Crew and labour

The five steps of a shipboard risk assessment and the order of preventive measures (MLC Standard A4.3 and the ILO guidelines)

MLC, 2006 Standard A4.3 treats risk evaluation not as a separate document but as part of the occupational safety and health policy and programme. How it is done, the Convention text does not say. That gap is filled by the guidelines the ILO issued in 2014 for implementing the OSH provisions of the MLC.

The guidelines are not the Convention. They are a document the flag State draws on when it develops national guidelines under Regulation 4.3, paragraph 2. This article therefore keeps apart what the Convention text requires and what the ILO guidelines recommend.

The skeleton is the five steps the guidelines set out. What has to be written at each step, and what order to follow when choosing measures.

Risk evaluation is required by Standard A4.3 and rests on statistics

(a) the adoption and effective implementation and promotion of occupational safety and health policies and programmes on ships that fly the Member’s flag, including risk evaluation as well as training and instruction of seafarers;

Standard A4.3, paragraph 1(a). The first subject flag State law has to cover is the safety and health policy and programme, and risk evaluation sits inside it (including). A policy document with no risk evaluation does not fill this subparagraph.

The competent authority shall require that shipowners conducting risk evaluation in relation to management of occupational safety and health refer to appropriate statistical information from their ships and from general statistics provided by the competent authority.

Paragraph 8 fixes who does it and on what basis. The party conducting risk evaluation is the shipowner, and the basis is statistics from its own ships and general statistics provided by the competent authority. Statistics from your own ships only exist if accidents and near misses were recorded on board. Without those records one leg of the evaluation is missing.

The guidelines first separate hazard from risk

Paragraph 22 of the ILO guidelines defines the two words.

(a) A hazard is the inherent potential to cause injury, harm or damage to a seafarer’s health. It can come from many sources, for example intrinsic properties, situations, potential energy, the environment or human factors. (b) A risk is the likelihood that a seafarer will be harmed or experience adverse health effects or that property will be damaged if exposed to a hazard.

A hazard (hazard) is the potential to cause harm in itself. A risk (risk) is the likelihood that harm actually results when someone is exposed to that hazard. An open manhole is a hazard, and walking past it at night without lighting is what creates the risk.

This distinction is what separates step 1 from step 3 of the five. Step 1 finds hazards, and step 3 evaluates risk. Put both in one box and the measures attach to the symptom rather than the hazard.

The five steps find, ask who is harmed, evaluate, assign, and record

Step 1. Identify the hazards Step 2. Identify who might be harmed and how Step 3. Evaluate the risk – identify and decide on the safety and health risk control measures Step 4. Record who is responsible for implementing which control measure, and the time frame Step 5. Record the findings, monitor and review the risk assessment, and update when necessary

Box 2 at paragraph 24 of the guidelines. It carries the five-step workplace risk assessment guide the ILO published in 2014 into the maritime sector.

Step	What has to be written
1	The hazards present in that task
2	Who might be harmed, and how
3	The level of risk and the control measures chosen
4	A responsible person and a time frame for each measure
5	The findings, how they are monitored, and when they are reviewed

Steps 4 and 5 are what produce the document. Up to step 3 it is judgement; from step 4 names and dates attach. A list of measures with no owner and no deadline has skipped step 4.

Paragraph 25 gives, as an example of a tool for setting the level of risk, a risk matrix that crosses the probability of occurrence with the severity of the consequences. The guidelines offer it as one example and do not require any particular matrix.

Review is due when working methods, personnel or the shipowner change, and after an accident

Risk assessments should be reviewed when working methods, processes or personnel are changed, or when there is a change in shipowner, to ensure that safety procedures are appropriate and are implemented. It is also important to review risk assessments after investigations of accidents and incidents and analyses of hazardous situations, to ensure that systems and procedures are improved to prevent future problems.

Paragraph 25 says when the review in step 5 falls due. When working methods or processes change, when personnel change, when the shipowner changes, and after investigations of accidents and incidents and analyses of hazardous situations.

A new seafarer joining at a crew change is a change of personnel. If the date on the assessment is earlier than the last crew change, the assessment is due for review in the light of this recommendation. Fixing the review interval by the calendar alone misses these conditions.

Elimination, substitution and isolation come before protective equipment

The Convention text also carries an order. Guideline B4.3.1, paragraph 3.

The necessary measures should take due account of the preventive principle according to which, among other things, combating risk at the source, adapting work to the individual, especially as regards the design of workplaces, and replacing the dangerous by the non-dangerous or the less dangerous, have precedence over personal protective equipment for seafarers.

Removing the risk at the source, adapting the work to the person, and replacing the dangerous with the less dangerous come before personal protective equipment. Paragraph 28 of the ILO guidelines opens this out into a five-rung ladder.

Prevention principles are based on collective, rather than individual, preventive methods. The preferred sequence or hierarchy of collective risk control measures is: (1) elimination; (2) substitution; (3) isolation or combating of risk at the source; (4) technical or engineering controls; and (5) organizational measures.

Elimination, substitution, isolation or combating at the source, technical or engineering controls, organizational measures, in that order. Personal protective equipment is not one of the five rungs. Paragraph 31 allows it as a sole measure only once every other option has been exhausted.

If wearing a helmet is the first measure written at step 3, there should be a trace of the four rungs above having been considered. An assessment whose list of measures consists of protective equipment alone has climbed this ladder from the wrong end.

Seafarers under 18 face restrictions on the type of work itself

(b) clearly specify the obligation of shipowners, seafarers and others concerned to comply with the applicable standards and with the ship’s occupational safety and health policy and programme with special attention being paid to the safety and health of seafarers under the age of 18;

Standard A4.3, paragraph 2(b) requires special attention to the safety and health of seafarers under the age of 18. What that special attention consists of is written in Guideline B4.3.10.

Except where a young seafarer is recognized as fully qualified in a pertinent skill by the competent authority, the regulations should specify restrictions on young seafarers undertaking, without appropriate supervision and instruction, certain types of work presenting special risk of accident or of detrimental effect on their health or physical development, or requiring a particular degree of maturity, experience or skill.

The provision lists twelve kinds of work as candidates for restriction. Lifting or carrying heavy loads, entry into boilers, tanks and cofferdams, exposure to harmful noise and vibration, operating hoisting and other power machinery, handling mooring or tow lines or anchoring equipment, rigging, work aloft or on deck in heavy weather, nightwatch duties, servicing electrical equipment, exposure to harmful materials or ionizing radiation, cleaning catering machinery, and handling ships’ boats.

Paragraph 208 of the ILO guidelines adds one line. The safety committee should be involved in the planning, implementation, monitoring and risk assessment of work done by seafarers under 18. Where step 2, who might be harmed, includes a seafarer under 18, that assessment becomes committee business.

Worth confirming

The Convention passages are from the Regulation 4.3 part of the consolidated MLC, 2006 (including the 2022 amendments). Standard A4.3 is mandatory, and Guidelines B4.3.1 and B4.3.10 are recommendatory. The five steps, the definitions of hazard and risk, the ladder of control measures and paragraph 208 are from the implementation guidelines the ILO issued in 2014. Those guidelines are not part of the Convention.

The national guidelines the flag State has developed under Regulation 4.3, paragraph 2 are the starting point for a given ship. Where the national guidelines use a different set of steps or a different matrix, those apply. This article goes no further than the Convention text and the ILO guidelines.

You can consult the cited source documents

These links lead to the official publishers of the documents discussed here. Match the edition and provisions cited in the article, and check subsequent amendments and flag-state implementation before applying them.

Bellbook attaches an approver and a validity period to each task risk assessment

Steps 4 and 5 of the five are about writing down who owns which measure and when it is looked at again. Bellbook has risk assessments written per task with an approval record, and puts them up for review when the validity period runs out.

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