Health and safety implications of the suspension of offshore helicopter flights over the UKCS due to volcanic ash

Introduction

This notice is to remind duty holders of the legal requirements that should continue to be complied with during the current disruption to helicopter.

Personnel transfer

HSE's policy for is described in Offshore Information Sheet 1/2007 Guidance for the transfer of personnel by carriers.

The guidance sets out a number of action points including Action Point (a):

Personnel transfer operations using lifting equipment and personnel carriers should only be undertaken when the particular circumstances make it essential, and it is not reasonably practicable to transfer personnel by less hazardous means.

The current restrictions on helicopter availability temporarily changes the balance of the reasonable practicability arguments. Transfer of personnel suspended from a crane to a vessel may be undertaken provided all necessary precautions are undertaken to ensure safety.

Actions points (b) - (g) set out in the information sheet provide further advice. In addition to using a suitable carrier, the crane must be suitable for lifting persons, marked accordingly and maintained in good condition.

Working Time

The majority of workers offshore in the UK sector will be working a two week offshore trip with a two or three week onshore rest period. While crew changes can take place throughout the week historically more occur on Tuesdays and Thursdays. As the fights ceased during Thursday the 15th April the majority of those currently held on installations are in their third week offshore. A small minority of crews are on three week tours and an even smaller number are on four week tours.

While the normal tour length is two weeks offshore longer periods offshore can be and are worked safely subject to a number of conditions:

1. Each day comprises a 12 hour work period and a 12 hour rest period.
2. Any worker offshore who considers themselves to be at risk due to fatigue can rest until they feel safe to continue with their work.
3. The basic human needs such as adequate meals, clean clothes and facilities for uninterrupted sleep are provided.
4. The time the crew have been offshore and their level of fatigue is taken into consideration when work is planned and risk assessed; e.g. where possible, tasks that require especially high levels of concentration allocated to those who have been offshore for less than two weeks or more crew are allocated to the task to spread the workload.

The Working Time Directive does apply offshore but there are no immediate WTD issues arising from the current situation. This is because:

1. The current offshore work schedules are averaged over a six month or one year period for WTD compliance and so a delay of a week or so can be accommodated without breaching the WTD as the rest can be "made up" later in the year. The majority of offshore schedules include a number of additional days to allow for operational imperatives and/or poor weather delays and that could be allocated to this situation.
2. The events that have caused this problem are natural phenomena (sometimes referred to as "Acts of God") that are exceptional in nature and any immediate disruption would fall outside the WTD.

HSE does not foresee any significant impact on offshore safety as a result to these travel delays, subject to the careful consideration of human fatigue for those affected and the careful control of any associated hazards. For those currently delayed offshore and many onshore waiting for them, or waiting to replace them there will be very significant disruption to their families, home life and travel plans but the skill of the industry is to deal with these sympathetically an ensure that safety offshore is not compromised.