PSC deficiency code 18412: Personal protective equipment (PPE)
Area 18 Maritime Labour Convention, 2006
Code 18412 sits in the MLC health and safety group and covers the protective gear crew use at work: helmets, safety shoes, gloves, eye and face protection, hearing protection, harnesses, coveralls, chemical protection and respirators. The inspector's doubt is whether the ship's risk assessments led to the right gear being issued, and whether people wear it.
What the inspector looks at
Most of this is seen on the walk round, by watching people at work.
- crew on deck and in the engine room wearing helmets, safety shoes, gloves and eye protection suited to the job
- hearing protection worn in noisy spaces, with signs at the entrances
- harnesses and lanyards for work aloft or overside, with inspection records
- chemical gloves, goggles and aprons where chemicals are handled, matched to the safety data sheets
- PPE stock in sizes for the crew on board, and an issue record
- risk assessments and permits that name the PPE for each task
- condition: cracked helmets, worn soles, torn gloves, gear past the maker's service life
Common findings
- Crew working on deck without safety helmets
- Hearing protection not worn in engine room
- Safety harness damaged, no inspection record
- Grinding carried out without eye protection
- Insufficient stock of PPE, sizes not available
- No chemical-resistant gloves or goggles at chemical store
- Safety helmets cracked or beyond maker's service life
The rule behind it
MLC 2006 Regulation 4.3 and Standard A4.3 require the flag's laws to cover reasonable precautions against occupational accidents, injuries and diseases, and on-board programmes whose preventive measures include the use of personal protective equipment. Guideline B4.3.1 lists PPE among the matters national guidelines should address and points to the ILO code of practice Accident prevention on board ship at sea and in port. Guideline B4.3.4 pairs the shipowner's duty to provide protective equipment with a requirement for seafarers to use it. The flag's rules and the company's safety management system set what is provided.
Action codes you are likely to see
Crew who put on the missing gear during the inspection are often marked 10. A stock shortfall or a damaged harness that needs replacing usually gets 17, sometimes 16. When nobody on deck wears PPE, the inspector may add an ISM finding with 18. PPE isn't on the IMO list of detainable deficiencies, which has no MLC section. Under MLC Standard A5.2.1, though, an officer can stop a ship whose conditions are clearly hazardous to seafarers' safety or health, so a serious case may be treated as a ground for detention (30). See action taken codes.
How to close it
The master, chief officer and chief engineer each own their department's PPE. Order missing items and sizes through the agent and replace damaged harnesses with certified ones. Brief the crew and check the risk assessments name the PPE for each task. Keep the delivery note, issue record, photos and briefing record with the Form B, and raise the finding at the next safety committee meeting. Related: entry into dangerous spaces, cleanliness of engine room and access and structural features.