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The Maritime Disciplinary Court of the Netherlands:

Focal Points Accident and damage prevention > Safety Committee

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Multi Purpose General Cargo vessel < 3000 gt [1]

It is recommended to explicitly mention in the safety protocols and draw attention to in the safety meetings that working on/from hatches not secured on all sides poses safety risks, and a height of more than 2.5 metres falls under the concept of 'working at heights', which is subject to safety regulations. From a safety point of view, loading supervision is (therefore) best done from the hatch crane. If that is impractical and the space on the (stacked) hatches is used for that reason, a fall protection device is required.