PPE awareness grows, but rules gap puts US mariners at risk
Our 890-foot oil tanker was underway from Tampa, Fla., for a planned passage through the Panama Canal, a stop for bunkers and stores at Long Beach, Calif., and then on to Valdez, Alaska, for a full load of crude destined for Hawaii. While at anchor in Long Beach, two British merchant marine officers — an unlimited chief engineer and master — boarded the ship for the full trip to Hawaii, hired by the company to conduct a safety audit at sea. One morning I was having breakfast when the British chief sat down at the same table. We exchanged greetings and introductions, and then I asked him what the audit had revealed thus far. In a smooth southern English accent, he replied, “There’s room for improvement, but overall things are pretty good, with the exception of the appalling lack of PPE use.” A bit more animatedly, he continued, “Yesterday I watched the boatswain and three ABs using a crane to shift cargo hoses on deck, and couldn’t believe that none of them were wearing a hard hat or goggles.” Listening to his narrative I nodded but never said a word, all the while thinking to myself, “PPE?”
As I later found out, PPE — otherwise known as personal protective equipment — refers to safety gear designed to protect mariners from workplace injury and/or illness. PPE includes but is not limited to hard hats, goggles, earmuffs, boots, breathing masks and gloves. Distinguished from emergency lifesaving equipment such as immersion suits and life jackets, PPE items are generally used during routine shipboard operations like mooring and unmooring, cargo handling and maintenance at sea.
Regulations specifically addressing the use of personal protective equipment on commercial vessels have been in place for years in a number of countries, including Denmark and the United Kingdom. Notice A, Chapter 7 from the Danish Maritime Authority decrees that all Denmark-registered shipowners must provide appropriate PPE to their crews at no cost. In the U.K., Marine Shipping Notice 1870 (MSN 1870) and the British Maritime and Coastguard Agency’s Code of Safe Working Practices for Merchant Seamen (COSWP) require all U.K.-registered shipowners to provide a suitable amount of PPE for crew use at no cost, maintained in good condition and of a quality and durability that meets officially established standards. Unfortunately, here in the United States there are no similar shipboard PPE requirements mandated by the Coast Guard that are applicable to all U.S.-flag commercial vessels.
PPE, and the lack of it, has played a role in a number of incidents at sea in my career. While sailing on a product tanker in the Gulf of Mexico, I was doing some work with a grinder on deck while wearing my PPE, which for that job included work boots, earplugs, leather-palm work gloves and safety goggles. A piece of metal was thrown out by the grinder and became embedded in the lens of the goggles. Without them, I surely would have lost my left eye. Conversely, a young guy I worked with on a crude oil tanker paid dearly for not using the PPE he needed. One rough but clear winter afternoon off Vancouver Island, he was wearing tennis shoes — not work boots — on deck. He slipped, losing his footing while pushing a heavy sandblasting pot over a catwalk. The sandblasting pot dropped right on his hand, chopping off three fingers in a bloody accident.
From my experience, a wide variance exists between companies as to the availability and use of PPE on their vessels. The best one was a dredge company I worked for one winter, filling in for a young mate so he could be home with his family in Maine for the holidays. Joining the ship in Panama on a warm December night, a pleasant surprise greeted me while opening the door to my stateroom. The previous mate left a clean hard hat, three pairs of new foam earplugs, two sets of safety goggles (one clear and the other tinted), an unused dust mask and two pairs of work gloves (one leather-palm and the other a gripper) for me to use. Everyone in the crew had access to the same company-provided PPE that I got, and from what I saw, they used the gear conscientiously and gratefully. I don’t think it was a coincidence that there were no lost-time accidents or injuries on board during the entire time I worked on that vessel.
Unfortunately, not all of the companies I’ve sailed for have viewed the use of PPE as seriously as the dredge outfit did. On a gasoline tanker shuttling between Lake Charles, La., and Corpus Christi, Texas, I walked into my stateroom on the day I joined the ship and found there was only a set of relief notes and a UHF radio — no hard hat, no goggles, no gloves and no ear protection. When I checked with the chief mate and asked about getting some PPE for myself, he replied, “The company has no obligation to provide you with any personal safety gear. If you need goggles or whatever, go to the boatswain’s locker — there may be a pair you can borrow.” Checking the boatswain’s locker, there was only a scraped-up set of goggles with a stretched-out head strap, one soiled dust mask and an empty paper box that used to hold foam earplugs.
Such a glaring disparity in how personal protective equipment is handled on different inspected ships is unacceptable. All U.S.-flag maritime companies required to comply with the International Safety Management (ISM) Code should have to clearly spell out their PPE policies in their safety management system procedures. Companies should stipulate what personal protective equipment will be provided to officers and crew, that the condition of the gear will be checked regularly, and that every mariner on board will receive instruction about when to use his or her PPE.
When it comes to establishing rules for PPE on commercial vessels at sea, maritime authorities in the United States need to step up their game as well. Currently, except for towing vessels and ships/barges carrying benzene, there are no PPE requirements to be found in Title 46 (Shipping) of the Code of Federal Regulations (CFR). The Coast Guard should establish specific PPE rules for all U.S.-registered commercial vessels, whether large oceangoing ships or small passenger boats, and then codify them in the CFR — making it clear that the onus for providing quality safety gear and training rests with the shipping companies.
Till next time, I wish you all smooth sailin’.