Health and Safety Executive

Personal buoyancy in recreational watersports

AALS Inspector Guidance Note - IGN 7.03

  • Version No & date: 1 - 06/05/2009
  • Review date: 05/2012

Issue: Providers need to make appropriate buoyancy aids (correctly called personal floatation aids) available for participants1.

Introduction

This Guidance Note assists inspectors with the identification of the appropriate selection of lifejackets and buoyancy aids for use in recreational watersports. It will also assist providers with the selection of appropriate devices.  The Adventure Activities Licensing Service (AALS), the Health and Safety Executive in its capacity as the Adventure Activities Licensing Authority (HSE), the British Canoe Union (BCU) and its related home-nation organisations, the Royal Yachting Association (RYA) and its related home-nation organisations, the Royal Society for the Prevention of Accidents (RoSPA) and other stakeholders have agreed this document.

Existing documentation

Recent developments have revealed a range of interpretations of existing standards when applied to recreational watersports, which this guidance note addresses.

A series of British Standards BS EN 393 – 399 (1994) existed which covered the entire range of operational possibilities, including all work and non-work situations.

A Health and Safety Executive Agricultural Information Sheet (HSE/AS1) summarises the situation for work-related activities such as fish farms, floating cage units, mussel rafts, farm or estate fisheries and similar activities.  It is not relevant to recreational watersports.

Devices manufactured before (approximately) 2005

The industry norm for most recreational watersports is the 50N buoyancy aid for which the relevant British Standard was BS EN 393 (1994).  This states:

'European Standards exist for a range of buoyancy garments, of which this standard (BS EN 393) is just one. The four are each intended as being suitable for different activities in different risk situations, and include:

  1. 275 Newtons lifejackets – these have a buoyancy of no less than 275 Newtons for the average adult and are intended for use offshore in extreme conditions, when heavy protective clothing is being used, or loads such as toolbelts are being carried (see EN399);
  2. 150 Newtons lifejackets – these have a buoyancy of no less than 150 Newtons for the average adult and are intended for use offshore or when foul weather clothing is being used (see EN396);
  3. 100 Newtons buoyancy aids – these have a buoyancy of no less than 100 Newtons for the average adult and are intended for use in relatively sheltered waters (see EN 395).
  4. 50 Newtons buoyancy aids – these have a buoyancy of no less than 50 Newtons for the average adult and are intended for use in sheltered water when help is close at hand and the user is a swimmer, in circumstances where more bulky or buoyant devices would impair the user’s activity or actually endanger him.'

N.B.

  1. The stated intended use in (d) does not match with the industry norm in recreational watersports;
  2. The statement is grammatically unclear as to whether it means non-swimmers and or where more bulky devices would impair.  However, the syntax used in HSE/AS 1 is less ambiguous; '… and the user is a swimmer; and in circumstances where more bulky ...'.  This clearly indicates an either/or situation.  This is the clause which acknowledges that a 50 Newton device can be appropriate in recreational watersports.

EN 393 did not define relatively vague terms such as ‘sheltered’, ‘relatively sheltered’, ‘swimmer’ or ‘close at hand’.

The major watersports NGBs (the Royal Yachting Association and the British Canoeing Union) and the Adventure Activities Licensing Service agreed that 50 Newton buoyancy aids were still considered to be the most appropriate device in most watersports situations.  These bodies, in consultation with the AALA and RoSPA have now reviewed the situation in the light of the current ISO 12402 standard on personal flotation devices (which has superseded EN393).

Devices manufactured after (approximately) 2005

Between 2005 and 2007 a single British Standard BS EN ISO 12402 (2006) was introduced to replace EN 393 – 399.  Section 4.4, paragraph 3 of the new standard states, 'In principle, national bodies, in particular those responsible for making recommendations, should be left to determine what is appropriate for the activities under their jurisdiction.  The advice of such bodies should be sought by groups, clubs or authorities in order to select a suitable device'.  It is in the context of this statement that this guidance has been prepared to assist those who use personal flotation devices in recreational watersports.

Watersports-specific requirements

In recreational watersports most people who have drowned were either not wearing a buoyancy aid of any type, were trapped underwater or both.  It is therefore the absence of a flotation device which is the main issue in recreational watersports not the type.  One aim of revisiting standards for personal flotation in watersports is to encourage a wider use of them, and appearance, comfort and mobility are important factors.  In recreational watersports, factors other than the ability to support the wearer are also relevant. These include:

  • Freedom of movement when not immersed in water.  Bulky devices can inhibit movement and visibility, and additional straps and attachments pose a risk of entanglement, so increasing the chances of an incident;
  • Freedom of movement when immersed in water.  Bulky devices can inhibit movement and visibility so as to make self-rescue or an assisted rescue difficult or impossible.  Movement through the water will also be inhibited thus inhibiting self-rescue or evacuation;
  • The ability to submerge.  The need to ‘duck’ under the surface is not unusual in recreational watersports.  This may arise, for example, when trying to escape from the air pocket underneath an upturned dinghy, or to escape from a ‘stopper’ wave in white-water kayaking;
  • Correct and simple fitting and adjustment to prevent the device slipping (and possibly impairing movement significantly) or coming off altogether;
  • The degree of physical protection (padding and/or warmth) which the device offers.  This is most significant in sports such as white-water kayaking, sea level traversing, or dinghy sailing;
  • Limited reliability.  No personal flotation device will ‘drown proof’ the wearer.  Drowning in recreational watersports can still occur, often associated with exhaustion, hypothermia, impact, unconsciousness, entrapment or a pre-existing medical condition.  Even a ‘lifejacket’ with 275 Newtons of flotation does not guarantee freedom from drowning, so prompt recovery (either self- or assisted) is generally more significant in recreational watersports than the amount of flotation.  Indeed the label specified by BS EN ISO 12402-10 includes the wording 'WARNING: FLOTATION DEVICES ONLY REDUCE THE RISK OF DROWNING, THEY DO NOT GUARANTEE RESCUE';
  • The ability to attract attention.  It should be noted that whistles are notoriously ineffective into the wind, lights are of limited value during the day, and flares are more likely to cause harm than prevent it.  It would be common therefore for many recreational watersports participants to wear devices fitted with NONE of these features.
  • Additional features.  Crotch straps prevent the device riding up but present a significant ‘snag hazard’.  Spray hoods can provide additional protection from wind and wave action, but reduce visibility as well as presenting a significant ‘snag hazard’.  Harnesses can be extremely hazardous and so D-Rings on lifejackets and buoyancy aids should only be used by those who have been appropriately trained.  It would be common therefore for many recreational watersports participants to wear devices fitted with NONE of these features;
  • Additional flotation.  Additional flotation in some recreational watersports is often provided in the form of wet-suits, other floating attachments such as spray decks and harnesses, or even purpose-designed floating clothing.  These will effect both the overall flotation available and its distribution.

These factors are all dealt with in the helpful introduction to BS EN 393, etc and a similar approach is set out very clearly in BS EN ISO 12402-10. 

Because of the conflicting factors of manoeuvrability, bulkiness and flotation, in recreational watersports it is generally desirable to wear as little flotation as is necessary, rather than as much flotation as is possible.  So opting for lifejackets may at times cause more problems than it solves in recreational watersports.

Most recreational watersports enthusiasts have become used to the stylish, low-cut, functional buoyancy aids of the modern era with little or no adverse effect on safety.  A return to bulky, bright orange devices would be detrimental to this positive trend.  In some craft it is common practice to carry personal buoyancy devices but not wear them unless needed.

Definitions used within this guidance note

Swimming ability - within the context of this guidance the ability to swim should be interpreted as the ability to swim whilst wearing the device in question.  The ability to swim whilst not wearing the device is generally irrelevant (many strong swimmers drown in situations where they might have been expected to survive comfortably).  The ability to swim even whilst wearing personal flotation may not be possible for medical reasons, (eg quadriplegia), because of also wearing heavy or restrictive work equipment (eg tool belt or climbing belt), or heavy clothing (eg heavy weather gear).  As a minimum, the ability to swim whilst wearing personal flotation can mean being able to remain upright, turned away from the weather, and make progress forward.

Flotation - total flotation needs to take into account other flotation being worn by the participant, or accessible to them.

Help is close at hand - this would include other craft if they can be used to perform either an assisted or unassisted rescue.  It should also include the casualty’s craft (upturned or otherwise) if it will remain afloat in the immediate vicinity of the participant following a capsize or similar event, and allow the casualty to hold onto it, or attach themselves to it.  This gives rise to the golden rule of ‘don’t leave your craft as long as it is afloat and the craft itself is in no imminent danger’.  This definition would include most canoes and kayaks, small dinghies and windsurfers.  It would not generally include motor craft not fitted with kill-cords, yachts etc which may continue on their way without crew.  Help will also be considered close at hand if a self-rescue, assisted rescue or casualty recovery can be promptly performed.  Groups in the company of appropriately competent instructors, whether or not in a dedicated rescue boat, can always be considered ‘close to help’.  Help would generally not be considered ‘close at hand’ if it were necessary to signal that help was required such as by whistle, flare or hand signals.

Unexpected immersion - trying to swim or cooperate with rescuers is often extremely difficult once someone has unexpectedly fallen into water.  However, providing a buoyancy device is worn it is seldom dangerous.  Water confidence is therefore more significant than an ability to swim.  Even where immersion was expected, many people will still panic, at least initially, in spite of being competent swimmers.  Consequentl,y even a high level of swimming ability is not generally justification for not wearing personal flotation in most recreational watersports.

Self rescue, assisted rescue and casualty recovery:

  • Self rescue – eg roll and empty, or paddle support entry in sea kayaks, flick empty and re-entry in an open canoe, or right and re-entry in a dinghy;
  • Assisted rescue – eg standard kayak X rescue, or assistance from a rescue boat to right and re-enter the craft;
  • Unassisted rescue – eg recovery of an unconscious or an incapacitated casualty.

BS EN ISO 12402 as applied to recreational watersports

Lifejackets - these devices provide face-up flotation with levels of support sufficient for various open and rough water uses.  Lifejackets have a buoyancy distribution sufficient to turn most users, when tested on users wearing swimming costumes according to ISO 12402, to a position where the mouth has a defined freeboard above the water’s surface, even when the user is unconscious.

N.B. This still will not drown-proof the wearer in anything other than extremely calm conditions.  Use: Normally stowed ready for emergency use.

275 Newton lifejacket:

  • This device can have inherent slab buoyancy with air or gas top-up facilities, or gas inflated (either manually or automatically) from a built in CO2 cylinder.
  • Normally stowed ready for emergency use.
  • This device is intended primarily for offshore use under extreme conditions.  It is also of value to those who are wearing clothing which traps air and which may adversely affect the self-righting capacity of the lifejacket.
  • See ISO 12402: Part 2.

150 Newton lifejacket:

  • This device can have inherent slab buoyancy with air or gas top-up facilities, or gas inflated (either manually or automatically) from a built in CO2 cylinder.
  • It is for continuous use on or near the water as opposed to emergency use.
  • It is intended for general application or for use with foul weather clothing, yachting or motor cruising when the decision to wear personal flotation has been taken by the skipper or other.  It is suitable but not essential for general offshore and heavy weather sailing when harnesses and lifelines may be used.  It is also suitable for sailing in poor visibility when there is an increased risk of collision, or operating a small power boat or tender other than a rescue boat.
  • See ISO 12402: Part 3.

Buoyancy aids - these devices should be comfortable for continuous wear and provide lift, without significant face-up turning ability, to float the conscious user with the level of support marked on the device.

100 Newton buoyancy aid;

  • This device can have inherent slab buoyancy with air or gas top-up facilities, or gas inflated (either manually or automatically) from a built in CO2 cylinder.
  • It is intended for those who may have to wait for rescue, but are likely to do so in sheltered water. The device is not designed for use in rough conditions.
  • The device is of limited use in recreational watersports. The disadvantages of reduced manoeuvrability, reduced visibility, additional snag hazard, and increased bulkiness outweigh any advantage from increased flotation.
  • See ISO 12402: Part 4.

50 Newton buoyancy aid:

  • This device has inherent slab buoyancy only.
  • It is intended for continuous use on or near the water. It has minimal bulk, and cannot be expected to keep the user safe for a long period of time.  They do not have sufficient buoyancy to protect people who are unable to help themselves.  They require active participation by the user.
  • Provided that the above limitations can be accommodated this device is suitable for most dinghy sailing, windsurfing, canoeing, kayaking, waterskiing, personal watercraft (‘jet-skis’), and similar activities on sheltered water (as defined above).
  • See ISO 12402: Part 5.

1 Adventure Activities Licensing Regulations 2004, regulation 9(b)(iii) and (iv)


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