Ensuring adequate safety during davit lifeboat drills, testing and maintenance on UK offshore installations

Introduction

1. This notice draws attention to recent changes intended to improve safety during lifeboat drills, maintenance and testing.

2. Reference to lifeboats in this document is to davit-launched boats, and includes both the lifeboat and the associated handling system. On offshore installations lifeboats are normally known as totally enclosed motor propelled survival craft (TEMPSC).

3. This notice does not apply to freefall lifeboats or their associated launching equipment.

Background

4. In view of accidents during lifeboat drills, maintenance and testing, the International Maritime Organisation (IMO) has recently published additional requirements and guidelines to improve the safety of these activities. The IMO documents draw attention to the issue, provide guidance, and amend an existing IMO convention. Details are given in the appendix.

5. Although the recent IMO requirements will formally apply only to those mobile UK offshore installations which are also designated as ships, and to mobile drilling units (MODUs) via the MODU Code, they also provide guidance on good practice for UK fixed and mobile offshore installations. However, as discussed in the appendix, some IMO requirements will need to be modified when applied on a UK offshore installation.

Action required

6. Dutyholders should review their arrangements to take account of the recent IMO requirements for lifeboat drills, maintenance and testing, as identified in the appendix. IMO requirements are not mandatory unless an installation is also designated as a ship, or as per the MODU code, but dutyholders should seek to achieve an equivalent standard unless their assessment shows the requirement is inappropriate.

Further information

Any queries relating to this notice should be addressed to:

Health and Safety Executive
Hazardous Installations Directorate
Offshore Division
Lord Cullen House
Fraser Place
Aberdeen AB25 3UB

Tel: 01224 252500
Fax: 01224 252615

Appendix: The application of recent IMO requirements to davit lifeboat drills, testing and maintenance on UK offshore installations

Introduction

Over the last few years, following reviews of accidents in the marine industry,^1-4 the IMO has published a number of documents to draw attention to the requirements for lifeboat drills, testing and maintenance.^5-7 The problems that continued to arise with lifeboats in the marine industry recently encouraged the IMO to amend the International Convention for the Safety of Life at Sea 1974 (SOLAS).⁸ Incidents and accidents involving lifeboats in the offshore industry worldwide have led to the publication of safety alerts on internet-based databases.^9,10

Where an offshore installation is designated as both an installation and a ship, marine regulations based on IMO requirements apply in addition to those HSE regulations applying to offshore installations. Marine regulations are outside the scope of this appendix.

For UK offshore installations that are not also designated as ships, nor subject to the MODU code, legislation permits flexibility in whether and how IMO requirements are applied. This appendix identifies the most recent IMO requirements and discusses modifications that may be necessary when applying them to a UK offshore installation.

This advice is intended to assist UK offshore dutyholders. It does not remove the requirement for UK offshore dutyholders to carry out risk assessments as described below. Dutyholders may adopt alternative, but equally effective, approaches to those described below.

Relationship between IMO requirements and requirements for UK offshore installations

Equipment and its use on UK offshore installations is subject to the Health and Safety at Work etc Act 1974 and associated Regulations (eg HSE publications L65, L30, L21 and L22).^11-14

The above legislation imposes a number of requirements related to lifeboat drills, maintenance and testing - the dutyholder shall:

• Provide an emergency plan, and emergency training.¹¹
• Provide arrangements for safe evacuation (lifeboats are typically one of the evacuation devices).¹¹
• Maintain the lifeboat system in an efficient state, in efficient working order, and in good repair.¹¹
• Prepare and implement a suitable written scheme for thorough examination and testing of the evacuation system, by a competent and independent person.¹¹
• Have available on the installation a copy of the procedures for lifeboat drills, maintenance and testing.¹⁴

The scope and frequency of lifeboat drills, tests and maintenance work are not stated in the legislation, but should be determined on the basis of a risk assessment.¹¹

In addition, anyone conducting lifeboat drills or putting together or implementing a lifeboat test and maintenance regime is required to carry out a risk assessment for the relevant activities. ¹³ This should be used as a basis for ensuring a safe system of work for the people involved.

These risk assessments should take account of existing offshore industry good practice (eg Lifeboat Safety Guidelines and Safety Notice 1/96).^15-17 Manufacturers' recommendations on equipment maintenance should also be taken into account. IMO requirements are a further source of good practice. UK dutyholders should ensure the IMO requirements for lifeboat drills, testing and maintenance (eg MSC/Circ. 1049, 1093, 1136 and MSC152(78))^5-8 have been taken into account, when devising arrangements for an offshore installation. However, as discussed below, some of the IMO requirements will need to be modified when applied to an offshore installation.

IMO requirements for lifeboat drills, testing and maintenance

IMO requirements are promoted via SOLAS to ships, and via the MODU Code¹⁸ to mobile drilling units. Lifesaving appliances and arrangements are covered in SOLAS Chapter III. The main SOLAS requirements which apply to lifeboat drills, testing and maintenance are parts of regulations III/19, III/20 and III/36.

Over the last few years, the IMO Marine Safety Committee has produced additional requirements and guidelines that relate to lifeboats. This appendix deals only with the most recent, produced since 2002, namely MSC/Circ. 1049,⁵ MSC/Circ. 1093,⁶ MSC/Circ. 1136,⁷ and Resolution MSC152(78).⁸ This appendix discusses only the extent to which these requirements may need to be modified for an offshore installation. Dutyholders will need to review the IMO documents to appreciate their full implications.

Since this appendix only discusses recent IMO requirements, it does not deal with the initial commissioning tests of lifeboats and davits. However, dutyholders should ensure that they have taken account of the total body of IMO requirements relevant to lifeboat commissioning, drills, testing and maintenance, particularly as per SOLAS Chapter III, MSC48(66)¹⁹ and MSC81(70),²⁰ in addition to the above MSC documents.

MSC/Circ. 1049 Accidents with lifeboats

MSC/Circ. 1049 was issued by the IMO Maritime Safety Committee in May 2002. It invites member governments to ensure compliance with certain existing SOLAS requirements, and includes some additional detailed guidance.

It also identifies the following causes of lifeboat accidents, to which special attention should be paid:

• failure of on-load release mechanism;
• inadvertent operation of on-load release mechanism;
• inadequate maintenance of lifeboats, davits and launching equipment;
• communication failure;
• lack of familiarity with lifeboats, davits equipment and associated controls;
• unsafe practices during lifeboat drills and inspections; and
• design faults other than on-load release.

Lifeboat accidents in the UK offshore industry have mainly centred on incorrect connection of maintenance pennants followed by operation of the release gear, arising from lack of familiarity with the equipment. UK offshore industry guidance^15,16 seeks to introduce systems of work that minimise the risk from incorrect connection of pennants. Dutyholders should ensure that anyone who is responsible for fitting hanging-off pennants, or who operates, or resets, or is responsible for checking the setting of lifeboat on-load release gear, has received adequate training to do so and is comfortable with this responsibility.

The specific measures described in MSC/Circ. 1049 will normally be relevant to UK offshore installations except that:

• MSC/Circ. 1049 refers to SOLAS regulation III/19.3.3, which requires launching of each lifeboat every three months. This is not usually practicable on a UK offshore installation. See below for further discussion of lifeboat launching.
• MSC/Circ. 1049 states that hanging-off pennants should only be used for maintenance purposes and not during training exercises. A more flexible position is taken in the UK offshore industry.¹⁷ The dutyholder's risk assessment will provide the basis for determining whether hanging-off pennants should be used during lifeboat drills.

MSC/Circ. 1093 Guidelines for periodic servicing and maintenance of lifeboats, launching appliances, and on-load release gear

MSC/Circ. 1093 was approved in June 2003, for implementation as soon as possible. Dutyholders for UK offshore installations should normally implement the same or equivalent standards, where appropriate, but noting that:

• The scope and frequency of activities to be carried out should be determined by the dutyholder's risk assessment, and in conjunction with the appropriate independent competent person (ICP) who has been appointed by the dutyholder as the ICP for lifeboats and launch/recovery systems.
• MSC/Circ. 1093 Annex paragraph 12 requires all work on lifeboats and davits, apart from weekly and monthly inspections and routine maintenance, to be carried out by the manufacturer's representative or a person appropriately trained and certified by the manufacturer. However, UK offshore legislation does not require this. Offshore dutyholders have the option of assuring themselves by other means (such as suitable accreditation schemes) that people who carry out work are competent to do so (PUWER regulation 9).¹⁴
• MSC/Circ. 1093 Appendix Section 2, Thorough examination, specifies the minimum scope of equipment to be examined for satisfactory condition and operation, including the lifeboat systems, release gear, davit (including davit mounting arrangements and associated supporting structure), and winch. Dutyholders should normally include the same scope within their own arrangements. However, MSC/Circ. 1093 assumes that some of the operational tests can be carried out when launching the lifeboat. Launch testing may not be appropriate on a UK offshore installation, in which case it will be necessary to devise alternative ways of carrying out the same tests with the lifeboat in situ. Dutyholders should pay particular attention to the safety of people carrying out in-situ testing, since work is carried out at a considerable height above the sea.
• MSC/Circ. 1093 Appendix Section 3 describes dynamic testing of the winch brake - annually with the empty boat, and five-yearly with the boat loaded to a proof load of 1.1 times the maximum working winch load. dutyholders should include similar tests within their own arrangements, but should arrange for the lifeboat proof load to be added and removed remotely (eg via a water bag system) to make it unnecessary for people to be in the boat while the proof load is present. The boat should be dropped sufficiently to ensure the system is tested with the fall wires almost fully extended. Note:
  • for offshore installations, the five-yearly interval between the 1.1 times proof tests may not be appropriate since this test should be carried out after change out (or 'end for ending') of the fall wires, which is normally more frequent than every five years;
  • lowering the lifeboat permits the wire ropes (and their termination with the winch drum) to be examined as required by MSC/Circ. 1093 Appendix Section 2.8.
• MSC/Circ. 1093 Appendix Section 4 describes overhaul and examination of on-load release gear, followed by a requirement for an operational test as per SOLAS regulation III/20.11.2.3, ie under a proof load of 1.1 times the total mass of the lifeboat when loaded with its full complement of people and equipment. Dutyholders take account of these requirements, but special arrangements will be necessary to ensure the safety of people testing the release gear under proof load. Alternatives include:

1.  in-situ testing with the unladen boat hanging off the maintenance pennants, and using a hydraulic device which applies the proof load to the hook; or
2. lowering the boat to water before loading the boat and carrying out the test with the boat raised just out of the water.

Approach (ii) above can be carried out safely provided people can board/disembark from the lifeboat at water level, or if the release gear has a 'harbour bolt' facility (or some other equally effective method) which ensures the hook cannot release while the boat is being lowered and raised with someone in it.

MSC/Circ. 1136 Guidance on safety during abandon-ship drills using lifeboats

MSC/Circ. 1136 was approved in December 2004 for immediate implementation. It provides good practice guidance for abandon-ship drills using lifeboats.

Offshore dutyholders should follow this guidance, where applicable. However, if a boat is to be launched, offshore dutyholders will need to take appropriate steps to:

• avoid dropping the boat from a height with people on board; and
• minimise risks during reconnection of the lifeboat to the hooks.

Such steps may include:

• in the case of an installation at sea, using lifeboats fitted with release gear that has a 'harbour bolt' facility which can fix the hook in place, or by using some other equally effective method to prevent any inadvertent fall of the lifeboat from a height. Also, the launch to only take place on a relatively calm sea, so that the operation of reconnecting the hook can be carried out with minimum risk to the person carrying out the reconnection.
• in the case of an installation in harbour, lowering the unladen boat to just above water level, before placing people in the boat to release the boat. Such people to disembark before the empty boat is retrieved to its stowed position.

If an offshore dutyholder determines that drills should no longer include launching, the dutyholder will need to put in place some other arrangement to replace this component of the coxswain's training.

Resolution MSC152(78) Adoption of amendments to the International Convention for the Safety of Life at Sea, 1974, as amended

Resolution MSC152(78) was adopted in May 2004, and is expected to come into force on 1 July 2006. It requires testing and maintenance of lifesaving appliances to be carried out based on the guidelines in MSC/Circ. 1093 (see above), and introduces other amendments to SOLAS regulations III/19 and III/20. Dutyholders for UK offshore installations should normally implement the same or equivalent standards, where appropriate, but noting that:

• The scope and frequency of activities to be carried out should be determined by the dutyholder's risk assessment, and in conjunction with the appropriate independent competent person (ICP) who has been appointed by the dutyholder as the ICP for lifeboats and launch/recovery systems.
• SOLAS regulation III/19 is amended to remove the previous requirement for the assigned operating crew to be onboard the lifeboat during launch, although lifeboat launch at least once every three months is still required. The implication is that the lifeboat may now be boarded at water level after it has been lowered, and subsequently the crew will disembark before the empty boat is retrieved to its stowed position. This avoids any risk to people arising from the boat being dropped inadvertently from a height during launch or recovery.
  
  Water-level access to the lifeboat may not be possible from an offshore installation, but the principle above is correct in that dutyholders should avoid having people in a lifeboat at a height during the lowering or recovery phase, except with special precautions to avoid the lifeboat falling inadvertently, or except in an emergency. Options available to offshore dutyholders include:
  • abandon launching, and apply alternative tests (as discussed under MSC/Circ. 1093 above); or
  • retain launching, with boarding at installation level, but taking appropriate steps to avoid dropping the boat from a height with people on board, and to minimise risks during reconnection of the lifeboat to the hooks (as discussed under MSC/Circ. 1136 above).
• As a further measure to reduce the risks to people who board a lifeboat, the UK offshore industry (Step Change in Safety organisation) has issued guidance that offshore lifeboat drills should be conducted with no more than five people in the lifeboat at one time unless the boat is solidly supported either on deck or on shore.¹⁷ This recommendation is based on a generic industry risk assessment for lifeboat drills.

References

1. Review of Lifeboat and Launching Systems Accidents Safety Study 1/2001 Marine Accident Investigation Branch (MAIB), UK Department of Transport (Available at: http://www.dft.gov.uk )
2. Lifeboat Incident Survey 2000 Results from a Joint Industry Survey carried out by OCIMF, INTERTANKO and SIGTTO
3. Results of a survey into lifeboat safety Oil Companies International Marine Forum (OCIMF) July 1994
4. UK Marine Accident Investigation Board (MAIB) accident reports.
5. MSC/Circ. 1049 Accidents with lifeboats May 2002 IMO Maritime Safety Committee.
6. MSC/Circ. 1093 Guidelines for periodic servicing and maintenance of lifeboats, launching appliances and on-load release gear June 2003 IMO Maritime Safety Committee.
7. MSC/Circ. 1136 Guidance on safety during abandon ship drills using lifeboats IMO Maritime Safety Committee December 2004
8. Resolution MSC152(78) Adoption of amendments to the International Convention for the Safety of Life at Sea, 1974, as amended In force 1 July 2006 IMO Maritime Safety Committee
9. UK Step Change in Safety Safety alert database (SADIE).
10. US Coastguard Safety alert database. 
11. Prevention of fire and explosion and emergency response on offshore installations. Offshore Installations (Prevention of Fire and Explosion, and Emergency Response) Regulations 1995. Approved Code of Practice and guidance L65 HSE Books 1997 ISBN 0 7176 1386 0
12. A guide to the Offshore Installations (Safety Case) Regulations 1992. Guidance on Regulations L30 (Second edition) HSE Books 1998 ISBN 0 7176 1165 5
13. Management of health and safety at work. Management of Health and Safety at Work Regulations 1999. Approved Code of Practice and guidance L21 (Second edition) HSE Books2000 ISBN 0 7176 2488 9
14. Safe use of work equipment. Provision and Use of Work Equipment Regulations 1998. Approved Code of Practice and guidance L22 (Second edition) HSE Books 1998 ISBN 0 7176 1626 6
15. Lifeboat Safety Guidelines E&P Forum June 1995
16. Information sheet on Testing of TEMPSC release gear HSE Offshore Division.
17. Loading of lifeboats during drills Step Change guidance document 2004 
18. Code for the construction and equipment of mobile offshore drilling units ('MODU Code') Consolidated Edition IMO 2001
19. Resolution MSC 48(66) International Life-Saving Appliance Code IMO Maritime Safety Committee June 1996
20. Resolution MSC 81(70) Annex 6 Revised recommendation on testing of life-saving appliances IMO Maritime Safety Committee December 1998