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

  • Safety notice:  01/2006 (revised)
  • Issue date: January 2017

Introduction

This notice replaces Safety Notice 01/2006 which is now withdrawn.  It draws attention to changed guidance intended to improve the management by Offshore Installation duty holders of risks associated with the entry into and deployment of davit-launched lifeboats provided with Lifeboat Release and Recovery Systems (LRRS) allowing on-load release. 

HSE’s offshore interventions have identified concerns that the risks associated with the necessary loading of lifeboats, whilst the craft are suspended by the LRRS, are not always properly assessed and controlled in line with offshore Health & Safety legislation.

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

Background

Revisions to International Maritime Organisation (IMO) LSA Code as per SOLAS III/1.5 introduce new standards for all Lifeboat Release and Retrieval Systems, including those installed on existing vessels. The standard requires all ship-based TEMPSC LRRS systems not in compliance with the revisions to the Code to be replaced or modified no later than 1 July 2019. Furthermore, as an interim measure, IMO require all relevant lifeboat systems to be fitted with a Fall Prevention Device (FPD) until such times as the lifeboat system has been found to be compliant with the LSA Code.

A list of compliant and non-compliant Lifeboat LRRS has been produced by IMO through their Global Integrated Shipping Information System (GISIS): https://gisis.imo.org/Public/HOOKS/Default.aspx

IMO have produced a number of Marine Safety Committee (MSC) Circulars in order to provide guidance to vessel owners and operators on actions required to comply with SOLAS III/1.5. A list of these circulars is contained in the appendix to this Notice.

Although the IMO requirements 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 best practice for UK fixed and mobile offshore installations.

HSE takes the opinion that the approach recommended by IMO can be considered reasonably practicable under Section 2(1) and 3(1) of the Health and Safety at Work etc. Act 1974 and under Regulation 15 of PFEER; and should be adopted by duty holders in the offshore oil and gas industry unless equally effective alternative measures are taken: 

Action required

In the light of the concerns described in the introduction to this Notice - and mirrored widely within the industry - duty holders for Offshore Installations are expected to: 

and,

Note:  Fall Preventer Devices include locking pins, maintenance pennants, strops and slings. Some provide an extra measure of safety against a TEMPSC falling from the davit; others against dropping from the suspension falls in the event of unintentional release of the hook(s) once the lifeboat has been lowered from its davit.  Each device has a unique mode of operation.   IMO released MSC.1/Circ.1327 (11 June 2009) Guidelines for the selection and use of Fall Preventer Devices (FPDs and MSC.1/Circ.1466 Unified interpretation on fall prevention devices, which provide some guidance as to the selection and use of FPDs to protect persons entering davit-launched TEMSPCs against on-load hook release during inspection and  maintenance activities and  drills.  MCA Marine Guidance Notes MGN 388 and 540 provide reasonably practicable guidance as to the selection and use of FPDs.  The design / selection of appropriate FPDs must be undertaken in consultation with the OEM or a suitably competent person based on the findings of the risk assessment(s) described above.  The use of FPDs must be carefully managed, and the devices themselves require periodic thorough inspection and examination as lifting equipment under Regulation 9 of the Lifting Operations and Lifting Equipment Regulations 1998 (LOLER).

Out of date guidance documents / media in the public domain

Duty holders should be aware that there are a number of conflicting pieces of guidance available from various sources on the web.  It is not the role of HSE to police the publishing / withdrawal of industry-based guidance, and duty holders are advised information gained from some such sources may not reflect current accepted / good practice.

Further information

Any queries relating to this notice should be addressed to:
Health and Safety Executive
Energy Division - Offshore
Lord Cullen House
Fraser Place
Aberdeen AB25 3UB
Tel: 020 3028 1493

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

Introduction

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. . Duty holders should check the IMO website for the latest amendments and updates to these publications.

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

IMO requirements for lifeboat drills, testing and maintenance

IMO requirements are promoted via SOLAS to ships, and via the MODU Code13 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 those produced since 2002, namely MSC/Circ.1049, MSC/Circ. 1093, MSC/Circ. 1136, MSC/Circ.1392, MSC/Circ.1466, MSC/Circ.1486, Resolution MSC.152(78) and Resolution MSC.320(89). 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, duty holders 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) and MSC81(70), 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:

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 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.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:

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

Such steps may include:

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.

MSC/Circ.1392 Guidance for Evaluation and Replacement of Lifeboat release and Retrieval Systems

MSC/Circ.1392 explains in detail the evaluation process when determining whether an existing LRRS meets the standard as described in SOLAS III/1.5 and the changes to the LSA Code. It is aimed at LRRS providers as well as vessel operators. Dutyholders for UK offshore installations should normally implement the same or equivalent standards, where appropriate, but noting that:

MSC/Circ.1466 Unified Interpretation on Fall Preventer Devices and MSC/Circ.1327 Guidelines for the Fitting and Use of Fall Preventer Devices (FPD’s).

MSC/Circ.1466 and MSC/Circ.1327 describe the design and operation of the most common type of FPD. The use of FPD is at the discretion of the vessel master and will depend on the type of vessel and type of lifeboat. It may also be the case that FPD are used for tests and drills but are removed prior to the lifeboat being used during a real abandonment. Circ.1327 addresses the fact that in some cases the use of FPD may be detrimental during an abandonment, specifically where airtight integrity may be required throughout the abandonment and the FPD cannot be released without the need to open lifeboat hatches.

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, came into force on 1 July 2006 and has now been included in SOLAS 2014 edition. It requires testing and maintenance of lifesaving appliances to be carried out based on the guidelines in MSC/Circ. 1093 (see above), and introduced 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:

Resolution MSC.320(89) Adoption of amendments to the International Life-Saving Appliance (LSA) Code

Resolution MSC.320(89) details the specific amendments to the LSA Code. The following subparagraphs were added to paragraph 4.4.7.6 of Chapter IV – Survival Craft and pertain to SOLAS III/1.5.

4 to provide hook stability, the release mechanism shall be designed so that, when it is fully reset in the closed position, the weight of the lifeboat does not cause any force to be transmitted to the operating mechanism;

5 locking devices shall be designed so that they can not turn to open due to forces upon the hook load; and

6 if a hydrostatic interlock is provided, it shall automatically reset upon lifting the boat from the water.

This is the standard against which vessel operators should assess their current Lifeboat LRRS arrangements and it is recommended that Duty Holders also assess their LRRS against this standard.

Providers of LRRS were required to perform tests to confirm whether their respective products met this standard. These tests were completed by 2013 and the results have been published by IMO on their website.

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. UK Step Change in Safety Safety alert database (SADIE ).
  6. US Coastguard Safety alert database
  7. 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
  8. A guide to the Offshore Installations (Safety Case) Regulations 1992. Guidance on Regulations L30 (Second edition) HSE Books 1998 ISBN 0 7176 1165 5
  9. 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 Books 2000 ISBN 0 7176 2488 9
  10. 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
  11. Lifeboat Safety Guidelines E&P Forum June 1995
  12. Information sheet on Testing of TEMPSC release gear HSE Offshore Division.
  13. Code for the construction and equipment of mobile offshore drilling units ('MODU Code') Consolidated Edition IMO 2001

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

Updated 2017-04-21