Fumigation Risks On Board Vessels

Paper CCC 11/5/6 ‘Fumigation-related casualties’ was submitted to the IMO this month as a joint document between several competent authorities and IMO recognised non-governmental organisations. It lists 31 incidents, 25 of which involved workplace fatalities.

The report notes that “At least 46 seafarers and shore workers have lost their lives after being exposed to hazards associated with the fumigation of cargo holds” since the Recommendations on the safe use of pesticides in ships applicable to the fumigation of cargo holds (MSC.1/Circ.1264) was drafted in 2008.

The predominant cause of death in the data is exposure to fumigant. There were also a smaller number of fatalities associated with fumigation related fire or explosion.

Fumigant not contained

At least ten incidents evidenced a ‘lack of effective physical barriers between fumigated cargo space and accommodation’.

Twenty five seafarers died when fumigant entered their accomodation during the voyage; with thirteen fatalities in a single incident. This highlights the critical importance of vessel inspection and maintenance as well as understanding the vital need to appropriately and effectively contain the fumigant at all stages of the process.

Symptoms

In at least thirteen incidents, crew were for a time unaware that they had been exposed to fumigant; their initial assessment of symptoms were food poisoning or seasickness. This may have prevented them taking earlier action to protect themselves and their colleagues.

The carbide/garlic smell present in the phosphine which might have served as a warning to those being exposed was not noticed or recognised in almost all the casualties.

Testing Frequency

In at least eleven incidents, the prescribed 8-hourly frequency of testing did not effectively detect the presence of phosphine before crew were exposed to lethal levels of fumigant.

Single Point Testing

Three incidents showed that the measurement of the atmosphere at a single point was insufficient to prevent casualties and that ‘pockets of fumigant’ may not be detected.

Provision of equipment capable of continuous monitoring could contribute to improved safety. Work processes should take into account the practicalities of what the operator is expected to do in the workplace and include the necessary training to conduct the task effectively.

Cargo certified ‘gas free’

In two incidents the risk was not eliminated when the spent fumigant was removed and the cargo certified as “gas free”.

Multiple Hazards

In at least eight of the incidents, the fire and explosion risk posed by fumigants is not limited to handling of fumigant remnants.

Six cases showed that controls that “focus only on a single hazard are not effective at mitigating risk. Exposure to fumigant is not the only hazard associated with the carriage of fumigated cargoes.”

Ways forward

The report proposes “four key areas where change would improve safety for people exposed to the hazards created by the fumigation process.”

Provide gas detection equipment capable of continuous and reliable monitoring.As fumigants are acutely toxic, exposure to high concentrations causes immediate effects. Periodic monitoring may not detect the presence of fumigant before fatal exposure. Detection equipment capable of continuously monitoring for phosphine and other gases, are “readily available at a cost that is only marginally higher than for a manual pump.”

None of the casualty investigation reports found that the holds were tested for gas tightness prior to loading. The proposal is that where the fumigator-in-charge cannot determine that the cargo can be made sufficiently gastight, there should be further controls on all spaces where people are at risk e.g. additional, continuous, gas monitoring.

In some cases, crews were not sufficiently aware of the risks of carrying fumigated cargo, including exposure symptoms and appropriate actions. The paper suggests making the fumigator-in-charge responsible for briefing the crew directly to help standardise training by the person most qualified to deliver it. This briefing should include an understanding that fumigant may be present in the cargo and/or trapped in the hold even after the cargo is discharged.

Finally, the paper notes that ‘fumigation hazards are not limited to exposure to the toxic gas’. Fumigated cargoes may be oxygen depleting. There is also a fire or explosion risk throughout the voyage. Phosphine is flammable, highly reactive and prone to self-ignition in relatively low concentrations. Over-pressurization can lead to explosion in the early fumigation stages. So application of the fumigant needs to be carefully planned to avoid over-pressurisation and avoid ignition.

Conclusion

The paper argues that an update and combining of:

Recommendations on the safe use of pesticides in ships (MSC.1/Circ.1358)
Revised recommendations on the safe use of pesticides in ships applicable to the fumigation of cargo transport units (MSC.1/Circ.1361/Rev.1)

would provide a ‘significant benefit’ and that this could be progressed via a new output to MSC 111 in May 2026.

Footnote

It is ICHCA general policy not to list countries and organisations that submit IMO papers unless it is an ICHCA joint paper with all stakeholders giving their permission. This is in order to be respectful of IMO confidentiality and working processes. A limiting consequence of this, is that we are unable to give full credit here to those contributors for their diligent and constructive work. Our thanks to all of those involved. To any readers with access to the IMO documents system, we encourage you to consider the full CCC 11/5/6 paper.

JonM2025-09-04T12:58:25+01:00September 4th, 2025|