I:\DSC\12\10-1.doc For reasons of economy, this document is printed in a limited number. Delegates are kindly asked to bring their copies to meetings and not to request additional copies.

INTERNATIONAL MARITIME ORGANIZATION

IMO

E

SUB-COMMITTEE ON DANGEROUS GOODS, SOLID CARGOES AND CONTAINERS 12th session Agenda item 10

DSC 12/10/1 15 June 2007 Original: ENGLISH

GUIDANCE ON PROVIDING SAFE WORKING CONDITIONS FOR SECURING OF

CONTAINERS

Report of the correspondence group

Submitted by the United Kingdom

SUMMARY

Executive summary:

The main task of the group was to produce a draft Annex to the Code of Safe Practice for Cargo Stowage and Securing (CSS Code) on “Providing Safe Working Conditions for Securing of Containers”

Action to be taken:

Paragraphs 3 and 4

Related document:

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Introduction 1 The Sub-Committee, at its 11 session, established a correspondence group to continue the work of the Working Group on Providing Safe Working Conditions for Securing of Containers under the coordination of the United Kingdom with the aim of completion of the work at DSC 12. 2 The following Member Governments participated in the group:

AUSTRALIA CANADA CHILE CHINA DENMARK IRAN (ISLAMIC REPUBLIC OF) ITALY JAPAN

NETHERLANDS NORWAY PANAMA REPUBLIC OF KOREA RUSSIAN FEDERATION SWEDEN UNITED KINDOM UNITED STATES

and the following non-governmental organizations.

BIMCO INTERNATIONAL CHAMBER OF SHIPPING (ICS) ICHCA INTERNATIONAL LIMITED INTERNATIONAL CONFEDERATION OF FREE TRADE UNIONS (ICFTU) MARITIME ORGANIZATION OF WEST AND CENTRAL AFRICA (MOWCA)

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Method of work 3 The report of the working group is split into two parts with annex 1 containing a draft of the guidelines and annex 2 containing the outstanding issues that could not be effectively resolved in a correspondence group. The intention, with the agreement of the Sub-Committee, is to resolve these issues in a working group at DSC 12 so that a completed new annex to the CSS Code can be presented for consideration at the Sub-Committee. Action requested of the Sub-Committee

4 The Sub- Committee is invited to consider the work of the correspondence group and take action as appropriate.

***

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ANNEX

ANNEX 1

GUIDANCE ON PROVIDING SAFE WORKING CONDITIONS FOR SECURING OF CONTAINERS

1 Aim To ensure that persons employed in carrying out container lashing operations on deck

have safe access and places of work; and that this requirement is taken into account at the design stage when lashing systems are devised. These guidelines provide ship-owners, ship builders, classification societies, Administrations and ship designers with guidance on producing a Cargo Safe Access and Securing Plan (CSAP).

2 Scope 2.1 All ships built or modified for the purpose of carrying containers on deck. 3 General 3.1 Introduction 3.1.1 Injuries to dockworkers onboard visiting ships account for the majority of accidents that

occur within container ports, with the most common activity that involves such injuries being the lashing/unlashing of deck containers. Ships crew that are required to lash/unlash deck containers face similar dangers.

3.1.2 During the development and construction of container ships the provision of a safe place

of work for the crew and dockworkers should be considered as of equal importance to the container capacity.

3.1.3 Container shipowners and designers are reminded of the dangers associated with

container securing operations and urged to develop and use container securing systems which are safe by design. The aim should be to eliminate the need for:

• container top work; • work in other equally hazardous locations; and

• the handling by crew or dockworkers of heavy and unwieldy securing equipment.

See note 1 3.2 Recommendations on safety of personnel during container securing operations

(MSC/Circ.886) 3.2.1 Ship designers and Administrations are encouraged to take into account the

recommendations made for safe design for deck lashing contained in these guidelines, and in “Recommendations on safety of personnel during container securing operations” (MSC/Circ.886).

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3.3 Cargo Safe Access and Securing Plan (CSAP) 3.3.1 The CSS code requires ships carrying containers to have an approved Cargo Safe Access

and Securing Plan (CSAP) on board. 3.3.2 All stakeholders, such as ship designers, ship builders, administrations, classification

societies and shipowners should be involved at an early stage in the design of lashing and securing arrangements on containerships and in the development of the CSAP.

See note 2 3.3.3 The CSAP should be developed at the design stage with details of safe work platforms

and fencing, complete with integrated and protected illumination for these work areas, taking into account the requirements of this annex.

3.3.4 Designers should incorporate the requirements of this annex so that safe working

conditions can be maintained during all anticipated configurations of container stowage. Compliance with these requirements should be detailed in the CSAP.

See note 3 3.4 Design, Operation and Maintenance See note 4 3.4.1 It should be borne in mind that providing safe working conditions for securing containers

deals with matters relating to design, operation, and maintenance, and that the problems on large container ships are not the same as on smaller ones.

3.4.2 In line with section 2.3 of MSC/Circ.745 all ships should maintain a record book, which

should contain the procedures for accepting, maintaining and repairing or rejection of cargo securing devises. The record book should also contain a record of inspections.

3.4.3 Safe lashing and securing operations should be included in the ships Safety Management

System as part of the ISM Code documentation. 3.4.4 Any failure to provide safe lashing positions should be recorded and reported to the

Administration and the port State. 3.4.5 Lighting must be properly maintained. 3.4.6 Walkways, ladders and stairways must be subject to a periodic maintenance programme

which will reduce/prevent corrosion and prevent subsequent collapse. 3.4.7 Corroded walkways, ladders and stairways must be repaired/replaced.

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3.5 Training See note 5 See note 22 3.5.1 All personnel whether shore-based or ships crew should be fully trained in the

lashing/unlashing of containers as necessary to complete their duties in a safe manner. 3.5.2 Personnel engaged in cargo securing operations should be trained to develop the

knowledge, psychomotor and attitude skills that they require to do their job safely and efficiently, as well as to develop general safety awareness, (ILO CoP 2.6.2) and to recognize and avoid potential dangers.

3.5.3 Training should include situational awareness to identify and avoid hazards. 3.5.4 Personnel should be suitably trained in lashing operations using the different types of

lashing equipment that they will be expected to use. See note 6 4 Safe Access and Cargo Securing Requirements 4.1 Administrations should ensure that:

• approved lashing plans contained within the Cargo Securing Manual must be compatible with the current design of the ship and that the intended container securing method must be both safe and physically possible;

• the Cargo Securing Manual, lashing plans and the Cargo Safe Access and

Securing Plan (CSAP) are kept up to date; and

• lashing plans are compatible with the design of the vessel and the equipment available.

4.1.2 Shipowners and operators should ensure that: See note 23

• Portable cargo securing devises should be certified and assigned with an MSL. The MSL should be documented in the cargo securing manual as required by the CSS code.

• The operational requirements of this annex are complied with.

4.1.3 Container ship terminal operators should ensure that.

• The requirements of section 6.3 of this annex are complied with.

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See note 7 5 Responsibilities 5.1 Designers

SHOULD FOLLOW DESIGN REQUIMENTS OF THESE GUIDELINES 5.2 Shipbuilders SHOULD FOLLOW DESIGN REQUIMENTS OF THESE GUIDELINES

See note 8

6 Design 6.0 General Design Considerations for Shipbuilders and Ship Designers 6.0.1 In conjunction with builders, designers should conduct risk assessments, taking into

account the requirements of this annex, at the design stage of the ship to ensure that lashing/unlashing tasks can be safely carried out in all anticipated container configurations. This assessment is to be conducted with a view to the development of the Cargo Safe Access and Securing Plan (CSAP). Hazards to be assessed should include:

• Slips, trips and falls.

• Falls from height.

• Injuries whilst manually handling lashing gear.

• Being struck by falling lashing gear or other objects.

This paragraph should be taken into account during the carrying out of the

risk assessment. See note 9 6.0.2 Shipbuilders should collaborate with designers in conducting risk assessments and ensure

that the following basic criteria are adhered to when building container ships. 6.0.3 If it is necessary to secure containers in the outer positions, this should be achievable

from a safe position. 6.0.4 The space provided between the containers stows for workers to carry out lashing

operations should provide:

• A firm and level working surface.

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See note 36 See note 51

• A working area, excluding lashings in place, not less than 750 mm wide, to

provide a clear sight of twist lock handles and allow for the manipulation of lashing gear.

• Sufficient space to permit the lashing gear and other equipment to be stowed

without causing a tripping hazard. See note 25 See note 37

• Sufficient space between the fixing points of the lashing bars on deck, or on the

hatch covers, to tighten the turnbuckles. • Access in the form of simple ladders on hatch coamings. • Safe access to lashing platforms. • Protective fences on lashing platforms (an appropriate design is given in ILO CoP

Section 3.3.4). • adequate lighting in line with these guidelines.

6.0.5 The possible health effects of funnel emissions on dock workers such as crane drivers

should be considered in the design of the ship. See note 10

6.0.6 Clearance for ships cargo lifting gear. 6.0.6.1 There must be adequate clearance between containers tops and ships cargo gear such as

derricks and crane to prevent damage. See note 11 6.1 Lashing Platform Design In this section the term ’fencing’ (ILO ACoP 3.3.4) is used as a generic term for

guardrails, safety rails, handrails, safety barriers and other similar structures that provide protection against falls.

See Note 12 6.1.1 Double platforms are the preferred design as they eliminate or greatly reduce the use of

three high lashing bars and provide efficient vertical stowage of the bars along the platform. An overhead protection would further protect lashers and provide increased opportunity for better lighting. If single platforms are provided, they should be designed to provide a clear work area, unencumbered by deck piping and other obstructions and take into consideration:

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• Containers must be capable of being stowed within the reach envelope of the

workers using the platform. • The work area size and the size of the securing components used.

• Workers should not have to lean over the rail or reach through the rail to handle

cargo securing equipment. 6.1.2 Where outboard stations are level with the hatch covers or coamings, and the height does

not exceed two metres, removable flat sections of grating may be used to bridge the well deck. However, they should be wide enough to perform the task and the width will depend on whether one, two or three high lashings are required. These removable sections should be capable of being temporarily secured into position, to prevent shifting whilst in use.

See note 26 See note 40 6.1.3 Permanent platforms should, where possible, be at least 1000 mm (39 inches) wide but

not less than 750 mm (30 inches) wide. Likewise, platforms provided at outboard lashing stations should not be less than 750 mm x 750 mm.

6.1.4 Toe boards (or kick plates) that are at least 100 mm (4 inches) high, should be provided

around the sides of the permanent platforms, whenever practicable. See note 31 See note 38 See note 42 6.1.5 Portable or removable lashing platforms should where possible be at least 750 mm

(30 inches) wide, but no less than 500 mm (20 inches) wide and sufficiently strengthened to prevent springing or warping.

6.1.6 The access should be designed to ensure there are no gaps for workers to fall into, whilst

lashing, by fitting a hinged plate where possible. 6.1.7 There should be no obstructions, such as lashing bar storage bins or guides to land hatch

lids, on the working platform where lashers work. 6.2 Fencing Design See note 13

6.2.1 If platforms are above 2 m (6.6 ft) high, they must be fenced. The following criteria for

the design of fencing are proposed as adequate to allow lashing operations to be carried out safely, based on practical experience and ILO CoP Section 3.3.4. They should take into consideration:

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See note 43

• The strength and height of the rails, considering that workers will likely lean and brace themselves against them when lifting cargo securing equipment.

See note 14

• The flexibility of the fencing placement gaps within specified parameters based on the containers expected to be stowed in the adjacent locations.

• Provisions for locking and removal of fencing as operational situations change

based on stowage anticipated for that area. • Damage to fencing and how to prevent failure due to that damage. • Collapsible posts and ropes are acceptable if correctly raised and tensioned before

lashing operations, wire ropes have sufficient wires per strand to be flexible, are free from broken wires and any loose ends are fitted with ferrules or other means of protection to prevent injury.

6.2.2 The top rail of fencing should be 1 m (40 inches) high from the base, with an

intermediate rail at 500 mm (20 inches). See note 15 See note 32 6.2.3 Where possible fences and handrails should be highlighted with a different colour to the

background. 6.2.4 Fencing in wing positions should be adjustable to allow for different length

container stows. 6.2.5 Athwartships cargo securing walkways should be protected by substantial fencing if an

unguarded edge exists when the hatch cover is removed. 6.3 Ladder and Manhole Design 6.3.1 Where a fixed ladder gives access to the outside of a platform, the stringers should be

connected at their extremities to the guardrails of the platform, irrespective of whether the ladder is sloping or vertical.

See note 16 6.3.2 Where fixed a ladder gives access to a platform through an opening in the platform, the

opening shall be protected with either a fixed grate with a lock back mechanism, which can be closed after access or fencing. Handholds should be provided to ensure safe access through the opening.

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See note 26 See note 27 See note 39 See note 44 6.3.2 Where a fixed ladder gives access to a platform from the outside of the platform, the

stringers of the ladder should be opened above the platform level to give a clear width of 700 to 750 mm to enable a person to pass through the stringers.

See note 28 6.3.3 A fixed ladder should not slope at an angle greater than 25° from the vertical. Where the

slope of a ladder exceeds 15° from the vertical, the ladder should be provided with suitable handrails not less than 540 mm apart, measured horizontally.

See note 29 6.3.4 A fixed vertical ladder of a height exceeding 3 m (10 ft) and any fixed ladder less

than 3 m high from which a dock worker may fall into a hold should be fitted with guard hoops, which should be constructed as follows:

6.3.4.1 The ladder should be uniformly spaced at intervals not exceeding 900 mm (3 ft apart) and

should have a clearance of 750 mm from the rung to the back of the hoop and be connected by longitudinal strips secured to the inside of the hoops, each equally spaced round the circumference of the hoop.

6.3.4.2 The stringers should be carried above the floor level of the platform by at least 1 m and

the ends of the stringers should be given lateral support and the top step or rung should be level with the floor of the platform unless the steps or rungs are fitted to the ends of the stringers.

6.3.5 Access ladders and walkways, and work platforms should be designed so that workers do

not have to climb over piping or work in areas with permanent obstructions. 6.3.6 There should be no unprotected openings in any part of the workplace. Access opening

must be protected with handrails or access covers that can be locked back during access. 6.3.7 Manholes should not be situated in transit areas. If they have to be situated in such areas,

proper fencing should protect them. 6.3.8 Access ladders and manholes must be large enough for workers to safely enter and leave.

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See note 17 6.4 Twistlock Design See note 50 6.4.1 Ships should ensure that the number of different types of twistlock provided for cargo

securing is kept to a minimum and clear instructions are provided for their operation. The use of too many different types of twistlock may lead to confusion as to whether the twistlock is locked or not resulting in the container not be secured.

6.4.2 Semi-automatic twistlocks (SATL) should not have a single pull wire mechanical design.

Such designs make it difficult to ascertain if the SATL is locked and is prone to failure. 6.4.3 Semi-automatic twistlocks (SATL) with a double lock/unlock pull wire which have bright

colour knobs are a safer design as it much easier to assess if it is locked. This design also tends to be more reliable and easier to handle.

6.4.4 Only those semi-automatic twistlocks that are designed to ensure positive locking with

easy up and down side identification should be used. 6.5 Lashing Bar Design 6.5.1 The designers of container ship securing systems should consider the practical abilities of

the workers to lift, reach, hold, control and connect the components called for in all situations anticipated in the cargo securing plan.

6.5.2 The maximum length of a lashing bar which is sufficient to reach the lower corner of a

high cube container on the third tier should be 5200 mm. See note 33 6.5.3 The NIOSH lifting equation should be used to calculate the max weight of lashing bars

that has a starting point of 25 kg. This figure may need to be reduced dependent on the design of the ship and lashing system employed. The weight of lashing bars and turnbuckles should be reduced to a level as low as practicable.

See note 18 6.5.4 The head of the lashing bar that is inserted in the corner fitting should have a pivot/hinge

design so that the bar does not come out of the corner fitting if left hanging vertically. See note 34 6.5.5 The bars length in conjunction with the length and design of the turnbuckle should be

such that the need of extensions is eliminated when lashing high cube (9’ 6”) containers. 6.5.6 Light weight bars should be provided where special tools are needed to lash high cube

containers.

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See note 19 6.6 Storage Bins and Lashing Equipment Stowage Design See note 35 6.6.1 Bins or stowage places for lashing materials should be provided where possible between

the container bays. 6.6.2 Bins for faulty or damaged gear should also be provided and appropriately marked. 6.7 Provision of Safe Access (Design) See note 52 6.7.1 Safe means of access should be provided to all places onboard the ship that a dockworker

is required to go in the course of their work. 6.7.2 Transit areas connect the working places for stevedores with the means of access or other

working places. 6.7.3 The minimum clearance for transit areas is 2 m (6 ft 6 ins) high and 600 mm (24 ins)

wide. See note 53 6.7.4 All deck surfaces used for movement about the ship and all passageways and stairs should

have non-slip surfaces. 6.7.5 Where necessary for safety, walkways on deck should be delineated by painted lines or

otherwise marked by pictorial signs. 6.8 Lighting Design

A lighting plan should be developed to provide for: See note 24 6.8.1 The proper illumination of access ways (not less than 10 Lux, 1 ft. candle), taking into

account the shadows created by containers that may be stowed in the area to be lit. 6.8.2 A separate fixed lighting system for each working space between the container bays,

which is bright enough (not less than 50 lux, 5-foot candles, ILO CoP 7.1.5) for the work to be done, but minimizes glare to the deck workers.

6.8.3 Lighting systems should take into account the deep shadows which may develop by

stowing different length containers in or over the work area.

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See note 41 6.8.4 Such illumination should, where possible, be designed as a permanent installation and

adequately guarded against breakage. 6.8.5 The illumination intensity should take into consideration the distance to the uppermost

reaches where cargo securing equipment is utilized. 6.9 Lashing Gear and Equipment See note 45 6.9.1 Lashing rod systems, including tensioning devices, should comply with the following

criteria:

• ISO 3874, Annex D. • Compatibility with the planned container stowages. • Compatibility with the physical ability of persons to safely hold, deploy and use

such equipment.

NOTE: comments are invited as to whether these criteria should be expanded. See note 20 See note 30 See note 48 See note 49 7 Operational Procedures 7.1 Failure to Provide Safe Lashing Stations Onboard/Carry Out Lashing by Port

Workers 7.1.1 Where there are lashing and unlashing locations onboard ship where no fall protection,

such as adequate handrails are provided, and no other safe method can be found, the containers should not be lashed or unlashed and the situation should be reported to shore side supervision and the Captain or Deck Officer immediately.

7.1.2 If protective systems cannot be designed, adapted or retro fitted to provide safe protected

access and lashing work positions, in all cargo configurations then cargo should not be stowed in that location. Neither crew nor shore workers should be subjected to hazardous working conditions in the normal course of securing cargo.

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7.2 Container Stowage See note 46 7.2.1 Container stows must be properly planned as follows:

• The stowage of 45 ft containers on 40 ft hatches should be avoided.

• If this is unavoidable then they should be stowed above the third tier only. • Vessels that intend to stow multiple 2.9 m high containers in one stack, should

provide a sufficient number of lashings of compatible bar/turnbuckle design. These must be of sufficient length, to allow such a stack to be lashed without the need for extension bars.

• Otherwise all 2.9 metre high containers should be placed only at the three

high level or above on deck. 7.2.2 No 40 ft containers on 45 ft hatches, unless deck cleats are provided on the hatch lids, or

adequate arrangements are made by the ship operators to provide special securing tools and equipment.

7.2.3 All containers should be stowed in the same direction, i.e. parallel with the ship’s

longitudinal axis (fore-aft). 7.3 Containership Condition Report The Terminal Operator should ensure: 7.3.1 That stevedores are properly trained to carry out lashing operations aboard ship.

In addition, because every ship may have its own safety issues onboard, identified by the Vessel Condition Report (see below), it is also necessary that they are properly informed of the potential hazards aboard the ship being worked. The information may be passed on in the form of toolbox talks or gangway briefings.

7.3.2 That a system is in place to ensure that an onboard inspection is completed on the first

call of any ship to the Terminal involving a competent person who should compare actual lashing conditions aboard to those outlined on a checklist.

7.3.3 A subsequent Vessel Condition Report should be completed. This Inspection Report

should consist of a pre-printed list arranged in such a way as to include all the basic requirements for safe lashing described in this annex. An example of such an Inspection Report and checklist is shown in Appendix 1.

7.3.4 Any discrepancies found during the above vessel inspection are reported to the ships

owners and operators. When possible this inspection should take place jointly with an appropriate ships representative.

7.3.5 That if defects are not rectified within a suitable period of time, the ship is reported to the

Port State Control Authority of the port concerned.

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7.4 Lashing Gear and Twistlocks 7.4.1 Lashing gear must be uniform and compatible, e.g., semi-automatic twistlocks should

only be used with suitable lashing bars, such as the swivel headed bars, and must be subject to a periodic inspection and maintenance regime. Non-conforming items should be segregated for repair or disposal.

7.4.2 Single wire toggled twistlocks can cause a number of problems during operation as

toggles can get damaged with certain lashing rods, leaving only the wire of the twistlock to operate. This can be a major problem when trying to release containers at any height. Vessel should provide the necessary equipment provided by the manufacturer for safe release.

7.4.3 The correct lashing gear is used for the intended lashing plan, i.e. one high bars for one

high containers etc. Unless the correct bar is used it may be impossible to secure containers properly, and there is the added risk of the bar falling out and injuring workers.

7.4.4 Lashing gear should be stowed in the area provided and not where it is underfoot or in the

work area. 7.4.5 Appropriately and prominently marked bad order bins must be provided for dockside use,

for quarantining twistlocks requiring maintenance. 7.5 Container Deck Working 7.5.1 Transit areas should be safe and clear of cargo and all equipment. 7.5.2 Any necessarily unprotected openings in work platforms (i.e. those with a potential fall of

less than 2 metres), and gaps and apertures on deck should be properly highlighted. 7.5.3 The use of fencing is essential to prevent falls. When openings in safety barriers are

necessary to allow container crane movements, particularly with derricking cranes, removable fencing should be used whenever possible.

7.5.4 It should be taken into account that when lifting lashing bars that can weigh

between 11 & 21 kg and turnbuckles between 16 & 23 kg, there may be a risk of injury if handled above shoulder height with the arms extended. It is therefore recommended that personnel work in pairs to reduce the individual workload in securing the lashing gear.

7.5.5 It is recommend when handling such heavy weights that the lifter use their body weight to

raise the bar to an upright position which will allow the large muscles of the legs to take most of the weight keeping a firm grip and a straight back.

7.5.6 Personnel engaged in container ship cargo operations should wear appropriate PPE whilst

carrying out lashing operations. 7.5.7 Personnel engaged in container ship cargo operations should be familiarized with the

ship’s unique characteristics and potential hazards arising from such operations necessary to carry out there duties.

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7.5.8 The health of dockworkers should be considered in the prevention of excessive toxic substances found in exhaust gas from the ship.

See note 21 7.5.9 The ship’s crew must be properly trained to use the equipment provided and recognize

and avoid potential hazards and be familiar with the vessel layout. 8 Specialized Container Safety Design 8.1 Reefer Power Outlets should be interlocked and shipboard terminals provide a safe,

watertight electrical connection. 8.2 Reefer power outlets should feature a heavy duty, interlocked and circuit breaker

protected electrical power outlet. This should ensure the outlet can not be switched ‘live’ until a plug is fully engaged and the actuator rod is pushed to the ‘On’ position. Pulling the actuator rod to the ‘Off’ position should manually de-energize the circuit.

8.3 The reefer power circuit should de-energize automatically if the plug is accidentally

withdrawn while in the ‘On’ position. Also, the interlock mechanism should break the circuit while the pin and sleeve contacts are still engaged. This provides total operator safety and protection against shock hazard while eliminating arcing damage to the plug and receptacle.

8.4 Reefer power outlets should be designed to ensure that the worker is not standing directly

in front of the socket when switching takes place. 8.5 The positioning of the reefer feed outlets should not be such that the flexible cabling

needs to be laid out in such a way as to cause a tripping hazard. 8.6 Stevedores or ships crew who are required to handle reefer cables and/or connect and

disconnect reefer units should be given training in recognizing defective wires and plugs. 9 References

ILO Code of Practice – Safety and Health in Ports ISO Standard 3874 – The Handling and Securing of Type 1 Freight Containers

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APPENDIX 1: VESSEL CONDITION REPORT

VESSEL CONDITION REPORT

Lloyd’s Register No. (Office Use Only)

Vessel: Line: Date:

Vessel superstructure Poor Fair Good

Gangway access

Well decks (highlighting of obstructions)

Access between hatches (safe access, working space and protective fencing)

Lashing access (walkways staging and protective fencing)

Outboard lashing stations protective fencing)

Ships lighting for lashing on deck

Walkways under deck

Ships lighting for lashing under-deck

Lashing gear (use tick boxes as appropriate)

Accessibility (stacking cones : twistlocks : bars)

Compatibility Bars with bottlescrews

Bars & T/Ls

Greased

Twistlocks S/Auto Manual Mixed L/R

Stacking Cones

S/Auto

Bad order bins

Ship’s crew

Ship’s general cleanliness

Remarks Does a VSI (restriction) form exist for this vessel?

Yes No

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Vessel notification (complete only if the stowage remarks have been brought to the attention of a Ships’ Officer): If and when conditions and facilities are rated as’ Poor’ consideration should be given as to whether that area/equipment should be worked Reported to: For ship date: at hrs

Print name: Position: Master

--------------- Officer

Signed: Terminal:

Appendix 2: Notes Note 1 Add definitions in this section such as ‘fencing’, stringer and Administration. Note 2 Is there scope for cargo handlers being involved in these considerations such as representatives of the terminals that are involved in the lashing operations. Note 3 The following text should be added. It should be borne in mind that providing safe working conditions for securing

containers deal with matters relating to design, operation and maintenance, and that the problems on large container ships are not the same as on small ones.

Note 4 The word design should be removed. Note 5 This section could be shortened and the points brought together. It is however

relevant if operations are to be included. Note 6 The following text should be added: Where lashing work involves working at heights, the training should include the

use of harnesses and other equipment and the safe system of work. Note 7 It is suggested that the above text be move to section 4 - Responsibilities. Note 8 It is suggested that Classification societies are added to section 4. Note 9 Is this necessary given the next point. Note 10 What is the relevance of this to the subject of this annex? Note 11 What is the relevance of this to the subject of this annex? Note 12 It is suggested that this be moved to section 3 - General under a heading of

definitions applied throughout.

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Note 13 It is suggested that the word design be deleted. Note 14 It is suggested the above be deleted. Note 15 The above is based upon the ILO COP standards ant there are now EN standards

that are suggesting higher levels. Note 16 Needs a definition of stringer. Note 17 It is suggested the following text be included. Basic dimensions of ladders should be given e.g., Width of rungs, spacing of

rungs and depth behind ladder (these should accord with the ILO Cop 3.5.3. Note 18 What is needed is a simple standard that can be internationally applied,

The NIOSH system could be evaluated and explained as a possible way of doing this but the essential sentence is the last one and should be the emphasis. The weigh of bars should be minimized as low as possible consistent with the necessary mechanical strength.

Note 19 It is suggested that the following text be added. Lashing systems, including tensioning devices should comply with the following

criteria.

• ISO 3874 Annex D.

• Compatible with the planned container stowage’s.

• Compatible with physical ability of persons to safely hold, deploy and use such equipment.

Note 20 It is suggested that 5.9 be deleted. Note 21 Is this relevant to this document? Note 22 This guidance provides constructional requirements and training requirements

should not be included. Note 23 The CSS Code does not require securing devises to be certified and marked with

the MSL. Note 24 What are bases on levels of 10 lux and 50 lux? Note 25 1 metre is too wide and 500 mm is enough for working. Access between container

lashings should be at least 500 mm. Note 26 Clear width of 700 – 750 mm is too wide comparing with the size of platforms

of 750 mm x 750 mm.

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Note 27 Figures provided should be further considered taking into account human engineering.

Note 28 Figures provided should be further considered taking into account human

engineering. Note 29 Figures provided should be further considered taking into account human

engineering. Note 30 Operational requirements should be deleted. Note 31 The height of toe boards and kick plates could be made lower than 75 cm if

suitable hand rails are provided. The height of 20 – 30 mm is enough for toe boards and kick plates.

Note 32 Colour should not be provided. Note 33 Requirements are not clear. Figures should be provided by using NIOSH lifting

equation based on some typical positions of workers. Note 34 The reason to eliminate the need of extensions is unclear. Note 35 The phrase where possible should be added because bins can not always be

provided. Note 36 Careful consideration should be made on working area taking into account

comments from ship building industry because requirements of working area have impact on ship design.

Note 37 The meaning of tripping hazards should be clarified. Note 38 The ISO standard dictates 100 mm (but previously 75 mm) whether handrails are

provided is irrelevant. Toe boards are provided to prevent twist locks and gear from being knocked over the side of the platform and hitting people or becoming lost.

Note 39 12 inches is too narrow and not inline with ISO standard. there may be some

locations that due to ships structure 300 mm wide ladders might be acceptable, but not as a general design standard.

Note 40 750 x 750 is the minimum required to be able to handle and locate a

three high bar. Note 41 The phase where possible should be added because permanent illuminations are

not always possible. Note 42 A height of 20 – 30 mm is enough for toe boards and kicking plates. Note 43 Fences are not for holding position of workers during lashing/unlashing.

Only their strength to protect workers against a fall is required.

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Note 44 The definition of transit area should be clarified. Clear width of 700 – 750 mm is too wide compared with the size of platforms of 750 mm x 750 mm.

Note 45 The ISO standard should be deleted. Prescribed standards of lashing materials

without precise consideration should be avoided. Note 46 This section should be deleted because design standards of containers fall out side

the scope of these guidelines. Note 47 This report is not necessary. Note 48 Normally ships crew are not involved in lashing/unlashing operations of

containers and consequently, accidents involving crew seldom or never occur. Therefore, guidance on operational procedures for ships crew seems not necessary. Additionally, on board inspections should be deleted from guidance.

Note 49 Operational procedures are included in the terms of reference for the work of the

group. Ships crew do on occasions lash and unlash cargo, particularly on the smaller feeder container ships. Accidents do happen to crew when required to lash or unlash containers and there are several accident reports that bear witness to this.

Note 50 Only the first paragraph about unity of twist locks should be kept, the

paragraph about semi-automatic twistlocks should be deleted as we should not stipulate the design of automatic, semi automatic or manual twistlocks only that they should be approved.

Note 51 It is suggested that the word ‘normally’ is placed before not less than in the text

‘a working area, excluding lashing in place, not less than 750 mm wide’ as placing two 20 ft containers in the place of one 45 ft container may constitute a problem in certain cases with the working space being very limited. It is not only a practical question of stowing arrangement for ordinary container types, but a matter of minimum working space. In guidelines produced by AMSA it is recommended that a working space be provided that is clear of all obstructions over a width of at least 550 mm.

Note 52 Safe means of access should be provided to all places onboard the ship for

dockworkers, however these guidelines may be in conflict with ISPS regulations, In some cases there is simply not enough space on deck to have access to all the equipment and special equipment may better be stowed in the forecastle with the crew providing the equipment to the dockworkers when necessary. It is suggested that a new sentence be added as follows; “With regard to special equipment as well as additional equipment, this should be provided to dockworkers by the crew”.

Note 53 Not all deck surfaces should be non slip surfaces a better wording would be

‘All relevant surfaces’.

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