring of Repair Activity

It should be made clear to the yard that ship's personnel have been instructed to closely monitor all repair activity undertaken by the yard and that any infringements of safety requirements will be immediately brought to the attention of the repair manager. Ship's personnel should not hesitate to intervene and even to stop the work if they see something which, in their opinion, poses an immediate threat to the safety of life or the ship.

Conversely the yard should be invited to monitor all work being carried out by ship's personnel and to advise the master or company representative should any safety concerns be noted.

    1. Daily Safety and Progress Meetings

There should be a procedure which requires daily meetings to be held. Such meetings should include as required:

The purpose of these meetings, which should be minuted, is to:

Immediately after the daily meeting, the centrally located status board should be updated accordingly.

  1. PERSONAL SAFETY

    1. Management of Safety

Shipyards are beehives of non-routine activity. All ship and company personnel must be particularly

diligent about ensuring the safety of each other and contractors. A ship in a shipyard presents a unique combination of hazards which company personnel may be unfamiliar with.

    1. Housekeeping

The first approach to personal safety should be to eliminate all potential hazards wherever possible. Effective housekeeping will go a long way towards minimising the risk of personal injury. Poor housekeeping may not only cause injuries but also makes the identification of other hazards, such as damaged electrical equipment, or leaking gas hoses, more difficult. The master and company representatives should establish housekeeping standards in conjunction with the shipyard. These standards should include:

Poor housekeeping is an accurate indicator of a badly controlled or ineffective safety management system.

    1. Openings

Repair activity invariably results in the removal of parts of the ship structure either for repair or for access to a work site. Thus there are likely to be a large number of openings through which a person might fall. This includes tank cleaning openings, access holes cut to facilitate work, removal of gratings and ladders, lightening holes in the structure and corroded areas that will no longer support personnel. The removal of ship side rails, or rails in the engine room presents a significant hazard. This hazard should be carefully managed by the use of substantial guards and notices around, or over, each opening. However, ship's personnel should be particularly alert to the fact that, despite precautions being taken, unexpected hazards may still arise.

    1. Slip and Trip Hazards

Decks, gratings, ladders and walkways are likely to become slippery or hazardous due to cargo residues, welding rod ends, spilt liquids, dunnage, scrap metal, etc. Whilst good housekeeping practices will minimise these risks, ship staff should always be alert to the potential hazards. In this respect it' is important to ensure that lighting is adequate. Many slips, trips and falls are the result of the person involved being unaware of the risk because they could not see the hazard.

    1. Ladders and Walkways

Work in tanks will often require people to move around the tank structure using ladders and walkways which are not routinely used. All personnel should verify prior to use that such ladders and handrails are safe to use, properly secured and that their footing is secure.

    1. Hazards from Above

Ship and yard personnel should be alert to the threat of falling objects. Apart from the obvious hazards from the many lifts of material on and off the ship, there are also numerous lifts of equipment and material within tanks, engine rooms and pumprooms and the constant possibility of equipment or materials falling from a work site. Safety helmets should be worn by all personnel at all times that work is in progress.

    1. Confined Space Entry

Entry into tanks and confined spaces should be carefully controlled, firstly to ensure that the atmosphere in the space is safe to breathe and secondly to ensure that in an emergency, rescue teams are able to check the whereabouts of individuals. It will also help to prevent individuals from being trapped should a tank be unexpectedly closed. Any enclosed space should only be closed after it has undergone a final inspection by a responsible ship's officer. If the shipyard does not have such a system in place the master should establish a personnel tracking system for any ship or company

personnel entering a tank or other confined space.

Note: A system that has recently been used successfully includes providing each person who might enter a tank or confined space with a unique "tank entry badge" or name badge preferably of a magnetic material. When a person enters a tank or confined space, this badge is attached to a board, or placed in a box, at the point of entry. In this way, if there is an emergency in a particular tank, the emergency response team will be able to determine the number of persons in the confined space and take appropriate action .

    1. Personal Protective Equipment

The wearing of the appropriate personal protective equipment (PPE) is a highly visible display of both commitment to safety and personal awareness of risk. At the personal level, the master and company representatives should insist that ship's personnel and all contractors wear appropriate PPE manufactured to a recognised national standard. This should include boiler suits or coveralls, gloves, safety footwear, safety helmets, safety spectacles or goggles (depending on the work) and hearing

protection if noise levels in the work area exceeds 85 dbA. Insistence that the shipyard and sub- contractor work force do the same should be paramount.

    1. Respiratory Protection

If the work being done causes contamination of the atmosphere by material that is an inhalation hazard, respiratory protection should be worn. Potential sources of such airborne contamination include asbestos, paint mist, boiler cleaning and other chemicals, blasting dust, etc. The permissible exposure limit (PEL) for these and other substances may be established by the flag State or the country where the shipyard is located. Such regulations should be consulted to determine if respiratory protection is appropriate. Asbestos should be handled by approved contractors only and disposed of in an environmentally responsible way.

Sand used for blasting is a particularly insidious material because of the long term health effects of exposure to sand; dust and the large amount of blasting typically done during a shipyard repair period. Preference should be given to selecting a non-sand blasting material such as copper slag.

Where sand blasting is unavoidable special precautions will be needed to protect personnel and to contain any escaping dust, sand etc.

  1. ENVIRONMENTAL PROTECTION

Particular attention should be paid to ensuring that pollution of the environment does not occur during shipyard repair periods. Some of the issues that should be addressed include:

In order to eliminate the risk of inadvertently draining a tank which might contain fuel or lubricating

oil, a senior ship's officer should be responsible for clearly establishing the identity of tank bottom plugs and for supervising their removal and correct replacement.

  1. COMPLETION OF REPAIRS

Returning the ship to service after a repair period is a time of high stress and intense activity. As such the potential for a serious incident can be higher than during the rest of the repair period. Historically some of the most serious shipyard accidents have happened during this time.

All personnel must be extremely vigilant during this period to ensure that all the ship systems have been restored to their optimum seagoing condition and properly recommissioned prior to final testing. There is a huge potential for various work items to conflict as work moves to a completion to meet the ship's departure time. The daily meeting must cover in some depth all the testing and recommissioning work planned for that day, in order to ensure that all potential conflicts are identified and resolved.

Particular care must be taken to ensure that the pressure testing of pipeline systems cannot result in a hazardous situation arising at any location along the length of the system, or in any space through which the system passes.

Regardless of whether the work is being carried out by yard or ship's personnel, when starting machinery which has been repaired and/or has not been operated for some time the recommissioning is the direct responsibility of the responsible officers onboard and therefore ship's personnel should establish prior to start up:

Machinery start up should be carried out in a controlled and sequential manner in accordance with a predetermined plan. This plan should establish the respective responsibilities of both yard and ship's personnel during the start-up period.

Personnel should be alert to the hazards which the start-up of machinery may cause, e.g. exhaust fumes, high noise levels etc. and to hazards which might be introduced as the result of a failure in any system, e.g. the release of noxious or toxic vapours. The appropriate personal protective equipment should be worn during start-up and system verification procedures. Adequate fire fighting and machinery space smothering systems should be available during start up.

Prior to refloating from a dry dock, ship's personnel should carry out an external examination to ensure that all openings in the hull are properly secured. As the dock is filling they should carry out an internal examination of all spaces to verify their integrity.



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