Hot Work Safety Risks on Ships Are Being Controlled. Until They Aren't.
Updated: Feb 25
Everybody Wants to Be Covered
Every officer, manager, DPA and crew member wants to be covered. And even more importantly, everybody wants to stay safe.
While reviewing documentation at office, the system often looks solid. There is Permit-to-Work, there is Risk Assessment and the emergency preparedness procedures exist, in case something would go wrong. Company complies with the ISM Code and recent audits didn’t mention deficiencies. Therefore, company is covered. On paper, hot work safety risks are controlled. And most of the time they are.
Until they aren't.
Hot Work Remains a Leading Cause of Serious Casualties
Despite layers of procedures, hot work continues to feature in engine room fires, cargo hold explosions and shipyard fatalities. Multiple maritime safety studies recognize hot work as a hazardous process that causes many accidents onboard ships, and even today, remains one of the leading causes of shipboard fires, explosions, and fatalities, especially when control verification fails. ()
Long-term fire and explosion accident reviews confirm that such incidents remain persistent in maritime transport, with human error and maintenance activities among significant contributing factors.
Due to the unexpected nature of fire and explosion incidents, which leaves little time for evacuation of crew and passengers, number of fatalities from such occurrences is often found to be comparatively higher than other types of accidents. (National Research Council, 1991)
Another study concluded that due to the instantaneous nature of ship fires, in the absence of appropriate protection and response procedures even a minor error leading to fire or explosion event can potentially lead in the loss of vessel, environmental pollution incident, injuries, and deaths (Shichuan et al., 2012).
One study from 2016 identified five causal factors in fire and explosion events in tankers transporting hazardous liquid cargoes between 1999 and 2013. These factors were violation of entry permit, violation of work permit (VWP), lack of risk analysis (LRA), deficiency in safety management system, and deficiency in planned maintenance system. Author of the study argued that hot works among electric arcs, static electricity and combustible gas accumulation are the most causes of fires and explosion accidents in tankers transporting hazardous liquid cargoes, and that lack of risk analysis and violation of work permit are the main causative factors.
DNV states in their article from year 2023, that engine room fires, common locations for hot work, have not declined in recent years and continue to be a major risk area.
Furthermore, regulatory safety data indicates that hot work–related activities account for a substantial proportion of shipyard fatalities due to fires and explosions.
Collectively, these findings support the conclusion that hot work remains a major hazard where control measures, not just forms, determine safety outcomes. Investigations across flag states and classification societies show the same theme: Procedures exist, forms are signed, and toolbox talks are conducted. Nevertheless, fires break out, sometimes with irreversible outcomes.
Danger from hot works does not stem from the lack of rules or paperwork. Danger comes from the fast compounding of small control failures.
The Regulatory Framework Is Clear
The maritime industry is not short on guidance.
SOLAS Chapter II-2 – Fire Protection
Requires effective fire prevention, detection, and extinguishing arrangements onboard.
International Safety Management Code (ISM Code)
1.2.2 – Establish safeguards against all identified risks
7 – Develop procedures for key shipboard operations
8 – Establish emergency preparedness
International Maritime Organization Guidance
Various circulars and industry publications outline safe hot work practices, enclosed space considerations, and control measures. From a compliance standpoint, the expectations are not ambiguous. Hot work should be, and for the most part, is controlled. On paper. But the real question is, whether the hot work operation is actually controlled.
Hot Work Safety Fails in Practice, Not in Theory
Hot work incidents rarely happen due to lack of procedures. They happen because:
The Risk Assessment was generic
The Permit to Work became mechanical
The crew was familiar and relaxed
A copied risk assessment does not identify the specific insulation behind a certain bulkhead. A signed work permit does not guarantee gas testing was done correctly. A toolbox talk does not eliminate complacency. Over time, repetition creates confidence, which slowly replaces alertness. This phenomenon is called “risk habituation”, which especially develops in deficient safety cultures. And this is where controls start to degrade.
Shifting From Documentation to Verification
For DPAs and technical managers, the uncomfortable truth is this: Hot work is not primarily a paperwork issue. Instead, it is mainly a control verification issue.
A robust system must ask:
Is the Risk Assessment job-specific and dynamic?
Does the PTW require physical verification, not just signatures?
Is atmosphere testing documented and understood?
Are fire watches trained, briefed, and empowered?
Is emergency response rehearsed for this scenario?
The ISM Code asks for safeguards against identified risks, not filled forms. And safeguards don’t work if they only exist in paper.
Strengthening Control at Three Levels
If hot work is to remain controlled, the system must function at all three levels:
1. Risk Identification
Move beyond generic hazard libraries. Ensure the assessment reflects the exact compartment, cargo condition, ventilation status, and adjacent spaces.
Hot work is not a static low-risk routine job for which the associated risks can be assessed six months advance on a generic table. Risks must be identified and evaluated for the exact location, for given time period on prevailing conditions.
2. Control Verification
Permit to work must require confirmation of:
Gas testing results and frequency
Isolation measures
Fire watch positioning
Communication methods
Post-work monitoring period
Verification is not an administrative box-ticking task. It is an active confirmation that the necessary controls (regular ones, and the ones identified by the Risk Assessment for the specific job) are in place.
3. Operational Ownership
Control integrity depends on who feels responsible for the barrier. Hot work controls may be documented, reviewed, and approved, yet, they still weaken if ownership is diffused.
Key questions include:
Do crew understand why each barrier exists?
Do crew consider the work procedures as practical control tools or do they find them primarily as administrative requirements?
Are deviations challenged immediately, or are they rationalized?
Is supervision actively maintaining control or merely observing compliance?
When responsibility becomes procedural instead of personal, barriers degrade. If ownership is not embedded at the operational level, control remains theoretical.
The Cost of Assuming We Are Covered
When hot work control becomes routine, near misses go unreported, deviations become normalized, gas testing intervals start stretching, fire watches become distracted, work permits become a box-ticking exercises and so on. The vessel still appears compliant on paper, but in the practical level, probabilities are working against you.
Most vessels and companies are compliant on paper. The procedures might look slightly off, or they might even look quite good, but more often than not, even the good-looking procedures fail to guide the work in reality.
This is how the accidents develop. It is not through one reckless act or because someone “ignored the rules”. Rules and permits start to become ignored when the crew feels that they are not designed for the actual job. When the paperwork and the safety culture in the company are not encouraging thorough assessment of hazards and proper reporting of safety issues.
This disengagement between the paperwork and the actual job leads to generic completion of the forms. Instead of using risk assessment and work permits as tools for thinking, and as structured and documented verification, the real decision-making starts happening informally.
This is where the danger lies.
When the documented procedures are no more guiding the actual controls, the quality of paperwork can begin to mask the quality of safety. It may appear that the officer who completes the permits with greatest precision is the safest one onboard. In reality, since the thinking and hazard control are happening outside the documented system, unchallenged and unshared, that precision becomes cosmetic.
Because safety is not measured by how cleanly a permit is filled in. Instead, it is measured by whether the documented system is genuinely shaping the decisions that prevent accidents.
What Real Control on Ships Looks Like
On an effective safety management system, documentation is not done for the sake of the documentation itself. On an effective system, documentation shapes the job.
Work permits are not there to collect signatures. Risk Assessments are not just templates to be printed and filed. They both are living documents that reflect the specific task, specific location, and specific controls and verifications. Furthermore, when the safety system is effective, crew feels comfortable challenging assumptions, and they are actively encouraged to speak up when something feels off. This then further strengthens the overall safety and alertness of the crew.
In such an environment, hot work remains controlled.
Not because the paperwork exists, but because the paperwork describes the actual controls, which are then physically verified, collectively understood and actively used. And that is the difference between compliance and safety.
The question that everybody should ask for themselves: Is our system built to establish control and maintain safe operations, or is it built merely to document it?
And that is the difference between compliance and safety.
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