PNI [2025] 01
22 January 2025
China MSA Launched a Special Campaign
against Illegal Entry into Enclosed Spaces
onboard Ships
Dear Sir/Madam,
It is reported that China Maritime Safety Administration (China MSA) has
recently launched a nine-month special campaign against illegal entry into
dangerous enclosed spaces onboard ships. On basis of the information we
obtained thus far, we have prepared this Circular to briefly introduce the
special campaign and provide relevant suggestions for the reference of the
Clubs and their Members.
The Main Contents of the Special Campaign
Period of Special Campaign
From January 15 to October 14, 2025.
Targets of Special Campaign
Ships and waterborne facilities equipped with enclosed spaces that meet the
following definitions.
Enclosed space means a space which has any of the following characteristics:
1. limited openings for entry and exit;
2. inadequate ventilation; and
3. is not designed for continuous worker occupancy.
Enclosed spaces include, but are not limited to, cargo spaces, double bottoms,
fuel tanks, ballast tanks, cargo pump-rooms, cargo compressor rooms,
cofferdams, chain lockers, void spaces, duct keels, inter-barrier spaces,
boilers, engine crankcases, engine scavenge air receivers, sewage tanks, and
the adjacent connected spaces which are normally unventilated and not used
for cargo storage but which may share the same atmospheric characteristics
with the enclosed spaces.
Frequency of Inspection
In principle, only one special inspection shall be carried out onboard the same
ship during the special campaign period, except for the following situations:
1. Where an accident or dangerous situation is triggered due to illegal entry
into the enclosed space onboard a ship.
2. Where serious deficiencies or potential risks in the management of entering
enclosed spaces onboard the ship are identified during on-site ship
supervision.
3. Where a ship is reported under real name for serious problems or potential
risks in the management of entry into the enclosed spaces.
4. Where special inspections are required as designated by the MSA of the
Ministry of Transport.
Key Points of Inspection
The special campaign action plan provides an inspection checklist with the
following contents:
1. Are crew members responsible for enclosed space entry aware of the
associated risks?
2. Are the measures in place to permit to work for visitors and crew members
for enclosed space entry?
3. Is there a list of enclosed space identified?
4. Are the enclosed spaces marked and for authorized personnel only?
5. Are the atmosphere testing devices regularly checked and calibrated?
6. Are the emergency rescue equipment for enclosed space entry in good
condition?
7. Are the personnel familiar with the safe entry and risk assessment
procedures for enclosed space?
8. Are the personnel familiar with the operation of safety protective equipment
and devices?
9. Is the enclosed space entry and rescue drill in accordance with SOLAS
Chapter III, Regulation 19.3.3?
10. Is the SMS related to enclosed space operations effectively implemented
on board?
Huatai Suggestions
In recent years, the number of accidents caused by the act of illegally entering
enclosed spaces has been increasing year by year, and such illegal acts have
pose serious threaten to the safety of both personnel and ships. In view of this,
China MSA has launched a special campaign on the illegal entry into enclosed
spaces onboard ships, aiming to standardize the behavior of operation
personnel entering enclosed places onboard ships and prevent and curb the
occurrence of such accidents.
Viewing from an organizational perspective, the special campaign is similar to
the Concentrated Inspection Campaign (CIC) held annually by some PSC
Memorandum of Understanding organizations, but the inspection period of this
campaign is much longer than the PSC CIC. According to the requirements of
the special campaign, it will be conducted in combination with the daily
supervision and management of shipping companies, safety management
system audits, ship safety inspections and on-site supervision, etc. The targets
of this special campaign are the ships entering Chinese ports, regardless of
their nationality.
In order to effectively respond to this long-term special campaign and avoid the
identification of deficiencies related to illegal entry into enclosed spaces during
the flag state / PSC inspection, we suggest that whilst conducting
self-inspection in accordance with the items listed in the above mentioned
inspection checklist, the Shipowners, Managers / Operators and ships should
also draw their particular attention on the following aspects in order to pass the
inspection smoothly:
1. Self-check the relevant procedures in the SMS documents
Check and confirm that the ship's SMS documents contain the safety
operation procedure for guiding the personnel entering enclosed spaces, the
emergency response and rescue plan and the maintenance procedure/plan for
the safety equipment, communication devices, rescue and first aid tools which
are necessary for entering enclosed spaces by way of a thorough
self-inspection. The SMS documents should be modified and improved in
accordance with appropriate procedures if the aforementioned procedures /
plans are found to be absent.
2. Establish and strictly comply with the risk assessment and entry permit
system
Ensure that crew members possess the ability to determine the various types
of hazards and risk levels that may exist in the enclosed spaces by
comprehensively analyze on the various factual conditions such as cargo type,
ventilation status, operation type, gas composition, tank coating, adjacent area
conditions, etc., and able to propose reasonable measures to reduce the
corresponding risks to an acceptable level and keep proper records. After
sufficient risk assessment, an authorized entry permit from the master or the
designated person in charge shall be obtained before entering. Furthermore,
the entry permit should be kept on board along with the risk assessment
documents for inspection.
3. Physical inspection of enclosed spaces and the related equipment
Ships should regularly identify and establish a list of enclosed spaces on board.
Through regular inspections, ships shall confirm that the entrances or
passageways to the enclosed space are in good maintenance condition, free
from obstacles that could affect the safe entry of personnel and rescue
operations; the internal structures within the enclosed spaces are complete,
safe and reliable; the connecting ventilation systems are working properly; and
the interior equipment such as lighting, fixed gas monitoring equipment, water
level detectors (if any), etc. are in good working condition. In addition, regular
inspection should also be carried out to ensure the personal protective
equipment, rescue tools, communication devices etc. are in good order.
4. Training and Emergency Drills
Provide regular training to crew members, conduct drills for entering enclosed
spaces strictly in accordance with the requirements of the Convention (every
two months) and keep the training and drill records. Through adequate training
and drills, ensure that crew members are familiar with their emergency
responsibilities, aware of the dangers of enclosed spaces, understand the
correct procedures for entering enclosed spaces and familiar with emergency
evacuation and the rescue procedures. Ensure that the responsible personnel
can correctly inspect, use, and maintain the protective and rescue equipment,
and is proficient in the operating, inspection, testing, and calibration of the
fixed and portable gas detection instruments.
Last but not least, it is equally important to promptly notify ships destined for
Chinese ports about the ongoing special campaign being carried out by China
MSA during this period so that crew members have sufficient time to prepare
for the onboard inspections and pass them smoothly.
Should you have any inquiries, please feel free to contact Huatai Beijing
(pni.bj@huatai-serv.com) or our local branch offices.
Best regards,
CUI Jiyu
Head of Marine Team
