UK P&I Club

UK P&I Club reports “another good year”

MAY 11, 2015 — The UK P&I Club reported financial results for the year ended February 20, 2016 that saw its free reserves remain stable at $547 million and its capital position

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Hearing loss in crew on the rise


The well-being of crew has always been a priority for the UK P&I Club PEME scheme. When the PEME scheme was launched 20 years ago, in 1996, we noticed an increase in crew illness claims and a lack of accountability from clinics. We found huge inconsistencies in the standards used by clinics for pre-employment medical examinations; many clinics adhered only to the minimum standards required by their local authority and there was no liability to the ship owner. We also found that examinations of crew were not detailed enough to screen out pre-existing medical conditions that could impact on a ship owner’s obligation to compensation.

That is why the UK P&I Club developed the PEME Program, and since the launch, the Program has become one of the Club’s leading loss prevention initiatives. Clinics which are approved under the program are held accountable to both the Club and Members for their performance. The scheme is designed to protect ship owners from claims arising from medical conditions existing prior to employment, and to provide crew with a first rate health check before going to sea. The program has been appraised as the most extensive and inclusive system available in the industry. The PEME Program is a key element in the services provided by the Club’s Loss Prevention department.

The program aims to reduce the volume and value of crew illness claims which are caused by a pre-existing illnesses or disease. These underlying conditions often impact on the crew member’s fitness for service and can endanger not only the health of the seafarer, but also the on-board safety of other crew.

As part of the PEME examination an enhanced medical screening service is administered to all crew. The crew are screened on all the major body organs and functions. The confidential data collected from medical examinations is regularly analyzed and the results are used for identifying trends in crew health.

UK P&I Club has been reviewing findings and developments from screenings, with particular focus on the last decade.

The top 10 health issues found from UK P&I pre-employment medical examinations over the last 10 years are listed below, in order from most to least:

  1. Hepatitis B
  2. Hypertension
  3. Hearing defects
  4. Pulmonary Tuberculosis
  5. Diabetes
  6. Abnormal liver function
  7. Multiple illness
  8. Gallbladder disease
  9. Sight defects
  10. Kidney Disease

Worryingly, the decade long PEME study found that hearing defects are now the third main cause of pre-employment medical failure, with the incidence of hearing defects increasing by 40%. Put into perspective, 10 years ago hearing defects did not even make the top 10 list for pre-employment medical failure.

Audiometry exams are used to test crew’s ability to hear sounds within the UK P&I Club PEME medical. UK P&I Club found that the largest group of seafarers who were affected by abnormal audiometry results worked in engine rooms of ships. Typically, crew with poor audiometry results can also display signs of mild to moderate high frequency hearing loss.

Unsurprisingly, those seafarers working in engine rooms also had a higher tendency to experience hearing disabilities. This is especially true for crew who do not use precautionary measures. High levels of ambient noise, typically above 85 dBA cause noise-induced hearing loss. The negative effects of such levels of noise and higher, depend upon individual physiology and the duration of exposure.

Identifying hearing damage
Audiometric testing is the only reliable diagnostic evaluation relevant to indicate noise-induced hearing loss. The screening is performed by an audiometric testing machine , and receiver, located within a sound proof booth. The patient, wearing headphones, is subject to noises of various volumes and frequencies (pitches) and asked to respond by pressing a button when hearing each sound. Audiometry provides an accurate measure of any damage. Below are recommended measures Member’s should put in place for their crew:

  1. A baseline audiometry test to be performed within six months of exposure for all seafarers. The test should ideally be performed when the seafarer has not been exposed to hazardous noise for at least 14 hours.
  2. Seafarers exposed to higher noise levels may be required to attend training on the effects of loud noises on hearing, the purpose of audiometric testing and protective devices available to mitigate the effects of noise damage.
  3. As exposure to loud noises, such as in engine rooms, is unavoidable on ships, hearing protection within these areas is mandatory. Devices for hearing protection including earplugs or earmuffs can be easily sourced and used on-board. The most effective ear protection is the ear protector.
  4. Allow breaks for seafarers between each episode of exposure to loud noise (more than 85 dB) especially when sound levels are higher and prolonged.

Ensuring a robust hearing conservation program
The UK P&I Club PEME Program believes that if the above recommendations are implemented, they will help protect seafarers from hearing loss and thus safeguard ship owners/operators from facing claims resulting from hearing damage incurred while on-board.


Raising awareness and education of seafarers on hearing risks such as permanent hearing disability is required. Individual crew themselves also have a responsibility to safeguard their exposure to hearing risks. It is highly recommended shipping companies include, as part of their health and safety policy, hearing protection zones in machinery spaces and other working areas where levels of high noise are prevalent.


As a further measure, companies should allow breaks for seafarers between each episode of exposure to loud noise (levels in excess of more than 85 dB) especially when sound levels are excessive and prolonged. It is in the Members’ best interest to continually monitor the hearing of its seagoing employees and so to initiate schemes to carry out clinical examinations such as Otoscopy; Weber’s test; Rinne’s test (Tuning fork) every eight months. 


By implementing these recommendations the Club hopes its Members can improve the conditions of their sea-going staff and help to negate the dangers of hearing loss and prevent any future claim in this area.


Stowaways finding more creative ways to board ships

“With the migrant crisis in the Mediterranean and the media attention this continues to receive, it is often easy to forget that the problem of stowaways is still a very real problem for shipowners,” says UK P&I Club Claims Executive Amanda Hastings. “The majority of these stowaways are finding more creative ways in which to board ships.” 

“In addition to conducting thorough stowaway searches in accordance with the ship’s ISPS Code compliant security plan, and being vigilant whilst in port, additional precautions may need to be taken due to ship design,” notes Ms. Hastings. 

  • Ships with a design that leaves the rudder trunk exposed should consider retrofitting bars across the rudder trunk. This will help deter stowaways from entering the ship, as it will block the access route.
  • When a stowaway is discovered, their presence must be made known to the owners, port agents and the P&I Club. The stowaway and the area where he or she was discovered should be searched and findings noted/photographed. Stowaways should be questioned and a stowaway questionnaire filled out.
  • The Master should also produce a statement of the incident, confirming whether or not preventative procedures were followed. Some jurisdictions, such as Brazil, will require a sworn translation of this document in advance of the ship’s arrival.

 “Although there is currently no international regime dealing exclusively with stowaways, there are several international instruments that apply,” says Ms. Hastings. “These include the UN Declaration on Human Rights, the European Convention on Human Rights and the FAL Convention.  Shipowners should take care to ensure that stowaways are not subject to degrading or inhumane treatment whilst on board, and should be provided with water, food, clothing, medical treatment (if required) and accommodation. 

“Shipowners should also be aware of the potential costs of disembarking stowaways, for example in Brazil, a straightforward repatriation can cost upwards of US$30,000 per stowaway. This figure can quickly increase if the stowaway is detained for any particular length of time. Costs for shipowners can also be incurred, depending on the jurisdiction, through immigration fines, medical testing, police escorts, cost of travel documents, detention costs and repatriation expenses such as flights and additional clothes.

“Stowaways can often result in unexpected expenses for shipowners and the issue is unlikely to go away. As ship security improves, stowaways will find more creative ways of boarding ships. If a stowaway is discovered once the ship has left port, dependent on location, shipowners may find it more cost effective to return to port and disembark the stowaway there, rather than risk higher costs in other jurisdictions, such as Brazil.”

Safety: The Unseen Killer


A shift in the approach to safety management of enclosed spaces on board ships is needed. Fifteen years ago, while working as an independent surveyor, I was carrying out a condition survey on board a bulk carrier. The scope of the survey included testing the emergency generator, located in the steering flat and accessed by an inclined ladder.

Accompanied by the superintendent and the chief engineer, we had no sooner reached the bottom of the space when the chief engineer urgently ordered us all out. By the time we had exited the space, within seconds, we were all in a state of dizziness and confusion, compounded by our inability to comprehend what had just occurred. Further investigation revealed that Freon gas had leaked from refrigeration machinery located in the steering flat and being heavier than air, had migrated into the emergency generator space, displacing breathable air. It was a lucky escape. Victims of asphyxiation in enclosed spaces deficient in oxygen will normally receive no such warning that anything is wrong or have the ability to quickly escape.

Should we have been aware that this emergency generator space, not being enclosed in the usually perceived sense of the word, was potentially dangerous for entry? Absolutely.

The International Maritime Organization (IMO) currently defines an enclosed space as having any of the following characteristics:

  1. Limited openings for entry and exit;
  2. Inadequate ventilation; and
  3. Is not designed for continuous worker occupancy, and includes, but is not limited to, cargo spaces, double bottoms, fuel tanks, ballast tanks, cargo pump-rooms, cargo compressor rooms, cofferdams, chain lockers, void spaces, duct keels, inter-barrier spaces, boilers, engine crankcases, engine scavenge air receivers, sewage tanks, and adjacent connected spaces. This list is not exhaustive and a list should be produced on a ship-by-ship basis to identify enclosed spaces.”

Most could be forgiven for not considering our generator space to fall within this definition, although it was clearly proven to present a danger in a particular circumstance.

Another very common example of confusion over what actually constitutes an “enclosed space” is the inconsistent perception of the dangers presented by CO2 fixed fire extinguishing system cylinder storage rooms. A leak in the system may accumulate in the space and displace breathable air if not thoroughly ventilated.

Carbon dioxide (CO2) rooms are frequently not identified as enclosed spaces on board and not provided with appropriate warning signs at the space access. Crew members may easily fail to appreciate that a CO2 room should properly be included within the aforementioned definition of an enclosed space.

No atmosphere hazard warning notice
The IMO list of enclosed spaces is not exhaustive, it is therefore important that ship managers and crew apply a wide interpretation as to what spaces on board each vessel could potentially be deficient in oxygen, and/or contain flammable and/or toxic gases or vapours, therefore requiring safety precautions to be observed prior to entry.

The dangers associated with enclosed spaces are well known yet deaths continue to occur.

Part of the issue may be misconceptions as to what spaces are or may become dangerous, and how they are identified. At present, there is no industry standard for the design and siting of warning notices and symbols that may be universally understood by ship and shore personnel. Indeed, on many ships, no attempt is made to provide any such labelling at points of access.

Cargo hold access – No warning notices
Warning notices alone will not overcome the problem as otherwise professional and well trained seafarers continue to enter enclosed spaces. In May last year, three crew members on board a cargo ship lost their lives after entering a cargo hold loaded with sawn timber, a cargo known to cause oxygen depletion.

Another part of the solution must also lie in improved levels of education and training of both ship and shore personnel. Reference is made to IMO Resolution A.1050(27) “Revised Recommendations For Entering Enclosed Spaces Aboard Ships” adopted in 2011. These recommendations provide, inter alia, that shipowners must adopt a comprehensive safety strategy to prevent accidents on entry to enclosed spaces, and that procedures for enclosed space entry are included among the key shipboard operations concerning safety of personnel and the ship. The recommendations also provide that no person should open or enter an enclosed space unless authorized by the master or the nominated responsible person, and unless the appropriate safety precautions laid down for the particular ship have been followed.

Despite the training requirements included in the above revised recommendations, IMO has recognized that more needs to be done to respond to the continuing loss of life from personnel entering shipboard enclosed spaces. This has taken the form of amendments to SOLAS regulation III/19 “Emergency training and drills”, which entered into force on January 1, 2015, and requires that enclosed space entry and rescue drills are to be conducted at two month intervals. The amendments include the following:

“3.6 Enclosed space entry and rescue drills

3.6.1 Enclosed space entry and rescue drills should be planned and conducted in a safe manner, taking into account, as appropriate, the guidance provided in the recommendations developed by the Organization [i.e. Resolution A.1050(27)] .

3.6.2 Each enclosed space entry and rescue drill shall include:

.1 checking and use of personal protective equipment required for entry;

.2 checking and use of communication equipment and procedures;

.3 checking and use of instruments for measuring the atmosphere in enclosed spaces;

.4 checking and use of rescue equipment and procedures; and

.5 instructions in first aid and resuscitation techniques.

4.2 Every crew member shall be given instructions which shall include but not necessarily be limited to:

.5 risks associated with enclosed spaces and on board procedures for safe entry into such spaces which should take into account, as appropriate, the guidance provided in recommendations developed by the Organization.

In addition to these welcome changes, the IMO has recently seen fit to rectify the anomaly that until now, no industry wide requirements have been in place, requiring all vessels to carry atmosphere testing instruments.

For all of this to be effective, it is necessary that ship staff, with the support of shore management, perform mandatory drills, training and actual entry procedures with a dedication and seriousness that reflects the dangers that attend enclosed space entry. A Permit to Work must be fully completed and signed off at the site of the task so that it is contemporary and reflects the actual hazard and safety needs of the operation. All too often, On every occasion before carrying out a job, pre-work meetings or “tool box talks” need to be arranged to identify who does what, the tools needed to identify the risks involved and what to do if something goes wrong.

Drills and training should be properly planned and be used as an opportunity to assess the challenges of rescue from the variously identified enclosed spaces on board. Training should also emphasize to crew the importance of raising the alarm when persons are found to be in difficulty within an enclosed space, and that any rescue is properly coordinated in accordance with practiced procedures.

Comprehensive record keeping and interactive post drill de-briefs will assist in identifying any weaknesses in procedures and promote crew ownership of the training program.

Last but not least, a zero tolerance culture to unplanned and unprepared entry into any enclosed space requires to be rigorously enforced and ingrained into all personnel, on board and ashore.

—By David Nichol, Risk Assessor, UK P&I Club