Confidential Human Factors
Incident Reporting Programme
The Charity
Aviation
Maritime
M2454
Initial Report
While tidying up the engine room, an engineer placed several empty chemical drums in the workshop for disposal. The engineer used blue tape across the drums to indicate they were empty and wrote “Empty” on them. However, one drum still contained a small amount of residual acid.
Later that afternoon, a motorman entered the workshop to dispose of the drums. Unsure of the contents since the safety data sheet was covered in blue tape, he opened the cap and attempted to identify the contents by smell. The fumes caused severe inhalation exposure, leading to his hospitalisation for the remainder of the day.
The vessel had purchased several chemicals from the same supplier, including engine room detergents, acids, bases, and defoamers, all stored in identical containers. These were typically distinguished by safety data sheets attached to each drum. However, the labelling was obscured, creating a hazardous situation.
CHIRP Comment
Proper labelling of chemical drums is essential. Original labels must remain visible until containers are thoroughly cleaned and decontaminated. Never cover or remove safety data sheets. Use standardised “Empty” labels that don’t obscure critical information. Even small residues can pose serious risks. Drums must be drained, cleaned, and vented before being marked as empty. A designated “chemical residue area” can help manage partially emptied containers safely.
Safe handling is vital. Never try to identify chemicals by smell. If in doubt, check the safety data sheet or ask a senior officer. A “Stop and Check” policy should verify contents before handling or disposal. Always wear appropriate PPE—gloves, eye protection, and respirators—and use portable gas detectors when necessary, especially around unknown substances.
Suppliers should simplify identification with colour-coded drums or clear hazard markings. Drums for disposal should include decontamination instructions. To improve safety, review procedures regularly, enhance crew training on hazard awareness and PPE, and consider improved labelling systems. Work with your supplier to ensure better identification.
Key Issues relating to this report
Complacency—The label marked “empty” led to assumptions that it was safe without verifying its contents. The operator could not confirm the chemical type or contents but proceeded regardless.
Communication—There may have been no clear briefing or shared understanding of what was in the drum. There may have been a reluctance to question or challenge due to rank.
Situational Awareness—The leader did not foresee the impact of leaving chemical residues in “empty” drums. No thought was given to downstream risk (throughout the disposal process), showing a lack of hazard anticipation.
Culture—The need for better chemical handling procedures and awareness training points to systemic issues in how safety is embedded. In this case, the processes allowed hazardous residues to be overlooked or poorly identified.
Key Takeaways
Seafarers: “Do not trust the makeshift label—know what is inside.”
Just because a drum says “empty” does not mean it is safe. Never use smell to guess what is in a container—check and confirm. If something does not feel right, speak up.
Ship managers: “A chemical near-miss is a system failure.”
Training and procedures fail if the crew relies on labels or their noses. Reinforce clear communication about hazardous substances. Regardless of rank, ensure everyone feels confident raising a hand before risk becomes harm.
Regulators: “Risk doesn’t stop at the worksite—it travels downstream.”
Chemical residues left in so-called “empty” drums pose serious disposal risks. Review how hazardous waste is labelled, handled, and signed off. Operational spot checks should test actual practices.