This notice is to remind duty holders of the legal requirements that should continue to be complied with during the current disruption to helicopter.
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.
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:
The Working Time Directive does apply offshore but there are no immediate WTD issues arising from the current situation. This is because:
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.
This guidance is issued by the Health and Safety Executive. Following the guidance is not compulsory and you are free to take other action. But if you do follow the guidance you will normally be doing enough to comply with the law. Health and safety inspectors seek to secure compliance with the law and may refer to this guidance as illustrating good practice.