M2745 - Forepeak tank welding without any safety checks

Initial Report

Welding was being carried out in the forepeak tank while the vessel was loaded with diesel. The work was required to address seawater ingress through a crack in the bulkhead. The incident was reported to CHIRP because the work was unsafe. CHIRP has followed up with both the Flag State and the reporter.

Two contractors were carrying out the repairs under the supervision of a superintendent on board.

No permit-to-work or enclosed-space entry procedure was in place. There was no rescue equipment or crew present, and the reporter observed no evidence of gas monitoring.

It is currently unclear whether Class had issued a schedule of work for the repair. The Flag State investigation team has been notified and asked to liaise with Class for follow-up.

CHIRP Comment

This report identifies a serious breach of established international requirements for enclosed space entry and hot work. Welding was conducted in a forepeak tank while the vessel was loaded with diesel, without a permit-to-work system, enclosed space entry procedures, or evidence of atmosphere testing or continuous gas monitoring. No rescue equipment, standby personnel, or breathing apparatus were in place.

These failings contravene guidance from the International Maritime Organisation (MSC.1/Circ.1401 Rev.1) and the mandatory provisions of the International Safety Management Code. Entry into enclosed spaces must be controlled through risk assessment, permit-to-work, verified and continuous atmosphere testing, effective ventilation, and fully prepared rescue arrangements.

Forepeak and ballast tanks are high-risk enclosed spaces. Alongside flammable or toxic atmospheres, they present a significant and often underestimated risk of oxygen deficiency caused by internal corrosion, an established cause of multiple fatalities. Without proper monitoring, ventilation, and emergency preparedness, the risk of rapid incapacitation and death is high.

Conducting hot work or entering enclosed spaces without these safeguards represents a fundamental breakdown in risk control. The absence of rescue equipment and immediately available breathing apparatus significantly increases the likelihood of fatal outcomes and may result in enforcement action by Flag State and Port State Control authorities.

The involvement of contractors and a superintendent does not reduce these obligations. Contractors may be unfamiliar with ship-specific risks, particularly during urgent repairs. The shipowner and Master remain legally responsible for ensuring proper induction, supervision, and full compliance with the vessel’s safety management system. Responsibility for safe operations cannot be delegated.

This report is a stark reminder that entry into enclosed spaces and hot work require strict adherence to established standards. Permit-to-work systems, continuous hazard monitoring, effective supervision, and verified emergency preparedness are essential to prevent fatalities.

Key Issues relating to this report

Factors relating to this report

This event shows a cluster of high-risk human and organisational behaviours, rather than a single failure.

Communication – No clear communication regarding the work scope and associated hazards (hot work, diesel enclosed-space tank environment). Possibly, a power gap between office management and the crew prevented people from speaking up.

Complacency – The work activity was treated as a routine repair, and, due to a lack of effective control measures, it appeared to normalise unsafe practice.

Capability – Failure to recognise the work as a high-risk work environment and the need for basic safety controls.

Teamwork – was missing because if the crew had been operating as a team, there would have been a challenge to the work activity

Capability – Missing from the work were the following: a permit to work, gas-monitoring equipment, rescue equipment, and standby personnel with communications equipment.

Pressure – Likely urgency due to seawater ingress and the need to maintain operational readiness may have overridden safe decision-making

Norms (Unsafe Practices Becoming Standard) – Absence of a PTW strongly suggests:  “This is how we normally do it in this company”, so that deviations from standard operating practice have become accepted standards.

Key Takeaways

If the permit isn’t in place, we may not yet understand the risks well enough to start.

Regulators (Flag State / Class) – This case highlights the need to actively verify compliance with fundamental safety controls, including permit-to-work, gas monitoring, and enclosed-space procedures. Greater oversight is needed to ensure that requirements are consistently applied in practice, with clear accountability among the Flag State, Class, and operators. Targeted inspections and follow-up on reported concerns can help close the gap between procedures and on-board reality.

Managers / Operators – This incident reflects a failure to enforce core safety management system barriers. Managers must ensure that critical controls are treated as non-negotiable, regardless of operational pressure. Stronger oversight of contractors and superintendents is essential, alongside reinforcing a culture in which unsafe work is challenged, and stop-work authority is fully supported.

Seafarers – This report reinforces that work should not proceed without essential safety measures in place. The absence of a permit-to-work, gas testing, or rescue arrangements should be clear grounds to stop the job. Seafarers should remain vigilant, challenge unsafe conditions, and avoid accepting risk as routine.