To:

All OSD Band 1-3 Inspectors

Purpose

• Purpose
• Background
  • Auto-inflating lifejackets
  • Recent problems
  • Lifejackets for overside working
  • Abandonment lifejackets
  • Competence/training implications
• Recommendations (advice to the IMTs)
• Further information
• Appendix 1: Proforma letter to duty holder
• Table 1: Summary of some safety alerts about auto-inflating lifejackets
• Appendix A: Safety alert - Inflatable lifejackets fail to inflate
• Appendix B: Extract from SADIE safety alert 437

Purpose

This note provides advice to HSE Offshore Division Inspection Management Teams (IMTs) in the light of problems with marine auto-inflating lifejackets.

There are two main uses for auto-inflating lifejackets on offshore installations:

• for overside working.
• as part of PPE (personal protective equipment) for platform abandonment.

It is likely that every offshore duty holder will employ marine auto-inflating lifejackets in one or both of the above functions.

Compared with inherently buoyant lifejackets, auto-inflating lifejackets have a number of advantages, including reduced bulk, reduced damage to an individual falling from a height, and (often) the inclusion of a spray guard. However, in the marine and offshore sectors there have been occasions in the last two years when auto-inflating lifejackets either have not, or would not have, operated when required. This indicates that particular care should be given to how auto-inflating lifejackets are used and inspected.

It is likely that many offshore duty holders already give adequate attention to the use and inspection of auto-lifejackets and will avoid the recent problems. This note identifies some simple checks to help confirm this. This note is also intended as a means of ensuring that duty holders are fully aware of the recent problems with auto-inflating lifejackets. This note may be given to duty holders.

This note does not address the following:

• aviation lifejackets.
• lifejackets incorporated into survival suits
• lifejacket design issues such as whether the lifejacket provides an adequate spray guard, or is compatible with a particular survival suit.

Background

Auto-inflating lifejackets

1. This note applies to marine auto-inflating lifejackets which are fitted with one or two gas cylinders and a device which is activated by entry to the water which causes the gas from the cylinder to be released into the lifejacket.

2. Auto-inflating lifejackets usually have the following additional features:

• Manual activation, by pulling on a toggle or ribbon to release the gas
• Oral inflation, whereby the wearer blows into a tube to inflate the lifejacket.

Recent problems

3. Incidents during the last two years have included:

• A fisherman died when his inflatable lifejacket failed to inflate by manual or auto activation. The lifejackets of three of his colleagues also failed to inflate. Checks on a sample of lifejackets revealed that gas cylinders had become unscrewed so that the release of gas could not be activated.
• A workboat crewman died when the inflatable lifejacket he was wearing failed to inflate. It is suspected that the gas cylinder may have worked loose.
• Lifejacket gas cylinders have been found to work themselves loose in lifejackets worn for scaffolding operations.
• A scaffolder who picked up a lifejacket to wear for overside working noticed that the lifejacket had already been activated, deflated and packed away again, and now appeared to be OK for use.

4. More details of the above incidents, including lessons learnt and recommendations, can be found in the safety alerts listed in Appendix 1 (Table 1).

5. In addition, OSD inspection has indicated that persons offshore are not always sufficiently informed as to how to don or use an auto-inflating lifejacket.

Lifejackets for overside working

6. Lifejackets for overside working are often intensively used, so that there is an opportunity for gas bottles to work loose, and for the lifejacket to get into a poor condition. For this reason, these lifejackets should be subject to a pre-use check before every use. Gas bottle attachment, and general condition of the lifejacket, should both be checked - see Appendix A for more details of recommended checks.

7. It is important that the user knows how to don these lifejackets - a poorly fitted lifejacket can easily come off in the water or become displaced, and therefore be useless.

8. In addition to a pre-use check, overside working lifejackets should either:

1. be inspected/serviced at regular intervals in accordance with the manufacturer's recommendations, or
2. be subject to an equivalent replacement policy.

9. There needs to be adequate arrangements to ensure that an activated overside working lifejacket does not re-enter service before being recharged. Note that procedural checks may need to be more stringent if the lifejacket is not fitted with a gas bottle-activated indicator (available on modern lifejackets).

Abandonment lifejackets

10. It is important that the potential user knows how to don these lifejackets - a poorly fitted lifejacket can easily come off in the water or become displaced, and therefore be useless.

11. The potential user should also know how to manually activate the auto-inflation mechanism, and how to orally inflate the lifejacket. Sometimes the manual activation ribbon is incorrectly packed away under the lifejacket cover, so that it cannot be easily found. For some lifejackets, the location of the oral inflation tube may not be obvious. The potential user should also know how to deploy the spray hood (if fitted).

12. Abandonment lifejackets are unlikely to see much use, so the problem of gas bottles working loose is reduced, and frequent checks on gas bottle attachment are unlikely to be necessary. However, these lifejackets should still be inspected/serviced at regular intervals in accordance with the manufacturer's recommendations for the lifejacket, taking account of their relatively light duty.

13. There need to be adequate arrangements to ensure that an activated abandonment lifejacket does not re-enter service before being recharged. Note that procedural checks may need to be more stringent if the lifejacket is not fitted with a gas bottle-activated indicator (available on modern lifejackets).

Competence/training implications

114. Duty holders will need to assure themselves that the relevant persons have sufficient training/instruction and/or experience to carry out the following:

• to carry out the necessary pre-use check on an overside working lifejacket
• to don an overside working lifejacket
• to carry out inspection/servicing of an overside working lifejacket
• to don an abandonment lifejacket
• to manually activate or orally inflate an abandonment lifejacket
• to deploy the spray hood on an abandonment lifejacket, if fitted
• to carry out inspection/servicing of an abandonment lifejacket

15. Some duty holders rely on video instruction on the use of lifejackets. While this has value, it is recommended that persons under instruction also be given the opportunity to physically don the relevant lifejacket.

16. Lifejacket manufacturers/suppliers should be able to give advice on training for pre-use checks on overside working lifejackets.

17. Persons carrying out inspection/servicing of lifejackets will need to receive appropriate training in this activity. In addition, they will need to have access to manufacturer's safety alerts/bulletins for the lifejacket

Recommendations (advice to the imts)

18. It is recommended that the proforma letter (Appendix 1), or similar, be sent to each duty holder. This contains a simple question set to establish if the duty holder has sufficient arrangements in respect of auto-inflating lifejackets. If the duty holder does not have one or more of the indicated arrangements (i.e. if the answer to one of the questions is "no"), it is recommended that OSD 3.3 be consulted for further advice.

19. If an IMT inspector wishes to inspect the lifejacket arrangements offshore, this could include the following:

1. Establishing whether auto-inflating lifejackets are provided for overside working and/or abandonment.
2. Establishing whether a pre-use check is carried out on overside working lifejackets before every use.
3. A check on gas bottle attachment, and general lifejacket condition, for a sample of overside working lifejackets.
4. Establishing whether personnel are confident about donning, manually activating, and orally inflating the auto-inflating abandonment lifejackets, and deploying the spray hood (if fitted). This can be checked by either
   1. attending an instruction session (either part of the offshore induction or a lifeboat drill) and/or
   2. speaking to a sample of persons, including visitors.
5. A check on lifejacket inspection/servicing records.
6. Activation of one or more lifejackets (assuming the duty holder has some spares).

20. OSD 3.3 may be consulted for further advice.

Further information

Further information can be obtained from: OSD 3.3 (0151 951 3188), OSD 4.8 (0207 717 6921) or from Richard Barwick (Marine Accident Investigation Branch on 02380 395514).

Appendix 1. Proforma letter to duty holder

Dear Sirs,

Auto-inflating lifejackets

Introduction

We are writing to you in the light of some recent problems with marine auto-inflating lifejackets.

Compared with inherently buoyant lifejackets, auto-inflating lifejackets have a number of advantages, including reduced bulk, reduced damage to an individual falling from a height, and (often) the inclusion of a spray guard. However, in the marine and offshore sectors there have been occasions in the last two years when auto-inflating lifejackets either have not, or would not have, operated when required.

A number of safety alerts have been issued as listed in Table 1, which we would like to bring to your attention.

Please could you respond to the questions below, if relevant, by [date] (say, 2 months from date of letter to the duty holder).

Auto-inflating lifejackets for overside working

If auto-inflating lifejackets are used on your installations for overside working, please would you confirm whether:

1. The company has arrangements to ensure that the users know how to correctly don the lifejacket.
2. These lifejackets receive a pre-use check before each use, as per the manufacturer's recommendations and those in Appendix A attached.
3. These lifejackets are inspected/serviced in accordance with the manufacturer's recommendations, or are subject to an equivalent replacement policy.
4. The company has arrangements to ensure an activated lifejacket does not re-enter service before being recharged (see Appendix B).

Auto-inflating lifejackets for platform abandonment

If auto-inflating lifejackets are used on your installations for platform abandonment, please would you confirm whether:

1. The company has arrangements to ensure that all potential users know how to correctly don, manually activate the auto-inflation mechanism, and orally inflate the lifejacket, and deploy the spray hood (if fitted).
2. These lifejackets are inspected/serviced in accordance with the manufacturer's recommendations (taking account of the relatively light duty of these lifejackets).
3. The company has arrangements to ensure an activated lifejacket does not re-enter service before being recharged (see Appendix B).

Yours sincerely

Imt inspector

Table 1. Summary of some safety alerts about auto-inflating lifejackets

Ref.	Date of issue	Title	Brief summary
SADIE 358#	1/10/02	Fatality following failure of auto-inflation lifejackets to inflate	A fisherman died when the fishing vessel Radiant capsized* and his lifejacket failed to inflate by manual or auto activation. The lifejackets of three of his colleagues also failed to inflate. Checks on a sample of lifejackets revealed that gas cylinders had become unscrewed so that the release of gas could not be activated.
SADIE 437#	29/04/03	Work lifejackets	Lifejacket had already been activated, deflated and packed away again, and now appeared to be OK for use. See Appendix B for details. Note the need for arrangements to ensure an activated lifejacket does not re-enter service before being recharged.
SADIE 449#	21/05/03	Inflatable lifejackets	This refers to a fisherman and a workboat crewman who died when the inflatable lifejackets they were wearing failed to inflate. This SADIE alert is based on the MCA Safety Alert attached as Appendix A.
SADIE 453#	26/05/03	Gas cylinders unscrewing in lifejacket.	Lifejacket gas cylinders have been found to work themselves loose in lifejackets worn for scaffolding operations
SADIE 455#	28/05/03	Inflatable lifejackets fail to inflate	This refers to a fisherman and a workboat crewman who died when the inflatable lifejackets they were wearing failed to inflate. This SADIE alert is based on the MCA Safety Alert attached as Appendix A, but omits MCA Learning Point 5.
MCA Safety Alert	May 2003	Inflatable lifejackets fail to inflate	This refers to a fisherman and a workboat crewman who died when the inflatable lifejackets they were wearing failed to inflate. A copy is attached as Appendix A.

Key

* The full Report of the MAIB investigation [PDF 895KB] into the capsize and foundering of the fishing vessel Radiant, including the associated MAIB Safety Bulletin 2/2002,

# The SADIE alerts can be accessed after free registration with Sadie

Appendix A: Safety alert - Inflatable lifejackets fail to inflate

Recently a fisherman and a workboat crewman died when the inflatable lifejackets they were wearing failed to inflate. We suspect that the gas cylinders may have worked loose since the lifejackets were last inspected.

Manufacturers provide instructions and maintenance procedures for inflatable lifejackets which include details of regular and routine inspections.

Learning points:

Owners of inflatable lifejackets should have them serviced and inspected in accordance with the manufacturers' instructions;

Owners should include the servicing and maintenance of inflatable lifejackets within their safety management system;

Users of inflatable lifejackets should be instructed in their use;

Owners should maintain a record of servicing, inspection and the training of users of inflatable lifejackets;

Users of inflatable lifejackets should inspect them before putting them on.
Inspection should include:

6.1 Inspection of straps, buckles and outer cover;
6.2 Inspection of Safety harness, its stitching and buckles;
6.3 Inspection of the inflatable lung for abrasion damage
6.4 Inspection of the gas inflation cylinder for signs of corrosion
6.5 Inspection of the gas inflation cylinder for tightness of connection to the inflation mechanism
6.6 Inspection of the automatic inflation system, if fitted

MCA Aberdeen May 2003

Appendix B: Extract from SADIE safety alert 437

Description:

Recently a scaffolder on one of our Installations picked up a Lifejacket to wear whilst over-side working. He noticed that the Lifejacket had already been activated, deflated and packed away again and it now appeared to be OK for use. He reported the error and obtained a 'good' lifejacket to allow him to continue working.

Lessons learnt:

Although the Installation Safety Officer periodically checks lifejackets to ensure that they are ready for use and within the specified maintenance period, for lifejackets that are used for work activities this may not be sufficient. In addition to end-user checks, items of specialist PPE issued for use on worksites may require special checks to ensure their integrity and functionality.

Recommendations:

1. Specialist PPE should be numbered and registered then inspected by a competent person prior to issue for use. Thereafter the user should be responsible for the integrity of the equipment whilst it is in their custody.
2. All personnel should report non-functioning or poorly functioning PPE as soon as this is noticed - even if this is after the work is completed - to prevent the sub-standard equipment inadvertently being re-used.
3. Locations should consider the use of weak brightly coloured thread to indicate lack of use (As with the 'Air Pocket').

Figures:

No figures for this record.

Contact details:

Mike Forster, EH&S Department Amerada Hess Ltd. - Tel-01224 243317 / Fax-01224 243130. Email - mike.forster@hess.com