INTERNATIONAL MARITIME ORGANIZATION

E
IMO

SUB-COMMITTEE ON DANGEROUS DSC 13/8

GOODS, SOLID CARGOES AND 18 June 2008
CONTAINERS Original: ENGLISH
13th session
Agenda item 8

GUIDANCE ON PROVIDING SAFE WORKING CONDITIONS

FOR SECURING OF CONTAINERS

Draft amendments to the Code of Safe Practice for Cargo Stowage and Securing
(CSS Code)

Submitted by ICHCA International Limited

SUMMARY
Executive summary: This document provides the outcome of a group of interested parties
reviewing the incomplete document arising from DSC 12 and revising
it to assist the Sub-Committee in finalizing this work item
Strategic direction: 5.2
High-level action: 5.2.3
Planned output: 5.2.3.1
Action to be taken: Paragraph 6
Related document: DSC 12/WP.4

Introduction

1 DSC 12 considered the report of an intersessional group established by DSC 11 which

was tasked with developing a new annex to the CSS Code providing guidance on safe working
conditions for securing containers and worked on that document during the meeting.
Unfortunately, the work could not be concluded and the issue was left for finalization at DSC 13.

2 Interested parties from Member Governments and international organizations considered

the issue intersessionally with a view to assisting the Sub-Committee in finalizing this work.
Consideration was based on the document that emerged from the DSC 12 work (DSC 12/WP.4)
and the style, coverage and layout were maintained.

For reasons of economy, this document is printed in a limited number. Delegates are
kindly asked to bring their copies to meetings and not to request additional copies.

I:\DSC\13\8.doc
DSC 13/8 -2-

3 The original request (MSC 80/21/7) and the relevant decision of the Committee
(MSC 80/24, paragraph 21.8) were also reviewed and it was found that it was not entirely clear
whether the intention was to confine the new annex to new ships or to cover both new and
existing ships. All the work carried out by DSC 10, 11 and 12 was based on the view that it
covered both and also included relevant operational matters.

4 Accordingly, the interested parties have refined the DSC 12 document (DSC 12/WP.4)
and also developed an alternative proposal of three parts – Part A: New Ships (at annex 2),
Part B: Existing Ships (at annex 3) and Part C: Operational Aspects (at annex 4). This alternative
provision is entirely based on the contents of the attached revision of the DSC 12 document.

5 Whilst it is the view of the interested parties that the general approach of the DSC 12
document most closely follows the Committee’s instruction, it recognizes that there may be an
alternative view.

Action requested of the Sub-Committee

6 The revised DSC 12 document (DSC 12/WP.4) and the alternative set of three parts are
attached and the Sub-Committee is invited to:

.1 consider which of the two alternatives should be adopted;

.2 accept the outcome of the interested parties’ work in assisting the Sub-Committee
in progressing this work item; and

.3 instruct the working group, if established, to review the alternative selected with a
view to finalizing the work at this session.

***

I:\DSC\13\8.doc
 DSC 13/8

ANNEX 1

DRAFT AMENDMENTS TO THE CODE OF SAFE PRACTICE FOR CARGO

STOWAGE AND SECURING (CSS CODE)

DRAFT NEW ANNEX [...]

GUIDANCE ON PROVIDING SAFE WORKING CONDITIONS

FOR SECURING OF CONTAINERS

1 AIM

The aim of this Annex is to ensure that persons engaged in carrying out container securing
operations on purpose-built containerships have safe working conditions and, in particular safe
access, appropriate securing equipment and safe places of work. These guidelines should be
taken into account at the design stage when securing systems are devised or are retrofitted or
modified on existing containerships. These guidelines provide shipowners, shipbuilders,
classification societies, Administrations and ship designers with guidance on producing and
authorizing a Cargo Safe Access Plan (CSAP).

2 SCOPE

This Annex applies to all ships which are specifically designed and fitted for the purpose of
carrying containers:

.1 for which the building contract is placed on or after [date]; or

.2 in the absence of a building contract, the keels of which are laid or which are at a
similar stage of construction on or after [date]; or

.3 the delivery of which is on or after [date].

This Annex also applies to all ships built after [insert 10 years before the effective date] that were
designed or subsequently adapted for such purposes.

3 DEFINITIONS

3.1 Administration means the Government of the State whose flag the ship is entitled to fly.

3.2 Fencing is a generic term for guardrails, safety rails, safety barriers and similar structures
that provide protection against the falls of persons.

3.3 Lashing positions include positions:

• in between container stows on hatch covers;

• at the end of hatches;
• on outboard lashing stanchions; and
• outboard lashing positions on hatch covers.

I:\DSC\13\8.doc
DSC 13/8
ANNEX 1
Page 2

3.4 SATLs are semi-automatic twistlocks.

3.5 Securing includes unsecuring.

3.6 Stringers are the uprights or sides of a ladder.

3.7 Turnbuckles and lashing rods (ISO 3874, Annex D Lashing rod systems and tensioning
devices) include similar cargo securing devices.

4 GENERAL

4.1 Introduction

4.1.1 Injuries to dockworkers on board visiting ships account for the majority of accidents that
occur within container ports. The most common activity that involves such injuries is the lashing
and unlashing of deck containers. Ships’ crew engaged in cargo related activities face similar
dangers.

4.1.2 During the design and construction of containerships the provision of a safe place of work
for lashing personnel is essential.

4.1.3 Containership owners and designers are reminded of the inherent dangers associated with
container securing operations and are urged to develop and use container securing systems that
are safe by design. The aim should be to eliminate or at least minimize the need for:

.1 container top work;

.2 work in other equally hazardous locations; and

.3 the handling of heavy and unwieldy securing equipment by lashing personnel.

4.1.4 It should be borne in mind that providing safe working conditions for securing containers
includes consideration of matters relating to design, operation and maintenance, and that the
problems on large containerships are not the same as those on small containerships.

4.1.5 Administrations should ensure that the Cargo Safe Access Plan is maintained and
enforced throughout the life of the ship.

4.2 Recommendations on safety of personnel during container securing operations

(MSC/Circ.886)

4.2.1 Initial shipowners should specify the intended container loading/unloading patterns prior
to concluding the building contract with ship designers and builders. Ship designers and builders
should take into account the container operation specified by the owner. Administrations should
ensure that all concerned parties take into account the recommendations on safe design of
securing arrangements contained in these guidelines and in the Recommendations on safety of
personnel during container securing operations (MSC/Circ.886).

I:\DSC\13\8.doc
 DSC 13/8
ANNEX 1
Page 3

4.3 Cargo Safe Access Plan (CSAP)

4.3.1 The CSS Code requires ships that are specifically designed and fitted to carry containers
to have an approved CSAP on board. This should cover all areas where containers may be
secured.

4.3.2 Stakeholders, including, but not limited to shipowners, ship designers, shipbuilders,
administrations, classification societies and lashing equipment manufacturers, should be involved
at an early stage in the design of securing arrangements on containerships and in the development
of the CSAP:

.1 if a shipowner has a specific intended loading/unloading pattern, it should be

clearly stated in the building contract;

.2 if there is any restriction on the loading/unloading operation imposed by the

specific design, the designers/builders concerned should notify such restriction to
the shipowner; and

.3 Administrations should ensure that all concerned parties have a common

understanding of the intended loading/unloading patterns and restrictions that may
be imposed by the design.

4.3.3 The CSAP should be developed at the design stage in accordance with chapter 5 of the
annex to MSC/Circ.[...].

4.3.4 Designers should incorporate the recommendations of this annex into the CSAP so that
safe working conditions can be maintained during all anticipated configurations of container
stowage.

4.3.5 Compliance with these recommendations should be stated in the CSAP.

4.4 Training

4.4.1 Personnel engaged in cargo securing operations should be trained in the lashing and
unlashing of containers as necessary to carry out their duties in a safe manner. This should
include the different types of lashing equipment that are expected to be used.

4.4.2 Personnel engaged in cargo securing operations should be trained in the identification and
handling of bad order or defective securing gear in accordance with each ship’s procedures to
ensure damaged gear is segregated for repair and maintenance or disposal.

4.4.3 Personnel engaged in cargo securing operations should be trained to develop the
knowledge and mental and physical manual handling aptitudes that they require to do their job
safely and efficiently, and to develop general safety awareness to recognize and avoid potential
dangers.

4.4.4 Training should include awareness of potentially dangerous situations in order to identify
and avoid hazards.

I:\DSC\13\8.doc
DSC 13/8
ANNEX 1
Page 4

4.4.5 Personnel should be trained in safe systems of work. Where personnel are involved in
working at heights, they should be trained in the use of relevant equipment. Where practical, the
use of fall protection equipment should take precedence over fall arrest systems.

4.4.6 Personnel and their supervisors required to secure containers should be trained in the
reading and understanding of the CSAP.

4.4.7 Training should also be provided on the importance of providing updated information to
ensure the CSAP is correct and current.

4.4.8 Personnel who are required to handle reefer cables and/or connect and disconnect reefer
units should be given training in recognizing defective cables, receptacles and plugs.

5 SAFE ACCESS AND CARGO SECURING

5.1 Administrations should ensure that:

.1 lashing plans contained within the approved Cargo Securing Manual (CSM) are
compatible with the current design of the ship and that the intended container
securing method is both safe and physically possible;

.2 the CSM, lashing plans and the CSAP are kept up-to-date when there is a change
to the lashing plans; and

.3 lashing plans are compatible with the equipment available.

5.2 Shipowners and ship management companies should ensure that:

.1 portable cargo securing devices are certified and assigned a maximum securing
load (MSL). The MSL should be documented in the CSM as required by
the CSS Code;

.2 the operational recommendations of this Annex are complied with; and

.3 incompatible and unauthorized equipment and unsafe conditions are not used.

6 RESPONSIBILITIES

6.1 Designers

Ship designers should follow the design recommendations in these guidelines.

6.2 Shipbuilders

Shipbuilders should follow the design recommendations in these guidelines.

6.3 Shipowners

Shipowners should follow the design recommendations of these guidelines on new ships and
seek to implement them to the best practicable extent on existing ships.

I:\DSC\13\8.doc
 DSC 13/8
ANNEX 1
Page 5

6.4 Container Terminal Employers and Operators

Container terminal employers and operators should ensure that the relevant parts of these
guidelines are complied with.

7 DESIGN

7.1 General design considerations

7.1.1 Risk assessments should be performed at the design stage to ensure that securing
operations can be safely carried out in all the anticipated container configurations for the ship
taking into account operational matters and the recommendations of this Annex. These
assessments should be carried out before or during the development of the CSAP. Hazards to be
assessed should include:

.1 slips, trips and falls;

.2 falls from height;

.3 injuries whilst manually handling lashing gear;

.4 being struck by falling lashing gear or other objects;

.5 potential damage due to container operations. High risk areas should be identified
in order to develop appropriate protection or other methods of preventing
significant damage;

.6 adjacent electrical risks (refrigeration cable connections, etc.);

.7 the adequacy of the access to all areas that is necessary to safely perform container
securing operations;

.8 ergonomics of handling lashing equipment; and

.9 implications of lashing 9'6" high, or higher, containers and mixed stows

of 40' and 45' containers.

7.1.2 Shipbuilders and ship designers should collaborate with designers of securing equipment
in conducting risk assessments and ensure that the design ensures that container securing
operations performed at lashing positions can be carried out safely. As a minimum, a platform
should be provided on which to work safely. This platform should have fencing to prevent
workers falling off it. The dimensions and other criteria of the platform should be as specified
in 7.1.3 below. Dimensions and other criteria of lashing bridges should be as specified in 7.2.2.

I:\DSC\13\8.doc
DSC 13/8
ANNEX 1
Page 6

7.1.3 The space between the container stows that will be used by personnel to carry out lashing
operations should provide:

.1 a firm and level working surface;

.2 a working area providing clear sight of twistlock handles and allowing for the
manipulation of lashing gear. This should preferably be 1 m in width, excluding
lashings in place, but not less than 750 mm wide;

.3 sufficient standing area to permit the lashing gear and other equipment to be
stowed without causing a tripping hazard;

.4 sufficient standing area with a minimum of 300 mm between the adjacent fixing
points of the lashing bars on deck, or on the hatch covers, to tighten the
turnbuckles;

.5 safe access to hatch coamings, lashing platforms and other working areas;

.6 protective fencing on lashing platform;

.7 adequate lighting in line with these guidelines (see 7.4); and

.8 suitable siting to enable the turnbuckles to be readily reached both vertically and
horizontally from the platform.

7.1.4 Platforms for lashing outboard containers should provide a working area of at
least 750 mm between stacks or from the stack if at the end and at least 500 mm from
deck cleats.

7.1.5 Portable or removable lashing platforms should be at least 1 m wide, wherever possible,
but in no case should they be less than 750 mm wide. The design should take into account
whether one, two or three high lashings may be required. The platform should be sufficiently
strengthened to prevent springing or warping. Any removable sections of the platform should be
capable of being temporarily secured to prevent them falling.

7.1.5.1 For the purpose of identifying the standard placement of lashing rods to the stow, the
first tier is determined by the position of the turnbuckle whether it is directly on deck or on the
lashing bridge.

7.1.5.2 One-high lashing rods should be attached to the upper corner fitting of the first tier
containers.

7.1.5.3 Two-high lashing rods may be attached to the lower corner fitting of the second tier
containers.

7.1.5.4 Three-high lashing rods should be attached to the lower corner fitting of the three-high
container from the position of the turnbuckle whether it is directly on deck or on the platform.

7.1.5.5 It can be dangerous for those who unlash to use such rods in any other than the way
intended.
I:\DSC\13\8.doc
 DSC 13/8
ANNEX 1
Page 7

7.1.6 Ship designers should aim to eliminate the need to access and work on the tops of deck
stows.

7.2 Provisions for safe access

7.2.1 General provisions

7.2.1.1 The minimum clearance for transit areas should be 2.1 m high and 600 mm wide.

7.2.1.2 All relevant deck surfaces used for movement about the ship and all stairs should have
non-slip surfaces.

7.2.1.3 Where necessary for safety, walkways on deck should be delineated by painted lines or
otherwise marked by pictorial signs.

7.2.1.4 All protrusions in accessways, such as cleats, ribs and brackets, that may give rise to a
trip hazard should be highlighted in a contrasting colour.

7.2.2 Lashing bridge design

7.2.2.1 Lashing bridges should be designed to take into account:

.1 the demand of the lashing/unlashing task;

.2 the movement required;

.3 the tools that need to be used;

.4 the fact that in most circumstances two workers may be working together;

.5 the need for containers to be stowed within safe reach of the personnel using the
bridge so that the horizontal distance from the closest point of the bridge to the
container fitting to be secured does not exceed 1 m on all ships. On all ships the
distance should not be less than 220 mm; and

.6 the work area size and the size of the securing components used.

7.2.2.2 Bridges designed to eliminate or greatly reduce the use of three high lashing bars and
provide efficient vertical stowage of the bars are preferred. They should be designed to provide a
clear work area, unencumbered by deck piping and other obstructions. For example, a design of
a three-high bridge would provide added protection for lashing personnel, uniform, adequate and
physically protected lighting as well as eliminating the need for unlocking containers 5 to 7 high
from above. The lashing as well as unlocking SATLs, anchoring lashing gear and/or
plugging/unplugging three high reefers would be carried out at the second and third level.

7.2.2.3 The width of permanent lashing bridges should be:

• 750 mm between railings; and

• a clear minimum of 600 mm between storage racks, lashing cleats and any other
obstruction.
I:\DSC\13\8.doc
DSC 13/8
ANNEX 1
Page 8

7.2.2.4 Appropriate toe boards (or kick plates) at least 150 mm high should be provided around
the sides of all platforms to prevent securing equipment from falling and injuring personnel.

7.2.2.5 There should be no obstructions such as lashing bar storage bins or guides to land hatch
lids on working platforms – see 7.3.5.

7.2.3 Fencing design

7.2.3.1 Bridges and elevated platforms, where appropriate, should be fenced. As a minimum,
the design of the fencing should provide:

.1 sufficient strength and height to prevent workers from falling;

.2 flexibility in positioning the fencing of gaps. A horizontal unfenced gap should

not be greater than 300 mm;

.3 suitable provisions for locking and removal of fencing, if its removal is necessary
for operational reasons;

.4 prevention of damage to fencing and the prevention of failure of the fencing due
to such damage; and

.5 adequate strength of any temporary fittings. These should be capable of being

safely and securely installed.

7.2.3.2 The top rail of fencing should be 1 m high from the base with an intermediate rail
at 500 mm.

7.2.3.3 Handrails and grabrails (handles) should be highlighted in a contrasting colour to the
background.

7.2.3.4 Athwartships cargo securing walkways should be protected by adequate removable

fencing where it is possible to fall from an unguarded edge when a hatch cover is removed.

7.2.4 Ladder and manhole design

In this section, the reference to platforms should also be taken to refer to lashing bridges where
relevant.

7.2.4.1 Where a fixed ladder gives access to the outside of a platform, the stringers should be
connected at their extremities to the guardrails of the platform, irrespective of whether the ladder
is sloping or vertical.

7.2.4.2 Where a fixed ladder gives access to a platform through an opening in the platform, the
opening shall be protected with either a fixed grate with a lockback mechanism, which can be
closed after access, or fencing. Grabrails should be provided to ensure safe access through the
opening.

I:\DSC\13\8.doc
 DSC 13/8
ANNEX 1
Page 9

7.2.4.3 Where a fixed ladder gives access to a platform from the outside of the platform, the
stringers of the ladder should be opened above the platform level to give a clear width
of 700 to 750 mm to enable a person to pass through the stringers.

7.2.4.4 A fixed ladder should not slope at an angle greater than 15° from the vertical.

7.2.4.5 A toe hold of at least 150 mm should be provided.

7.2.4.6 A fixed vertical ladder of height exceeding 3 m, and any fixed ladder less than 3 m high,
from which a person may fall into a hold should be fitted with a fall arrest device or, where this is
not practicable, guard hoops. The ladder hoops should be uniformly spaced at intervals not
exceeding 900 mm and should have a clearance of 750 mm from the rung to the back of the
hoop. The hoops should be connected by longitudinal strips that are equally spaced round the
circumference of the hoops and secured to the inside of them.

7.2.4.7 The stringers should be carried above the floor level of the platform by at least 1 m.
The ends of the stringers should be given lateral support and the top step or rung should be level
with the floor of the platform unless the steps or rungs are fitted to the ends of the stringers.

7.2.4.8 Whenever practicable, access ladders, walkways and work platforms should be designed
so that workers do not have to climb over piping or work in areas with permanent obstructions.

7.2.4.9 There should be no unprotected openings in any part of the workplace where a person
might fall and be injured. Access openings should be protected with handrails or access covers
that can be locked back during access.

7.2.4.10 As far as practicable, manholes should not be situated in transit areas. However, if they
are, they should be protected by secure fencing.

7.2.4.11 Access manholes should be large enough for persons to safely enter and leave and fitted
with fall protection.

7.2.4.12 Handholds should be provided at the top of the ladder to enable safe access to the
platform to be gained.

7.2.4.13 Manhole openings that may present a fall hazard should be highlighted in contrasting
colour around the rim of the opening.

7.2.4.14 Manhole openings at different levels of the lashing bridge should not be located directly
below one another.

7.3 Lashing systems

7.3.1 General provisions

Lashing systems, including tensioning devices, should:

.1 conform to ISO 3874, Annex A-D;

.2 be compatible with the planned container stowages;

I:\DSC\13\8.doc
DSC 13/8
ANNEX 1
Page 10

.3 be compatible with the physical ability of persons to safely hold, deploy and use
such equipment;

.4 be uniform and compatible, e.g., semi-automatic twistlocks should only be used

with suitable lashing rods, such as swivel headed rods, and should be subject to a
periodic inspection and maintenance regime. Non-conforming items should be
segregated for repair or disposal; and

.5 as designated by the CSM.

7.3.2 Twistlock design

7.3.2.1 Shipowners should ensure that the number of different types of twistlocks specified in
the CSM is kept to a minimum. The twistlocks provided should be as provided for by CSM.

7.3.2.2 The design of twistlocks specified in the CSM should ensure:

.1 positive locking;

.2 clear up and down orientation identification;

.3 dislodgement of a twistlock from a corner fitting is not possible even when

grazing a surface;

.4 access and visibility of the unlocking device is effective in operational situations;

.5 unlocked positions are easily identifiable;

.6 twistlocks do not relock inadvertently due to jolting or vibration; and

.7 unlocking poles are as light as possible, of a simple design for ease of use and user
friendly.

7.3.2.3 Where it is not feasible to entirely eliminate working on the tops of container stows, the
twistlock designs used should minimize the need for such working, e.g., use of SATLs or similar
design.

7.3.3 Lashing rod design

7.3.3.1 The design of containership securing systems should take into account the practical
abilities of the workers to lift, reach, hold, control and connect the components called for in all
situations anticipated in the cargo securing plan.

7.3.3.2 The maximum length of a lashing rod, which is sufficient to reach the lower corner of a
high cube container on the third tier, should be 5,200 mm.

7.3.3.3 The weight of lashing rods should be as low as possible, consistent with the necessary
mechanical strength.

I:\DSC\13\8.doc
 DSC 13/8
ANNEX 1
Page 11

7.3.3.4 The head of a lashing rod that is to be inserted into a corner fitting should be designed
with a pivot/hinge or other appropriate device so that it does not come out of the corner fitting
accidentally if the rod is left hanging vertically.

7.3.3.5 The design of the lashing rods should be compatible with the twistlocks to be used on
the ship and should not adversely impede their effectiveness.

7.3.3.6 The length of a lashing rod in conjunction with the length and design of a turnbuckle
should be such that the need for extensions is eliminated when lashing high cube
(9'6") containers.

7.3.3.7 Lightweight rods should be provided where special tools are needed to enable them to be
lifted and fitted into the corners of high cube containers.

7.3.3.8 Lashing rods should be those specified in the CSM. Additional lashing rods not
specified by the ship’s CSM should not be allowed.

7.3.3.9 Extension tools should not be specified in the CSM for use on three-high lashing rods.

7.3.4 Turnbuckle design

7.3.4.1 Turnbuckle end fittings should be designed to harmonize with the design of lashing rods.

7.3.4.2 Turnbuckles should have a double screw design or similar to minimize the number of
rotations needed to tighten the lashing rods.

7.3.4.3 The anchor point location on the platform, lashing bridge or hatch cover for each
turnbuckle should be staggered from the next anchor point by a distance no less than the
thickness of the lashing rod. This ensures there is no lateral pressure where the two opposing
lashing rods meet when tightened. Such pressure may cause the rods to bend and spring out
when released.

7.3.4.4 To prevent hand injury during tightening or loosening motions, there should be a
minimum distance of 70 mm between turnbuckles. The use of a turnbuckle capable of saddling
two lashing rods eliminates the problem and reduces overall handling, however such an
arrangement should not be used unless specifically included in the CSM.

7.3.4.5 The turnbuckle or bottle screw should incorporate a locking mechanism which will
ensure that the lashing does not work loose during the voyage.

7.3.4.6 It should be borne in mind that rectangular framed turnbuckles or bottle screws covered
with grease are difficult to handle when tightening.

7.3.5 Storage bins and lashing equipment stowage design

7.3.5.1 All lashing gear should be stowed as close to its intended place of use as possible. The
stowage of lashing rods and turnbuckles should be arranged so they can easily be retrieved from
their stowage location by lifting from one end.

7.3.5.2 Bins or stowage places for lashing materials should be provided.

I:\DSC\13\8.doc
DSC 13/8
ANNEX 1
Page 12

7.3.5.3 Bins for faulty or damaged gear should also be provided and appropriately marked.

7.3.5.4 Bins should be of sufficient height for easy access, use and handling.

7.3.5.5 Bins should be of sufficient strength for the environment.

7.3.5.6 Bin racks or platforms should be of sufficient design to be lifted off the vessel and
restowed in a single lift.

7.4 Lighting design

7.4.1 The ship’s lighting plan should provide for:

.1 illumination designed, where possible, as a permanent installation, adequately

guarded against breakage utilization. The illumination intensity should take into
consideration the distance to the uppermost reaches where cargo securing
equipment is used;

.2 the proper illumination of access ways at not less than 10 lux (1 foot candle),
taking into account the shadows created by containers that may be stowed in the
area to be lit, for example different length containers in or over the work area; and

.3 a separate fixed lighting system for each working space between the container
bays at not less than 50 lux (5 foot candles), which is bright enough for the work
to be done, but minimizes glare to the deck workers.

8 OPERATIONAL AND MAINTENANCE PROCEDURES

Procedures for safe lashing and securing operations should be included in the ship’s CSAP.

8.1 Container deck working

8.1.1 Transit areas should be safe and clear of cargo and all equipment.

8.1.2 Any necessarily unprotected openings in work platforms (i.e. where there might be a fall
potential of less than 2 m) and gaps and apertures on deck should be appropriately highlighted.

8.1.3 The use of fencing is essential to prevent falls. When openings in safety barriers are
necessary to allow container crane movements, particularly with derricking cranes, removable
fencing should be used whenever possible.

8.1.4 When writing the CSM and the CSAP, it should be taken into account that lashing bars
can weigh between 11 and 21 kg and turnbuckles between 16 and 23 kg and that there will be a
risk of injury if they are handled above shoulder height with the arms extended. When this is
necessary, personnel should work in pairs whenever practicable in order to reduce the individual
workload in securing the lashing gear.

8.1.5 When it is necessary to handle such heavy weights, workers should follow the accepted
principles of kinetic handling by the use of their body weight to raise the bar to an upright
position which will allow the large muscles of the legs to take most of the weight while keeping a
firm grip and a straight back.
I:\DSC\13\8.doc
 DSC 13/8
ANNEX 1
Page 13

8.1.6 Personnel engaged in containership cargo operations should wear appropriate personal
protective equipment (PPE) while carrying out lashing operations.

8.1.7 Personnel engaged in containership cargo operations should be familiarized with the
ship’s layout, unique characteristics and potential hazards arising from such operations necessary
to carry out their duties.

8.1.8 Containers should not be stowed in spaces configured for larger sized containers unless
they can be adequately secured. This securing methodology should be described in the ship’s
approved CSM.

8.1.9 Manual twist locks should not be used to secure containers stowed on deck above the first
tier. It is acceptable to use manual twistlocks to secure containers to the hatch cover on the
bottom tier.

8.1.10 Clear instructions should be provided for the use of twistlocks specified in the CSM.

8.1.11 Twistlock types not specified in the CSM should not be used.

8.2 Container top working

8.2.1 Safe means of access should be provided when it is necessary to carry out work on the
tops of container stows on deck.

8.2.2 Industry best practice involves the use of a safety cage lifted by a spreader to minimize
the risk to personnel.

8.2.3 A safe method of work should be developed and implemented to ensure the safety of
lashers when on the top of container stows on deck. Where practical, the use of fall prevention
equipment should take precedence over fall arrest equipment.

8.3 Maintenance

8.3.1 In line with section 2.3 (Inspection and maintenance schemes) of the Revised Guidelines
for the preparation of the Cargo Securing Manual (MSC/Circ.[...]) all ships should maintain a
record book, which should contain the procedures for accepting, maintaining and repairing or
rejecting cargo securing devices. The record book should also contain a record of all such
inspections. The record book should be made available to the terminal facility and labour
representative when required.

8.3.2 Lighting should be properly maintained.

8.3.3 Walkways, ladders, stairways and fencings should be subject to a periodic maintenance
programme to minimize corrosion and prevent subsequent collapse.

8.3.4 Corroded walkways, ladders, stairways and fencings should be repaired or replaced as
soon as practicable. The repairs should be effected immediately if the corrosion could prevent
safe operations.

I:\DSC\13\8.doc
DSC 13/8
ANNEX 1
Page 14

8.4 Containership inspection

8.4.1 As directed by national laws and enforcement authorities, the Master of the ship and the
terminal employer and/or berth operator should:

.1 ensure that the workplace is safe for their employees to work in;

.2 ensure that an onboard safety inspection is completed by a competent person prior

to cargo operations commencing. This inspection should take place jointly with
an appropriate ships representative;

.3 make provision for any discrepancies found during this inspection to be reported
to the ship’s owners and operators. A simple vessel condition report may be used
for this purpose; and

.4 advise the Port State Control Authority for the port concerned if the defects are
not rectified within a suitable period of time,

8.4.2 Terminal employers and/or operators should:

.1 inform their relevant employees of any unique conditions and potential hazards
aboard the ship to be worked. This information may be passed to the workforce in
the form of gangway safety talks before work commences.

8.5 Failure to provide safe lashing stations on board

8.5.1 For lashing and unlashing locations where no fall protection, such as adequate handrails
or other suitable provision, is provided, and no other safe method can be found, the containers
should not be lashed or unlashed. The situation should be reported immediately to a shoreside
supervisor and the Master or cognisant deck officer and reference made to the CSAP.

8.5.2 If protective systems cannot be designed, adapted or retrofitted to provide safe protected
access and lashing work positions in all every configurations, cargo should not be stowed in
those locations not safely protected. Neither crew nor shore workers should be subjected to
hazardous working conditions in the normal course of securing cargo.

9 OPERATIONS WITH REFRIGERATED CONTAINERS

9.1 Reefer Power Outlets should be interlocked so that the plug cannot be inserted into or
removed from the receptacle unless the power to the receptacle is secured. Shipboard outlets
should provide a safe, watertight electrical connection.

9.2 Reefer power outlets should be protected by an appropriately-sized circuit breaker.

9.3 The reefer power circuit should de-energize automatically if the plug is accidentally
withdrawn while in the “On” position. Also, the interlock mechanism should break the circuit
while the pin and sleeve contacts are still engaged. This provides total operator safety and
protection against shock hazard while eliminating arcing damage to the plug and receptacle.

9.4 The operator should not stand directly in front of the socket when switching takes place.
Reefer power outlets should be designed to ensure that this is not possible.
I:\DSC\13\8.doc
 DSC 13/8
ANNEX 1
Page 15

9.5 Cables should be laid out in such a way as to avoid causing a tripping hazard and should
be safely stowed. The positioning of the reefer outlets should allow for this to take place.

9.6 Special ducts should be provided to lay the reefer cables in and protect them from lashing
equipment falling on them during lashing operations.

9.7 Defective or inoperative reefer plugs/electrical banks should be identified and confirmed
as “locked out/tagged out” by the vessel.

9.8 The operator should check that the power is off before attempting to connect or
disconnect.

***

I:\DSC\13\8.doc
 DSC 13/8

ANNEX 2

DRAFT AMENDMENTS TO THE CODE OF SAFE PRACTICE FOR CARGO

STOWAGE AND SECURING (CSS CODE)

DRAFT NEW ANNEX [...]

GUIDANCE ON PROVIDING SAFE WORKING CONDITIONS

FOR SECURING OF CONTAINERS

Part A – New ships

1 AIM

The aim of this Annex is to ensure that persons engaged in carrying out container securing
operations on purpose-built containerships have safe working conditions and, in particular safe
access, appropriate securing equipment and safe places of work. These guidelines should be
taken into account at the design stage when securing systems are devised or are retrofitted or
modified on existing containerships. These guidelines provide shipowners, shipbuilders,
classification societies, Administrations and ship designers with guidance on producing and
authorizing a Cargo Safe Access Plan.

2 SCOPE

This Annex applies to all ships which are specifically designed and fitted for the purpose of
carrying containers:

.1 for which the building contract is placed on or after [date]; or

.2 in the absence of a building contract, the keels of which are laid or which are at a
similar stage of construction on or after [date]; or

.3 the delivery of which is on or after [date].

3 DEFINITIONS

3.1 Administration means the Government of the State whose flag the ship is entitled to fly.

3.2 Fencing is a generic term for guardrails, safety rails, safety barriers and similar structures
that provide protection against the falls of persons.

3.3 Lashing positions include positions:

• in between container stows on hatch covers;

• at the end of hatches;
• on outboard lashing stanchions; and
• outboard lashing positions on hatch covers.

3.4 SATLs are semi-automatic twistlocks.

I:\DSC\13\8.doc
DSC 13/8
ANNEX 2
Page 2

3.5 Securing includes unsecuring.

3.6 Stringers are the uprights or sides of a ladder.

3.7 Turnbuckles and lashing rods (ISO 3874, Annex D Lashing rod systems and tensioning
devices) include similar cargo securing devices.

4 GENERAL

4.1 Introduction

4.1.1 Injuries to dockworkers on board visiting ships account for the majority of accidents that
occur within container ports. The most common activity that involves such injuries is the lashing
and unlashing of deck containers. Ships’ crew engaged in cargo related activities face similar
dangers.

4.1.2 During the design and construction of containerships, the provision of a safe place of
work for lashing personnel is essential.

4.1.3 Containership owners and designers are reminded of the inherent dangers associated with
container securing operations and are urged to develop and use container securing systems that
are safe by design. The aim should be to eliminate or at least minimize the need for:

.1 container top work;

.2 work in other equally hazardous locations; and

.3 the handling of heavy and unwieldy securing equipment by lashing personnel.

4.1.4 It should be borne in mind that providing safe working conditions for securing containers
includes consideration of matters relating to design, operation and maintenance, and that the
problems on large containerships are not the same as those on small containerships.

4.1.5 Administrations should ensure that the Cargo Safe Access Plan is maintained and
enforced throughout the life of the ship.

4.2 Recommendations on safety of personnel during container securing operations

(MSC/Circ.886)

4.2.1 Initial shipowners should specify the intended container loading/unloading patterns prior
to concluding the building contract with ship designers and builders. Ship designers and builders
should take into account the container operation specified by the owner. Administrations should
ensure that all concerned parties take into account the recommendations on safe design of
securing arrangements contained in these guidelines and in the Recommendations on safety of
personnel during container securing operations (MSC/Circ.886).

I:\DSC\13\8.doc
 DSC 13/8
ANNEX 2
Page 3

4.3 Cargo Safe Access Plan (CSAP)

4.3.1 The CSS Code requires ships that are specifically designed and fitted to carry containers
to have an approved CSAP on board. This should cover all areas where containers may be
secured.

4.3.2 Stakeholders, including, but not limited to shipowners, ship designers, shipbuilders,
administrations, classification societies and lashing equipment manufacturers, should be involved
at an early stage in the design of securing arrangements on containerships and in the development
of the CSAP:

.1 if a shipowner has a specific intended loading/unloading pattern, it should be

clearly stated in the building contract;

.2 if there is any restriction on the loading/unloading operation imposed by the

specific design, the designers/builders concerned should notify such restriction to
the shipowner; and

.3 Administrations should ensure that all concerned parties have a common

understanding of the intended loading/unloading patterns and restrictions that may
be imposed by the design.

4.3.3 The CSAP should be developed at the design stage in accordance with chapter 5 of the
annex to MSC/Circ.[...].

4.3.4 Designers should incorporate the recommendations of this annex into the CSAP so that
safe working conditions can be maintained during all anticipated configurations of container
stowage.

4.3.5 Compliance with these recommendations should be stated in the CSAP.

5 SAFE ACCESS AND CARGO SECURING

5.1 Administrations should ensure that:

.1 lashing plans contained within the approved Cargo Securing Manual (CSM) are
compatible with the current design of the ship and that the intended container
securing method is both safe and physically possible;

.2 the CSM, lashing plans and the CSAP are kept up-to-date when there is a change
to the lashing plans; and

.3 lashing plans are compatible with the equipment available.

5.2 Shipowners and ship management companies should ensure that:

.1 portable cargo securing devices are certified and assigned a maximum securing
load (MSL). The MSL should be documented in the CSM as required by
the CSS Code;

I:\DSC\13\8.doc
DSC 13/8
ANNEX 2
Page 4

.2 the operational recommendations of this Annex are complied with; and

.3 incompatible and unauthorized equipment and unsafe conditions are not used.

6 RESPONSIBILITIES

6.1 Designers

Ship designers should follow the design requirements of these guidelines.

6.2 Shipbuilders

Shipbuilders should follow the design requirements of these guidelines.

6.3 Shipowners

Shipowners should follow the design recommendations of these guidelines on new ships.

7 DESIGN

7.1 General design considerations

7.1.1 Risk assessments should be performed at the design stage to ensure that securing
operations can be safely carried out in all the anticipated container configurations for the ship
taking into account operational matters and the recommendations of this Annex. These
assessments should be carried out before or during the development of the CSAP. Hazards to be
assessed should include:

.1 slips, trips and falls;

.2 falls from height;

.3 injuries whilst manually handling lashing gear;

.4 being struck by falling lashing gear or other objects;

.5 potential damage due to container operations. High risk areas should be identified
in order to develop appropriate protection or other methods of preventing
significant damage;

.6 adjacent electrical risks (refrigeration cable connections, etc.);

.7 the adequacy of the access to all areas that is necessary to safely perform container
securing operations;

.8 ergonomics of handling lashing equipment; and

.9 implications of lashing 9'6" high, or higher, containers and mixed stows

of 40' and 45' containers.

I:\DSC\13\8.doc
 DSC 13/8
ANNEX 2
Page 5

7.1.2 Shipbuilders and ship designers should collaborate with designers of securing equipment
in conducting risk assessments and ensure that the design ensures that container securing
operations performed at lashing positions can be carried out safely. As a minimum, a platform
should be provided on which to work safely. This platform should have fencing to prevent
workers falling off it. The dimensions and other criteria of the platform should be as specified
in 7.1.3 below. Dimensions and other criteria of lashing bridges should be as specified in 7.2.2.

7.1.3 The space between the container stows that will be used by personnel to carry out lashing
operations should provide:

.1 a firm and level working surface;

.2 a working area providing clear sight of twistlock handles and allowing for the
manipulation of lashing gear. This should preferably be 1 m in width, excluding
lashings in place, but not less than 750 mm wide;

.3 sufficient standing area to permit the lashing gear and other equipment to be
stowed without causing a tripping hazard;

.4 sufficient standing area with a minimum of 300 mm between the adjacent fixing
points of the lashing bars on deck, or on the hatch covers, to tighten the
turnbuckles;

.5 safe access to hatch coamings, lashing platforms and other working areas;

.6 protective fencing on lashing platform;

.7 adequate lighting in line with these guidelines (see 7.4); and

.8 suitable siting to enable the turnbuckles to be readily reached both vertically and
horizontally from the platform.

7.1.4 Platforms for lashing outboard containers should provide a working area of at
least 750 mm between stacks or from the stack if at the end and at least 500 mm from
deck cleats.

7.1.5 Portable or removable lashing platforms should be at least 1 m wide, wherever possible,
but in no case should they be less than 750 mm wide. The design should take into account
whether one, two or three high lashings may be required. The platform should be sufficiently
strengthened to prevent springing or warping. Any removable sections of the platform should be
capable of being temporarily secured to prevent them falling.

7.1.5.1 For the purpose of identifying the standard placement of lashing rods to the stow, the
first tier is determined by the position of the turnbuckle whether it is directly on deck or on the
lashing bridge.

7.1.5.2 One-high lashing rods should be attached to the upper corner fitting of the first tier
containers.

7.1.5.3 Two-high lashing rods may be attached to the lower corner fitting of the second tier
containers.
I:\DSC\13\8.doc
DSC 13/8
ANNEX 2
Page 6

7.1.5.4 Three-high lashing rods should be attached to the lower corner fitting of the three-high
container from the position of the turnbuckle whether it is directly on deck or on the platform.

7.1.5.5 It can be dangerous for those who unlash to use such rods in any other than the way
intended.

7.1.6 Ship designers should aim to eliminate the need to access and work on the tops of deck
stows.

7.2 Provisions for safe access

7.2.1 General provisions

7.2.1.1 The minimum clearance for transit areas should be 2.1 m high and 600 mm wide.

7.2.1.2 All relevant deck surfaces used for movement about the ship and all stairs should have
non-slip surfaces.

7.2.1.3 Where necessary for safety, walkways on deck should be delineated by painted lines or
otherwise marked by pictorial signs.

7.2.1.4 All protrusions in accessways, such as cleats, ribs and brackets that may give rise to a
trip hazard should be highlighted in a contrasting colour.

7.2.2 Lashing bridge design

7.2.2.1 Lashing bridges should be designed to take into account:

.1 the demand of the lashing/unlashing task;

.2 the movement required;

.3 the tools that need to be used;

.4 the fact that in most circumstances two workers may be working together;

.5 the need for containers to be stowed within safe reach of the personnel using the
bridge so that the horizontal distance from the closest point of the bridge to the
container fitting to be secured does not exceed 1 m on all ships. On all ships the
distance should not be less than 220 mm; and

.6 the work area size and the size of the securing components used.

7.2.2.2 Bridges designed to eliminate or greatly reduce the use of three high lashing bars and
provide efficient vertical stowage of the bars are preferred. They should be designed to provide a
clear work area, unencumbered by deck piping and other obstructions. For example, a design of
a three-high bridge would provide added protection for lashing personnel, uniform, adequate and
physically protected lighting as well as eliminating the need for unlocking containers 5 to 7 high
from above. The lashing as well as unlocking SATLs, anchoring lashing gear and/or
plugging/unplugging three high reefers would be carried out at the second and third level.
I:\DSC\13\8.doc
 DSC 13/8
ANNEX 2
Page 7

7.2.2.3 The width of permanent lashing bridges should be:

• 750 mm between railings; and

• a clear minimum of 600 mm between storage racks, lashing cleats and any other
obstruction.

7.2.2.4 Appropriate toe boards (or kick plates) at least 150 mm high should be provided around
the sides of all platforms to prevent securing equipment from falling and injuring personnel.

7.2.2.5 There should be no obstructions such as lashing bar storage bins or guides to land hatch
lids on working platforms – see 7.3.5.

7.2.3 Fencing design

7.2.3.1 Bridges and elevated platforms, where appropriate, should be fenced. As a minimum,
the design of the fencing should provide:

.1 sufficient strength and height to prevent workers from falling;

.2 flexibility in positioning the fencing of gaps. A horizontal unfenced gap should

not be greater than 300 mm;

.3 suitable provisions for locking and removal of fencing, if its removal is necessary
for operational reasons;

.4 prevention of damage to fencing and the prevention of failure of the fencing due
to such damage; and

.5 adequate strength of any temporary fittings. These should be capable of being

safely and securely installed.

7.2.3.2 The top rail of fencing should be 1 m high from the base with an intermediate rail
at 500 mm.

7.2.3.3 Handrails and grabrails (handles) should be highlighted in a contrasting colour to the
background.

7.2.3.4 Athwartships cargo securing walkways should be protected by adequate removable

fencing where it is possible to fall from an unguarded edge when a hatch cover is removed.

7.2.4 Ladder and manhole design

In this section, the reference to platforms should also be taken to refer to lashing bridges where
relevant.

7.2.4.1 Where a fixed ladder gives access to the outside of a platform, the stringers should be
connected at their extremities to the guardrails of the platform, irrespective of whether the ladder
is sloping or vertical.

I:\DSC\13\8.doc
DSC 13/8
ANNEX 2
Page 8

7.2.4.2 Where a fixed ladder gives access to a platform through an opening in the platform, the
opening shall be protected with either a fixed grate with a lockback mechanism, which can be
closed after access, or fencing. Grabrails should be provided to ensure safe access through the
opening.

7.2.4.3 Where a fixed ladder gives access to a platform from the outside of the platform, the
stringers of the ladder should be opened above the platform level to give a clear width
of 700 to 750 mm to enable a person to pass through the stringers.

7.2.4.4 A fixed ladder should not slope at an angle greater than 15° from the vertical.

7.2.4.5 A toe hold of at least 150 mm should be provided.

7.2.4.6 A fixed vertical ladder of height exceeding 3 m, and any fixed ladder less than 3 m high,
from which a person may fall into a hold should be fitted with a fall arrest device or, where this is
not practicable, guard hoops. The ladder hoops should be uniformly spaced at intervals not
exceeding 900 mm and should have a clearance of 750 mm from the rung to the back of the
hoop. The hoops should be connected by longitudinal strips that are equally spaced round the
circumference of the hoops and secured to the inside of them.

7.2.4.7 The stringers should be carried above the floor level of the platform by at least 1 m. The
ends of the stringers should be given lateral support and the top step or rung should be level with
the floor of the platform unless the steps or rungs are fitted to the ends of the stringers.

7.2.4.8 Whenever practicable, access ladders, walkways and work platforms should be designed
so that workers do not have to climb over piping or work in areas with permanent obstructions.

7.2.4.9 There should be no unprotected openings in any part of the workplace where a person
might fall and be injured. Access openings should be protected with handrails or access covers
that can be locked back during access.

7.2.4.10 As far as practicable, manholes should not be situated in transit areas. However, if they
are, they should be protected by secure fencing.

7.2.4.11 Access manholes should be large enough for persons to safely enter and leave and
fitted with fall protection.

7.2.4.12 Handholds should be provided at the top of the ladder to enable safe access to the
platform to be gained.

7.2.4.13 Manhole openings that may present a fall hazard should be highlighted in contrasting
colour around the rim of the opening.

7.2.4.14 Manhole openings at different levels of the lashing bridge should not be located
directly below one another.

I:\DSC\13\8.doc
 DSC 13/8
ANNEX 2
Page 9

7.3 Lashing systems

7.3.1 General provisions

Lashing systems, including tensioning devices, should:

.1 conform to ISO 3874, Annex A-D;

.2 be compatible with the planned container stowages;

.3 be compatible with the physical ability of persons to safely hold, deploy and use
such equipment;

.4 be uniform and compatible, e.g., semi-automatic twistlocks should only be used

with suitable lashing rods, such as swivel headed rods, and should be subject to a
periodic inspection and maintenance regime. Non-conforming items should be
segregated for repair or disposal; and

.5 as designated by the CSM.

7.3.2 Twistlock design

7.3.2.1 Shipowners should ensure that the number of different types of twistlocks specified in
the CSM is kept to a minimum. The twistlocks provided should be as provided for by CSM.

7.3.2.2 The design of twistlocks specified in the CSM should ensure:

.1 positive locking;

.2 clear up and down orientation identification;

.3 dislodgement of a twistlock from a corner fitting is not possible even when

grazing a surface;

.4 access and visibility of the unlocking device is effective in operational situations;

.5 unlocked positions are easily identifiable;

.6 twistlocks do not relock inadvertently due to jolting or vibration; and

.7 unlocking poles are as light as possible, of a simple design for ease of use and user
friendly.

7.3.2.3 Where it is not feasible to entirely eliminate working on the tops of container stows, the
twistlock designs used should minimize the need for such working, e,g., use of SATLs or similar
design.

I:\DSC\13\8.doc
DSC 13/8
ANNEX 2
Page 10

7.3.3 Lashing rod design

7.3.3.1 The design of containership securing systems should take into account the practical
abilities of the workers to lift, reach, hold, control and connect the components called for in all
situations anticipated in the cargo securing plan.

7.3.3.2 The maximum length of a lashing rod, which is sufficient to reach the lower corner of a
high cube container on the third tier, should be 5,200 mm.

7.3.3.3 The weight of lashing rods should be as low as possible, consistent with the necessary
mechanical strength.

7.3.3.4 The head of a lashing rod that is to be inserted into a corner fitting should be designed
with a pivot/hinge or other appropriate device so that it does not come out of the corner fitting
accidentally if the rod is left hanging vertically.

7.3.3.5 The design of the lashing rods should be compatible with the twistlocks to be used on
the ship and should not adversely impede their effectiveness.

7.3.3.6 The length of a lashing rod in conjunction with the length and design of a turnbuckle
should be such that the need for extensions is eliminated when lashing high cube (9'6")
containers.

7.3.3.7 Lightweight rods should be provided where special tools are needed to enable them to be
lifted and fitted into the corners of high cube containers.

7.3.3.8 Lashing rods should be those specified in the CSM. Additional lashing rods not
specified by the ship’s CSM should not be allowed.

7.3.3.9 Extension tools should not be specified in the CSM for use on three-high lashing rods.

7.3.4 Turnbuckle design

7.3.4.1 Turnbuckle end fittings should be designed to harmonize with the design of lashing rods.

7.3.4.2 Turnbuckles should have a double screw design or similar to minimize the number of
rotations needed to tighten the lashing rods.

7.3.4.3 The anchor point location on the platform, lashing bridge or hatch cover for each
turnbuckle should be staggered from the next anchor point by a distance no less than the
thickness of the lashing rod. This ensures there is no lateral pressure where the two opposing
lashing rods meet when tightened. Such pressure may cause the rods to bend and spring out
when released.

7.3.4.4 To prevent hand injury during tightening or loosening motions, there should be a
minimum distance of 70 mm between turnbuckles. The use of a turnbuckle capable of saddling
two lashing rods eliminates the problem and reduces overall handling, however such an
arrangement should not be used unless specifically included in the CSM.

I:\DSC\13\8.doc
 DSC 13/8
ANNEX 2
Page 11

7.3.4.5 The turnbuckle or bottle screw should incorporate a locking mechanism which will
ensure that the lashing does not work loose during the voyage.

7.3.4.6 It should be borne in mind that rectangular framed turnbuckles or bottle screws covered
with grease are difficult to handle when tightening.

7.3.5 Storage bins and lashing equipment stowage design

7.3.5.1 All lashing gear should be stowed as close to its intended place of use as possible. The
stowage of lashing rods and turnbuckles should be arranged so they can easily be retrieved from
their stowage location by lifting from one end.

7.3.5.2 Bins or stowage places for lashing materials should be provided.

7.3.5.3 Bins for faulty or damaged gear should also be provided and appropriately marked.

7.3.5.4 Bins should be of sufficient height for easy access, use and handling.

7.3.5.5 Bins should be of sufficient strength for the environment.

7.3.5.6 Bin racks or platforms should be of sufficient design to be lifted off the vessel and
restowed in a single lift.

7.4 Lighting design

7.4.1 The ship’s lighting plan should provide for:

.1 illumination designed, where possible, as a permanent installation, adequately

guarded against breakage utilization. The illumination intensity should take into
consideration the distance to the uppermost reaches where cargo securing
equipment is used;

.2 the proper illumination of access ways at not less than 10 lux (1 foot candle),
taking into account the shadows created by containers that may be stowed in the
area to be lit, for example different length containers in or over the work area;

.3 a separate fixed lighting system for each working space between the container
bays at not less than 50 lux (5 foot candles), which is bright enough for the work
to be done, but minimizes glare to the deck workers.

8 OPERATIONS WITH REFRIGERATED CONTAINERS

8.1 Reefer Power Outlets should be interlocked so that the plug cannot be inserted into or
removed from the receptacle unless the power to the receptacle is secured. Shipboard outlets
should provide a safe, watertight electrical connection.

8.2 Reefer power outlets should be protected by an appropriately sized circuit breaker.

I:\DSC\13\8.doc
DSC 13/8
ANNEX 2
Page 12

8.3 The reefer power circuit should de-energize automatically if the plug is accidentally
withdrawn while in the “On” position. Also, the interlock mechanism should break the circuit
while the pin and sleeve contacts are still engaged. This provides total operator safety and
protection against shock hazard while eliminating arcing damage to the plug and receptacle.

8.4 The operator should not stand directly in front of the socket when switching takes place.
Reefer power outlets should be designed to ensure that this is not possible.

8.5 Cables should be laid out in such a way as to avoid causing a tripping hazard and should
be safely stowed. The positioning of the reefer outlets should allow for this to take place.

8.6 Special ducts should be provided to lay the reefer cables in and protect them from lashing
equipment falling on them during lashing operations.

8.7 Defective or inoperative reefer plugs/electrical banks should be identified and confirmed
as “locked out/tagged out” by the vessel.

8.8 The operator should check that the power is off before attempting to connect or
disconnect.

***

I:\DSC\13\8.doc
 DSC 13/8

ANNEX 3

DRAFT AMENDMENTS TO THE CODE OF SAFE PRACTICE

FOR CARGO STOWAGE AND SECURING (CSS CODE)

DRAFT NEW ANNEX […]

GUIDANCE ON PROVIDING SAFE WORKING CONDITIONS

FOR SECURING OF CONTAINERS

Part B – Existing ships

1 AIM

The aim of this Annex is to ensure that persons engaged in carrying out container securing
operations on purpose-built containerships have safe working conditions and, in particular safe
access, appropriate securing equipment and safe places of work. These guidelines should be
taken into account at the design stage when securing systems are devised or are retrofitted or
modified on existing containerships. These guidelines provide shipowners, shipbuilders,
classification societies, Administrations and ship designers with guidance on producing and
authorizing a Cargo Safe Access Plan.

2 SCOPE

This Part applies to all ships built after [insert 10 years before the effective date] that were
designed or subsequently adapted for the purpose of carrying containers.

3 DEFINITIONS

3.1 Administration means the Government of the State whose flag the ship is entitled to fly.

3.2 Securing includes unsecuring.

3.3 Lashing positions include positions:

• in between container stows on hatch covers;

• at the end of hatches;
• on outboard lashing stanchions; and
• outboard lashing positions on hatch covers.

3.4 SATLs are semi-automatic twistlocks.

3.5 Securing includes unsecuring.

3.6 Stringers are the uprights or sides of a ladder.

3.7 Turnbuckles and lashing rods (ISO 3874, Annex D Lashing rod systems and tensioning
devices) include similar cargo securing devices.

I:\DSC\13\8.doc
DSC 13/8
ANNEX 3
Page 2

4 GENERAL

4.1 Introduction

4.1.1 Injuries to dockworkers on board visiting ships account for the majority of accidents that
occur within container ports. The most common activity that involves such injuries is the lashing
and unlashing of deck containers. Ships’ crew engaged in cargo related activities face similar
dangers.

4.1.2 During the design and construction of containerships the provision of a safe place of work
for lashing personnel is essential.

4.1.3 Containership owners and designers are reminded of the inherent dangers associated with
container securing operations and are urged to develop and use container securing systems that
are safe by design. The aim should be to eliminate or at least minimize the need for:

.1 container top work;

.2 work in other equally hazardous locations; and

.3 the handling of heavy and unwieldy securing equipment by lashing personnel.

4.1.4 It should be borne in mind that providing safe working conditions for securing containers
includes consideration of matters relating to design, operation and maintenance, and that the
problems on large containerships are not the same as those on small containerships.

4.1.5 Administrations should ensure that the Cargo Safe Access Plan is maintained and
enforced throughout the life of the ship.

4.2 Recommendations on safety of personnel during container securing operations

(MSC/Circ.886)

4.2.1 Initial shipowners should specify the intended container loading/unloading patterns prior
to concluding the building contract with ship designers and builders. Ship designers and builders
should take into account the container operation specified by the owner. Administrations should
ensure that all concerned parties take into account the recommendations on safe design of
securing arrangements contained in these guidelines and in the Recommendations on safety of
personnel during container securing operations (MSC/Circ.886).

4.3 Cargo Safe Access Plan (CSAP)

4.3.1 The CSS Code requires ships that are specifically designed and fitted to carry containers
to have an approved CSAP on board. This should cover all areas where containers may be
secured.

4.3.2 Stakeholders, including, but not limited to shipowners, ship designers, shipbuilders,
administrations, classification societies and lashing equipment manufacturers, should be involved
at an early stage in the design of securing arrangements on containerships and in the development
of the CSAP:

I:\DSC\13\8.doc
 DSC 13/8
ANNEX 3
Page 3

.1 if a shipowner has a specific intended loading/unloading pattern, it should be

clearly stated in the building contract;

.2 if there is any restriction on the loading/unloading operation imposed by the

specific design, the designers/builders concerned should notify such restriction to
the shipowner; and

.3 Administrations should ensure that all concerned parties have a common

understanding of the intended loading/unloading patterns and restrictions that may
be imposed by the design.

4.3.3 The CSAP should be developed at the design stage in accordance with chapter 5 of the
annex to MSC/Circ.[...].

4.3.4 Designers should incorporate the recommendations of this annex into the CSAP so that
safe working conditions can be maintained during all anticipated configurations of container
stowage.

4.3.5 Compliance with these recommendations should be stated in the CSAP.

5 SAFE ACCESS AND CARGO SECURING REQUIREMENTS

5.1 Administrations should ensure that:

.1 lashing plans contained within the approved Cargo Securing Manual (CSM) are
compatible with the current design of the ship and that the intended container
securing method is both safe and physically possible;

.2 the CSM, lashing plans and the CSAP are kept up-to-date when there is a change
to the lashing plans; and

.3 lashing plans are compatible with the equipment available.

5.2 Shipowners and ship management companies should ensure that:

.1 portable cargo securing devices are certified and assigned a maximum securing
load (MSL). The MSL should be documented in the CSM as required by
the CSS Code;

.2 the operational recommendations of this Annex are complied with; and

.3 incompatible and unauthorized equipment and unsafe conditions are not used.

6 RESPONSIBILITIES

6.1 Shipowners

Shipowners should follow the design recommendations of these guidelines and seek to
implement them to the best practicable extent on existing ships.

I:\DSC\13\8.doc
DSC 13/8
ANNEX 3
Page 4

7 DESIGN

7.1 General design considerations

7.1.1 Risk assessments should be performed at the design stage to ensure that securing
operations can be safely carried out in all the anticipated container configurations for the ship
taking into account operational matters and the recommendations of this Annex. These
assessments should be carried out before or during the development of the CSAP. Hazards to be
assessed should include:

.1 slips, trips and falls;

.2 falls from height;

.3 injuries whilst manually handling lashing gear;

.4 being struck by falling lashing gear or other objects;

.5 potential damage due to container operations. High risk areas should be identified
in order to develop appropriate protection or other methods of preventing
significant damage;

.6 adjacent electrical risks (refrigeration cable connections, etc.);

.7 the adequacy of the access to all areas that is necessary to safely perform container
securing operations;

.8 ergonomics of handling lashing equipment; and

.9 implications of lashing 9'6" high, or higher, containers and mixed stows

of 40' and 45' containers.

7.1.2 Shipbuilders and ship designers should collaborate with designers of securing equipment
in conducting risk assessments and ensure that the design ensures that container securing
operations performed at lashing positions can be carried out safely. As a minimum, a platform
should be provided on which to work safely. This platform should have fencing to prevent
workers falling off it. The dimensions and other criteria of the platform should be as specified
in 7.1.3 below. Dimensions and other criteria of lashing bridges should be as specified in 7.2.2.

7.1.3 The space between the container stows that will be used by personnel to carry out lashing
operations should provide:

.1 a firm and level working surface;

.2 a working area providing clear sight of twistlock handles and allowing for the
manipulation of lashing gear. This should preferably be 1 m in width, excluding
lashings in place, but not less than 750 mm wide;

.3 sufficient standing area to permit the lashing gear and other equipment to be
stowed without causing a tripping hazard;

I:\DSC\13\8.doc
 DSC 13/8
ANNEX 3
Page 5

.4 sufficient standing area with a minimum of 300 mm between the adjacent fixing
points of the lashing bars on deck, or on the hatch covers, to tighten the
turnbuckles;

.5 safe access to hatch coamings, lashing platforms and other working areas;

.6 protective fencing on lashing platform;

.7 adequate lighting in line with these guidelines (see 7.4); and

.8 suitable siting to enable the turnbuckles to be readily reached both vertically and
horizontally from the platform.

7.1.4 Platforms for lashing outboard containers should provide a working area of at
least 750 mm between stacks or from the stack if at the end and at least 500 mm from
deck cleats.

7.1.5 Portable or removable lashing platforms should be at least 1 m wide, wherever possible,
but in no case should they be less than 750 mm wide. The design should take into account
whether one, two or three high lashings may be required. The platform should be sufficiently
strengthened to prevent springing or warping. Any removable sections of the platform should be
capable of being temporarily secured to prevent them falling.

7.1.5.1 For the purpose of identifying the standard placement of lashing rods to the stow, the
first tier is determined by the position of the turnbuckle whether it is directly on deck or on the
lashing bridge.

7.1.5.2 One-high lashing rods should be attached to the upper corner fitting of the first tier
containers.

7.1.5.3 Two-high lashing rods may be attached to the lower corner fitting of the second tier
containers.

7.1.5.4 Three-high lashing rods should be attached to the lower corner fitting of the three-high
container from the position of the turnbuckle whether it is directly on deck or on the platform.

7.1.5.5 It can be dangerous for those who unlash to use such rods in any other than the way
intended.

7.1.6 Ship designers should aim to eliminate the need to access and work on the tops of deck
stows.

7.2 Provisions for safe access

7.2.1 General provisions

7.2.1.1 The minimum clearance for transit areas should be 2.1 m high and 600 mm wide.

7.2.1.2 All relevant deck surfaces used for movement about the ship and all stairs should have
non-slip surfaces.

I:\DSC\13\8.doc
DSC 13/8
ANNEX 3
Page 6

7.2.1.3 Where necessary for safety, walkways on deck should be delineated by painted lines or
otherwise marked by pictorial signs.

7.2.1.4 All protrusions in accessways, such as cleats, ribs and brackets that may give rise to a
trip hazard should be highlighted in a contrasting colour.

7.2.2 Lashing bridge design

7.2.2.1 Lashing bridges should be designed to take into account:

.1 the demand of the lashing/unlashing task;

.2 the movement required;

.3 the tools that need to be used;

.4 the fact that in most circumstances two workers may be working together;

.5 the need for containers to be stowed within safe reach of the personnel using the
bridge so that the horizontal distance from the closest point of the bridge to the
container fitting to be secured does not exceed 1 m on all ships. On all ships the
distance should not be less than 220 mm; and

.6 the work area size and the size of the securing components used.

7.2.2.2 Bridges designed to eliminate or greatly reduce the use of three high lashing bars and
provide efficient vertical stowage of the bars are preferred. They should be designed to provide a
clear work area, unencumbered by deck piping and other obstructions. For example, a design of
a three-high bridge would provide added protection for lashing personnel, uniform, adequate and
physically protected lighting as well as eliminating the need for unlocking containers 5 to 7 high
from above. The lashing as well as unlocking SATLs, anchoring lashing gear and/or
plugging/unplugging three high reefers would be carried out at the second and third level.

7.2.2.3 The width of permanent lashing bridges should be:

• 750 mm between railings; and

• a clear minimum of 600 mm between storage racks, lashing cleats and any other
obstruction.

7.2.2.4 Appropriate toe boards (or kick plates) at least 150 mm high should be provided around
the sides of all platforms to prevent securing equipment from falling and injuring personnel.

7.2.2.5 There should be no obstructions such as lashing bar storage bins or guides to land hatch
lids on working platforms – see 7.3.5.

I:\DSC\13\8.doc
 DSC 13/8
ANNEX 3
Page 7

7.2.3 Fencing design

7.2.3.1 Bridges and elevated platforms, where appropriate, should be fenced. As a minimum,
the design of the fencing should provide:

.1 sufficient strength and height to prevent workers from falling;

.2 flexibility in positioning the fencing of gaps. A horizontal unfenced gap should

not be greater than 300 mm;

.3 suitable provisions for locking and removal of fencing, if its removal is necessary
for operational reasons;

.4 prevention of damage to fencing and the prevention of failure of the fencing due
to such damage; and

.5 adequate strength of any temporary fittings. These should be capable of being

safely and securely installed.

7.2.3.2 The top rail of fencing should be 1 m high from the base with an intermediate rail
at 500 mm.

7.2.3.3 Handrails and grabrails (handles) should be highlighted in a contrasting colour to the
background.

7.2.3.4 Athwartships cargo securing walkways should be protected by adequate removable

fencing where it is possible to fall from an unguarded edge when a hatch cover is removed.

7.2.4 Ladder and manhole design

In this section, the reference to platforms should also be taken to refer to lashing bridges where
relevant.

7.2.4.1 Where a fixed ladder gives access to the outside of a platform, the stringers should be
connected at their extremities to the guardrails of the platform, irrespective of whether the ladder
is sloping or vertical.

7.2.4.2 Where a fixed ladder gives access to a platform through an opening in the platform, the
opening shall be protected with either a fixed grate with a lockback mechanism, which can be
closed after access, or fencing. Grabrails should be provided to ensure safe access through the
opening.

7.2.4.3 Where a fixed ladder gives access to a platform from the outside of the platform, the
stringers of the ladder should be opened above the platform level to give a clear width
of 700 to 750 mm to enable a person to pass through the stringers.

7.2.4.4 A fixed ladder should not slope at an angle greater than 15° from the vertical.

7.2.4.5 A toe hold of at least 150 mm should be provided.

I:\DSC\13\8.doc
DSC 13/8
ANNEX 3
Page 8

7.2.4.6 A fixed vertical ladder of height exceeding 3 m, and any fixed ladder less than 3 m high,
from which a person may fall into a hold should be fitted with a fall arrest device or, where this is
not practicable, guard hoops. The ladder hoops should be uniformly spaced at intervals not
exceeding 900 mm and should have a clearance of 750 mm from the rung to the back of the
hoop. The hoops should be connected by longitudinal strips that are equally spaced round the
circumference of the hoops and secured to the inside of them.

7.2.4.7 The stringers should be carried above the floor level of the platform by at least 1 m. The
ends of the stringers should be given lateral support and the top step or rung should be level with
the floor of the platform unless the steps or rungs are fitted to the ends of the stringers.

7.2.4.8 Whenever practicable, access ladders, walkways and work platforms should be designed
so that workers do not have to climb over piping or work in areas with permanent obstructions.

7.2.4.9 There should be no unprotected openings in any part of the workplace where a person
might fall and be injured. Access openings should be protected with handrails or access covers
that can be locked back during access.

7.2.4.10 As far as practicable, manholes should not be situated in transit areas. However, if they
are, they should be protected by secure fencing.

7.2.4.11 Access manholes should be large enough for persons to safely enter and leave and fitted
with fall protection.

7.2.4.12 Handholds should be provided at the top of the ladder to enable safe access to the
platform to be gained.

7.2.4.13 Manhole openings that may present a fall hazard should be highlighted in contrasting
colour around the rim of the opening.

7.2.4.14 Manhole openings at different levels of the lashing bridge should not be located directly
below one another.

7.3 Lashing systems

7.3.1 General provisions

Lashing systems, including tensioning devices, should:

.1 conform to ISO 3874, Annex A-D;

.2 be compatible with the planned container stowages;

.3 be compatible with the physical ability of persons to safely hold, deploy and use
such equipment;

.4 be uniform and compatible, e.g., semi-automatic twistlocks should only be used

with suitable lashing rods, such as swivel headed rods, and should be subject to a
periodic inspection and maintenance regime. Non-conforming items should be
segregated for repair or disposal; and

.5 as designated by the CSM.

I:\DSC\13\8.doc
 DSC 13/8
ANNEX 3
Page 9

7.3.2 Twistlock design

7.3.2.1 Shipowners should ensure that the number of different types of twistlocks specified in
the CSM is kept to a minimum. The twistlocks provided should be as provided for by CSM.

7.3.2.2 The design of twistlocks specified in the CSM should ensure:

.1 positive locking;

.2 clear up and down orientation identification;

.3 dislodgement of a twistlock from a corner fitting is not possible even when

grazing a surface;

.4 access and visibility of the unlocking device is effective in operational situations;

.5 unlocked positions are easily identifiable;

.6 twistlocks do not relock inadvertently due to jolting or vibration; and

.7 unlocking poles are as light as possible, of a simple design for ease of use and user
friendly.

7.3.2.3 Where it is not feasible to entirely eliminate working on the tops of container stows, the
twistlock designs used should minimize the need for such working, e.g., use of SATLs or similar
design.

7.3.3 Lashing rod design

7.3.3.1 The design of containership securing systems should take into account the practical
abilities of the workers to lift, reach, hold, control and connect the components called for in all
situations anticipated in the cargo securing plan.

7.3.3.2 The maximum length of a lashing rod, which is sufficient to reach the lower corner of a
high cube container on the third tier, should be 5,200 mm.

7.3.3.3 The weight of lashing rods should be as low as possible, consistent with the necessary
mechanical strength.

7.3.3.4 The head of a lashing rod that is to be inserted into a corner fitting should be designed
with a pivot/hinge or other appropriate device so that it does not come out of the corner fitting
accidentally if the rod is left hanging vertically.

7.3.3.5 The design of the lashing rods should be compatible with the twistlocks to be used on
the ship and should not adversely impede their effectiveness.

7.3.3.6 The length of a lashing rod in conjunction with the length and design of a turnbuckle
should be such that the need for extensions is eliminated when lashing high cube (9'6")
containers.

I:\DSC\13\8.doc
DSC 13/8
ANNEX 3
Page 10

7.3.3.7 Lightweight rods should be provided where special tools are needed to enable them to be
lifted and fitted into the corners of high cube containers.

7.3.3.8 Lashing rods should be those specified in the CSM. Additional lashing rods not
specified by the ship’s CSM should not be allowed.

7.3.3.9 Extension tools should not be specified in the CSM for use on three-high lashing rods.

7.3.4 Turnbuckle design

7.3.4.1 Turnbuckle end fittings should be designed to harmonize with the design of lashing rods.

7.3.4.2 Turnbuckles should have a double screw design or similar to minimize the number of
rotations needed to tighten the lashing rods.

7.3.4.3 The anchor point location on the platform, lashing bridge or hatch cover for each
turnbuckle should be staggered from the next anchor point by a distance no less than the
thickness of the lashing rod. This ensures there is no lateral pressure where the two opposing
lashing rods meet when tightened. Such pressure may cause the rods to bend and spring out
when released.

7.3.4.4 To prevent hand injury during tightening or loosening motions, there should be a
minimum distance of 70 mm between turnbuckles. The use of a turnbuckle capable of saddling
two lashing rods eliminates the problem and reduces overall handling, however such an
arrangement should not be used unless specifically included in the CSM.

7.3.4.5 The turnbuckle or bottle screw should incorporate a locking mechanism which will
ensure that the lashing does not work loose during the voyage.

7.3.4.6 It should be borne in mind that rectangular framed turnbuckles or bottle screws covered
with grease are difficult to handle when tightening.

7.3.5 Storage bins and lashing equipment stowage design

7.3.5.1 All lashing gear should be stowed as close to its intended place of use as possible. The
stowage of lashing rods and turnbuckles should be arranged so they can easily be retrieved from
their stowage location by lifting from one end.

7.3.5.2 Bins or stowage places for lashing materials should be provided.

7.3.5.3 Bins for faulty or damaged gear should also be provided and appropriately marked.

7.3.5.4 Bins should be of sufficient height for easy access, use and handling.

7.3.5.5 Bins should be of sufficient strength for the environment.

7.3.5.6 Bin racks or platforms should be of sufficient design to be lifted off the vessel and
restowed in a single lift.

I:\DSC\13\8.doc
 DSC 13/8
ANNEX 3
Page 11

7.4 Lighting design

7.4.1 The ship’s lighting plan should provide for:

.1 illumination designed, where possible, as a permanent installation, adequately

guarded against breakage utilization. The illumination intensity should take into
consideration the distance to the uppermost reaches where cargo securing
equipment is used;

.2 the proper illumination of access ways at not less than 10 lux (1 foot candle),
taking into account the shadows created by containers that may be stowed in the
area to be lit, for example different length containers in or over the work area; and

.3 a separate fixed lighting system for each working space between the container
bays at not less than 50 lux (5 foot candles), which is bright enough for the work
to be done, but minimizes glare to the deck workers.

8 OPERATIONS WITH REFRIGERATED CONTAINERS

8.1 Reefer Power Outlets should be interlocked so that the plug cannot be inserted into or
removed from the receptacle unless the power to the receptacle is secured. Shipboard outlets
should provide a safe, watertight electrical connection.

8.2 Reefer power outlets should be protected by an appropriately sized circuit breaker.

8.3 The reefer power circuit should de-energize automatically if the plug is accidentally
withdrawn while in the “On” position. Also, the interlock mechanism should break the circuit
while the pin and sleeve contacts are still engaged. This provides total operator safety and
protection against shock hazard while eliminating arcing damage to the plug and receptacle.

8.4 The operator should not stand directly in front of the socket when switching takes place.
Reefer power outlets should be designed to ensure that this is not possible.

8.5 Cables should be laid out in such a way as to avoid causing a tripping hazard and should
be safely stowed. The positioning of the reefer outlets should allow for this to take place.

8.6 Special ducts should be provided to lay the reefer cables in and protect them from lashing
equipment falling on them during lashing operations.

8.7 Defective or inoperative reefer plugs/electrical banks should be identified and confirmed
as “locked out/tagged out” by the vessel.

8.8 The operator should check that the power is off before attempting to connect or
disconnect.

***

I:\DSC\13\8.doc
 DSC 13/8

ANNEX 4

DRAFT AMENDMENTS TO THE CODE OF SAFE PRACTICE

FOR CARGO STOWAGE AND SECURING (CSS CODE)

DRAFT NEW ANNEX […]

GUIDANCE ON PROVIDING SAFE WORKING CONDITIONS

FOR SECURING OF CONTAINERS

Part C – Operational aspects

1 AIM

The aim of this Annex is to ensure that persons engaged in carrying out container securing
operations on purpose-built containerships have safe working conditions and, in particular safe
access, appropriate securing equipment and safe places of work. These guidelines should be
taken into account at the design stage when securing systems are devised or are retrofitted or
modified on existing containerships. These guidelines provide shipowners, shipbuilders,
classification societies, Administrations and ship designers with guidance on producing and
authorizing a Cargo Safe Access Plan.

2 SCOPE

This Annex applies to all ships which are specifically designed and fitted for the purpose of
carrying containers.

3 DEFINITIONS

3.1 Administration means the Government of the State whose flag the ship is entitled to fly.

3.2 Fencing is a generic term for guardrails, safety rails, safety barriers and similar structures
that provide protection against the falls of persons.

3.3 Lashing positions include positions:

• in between container stows on hatch covers;

• at the end of hatches;
• on outboard lashing stanchions; and
• outboard lashing positions on hatch covers.

3.4 SATLs are semi-automatic twistlocks.

3.5 Securing includes unsecuring.

3.6 Stringers are the uprights or sides of a ladder.

3.7 Turnbuckles and lashing rods (ISO 3874, Annex D Lashing rod systems and tensioning
devices) include similar cargo securing devices.

I:\DSC\13\8.doc
DSC 13/8
ANNEX 4
Page 2

4 GENERAL

4.1 Introduction

4.1.1 Injuries to dockworkers on board visiting ships account for the majority of accidents that
occur within container ports. The most common activity that involves such injuries is the lashing
and unlashing of deck containers. Ships’ crew engaged in cargo related activities face similar
dangers.

4.1.2 During the design and construction of containerships, the provision of a safe place of
work for lashing personnel is essential.

4.1.3 Containership owners and designers are reminded of the inherent dangers associated with
container securing operations and are urged to develop and use container securing systems that
are safe by design. The aim should be to eliminate or at least minimize the need for:

.1 container top work;

.2 work in other equally hazardous locations; and

.3 the handling of heavy and unwieldy securing equipment by lashing personnel.

4.1.4 It should be borne in mind that providing safe working conditions for securing containers
includes consideration of matters relating to design, operation and maintenance, and that the
problems on large containerships are not the same as those on small containerships.

5 RESPONSIBILITIES

5.1 Shipowners and operators

Shipowners and operators should ensure that:

.1 the guidelines of this Annex are complied with; and

.2 incompatible and unauthorized equipment and unsafe conditions are not used.

5.2 Container terminal employers and operators

Container terminal employers and operators should ensure that the relevant parts of these
guidelines are complied with.

6 OPERATIONAL AND MAINTENANCE PROCEDURES

Procedures for safe lashing and securing operations should be included in the ship’s CSAP.

6.1 Container deck working

6.1.1 Transit areas should be safe and clear of cargo and all equipment.

6.1.2 Any necessarily unprotected openings in work platforms (i.e. where there might be a fall
potential of less than 2 m) and gaps and apertures on deck should be appropriately highlighted.
I:\DSC\13\8.doc
 DSC 13/8
ANNEX 4
Page 3

6.1.3 The use of fencing is essential to prevent falls. When openings in safety barriers are
necessary to allow container crane movements, particularly with derricking cranes, removable
fencing should be used whenever possible.

6.1.4 When writing the CSM and the CSAP, it should be taken into account that lashing bars
can weigh between 11 and 21 kg and turnbuckles between 16 and 23 kg and that there will be a
risk of injury if they are handled above shoulder height with the arms extended. When this is
necessary, personnel should work in pairs whenever practicable in order to reduce the individual
workload in securing the lashing gear.

6.1.5 When it is necessary to handle such heavy weights, workers should follow the accepted
principles of kinetic handling by the use of their body weight to raise the bar to an upright
position which will allow the large muscles of the legs to take most of the weight while keeping a
firm grip and a straight back.

6.1.6 Personnel engaged in containership cargo operations should wear appropriate personal
protective equipment (PPE) while carrying out lashing operations.

6.1.7 Personnel engaged in containership cargo operations should be familiarized with the
ship’s layout, unique characteristics and potential hazards arising from such operations necessary
to carry out their duties.

6.1.8 Containers should not be stowed in spaces configured for larger sized containers unless
they can be adequately secured. This securing methodology should be described in the ship’s
approved CSM.

6.1.9 Manual twist locks should not be used to secure containers stowed on deck above the first
tier. It is acceptable to use manual twist locks to secure containers to the hatch cover on the
bottom tier.

6.1.10 Clear instructions should be provided for the use of twistlocks specified in the CSM.

6.1.11 Twistlock types not specified in the CSM should not be used.

6.2 Container top working

6.2.1 Safe means of access should be provided when it is necessary to carry out work on the
tops of container stows on deck.

6.2.2 Industry best practice involves the use of a safety cage lifted by a spreader to minimize
the risk to personnel.

6.2.3 A safe method of work should be developed and implemented to ensure the safety of
lashers when on the top of container stows on deck. Where practical, the use of fall prevention
equipment should take precedence over fall arrest equipment.

I:\DSC\13\8.doc
DSC 13/8
ANNEX 4
Page 4

6.3 Maintenance

6.3.1 In line with section 2.3 (Inspection and maintenance schemes) of the Revised Guidelines
for the preparation of the Cargo Securing Manual (MSC/Circ.[...]) all ships should maintain a
record book, which should contain the procedures for accepting, maintaining and repairing or
rejecting cargo securing devices. The record book should also contain a record of all such
inspections. The record book should be made available to the terminal facility and labour
representative when required.

6.3.2 Lighting should be properly maintained.

6.3.3 Walkways, ladders, stairways and fencings should be subject to a periodic maintenance
programme to minimize corrosion and prevent subsequent collapse.

6.3.4 Corroded walkways, ladders, stairways and fencings should be repaired or replaced as
soon as practicable. The repairs should be effected immediately if the corrosion could prevent
safe operations.

6.4 Containership inspection

6.4.1 As directed by national laws and enforcement authorities, the Master of the ship and the
terminal employer and/or berth operator should:

.1 ensure that the workplace is safe for their employees to work in;

.2 ensure that an onboard safety inspection is completed by a competent person prior

to cargo operations commencing. This inspection should take place jointly with
an appropriate ships representative;

.3 make provision for any discrepancies found during this inspection to be reported
to the ship’s owners and operators. A simple vessel condition report may be used
for this purpose; and

.4 advise the Port State Control Authority for the port concerned if the defects are
not rectified within a suitable period of time.

6.4.2 Terminal employers and/or operators should:

.1 inform their relevant employees of any unique conditions and potential hazards
aboard the ship to be worked. This information may be passed to the workforce in
the form of gangway safety talks before work commences.

6.5 Failure to provide safe lashing stations on board

6.5.1 For lashing and unlashing locations where no fall protection, such as adequate handrails
or other suitable provision, is provided, and no other safe method can be found, the containers
should not be lashed or unlashed. The situation should be reported immediately to a shoreside
supervisor and the Master or cognisant deck officer and reference made to the CSAP.

I:\DSC\13\8.doc
 DSC 13/8
ANNEX 4
Page 5

6.5.2 If protective systems cannot be designed, adapted or retrofitted to provide safe protected
access and lashing work positions in all every configurations, cargo should not be stowed in
those locations not safely protected. Neither crew nor shore workers should be subjected to
hazardous working conditions in the normal course of securing cargo.

7 OPERATIONS WITH REFRIGERATED CONTAINERS

7.1 Reefer Power Outlets should be interlocked so that the plug cannot be inserted into or
removed from the receptacle unless the power to the receptacle is secured. Shipboard outlets
should provide a safe, watertight electrical connection.

7.2 Reefer power outlets should be protected by an appropriately sized circuit breaker.

7.3 The reefer power circuit should de-energize automatically if the plug is accidentally
withdrawn while in the “On” position. Also, the interlock mechanism should break the circuit
while the pin and sleeve contacts are still engaged. This provides total operator safety and
protection against shock hazard while eliminating arcing damage to the plug and receptacle.

7.4 The operator should not stand directly in front of the socket when switching takes place.
Reefer power outlets should be designed to ensure that this is not possible.

7.5 Cables should be laid out in such a way as to avoid causing a tripping hazard and should
be safely stowed. The positioning of the reefer outlets should allow for this to take place.

7.6 Special ducts should be provided to lay the reefer cables in and protect them from lashing
equipment falling on them during lashing operations.

7.7 Defective or inoperative reefer plugs/electrical banks should be identified and confirmed
as “locked out/tagged out” by the vessel.

7.8 The operator should check that the power is off before attempting to connect or
disconnect.

8 TRAINING

8.1 Personnel engaged in cargo securing operations should be trained in the lashing and
unlashing of containers as necessary to carry out their duties in a safe manner. This should
include the different types of lashing equipment that are expected to be used.

8.2 Personnel engaged in cargo securing operations should be trained in the identification and
handling of bad order or defective securing gear in accordance with each ship’s procedures to
ensure damaged gear is segregated for repair and maintenance or disposal.

8.3 Personnel engaged in cargo securing operations should be trained to develop the
knowledge and mental and physical manual handling aptitudes that they require to do their job
safely and efficiently, and to develop general safety awareness to recognize and avoid potential
dangers.

8.4 Training should include awareness of potentially dangerous situations in order to identify
and avoid hazards.
I:\DSC\13\8.doc
DSC 13/8
ANNEX 4
Page 6

8.5 Personnel should be trained in safe systems of work. Where personnel are involved in
working at heights, they should be trained in the use of relevant equipment. Where practical, the
use of fall protection equipment should take precedence over fall arrest systems.

8.6 Personnel and their supervisors required to secure containers should be trained in the
reading and understanding of the CSAP.

8.7 Training should also be provided on the importance of providing updated information to
ensure the CSAP is correct and current.

8.8 Personnel who are required to handle reefer cables and/or connect and disconnect reefer
units should be given training in recognizing defective cables, receptacles and plugs.

___________

I:\DSC\13\8.doc