The Republic of the Marshall Islands Maritime Administrator is conducting marine safety investigations following two different incidents involving in transit cargo fumigation.
One of these incidents resulted in the death of a crewmember soon after removing fumigant from the cargo holds prior to arrival at the discharge port. The other resulted in the hospitalization of a stevedore after being exposed to fumigant that had been applied by the crew prior to departure from the loading port.
The Administrator’s investigations of these two cargo fumigation incidents have identified that crewmembers on board both ships were required to handle fumigant because of COVID-19 related restrictions imposed by the port State’s public health authorities.
These restrictions prohibited qualified shore personnel from going aboard the ship to either remove the fumigant residues from the cargo holds following the vessel’s arrival or to apply the fumigant after the cargo had been loaded.
Fumigation of dry bulk cargo requires introducing a toxic gas, or a material that reacts with moisture in the air to produce a toxic gas, into a ship’s cargo holds. Exposure to fumigant gases can lead to severe injury or death says Marshall Islands, adding that “it is essential that all appropriate precautions be taken to ensure the safety of the ship’s crew and any other persons (e.g., cargo surveyors, customs agents, stevedores, etc.) who might be on board during all stages of cargo fumigation.”
In its publication entitled “Recommendations on the Safe Use of Pesticides in Ships Applicable to the Fumigation of Cargo Holds,” IMO notes the following:
– Crew should not handle fumigants, they should be handled only by qualified personnel;
– The fumigation company, a government agency, or appropriate authority should designate an appropriately qualified “fumigator-in-charge”;
– When fumigation is carried out in port or at anchor, with limited exceptions, all crew should be landed ashore until the fumigator-in-charge or other authorized person certifies in writing that the ship is gas free;
– In transit fumigation should only be carried out at the discretion of the Master and that this should be clearly understood by the ship’s owners, operators, charterers, and all other involved parties;
– If in transit fumigation is conducted: at least two crewmembers should brief the vessel’s crewmembers before fumigation is conducted and satisfying the fumigator-in-charge that this was completed; and verify the actions taken to prevent fumigant from entering, and then monitoring the atmosphere in the accommodations, bridge, engine room, and other working spaces throughout the voyage;
– The vessel should have on board: gas-detection equipment with sufficient supplies (e.g., gas-detection tubes) for monitoring the atmosphere in the accommodations, bridge, engine room and other working spaces along with occupational exposure limits for the fumigant that was applied; instructions for disposing of residual fumigant; at least four sets of appropriate respiratory protective equipment; and a copy of the current version of the Medical First Aid Guide for Use in Accidents Involving Dangerous Goods, along with appropriate medicines and medical equipment.
– Cargo holds sealed for in transit fumigation should not be opened at sea or entered, except in an extreme emergency;
– The Master must inform the appropriate authorities prior to arrival at the discharge port and any intermediate ports of call that in transit fumigation is being conducted.