Ship cargo holds

Background

Cargo holds as confined spaces pose a serious risk to the health and safety of employees and others working in the cargo hold if precautions are not taken. Accidents related to entering and working in cargo holds are preventable. This hazard alert provides information on the steps to be taken by employers and employees to work safely in cargo holds.

Target audience

Federal marine industry employers and employees who are involved in loading and unloading of ships.

Hazard with cargo holds

Cargo holds may have low oxygen levels or toxic gases. Employees entering cargo holds may suffer from severe injuries or death. The danger may be present at any time while accessing and leaving cargo holds.

Elimination and prevention

Employers must:

• determine if cargo holds are a confined space and if any future changes could create a hazard
• put in place safety procedures for entering and working in cargo holds
• provide training to employees on cargo holds hazards and safe work procedures; and
• have rescue equipment in place

Employees who load or unload ships and access cargo holds must:

• work in collaboration with all individuals involved with cargo operation
• know safety procedures (shipper/receiver included) and safety data sheets for the cargo
• use the required safety equipment for cargo holds; and
• know the hazards with cargo operations and their workplace’s hazard prevention program

Important: Employees have the right to refuse dangerous work if they believe it presents a danger.

Legislative requirements

Under Part II (Occupational Health and Safety) of the Canada Labour Code, employers must protect the health and safety of employees and anyone granted access to the workplace. In consultation with their Health and Safety committee (if any) and representative, they must also:

• assess, identify, and prevent workplace hazards to all types of cargo
• establish and maintain a Hazard Prevention Program
• put in place preventative measures, such as personal protective equipment; and
• provide training to employees related to safety procedures for all types of cargo

Under Part 7 (Hazard Prevention Program) of the Maritime Occupational Health and Safety Regulations, employers must:

• assess cargo holds to determine if they are a confined space, and reassess when any changes occur;
  • When identified as a confined space, they must also apply:
    • Part 5 (Safe Occupancy of the Work Place), especially emergency evacuation and procedures
    • Part 13 (Work Permit); and
    • Part 14 (Confined space), especially entry procedures
• provide proof of the assessment to a Transport Canada Health and Safety Officer

Important: Without proof, Transport Canada Health and Safety Officers will consider the cargo holds as a confined space.

Guidance material

Confined spaces

• Confined spaces – No easy way out (updated) - Canada.ca
• Guidance for the interpretation and application of the amended Canada Occupational Health and Safety Regulations Part XI Confined Spaces
• Protect your lungs
• Guidance on Confined Spaces – Cargo hold (Transport Canada)

Personal protective equipment

• Following preventive measures in order: A requirement to address workplace hazards and support inclusive workplaces
• Personal Protective Equipment (Canadian Centre for Occupational Health and Safety)

Contact us

For more information or questions, workplace parties can contact the Transport Canada, Marine Safety by email at tc.mssquestions-questionsssm.tc@tc.gc.ca.