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Bypassing safety controls – violation of working at height requirements

What went wrong

On a vessel in dry dock, painting of the the hull was ongoing, using the shipyard crane and a personnel basket. During this work process it was observed that the workers in the basket were not provided with safety harnesses.

The shipyard representative was requested to provide certificates for basket in use, but it was revealed that neither basket nor fall arrest equipment had valid test certificates.

The job was stopped and the shipyard was required to correct the situation. Relevant certified equipment was then immediately provided.

Uncertified basket
Working at height without a safety harness

What were the causes?

Preliminary causes identified by our member were:

  • Shipyard failed to follow agreed Control of Work process, or follow equipment certification & PPE requirements related to Work at Height activities as agreed by the contractor and the yard;
  • It was not clear who was responsible for Control of Work and HSE oversight between the contractor and the yard. (IMCA italics)


  • Revision of Safety Management System to include implementation of vessel pre-docking checklist to verify HSE readiness, including shipyard arrangements, cranes, relevant equipment and workforce certification prior to vessel docking;
  • Arrange development of bridging agreements between shipyard and contractor, to specify Control of work responsibilities for any activities onboard of vessel, including external activities related to vessel hull.

Members may wish to refer to

  • IMCA HSSE 032/M 221 Guidance on safety in shipyards – this document provides thorough and comprehensive guidance on this potentially difficult topic.   

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