ENCLOSED SPACE ENTRY FOR SHORE WORKERS March 2026 RISK WATCH | CONTENTS | 3 ENCLOSED SPACE ENTRY FOR SHORE WORKERS ANTHONY GARDNER, LOSS PREVENTION MANAGER, BRITANNIA P&I ADVICE 04 NON-HARBOUR TOWING OPERATIONS ANTHONY GARDNER, LOSS PREVENTION MANAGER, BRITANNIA P&I ADVICE 06 ADVICE 12 NAVIGATION IN RESTRICTED VISIBILITY JOBIN MATHEW, ASSISTANT LOSS PREVENTION MANAGER, BRITANNIA P&I REGULATIONS 08 ADVICE 10 NEW REGULATION AFFECTING LIFTING APPLIANCES ANTHONY GARDNER, LOSS PREVENTION MANAGER, BRITANNIA P&I 2 | RISK WATCH | EDITORIAL This month’s Risk Watch brings together guidance that reinforces how safety continues to evolve through both technology and human awareness. From innovations such as vacuum mooring systems, which reduce manual handling risks and improve operational efficiency, to updated SOLAS lifting-appliance requirements, the focus remains on strengthening the foundations crews rely on every day. We also highlight the importance of informed decisionmaking and clear communication. Updated IMO guidance on enclosed space entry for shore workers stresses education and supervised access, while our features on restricted visibility emphasises situational awareness and compliance with COLREGs. We also explore practical legal and operational topics that support Members’ day-to-day work, from understanding the three core functions of a Bill of Lading, to lessons from A&N Seaways v Allianz on arbitration strategy, to guidance for planning and approving non-harbour towage. We hope you find this edition insightful in supporting a strong, proactive safety culture across your fleet. MEGAN DODD Editor VACUUM MOORING: SYSTEMS SAFER AND MORE EFFICIENT MOORING? JACOB DAMGAARD, HEAD OF LOSS PREVENTION, BRITANNIA P&I LEGAL 16 LEGALTEAM 1820 A&N SEAWAYS V ALLIANZ BULK CARRIERS DMCC [2025] EWHC 2126 (COMM) COLIN CHUNG, ASSOCIATE DIRECTOR, BRITANNIA P&I MEET THE LOSS PREVENTION TEAM THE THREE FUNCTIONS OF A BILL OF LADING RUTH DRESSER, FLEET MANAGER, BRITANNIA P&I ACCESS Access control is of great importance, and much work can be done in advance of port entry to ensure that the number of access points are minimised and that the opportunity for unsupervised entry is restricted. Firstly, all access points should be confirmed as clearly labelled to identify their purpose and the space they are connected to. The relevant ship’s crew members should be briefed on the operations planned before port entry, and the spaces that are to be entered identified. Where possible, any space that is not to be entered should be securely closed. In conjunction with ISPS requirements, the use of locking arrangements and/or seals is an effective method to prevent unauthorised access. When a space is no longer safe for entry, it should be clearly demonstrated as such. If an access is open but the space is unsafe, such as when ventilating, temporary barriers should be put in place that would require physical removal by a person to gain access. Regular rounds should be conducted to check that activity is only occurring at the intended spaces, and no attempts have been made to open a space that is not for entry. EMERGENCY The shipboard emergency plan should be explained to shore personnel prior to entering an enclosed space. Of critical importance is the need for all personnel to safely vacate the space when told to, when ventilation stops, or if any personal gas detector indicates an alarm. The need to allow only the rescue team to affect an entry must be clearly communi