Fatigue is one of those sneaky things that will creep up on you and often without you realising it until something happens. It’s been a major problem over the years in maritime industries but especially in the commercial fishing sector.

Crew members on charter vessels, ferries, water taxis and other passenger/vehicle transport vessels that operate in Australia are usually short voyage operations.


In addition, they usually operate between fixed times and often with crew changes scheduled in during their operating timetables. Crews on construction vessels are usually controlled by legislation in relation to their operating times.


This makes fatigue relatively easy to manage compared to some other sectors, but it can still be a major issue. Crew members and shore-based workers who fail to get adequate rest between working hours are in risk of suffering from fatigue.


Fishing operations such as net fishing or prawn trawling in bay and/or estuary waters are often either day or night operations allowing sufficient rest periods between voyages.


Others such as long liners, line fishing vessels and offshore trawlers operate offshore and may undertake round the clock operations. This is where fatigue management is critical to ensure the safety of all persons onboard.


In shore-based workplaces workers are subject to fatigue as well based on the hours they work, number of shifts and many other factors that often don’t get taken into account.

Things to consider

Your operations will determine how you manage fatigue. Here are a few pointers on what to consider…

  • Do you operate on scheduled times, around the clock or somewhere in-between
  • Crew/worker rosters (where applicable)
  • When developing rosters time taken for each crew member or worker to travel to and from work
  • Time in-between shifts (hours for rest)
  • How many days in a row (e.g., 3 days on 2 days off)
  • What berthing/bedding facilities are onboard (for extended voyages) or in the workplace (for on-site workers; e.g., FIFO)
  • For vessels operating extended hours how rest periods are managed
  • Who manages fatigue levels onboard or in the workplace

This is a starting point of things to consider before jumping into developing your fatigue management programme!

What to identify when assessing fatigue

To properly assess fatigue, you need to take into account two key elements which are:

  1. Standard working hours which includes
  • Total hours worked per day
  • Days worked per week
  • Total hours worked per week
  • Hours between shifts
  • Night shifts
  • Breaks per shift
  1. Additional hours which takes into account:
  • Overtime
  • Extended hours
  • Times you get called back to work
  • Secondary employment

The combination of the above will identify a crew member or workers risk of fatigue and then allow a process to be put in place, where required to minimise the risk.

Calculating fatigue exposure

The risk of fatigue is calculated by undertaking a risk assessment that is designed to identify all the areas that contribute to fatigue.

In general terms risk of fatigue is broken down as follows:

Low Risk is deemed that a person works less than 50 hours per week

Medium Risk is where a person works between 50 – 70 hours per week

High Risk is where a person works more than 70 hours per week

Developing a fatigue management procedure

This procedure can be quite tricky to ensure it’s on target and I always recommend doing a risk assessment on fatigue for your operations before you start.

When developing a fatigue management procedure here’s the key points to take into account…

  • Identify who monitors fatigue onboard or in the workplace
  • Identify who manages breaks onboard or in the workplace
  • For vessels that have crew changes during operations specify start and finish times; or
  • Workplaces that have worker rotation specify start and finish times
  • For vessels or workers operating extended hours when rest periods are to be taken; and
  • a roster for breaks (times when individual crew members are off duty)

The above points provide the basis for developing your fatigue management procedure but remember it is a tricky one to get right.

Remember that fatigue often goes unnoticed until something happens and that could be anything from a minor injury to loss of life or damage to or loss of a vessel or workplace.

So…please take fatigue seriously because it can be and is a killer!

Shorlink’s Recommendation

We strongly recommend that you take fatigue seriously and undertake a detailed risk assessment in relation to fatigue.

You can do a group risk assessment where you take into account all crew members or workers who are operating on the same work hours.

Where there are differences in specific crew members or workers hours you need to do a risk assessment on that person or persons.


When undertaking risk assessments for fatigue our tip is to ensure you cover all aspects of the group or individual crew member or workers hours including total hours worked per week, breaks and the one that most people don’t take into account travel time to and from work.

To get an honest appraisal of a person’s fatigue potential you need to be honest about all their hours both work and rest periods.

If in doubt or you need assistance with fatigue risk assessments don’t hesitate to contact our office because we’re here to help!

It’s interesting to note that some operators either did not know or failed to take the appropriate actions including updating their Safety Management System (SMS) in relation to AMSA changes.

AMSA announced an amendment to Marine Order 504 in relation to vessels carrying passengers that commenced in May 2020.

The changes!

For Class 1 and Class 2 vessels that are permitted to carry passengers you will be required to have an effective and verifiable means of passenger monitoring to ensure the master is able to find out the number of passengers onboard at any time.

You will be required to undertake a passenger count at the time of embarkation and disembarking for vessels that are:

  • a Class 2 vessel permitted to carry passengers or a Class 1 vessel that is permitted to carry no more than 75 passengers; and
  • is on a voyage of at least 30 minutes and no more than 12 hours scheduled duration and the vessel is not scheduled to stop for embarkation or disembarkation in the first 30 minutes; and
  • is operating in B, C or D waters at any time or E waters outside of daylight hours.

For operators who transport passengers to a water-based activity the passenger count:

  • must include an additional count before the vessel departs from the site; and
  • is not required to be conducted when a vessel is stopped for a water-based activity and a passenger enters or leaves:
  1. the water; or
  2. another vessel used in conjunction with the activity

This means if you’re operating a ferry service or water taxi which has voyages of less than 30 minutes this amendment does not apply.

For most operators who carry passengers on voyages of 30 minutes or more and less than 12 hours you will need to update your Safety Management System (SMS) to incorporate the changes.

The flowchart below will assist in determining what vessel is required to do in relation to passenger monitoring and counts:

Remember: Every passenger counts!

Current regulation is in place to improve passenger safety on domestic commercial vessels. These measures were made in response to fatal and serious non-fatal incidents involving passengers falling overboard.

There are severe penalties that align with the irresponsibility to always ensure the safety of your passengers.

It is equally important that the crew are made aware of their responsibilities, actions, procedures, and consequences.  If in doubt, arrange an immediate training session with your crew and make sure these are ‘real’ sessions, out on the water, with every member of the crew.

Shorlink’s Recommendation

If you operate a passenger carrying vessel as identified above and you haven’t implemented these procedures or updated your SMS to incorporate them we strongly recommend you take action now.

A failure to implement these procedures and/or update your SMS accordingly may attract a severe penalty and in the event of an incident you can end up facing serious legal actions.

Don’t wait! As we have seen with our clients, AMSA have been and will be extremely active this year with vessel and SMS inspections.  Ensure you stay up-to-date of the requirements. This will demonstrate that you are generating a culture of compliance within your business!

As mentioned above, training is key! We have seen so may times crew and other passengers alike, panic, when someone falls overboard. Training with your crew with alleviate the unnecessary panic reaction and replace with a calm and educated response. This will save lives and provide confidence for your crew and passengers.


If you’re having trouble working out what’s required or how to incorporate the changes into your SMS then give us a call and we’ll help get you compliant with the changes.

Shorlink offer ‘Onboard’ Safety training courses for both commercial and reactional operators that include ‘real’ person overboard demonstrations, as well as learning and understanding of your vessel, its equipment and emergency response scenarios including fire, person overboard, collision and more! Click Here for more details!


While most of us have seen Safety Data Sheets (SDS), previously known as a Material Safety Data Sheet (MSDS) how many actually know and understand them?

Unfortunately, a Person conducting a business or undertaking (PCBU) which includes vessel owners simply have them because they have too!

SDS are a valuable tool in ensuring workers (including crew members) health and safety by providing critical information about hazardous substances. A SDS includes information on:

  • The chemical’s identity and ingredients
  • Health and physical hazards
  • Safe handling and storage procedures
  • Emergency procedures
  • Disposal considerations

A SDS is a valuable tool for assessing and managing the risks associated with the use of hazardous chemicals in workplaces.’

WHS Regulation section 330 specifies that a manufacturer or importer to prepare and provide safety data sheets.

A chemical that is not hazardous does not require a SDS however if ones available it’s a good idea to have it on hand for general safety reasons.

Note that all SDS are to be prepared in accordance with the Code of Practice for the Preparation of safety data sheets for hazardous chemicals.

A SDS must:

  • be in English
  • contain units of measurement expressed in Australian legal units of measurements
  • state the date it was last reviewed or if it has not been reviewed the date it was prepared
  • state the name , Australian address and business telephone number of the manufacturer or importer
  • state an Australian business telephone number from which information about the chemical can be obtained in an emergency

A SDS for a hazardous chemical must state the following information about the chemical:

  • Section 1 – Identification: Product identifier and chemical entity
  • Section 2 – Hazard(s) identification
  • Section 3 – Composition and information on ingredients
  • Section 4 – First aid measures
  • Section 5 – Firefighting measures
  • Section 6 – Accidental release measures
  • Section 7 – Handling and storage including how the chemical may be safely stored
  • Section 8 – Exposure controls and personal protection
  • Section 9 – Physical and chemical properties
  • Section 10 – Stability and reactivity
  • Section 11 – Toxicological information
  • Section 12 – Ecological information
  • Section 13 – Disposal considerations
  • Section 14 – Transport information
  • Section 15 – Regulatory information
  • Section 16 – Any other relevant information

As you can see there is a lot of information in a SDS, information that is vital to the business/vessel owner/operator, end user and emergency services in the event of an incident.

While all the above sections are important the key sections relevant to the user are:

  • Section 2 – Hazard(s) identification
  • Section 4 – First aid measures
  • Section 5 – Firefighting measures
  • Section 6 – Accidental release measures
  • Section 7 – Handling and storage including how the chemical may be safely stored
  • Section 8 – Exposure controls and personal protection
  • Section 13 – Disposal considerations
  • Section 16 – Any other relevant information

There is a twist to the requirement for SDS that if you purchase a household use product from a general retailer in domestic use sizes then a SDS is not required. Even though it’s not required it’s still a good idea to have one if you purchase any quantities of household use products.

Shorlink’s Recommendation

We strongly recommend you comply with three import things:

  1. You have SDS for all chemical and/or hazards materials you store or use;
  2. All SDS are current; and
  3. Workers, including crew members who use or handle the product have easy access to all SDS.


While having SDS stored on electronic devices such as computers, tablets, etc. saves a lot of paper in the event that power is lost due to a fire or other reason you cannot access your SDS. Our best tip is to ensure you have hard copies available.

While most of us have chemicals either onboard or ashore do we handle and store them correctly?

Failure to handle and store chemicals of any sort can lead to injuries, health problems and damage to the vessel, workplace and the environment.

Every year in Australia over 2,000 workers die as a result of occupational exposure to hazardous substances. Only 30 – 40 of these are due to poisoning, many of the other deaths result from long latency, e.g., cancer.

Vessel and workplace damage can be repaired but environmental damage comes with penalties that can cause major financial disruption and even bankruptcy to owners and operators.

To avoid that you need to ensure you comply with two things, those being:

  1. The Code of Practice for Managing the risks of hazardous chemicals in the workplace. Note this means onboard vessels as well.
  2. The handling and storing details in the products Safety Data Sheet (SDS). You do have SDS’s for all your chemicals onboard or onsite, not just the hazardous ones don’t you?

This newsletter provides a brief outline of your requirements for the handling and storing of chemicals. If you need further information please feel free to contact our office.

Firstly, SDS are required for all chemicals stored onboard or onsite and are required to be stored in a location that is accessible to all people onboard or in the workplace. More on SDS next week.

A Hazardous Chemicals Register which contains a list of all hazardous chemicals onboard or at your workplace. This register is a requirement under WHS Regulations and should be accompanied by the current SDS for each of those chemicals.

The handling of chemicals can cause serious injury and/or illness and death in some cases. Ensuring you comply with the handling instructions and PPE requirements listed in the SDS is critical to your health and safety.

Storage of hazardous chemicals including flammable and combustible liquids must be in an approved storage containers and a space designed and constructed in accordance with AS1940.

Special care must be taken when storing hazardous chemicals due to cross contamination with incompatible materials which can result in explosion, fire, toxic fumes/gases or other potentially harmful situations.

When handling hazardous chemicals or material ensure you follow the handling precautions contained in the products SDS at all times.

The storage of non-hazardous chemicals must be in accordance with the storage instructions contained in the products SDS.

As with all chemicals always refer to and follow the handling instructions contained in the products SDS.

PPE is a major issue as many people either don’t know what PPE to use or simply fail to use it for whatever reason. Business and vessel owners and operators are responsible for ensuring the appropriate PPE is readily available to all workers and crew members.

What are hazardous substances?

Hazardous substances are substances that have the potential to harm people’s health in the medium or long term. They can be solids, liquids or gases, and when used in the workplace, they are often in the form of fumes, dusts, mists and vapours.

Examples of hazardous substances include:

  • acute toxins such as cyanide,
  • substances harmful after repeated or prolonged exposure such as mercury and silica,
  • corrosives such as sulphuric acid and caustic soda,
  • irritants such as ammonia,
  • sensitising agents such as isocyanates and
  • carcinogens (cancer causing substances) such as benzene and vinyl chloride.

 How can exposure affect your health?

Hazardous substances can be inhaled, ingested or absorbed through the skin and can cause both immediate and long-term health problems. Health effects depend on the type of hazardous substance and the level of exposure. Some of the potential health effects can include:

  • irritation
  • sensitisation
  • cancer
  • poisoning
  • nausea and vomiting
  • headache
  • chest pains
  • skin rashes, such as dermatitis
  • chemical burns
  • birth defects
  • disorders of the lung, kidney or liver
  • nervous system disorders
  • birth defects

Injuries and symptoms are also dependant on a variety of variables including length, quality and frequency of exposure, history and method of exposure, training received, sensitivity to the substance, general health and height and weight.


Shorlink’s Recommendation

We recommend that as a vessel or business owner or operator you should assess the health risk associated in working with hazardous substances. To do this we recommend you should know:

  • what the substance is.
  • whether the substance is hazardous or not.
  • how the substance is used (and misused) in the work process.
  • if there is a chance of a person being exposed to the hazardous substances, how much they are exposed to, for how long and how often they are exposed.
  • how to use this knowledge to assess the risk to a person’s health.


The best tip we can give is to ensure you have SDS for all chemicals stored onboard your vessel or in your workplace and they are current. Having them is one thing but ensure they are easily accessible to all relevant workers, and they know where they are.

There is a twist to this requirement that if you purchase a household use product from a general retailer in domestic use sizes then a SDS is not required. Even though it’s not required it’s still a good idea to have one if you purchase any quantities household use product.

So, what is a Safety Data Sheet. These provide detailed information about chemicals including:

  • the identity of the chemical product and its ingredients;
  • the hazards of the chemical including health, physical and environmental hazards;
  • physical properties of the chemical, like boiling point, flash point and incompatibilities with other products;
  • workplace exposure standards for airborne contaminants;
  • safe handling and storage procedures
  • what to do in the event of an emergency or spill;
  • first aid information; and
  • transport information

Firstly, what is restricted visibility?

Many people consider restricted visibility as fog or heavy rain, but the hours between sunrise and sunset are all regarded as restricted visibility. Any condition or situation that restricts your ability to see clearly or hampers your vision is restricted visibility!

In fact, the hours leading up to daylight and sunset can make visibility exceedingly difficult depending on your course in relation to the rising or setting sun.

Most of us have had to operate in these sort of conditions at some time or another and hopefully survived without incident!

By following a simple procedure (you do have one don’t you?) you can make it safer not only for yourself but others as well.

Here’s a guide to good seamanship when operating in restricted visibility.

  1. Always proceed at a safe speed relative to the conditions
  2. Maintain a watch by sight, sound, including your radio and all other available means
  3. Where necessary use the appropriate sound signals (see Sound Signals below)
  4. If a close quarters situation exists you must take appropriate action to avoid a collision (collision means not only with another vessel but also navigational markers or beacons, etc.)
  5. At all times monitor the radio
  6. If other vessels are nearby broadcast your intended movements

Sound Signals

These sound signals are to be used when operating in restricted visibility.

  1. Underway: sound at intervals of not more than 2 minutes apart 1 prolonged blast;
  2. Underway but stopped: sound at intervals of not more than 2 minutes 2 prolonged blasts in succession with an interval of 2 seconds between them
  3. At anchor: ring the bell (if fitted) rapidly for about 5 seconds

When you’re operating in restricted visibility it’s vital that you follow this procedure to ensure the safety of your vessel, all persons onboard and other vessels!

It’s important that you comply with the regulations at all times and for this procedure you can go to the COLREGS Rule 9 – Conduct of vessels in restricted visibility.

Shorlink’s Recommendation

We strongly recommend placing a lookout on the bow when operating in close proximity to other vessels, entering port where maneuverability may be restricted or where other potential dangers exist.

Operating from the wheelhouse where vision is impaired by fog, heavy rain, sunset, sunrise or any other condition can make navigating more difficult.

You may have your sight impacted by interior lights, lights from gauges and/or navigational equipment or other things all of which can cause significant issues. By using a forward lookout, you minimise the risks!


Remember that during periods of heavy rain or other conditions your radar may be impacted and not display potential dangers, especially other vessels. When operating in close proximity to other vessel ensure you maintain communications by using your radio.

This is such a simple action but unfortunately many collisions occur due to a failure to communicate!

Crossing a coastal bar can be an easy task or it can be one of the most dangerous parts of a voyage, so by ensuring you have the knowledge and a sound procedure in place lessens the dangers!

Coastal bars build up at the entrance to coastal rivers and are formed by the movement of sand and sediments. They cause waves to become steeper and often break as they approach the bar. Bars can change quickly and without warning making any crossing dangerous!

Any crossing of a coastal bar can be a dangerous event even when it appears calm. Bars can produce dangerous waves that have the potential cause injury or loss of life and severe damage to or loss of vessels.

All bars are different and remember that slow displacement vessels handle bars differently than high speed planning vessels do.

Going out

The vessel must match the energy of each incoming wave by maintaining a speed that will lift the bow over the wave and reduce the chance of the wave breaking over the bow into the vessel.

Do not hit waves at high speed but take them as close to head-on as possible. Be prepared to take a wave head-on and take water over the bow if there is no other way.

A guideline for you when crossing a bar:

  • cross on an incoming tide when possible
  • look for lulls and choose the line of least wave activity and avoid breaking waves or the calmest water
  • look for the deepest water to avoid grounding
  • keep your vessel head-on to approaching waves. Do not let your vessel turn side on to approaching waves
  • head up into the waves and accelerate where possible, but avoid getting airborne
  • head for the lowest part of the wave and continue until clear.

Coming in

When coming in, high-speed boats (capable of at least 18 knots) should travel at the same speed as the waves.

Slow displacement boats may have to come in very slowly to avoid surfing and getting caught side-on to a wave.

Try to travel in on the back of a wave and stay ahead of waves that break behind the boat. Watch for patterns and deeper areas.

When returning over a bar you should:

  • look for lulls and choose the route of least wave activity
  • look for the deepest water to avoid grounding
  • increase power to maintain speed within the set of waves when approaching from the sea
  • position the boat on the back of the wave – do not surf down the face of the wave
  • adjust the boat’s speed to match the speed of the waves, but do not try to overtake the waves.

In bad conditions, it can be safer to stand off in deeper water, or find another shelter, instead of re-crossing the bar.

For passenger vessels

If you’re operating a passenger vessel and carrying passengers when crossing a coastal bar, it’s critical that you notify all passengers that you are about to cross a bar.

In all but calm weather, advise them to be seated and hold on until advised the bar crossing has been completed. When the bar crossing has been completed advise passengers that the bar crossing has been completed.

Never, at any time allow passenger on the bow area when crossing a coastal bar!

Shorlink’s Recommendation

We strongly recommend that when crossing a bar everyone should wear a lifejacket as no matter the size of your vessel there is always the potential for capsize, especially on rough days! Remember putting a lifejacket on in the water is difficult but putting one in in rough seas is almost impossible!

Choose your route carefully and once you have started keep going as attempting to turn around in front of an incoming wave is dangerous.


Our vital tips for crossing coastal bars.

  • Check the tide and weather
  • Check your vessels steering
  • Check your vessels engine/s and controls
  • Ensure your vessels trim is appropriate
  • Secure all cargo, equipment and other items that may move around
  • Ensure all lines are secure and not likely to go overboard

When we’re doing either onboard training or vessel safety audits and look at the vessels deck log the information recorded….

often it does not meet the requirements of Marine Order 504 (MO504).


There are specific requirements relating to the information that must be recorded in your log book. In the event of an incident, failure to fill in your log book has the potential to cause serious issues for you or your crew!

In addition to the requirements of MO 504 there’s other information that we highly recommend you record.

Looking at deck or vessel log books for commercial fishing vessels, it’s common to see the start/finish times or position of shots and little more.

In charter vessels we regularly see start and finish times and in some cases refuelling again with little more.

It’s critical for your protection to ensure you or your Master keeps the log up to date at all times. A failure to do so leaves you exposed in the event of an incident or legal claim by a crew member or passenger!

MO504 specifies that the following details MUST be recorded in your log book:

  1. Any illness or injury of persons onboard. This means crew members, passengers or any other person onboard. Injury means injuries that are serious enough to need more than just a band aid. Any injury that requires first aid or has the potential to cause infection or may need further medical attention in the future must be recorded.
  2. Any marine incident, other incident or accident involving the vessel or its equipment.
  3. Any assistance rendered to another vessel.
  4. Any unusual occurrence or incident. This means anything that has the potential to impact on the safety of a person or persons onboard or the safe operation of the vessel.
  5. All communications and/or messages sent or received for an emergency. This is critical in the event of an investigation.
  6. All passenger counts conducted for the vessel. This only applies to vessels carrying passengers
  7. Any operation of the vessel for recreational purposes

Quite often Masters tell me that ”I’m busy running the vessel and don’t have time to record all of this.”

My answer is always “do you have weeks or months available to defend yourself in court if the vessel, crew member or a passenger is involved in an incident?”

When an incident or accident occurs AMSA will undertake an investigation and apart from the incident report they will look at your SMS and log book.

So, the two questions asked are:

  1. Does your SMS comply with MO504 and is the relevant procedure or procedures appropriate?; and
  2. Is the incident detailed in the vessels log book?

If your SMS does not meet the requirements then you may have a serious problem and a failure to record the incident or accident exposes you even further.

No matter what type of vessel you operate, I hope you can now see the value in keeping your vessels log book up to date with all the relevant information.

As a commercial mariner, I know it can sometimes be difficult to keep your log book up to date, but you should always ensure you enter the relevant details as soon as reasonably practicable after the event. This way the event is clear in your mind, and you don’t have to think back to what actually happened.

A key point many Masters forget and I’ve been guilty of it myself, is to ensure you sign the log book page at the end of every day. Doesn’t sound like much but it can potentially leave you exposed yet again so make sure you sign every day’s log page.

Shorlink’s Recommendation

We strongly recommend recording the following information:

  • Date and time of departure and arrival
  • Navigational track and/or position at relevant times
  • Summary of weather conditions, especially any sudden changes in weather
  • All inductions and training.

By including this information, you are so much better protected in the event of an incident or accident.


Our best tip to ensure you meet AMSA’s requirements and give yourself the best protection possible is to check the previous days log book entries to ensure all requirements are recorded appropriately and that you have signed the page.

Ensure to check out the Deck Log Book that we here, at Shorlink, produce to ensure you are meeting your requirements.  Our Log Books are available online with free postage. Click Here!

When working at height the risk of falling can be quite high and is often not addressed properly in many workplaces!

The Work Health and Safety Regulation 2011 sets out specific control measures that are required where there is a risk of a fall of at least:

  • 3 metres in housing construction work; and
  • 2 metres in other construction work.

Note that control measures may still be required for work below 3 metres in housing construction and below 2 metres for other construction work if a risk assessment suggests control measures should be provided.

In this newsletter we’ll be focused on the “other construction work” area as it best relates to our clientele.

If you don’t want to be issued an Improvement Notice or a Prohibition Notice then I strongly suggest you read this newsletter!

For other construction work where the risk of falling is 2 metres or more, or on a roof with a slope over 26°

Before starting work the person conducting the business or undertaking must have:

  • Fall prevention controls in place (e.g. edge protection or travel restraint system) to prevent a person falling any distance, or where this is not practicable;
  • Fall arrest controls that arrest a person’s fall (e.g. fall arrest harness or catch platform) and prevent or minimise the risk of death or injury to a person when the fall is arrested.

Note: For work carried out 2 metres and above lower order administrative controls are not permitted on their own.

For other construction work where the risk of falling is less than 2 metres, or on a roof with a slope less than 26°

Before starting work the person conducting the business or undertaking must:

  • Identify the hazards that may result in a fall or cause death or injury if a person were to fall e.g. a picket fence or stack of bricks that could cause injury if a person fell on it; and
  • Assess the risk of death or injury that may result because of the hazard i.e. how likely is it to happen?, how serious could the injury be?; and
  • Use any control measures necessary to prevent or minimise the level of risk. This could include fall prevention, fall arrest, and/or administrative controls.

To ensure you meet all the requirements I’ve provided a guideline for you.

The Risk Management process

While a risk assessment is not mandatory under WHS Regulation it is the best way to determine the measures that should be implemented to control risks. The key points in the process are:

  1. Identifying the hazards: This is the first step in undertaking a risk assessment. This involves finding things which could potentially cause harm to people.
  2. Inspect the workplace: Hazards may be identified by looking at the workplace and how work is carried out. Walk around the workplace and talk to your workers to find out where work is carried out that could result in falls. A checklist can be useful in this process.
  3. Review any available information including incident reports: It can be beneficial to view records of previous incidents (injuries and near misses) and worker complaints related to falls. Information and advice about fall hazards and risks and work activities are available from regulators, industry associations, technical specialists and safety consultants.

Assessing the risks

A risk assessment involves considering what could happen if someone is exposed to a hazard and the likelihood of it happening. A risk assessment can help you determine:

  • How severe the risk is
  • Whether any existing control measure are effective
  • What action you should take to control the risk
  • How urgently the action needs to be taken

Hazards and associated risks have the potential to cause different types of severities of harm ranging form minor discomfort to a serious injury or death.

Remember that if you’re working on a ladder and more than 2 metres high (for other construction work) you need to take this into account as well

Shorlink’s Recommendation

If you have to undertake any work that requires you to work at height as outlined in this newsletter where the potential for a fall exists I strongly recommend you check that you have an up to date procedure in place for working at heights.

A failure to have this in place leaves you exposed to the potential of being issued an Improvement Notice or a Prohibition Notice.


If you’re unsure about undertaking a workplace inspection in relation to potential falls our best tip is to contact our office and request our checklist in relation to identifying hazards relating to falls.

I’m regularly asked, “what’s the difference between an enclosed space and a confined space?”

SO…here’s my response…

What is Enclosed Space?

An enclosed space is defined as any enclosed space that has limited openings for entry or exit, inadequate ventilation and is not designed for regular occupancy.

Because of the lack of ventilation within enclosed spaces, these areas generate and store toxic gases that are either produced from chemicals within the place or from leakage out of surrounding pipelines.

Air movement is almost entirely limited, meaning any flammable atmosphere is unable to be dispersed.

What is Confined Space?

A confined space is any enclosed or partially enclosed space with normal atmospheric pressure not designed or intended to be occupied by a person.

Confined spaces are likely to contain an atmosphere with unsafe oxygen levels and can often contain contaminants such as airborne gases, which can cause injury or death.

Similar to that of enclosed spaces, the possibility of engulfment within confined spaces is very real. Thus, it is crucial that occupants of confined spaces have a strong understanding of precaution, working safety equipment and solid communication processes with colleagues in place.

Examples of confined spaces include pits, underground sewers, tunnels, wells, tanks, etc.

On your vessel

As you can see from the above both have a lot of similar properties therefore require a number of the same safety precautions. Below are the four most prevalent hazards when entering enclosed or confined spaces.

  1. Fuel fumes: Fumes from fuel, in particular gasoline are a major hazard. Highly volatile and a leading cause of marine related explosions and fires, gasoline fumes, which are heavier than air, can easily accumulate in a vessel’s bilge due to improper refuelling or fuel system leaks. There, it’s only a spark away from causing a fire or explosion.
  2. Liquid Propane Gas (LPG): LPG vapor is heavier than air and tends to “flow” like water, seeking the lowest possible point. As a boat’s hull is essentially a watertight envelope, escaping LPG can be trapped in bilges or other low areas, where they can rapidly accumulate to explosive concentrations.
  3. Carbon Monoxide: Carbon monoxide (CO) is a potentially lethal gas produced when burning any carbon-based fuel (e.g., gasoline, wood, propane). CO is colourless, odorless, and tasteless, and mixes evenly with air, meaning it readily travels throughout a boat’s interior spaces. CO enters the body through the lungs and is readily absorbed into the bloodstream, where it displaces oxygen levels in the body and can lead to carbon monoxide poisoning.
  4. Hydrogen Sulfide: Hydrogen sulfide (H2S) is a colourless, toxic gas that is also flammable and highly corrosive. Symptoms of H2S exposure include skin and eye irritation, headaches, loss of balance, nausea, delirium, tremors, and convulsions. Inhalation of high concentrations of H2S can lead to rapid unconsciousness and death. H2S gas occurs naturally during the breakdown of organic matter.

How do I stay safe?

The first question is to ask, “is it an enclosed or confined space?”

Question number two is “what hazards are there when I enter the space?”

Let’s look at a couple of different scenarios for enclosed spaces…

  1. The bilge space of a vessel under 35mtr. My quick check list
  • open the relevant hatch, ensure the hatch is fully open and secured in place
  • ventilate the space
  • check if there are any noticeable fumes
  • advise another person that I’m entering the space
  • have a person stand watch
  1. The engine room on a vessel under 35mtr. This depends on if the engine room has ventilation/ extraction fans. My quick check lists follow…

With fans:

  • open the relevant hatch, ensure the hatch is fully open and secured in place
  • advise another person that I’m entering the space
  • have a person stand watch

Without fans:

  • open the relevant hatch, ensure the hatch is fully open and secured in place
  • ventilate the space
  • check if there are any noticeable fumes
  • advise another person that I’m entering the space
  • have a person stand watch(if necessary)

Confined Spaces

NO person should enter a confined space without the appropriate training. It’s critical that if you have confined spaces on your vessel you have a dedicated procedure for entering them. The key steps for entering any confined space are:

  • Ensure any person entering the confined space has the appropriate training
  • Complete a “Confined Space Entry Permit”
  • Undertake a Risk Assessment (this is part of the Entry Permit)
  • Ventilate the space
  • Test the air quality using certified testing equipment
  • Having lighting equipment available if required
  • Use breathing apparatus if required
  • Ensure clear communications
  • Ensure there are rescue procedures in place

This list is not comprehensive but only a guideline for entering confined spaces

Shorlink’s Recommendation

Number one recommendation is if you have confined spaces on your vessel or in the workplace ensure you have a procedure for entry and the required equipment and documentation available.

Failure to complete a Confined Space Entry Permit, including a Risk Assessment leaves you in a dangerous position in the event of an incident.


If you have confined spaces our tip is to have at least one person trained in confined space entry available. In the event entry is required you have a qualified person available to deal with potential hazardous issues.

The alternative is to have a person or company readily available if the need arises!

Commercial fishing vessels and some other vessels have refrigerated holds which may be set to anywhere from 0°C to 3°C on average. Freezer holds can go from -2°C to -60°C or even lower in some cases.

So how safe is it to work in these holds?


If you follow a series of proven steps it’s very safe and crew have been doing it for years but…there are a few hazards that need to be monitored.

If you’re working in a refrigerated hold where the temperature is 0°C to 3°C on average there is no real need for all the PPE unless you’re going to be there for an extended period.

Working in a freezer hold is a whole different world where temperatures from -2°C to -60°C or even lower are maintained PPE is essential.

How does your body respond to the cold?

While this newsletter is about refrigerated holds this part is also relevant to being in the water!

When the body is exposed to the cold, it responds in two way to reduce heat loss:

  1. By constricting the blood vessels in the skin and extremities (fingers and toes) to keep your core as warm as possible: and
  2. By increasing the metabolic heat product rate, either by physical work you are doing, or by shivering. Shivering is an independent way of increasing your heat production through as it increases oxygen consumption and reduces your effectiveness.

As your body responds in these ways, it is using more energy than it would in ambient temperatures. Hence, it is burning food and drink faster and will tire faster.

The serious risks of working in cold environments

If you stay in cold environments for extended periods of time and/or are not wearing suitable protective clothing, your body may be at risk of more serious implications. These can include:

  • Frostbite. This is where the fluids in the body tissues actually freeze, causing permanent damage to the skin. Body parts at the most risk to this are the extremities; fingers, toes, the nose and the ear lobes.

  • Hypothermia. This is where your body temperature decreases significantly (below 35°C) and can ultimately (and quickly) lead to death. Early symptoms include confused though processes, loss of general motor control, slurred speech, aggressive shivering and a perception the victim feels hot. Hypothermia is rare in cold storage however and can be avoided through protective clothing that is adequate, and importantly, not damp or wet.
  • Long term conditions. Conditions such as arthritis, rheumatism and bronchitis are commonly associated with the cold, and may only come out years after working in the cold. Muscle and tissue damage can also occur.

Other factors for cold storage facilities

Cold Stores and Warehouses often have poor ventilation, which presents a hazard. Any gases or contaminants, such as LPG or fumes from forklifts, will not easily escape and could be dangerous for those working in the room.

Another thing to consider is ammonia is often used for refrigeration which can be deadly, should there be a leak on site. If you are worried about any irritating smells inside the cold store you should report them quickly to your supervisor.

Another area to focus on is door openings between different areas. Because of the changes in temperatures or conditions, ice/water/condensation can build up in these areas, making them extremely slippery and dangerous.

Back to the boats!

It’s critical that if you have cold storage on your vessel that you have a procedure to ensure the safety of your crew when entering and working in the refrigerated hold.

Here’s a few key point to observe:

  • Always notify someone that you are about to enter the refrigerated hold
  • Ensure you have another crew member in attendance while you are in the hold
  • Prior to entry ensure you have the appropriate PPE
  • Test the space prior to entering if you have the appropriate gas meter
  • Be aware of refrigeration gas, remember it colourless, odourless and can kill you. While some newer gases are less potent than the older ones still remain alert at all times
  • While working in the refrigerated hold the hatch must be left open
  • Do not enter a refrigerated hold if you see a crew member fall down due to refrigeration gas poisoning

Shorlink’s Recommendation

Our top recommendation is if you have refrigeration onboard it’s wise to carry an Emergency Life Support Apparatus (ELSA). By donning the ELSA, you have 15 minutes (or other time based on the brand) which allows you to enter the hold to rescue a crew member safely.


If you have refrigeration onboard remember it’s not just the refrigerated compartment that presents a potential problem. It may be the engine room or other area where the refrigeration equipment is located. So, at all times remain aware of potential refrigeration gas leaks.