PSC deficiency code 18415: Entry dangerous spaces
Area 18 Maritime Labour Convention, 2006
Code 18415 covers entry into tanks, holds, cofferdams, void spaces, chain lockers and any other space where the air may lack oxygen or hold toxic or flammable gas. It sits in the MLC health and safety group. The inspector's doubt is whether the ship's procedure would stop someone walking into a space that can kill them, and get them out if it goes wrong. Drills have their own code (04118), as do gas instruments (18410).
What the inspector looks at
The inspector usually asks for the procedure and recent permits, then looks at the equipment.
- the entry procedure in the safety management system, and a list of the ship's enclosed spaces
- completed permits: hazards, ventilation, atmosphere readings, attendant, communication, validity
- atmosphere testing instruments working and calibrated, personal gas detectors for entrants
- rescue equipment ready: breathing apparatus, harness and lifeline, hoist or tripod, stretcher
- spaces not in use kept closed, with warning signs
- crew answers to who authorises entry and what the attendant does
Common findings
- Enclosed space entry permit incomplete, atmosphere readings not recorded
- Ballast tank entered without permit
- Portable gas detector calibration overdue
- No list of enclosed spaces on board
- Rescue equipment for enclosed space entry incomplete
- Crew not familiar with enclosed space entry procedure
The rule behind it
MLC 2006 Regulation 4.3 and Standard A4.3 require the flag's rules to cover the prevention of occupational accidents, and Guideline B4.3.1 names work in enclosed spaces among the matters to address. SOLAS regulation XI-1/7 requires portable atmosphere testing instruments able to measure at least oxygen, flammable gases or vapours, hydrogen sulphide and carbon monoxide before entry. SOLAS III/19 requires crew with entry or rescue duties to take part in an entry and rescue drill at least once every two months. IMO's revised recommendations for entering enclosed spaces (MSC.581(110), 2025, following A.1050(27)) describe permits, testing and rescue.
Action codes you are likely to see
An incomplete permit corrected on board, or a detector calibrated with the ship's own kit, is often 10. Shore calibration or rescue gear that has to be delivered usually gets 17. Gaps in the procedure can bring an ISM finding with 18. Under MLC Standard A5.2.1 an officer can stop a ship whose conditions are clearly hazardous to seafarers, so entries made without testing or a rescue plan may be treated as a ground for detention (30). The IMO list of detainable deficiencies includes a serious deficiency in the operational requirements of its appendix 7, which covers enclosed space drills; that finding normally goes under 04118. See action taken codes.
How to close it
The chief officer and chief engineer usually own this. Calibrate or replace instruments and keep the certificate. Complete the rescue kit and post the list of enclosed spaces. Brief the crew on the permit system, ideally with a recorded drill. Keep certificates, delivery notes, the revised permit, the drill record and photos with the Form B. Related: personal protective equipment.