we have received the following obs from a MOC:
Inspectors Comments: Ship’s staff applied company policy recording gas atmosphere before entering, if ventilation stopped and if personal left the enclosed space for more than 30 minutes. Personal in enclosed space was equipped with a multi gas analyser for continuous monitoring and a portable gas detector was installed at the entry hatch.
Inspector Observations: There was no gas atmosphere records carried out at regular intervals in Enclosed space entry permit C/L while personal was into CTK 1S on 27 July 2013 between 12h36 and 15h00 and also on 30 July 2013 in CTK 2S between 08h44 and 11h50.
As stated in the inspectors comments the gas measurements were continuously obtained during the enclosed space entry with a gas analyser situated at the entrance hatch and by personal gas meters used by every person entering the enclosed space. This fully fulfils the requirements stated in chapter 10 of the ISGOTT from my understanding
QUOTE ISGOTT 10.3
Regeneration of hydrocarbon gas should always be considered possible, even after loose scale or sludge has been removed. Continual checks on the atmosphere in the space should be made as specified in the Safety Management System.
UNQUOTE ISGOTT 10.3
All personal gas meters used by crewmembers, which have entered the enclosed space and the gas analyser situated at the tank hatch allow to display peaks and averages of gases measured. Furthermore the values of the analyser situated at the tank hatch was monitored continuously by the person supervising entry.
From my understanding this fully satisfies ISGOTT requirements and this procedure was explained by the Master to the inspector. The requirement to manually document the measurements at specified time intervals seems to reflect the personal opinion / interpretation of the attending SIRE inspector rather than an industry necessity. Furthermore in addition to that we deem the procedure of continuously monitoring the values and logging them in the gas analyser unit as a much more accurate procedure to fulfil ISGOTT chapter 10.3 than taking one measurement at defined time interval.
Inspector Observations: there was a workshop installed in the starboard midship store.
The inspector found / observed tools in the stb midship store. This store contains the tank cleaning pump / heater and equipment for tank cleaning.
Form my point there is no requirement in industry guidelines which would prohibit this?
Could you kindly share your opninion on the obs above.