Risk of serious injury from motion compensated gangways

Health and Safety Executive - Safety notice

Issue

Incidents involving motion compensated gangways (MCG) within the UK Continental Shelf (UKCS) or Renewable Energy Zones have resulted in serious injury.

Processes and systems should be in place, as part of a wider safe system of work, to ensure that motion compensated gangways are safe during deployment, retraction and when in use by personnel transiting to and from offshore installations, offshore windfarms and offshore energy structures.

Outline of the problem

Motion compensated gangways have been used in the oil and gas sector for some time. Rapid expansion of the wind energy sector has led to an increase in manufacturers and suppliers of these systems and more vessel owners and operators installing them to provide access services to offshore installations, offshore windfarms and offshore energy structures.

Recent incidents have highlighted the potential for, and in some instances have resulted in, serious personal injury during the deployment and use of motion compensated gangways.

Entrapment and falls

There are risks of serious injury from motion compensated gangways from:

• entrapment in, and shearing between, moving parts such as the fixed and telescopic sections of walkway or handrail
• falls from height, such as from the open walkway end

Action required

Assess risk

Windfarm operators, installation duty holders and vessel owners or operators, using, planning to use or operating motion compensated gangways must ensure, so far as is reasonably practicable, that the system is safe and suitable for the purpose for which it is being provided.

Manufacturers and suppliers of motion compensated gangways should have identified the hazards and assessed the risks from the design and the operation of their system. Operators and duty holders should confirm that a suitable and sufficient risk assessment has been undertaken.

Motion compensated gangways are designed to move whilst in use. The hazards from entrapment and shearing between moving parts and falls from the open end of the gangway must be identified, assessed and the risks eliminated, safeguarded or mitigated. The assessment should explain how this has been achieved using the hierarchy of risk control.

Any assessment should also consider risks associated with someone stumbling or falling on, or from, a gangway following sudden movements of the system or vessel. Such risks are considered foreseeable due to the nature of the gangways compensating motions.

If the risks from entrapment or fall from height are still present on any MCG in use or being considered for use then further risk reduction measure will be required. If additional risk reduction measures require modifications or alterations to the gangway system then appropriate collaboration will be required between the operator or duty holder ,vessel owner or operator, and the system manufacturer.

Auto-retraction

Operators, duty holders and vessel owners or operators should ensure that any gangway auto-retraction function provides suitable audible and visible warnings which allow users sufficient time to make themselves safe before the auto-retraction function activates.

Instruction and training

Operators and duty holders must ensure that anyone who will be using a motion compensated gangway has received sufficient instruction and training in its use. Training must address normal operation of the system as well as what actions to take in an emergency or auto-retraction situation. A suitable system to verify user competence should be in place.

Vessel owners and operators must ensure that anyone who operates a motion compensated gangway has received sufficient instruction and training to ensure their safety whilst undertaking this work. Training must include what actions to take in emergencies and actions required to ensure, so far as reasonably practicable, the safety of users of the system whilst transferring across the gangway.

Inspection and maintenance

Windfarm operators and installation duty holders should verify that owners or operators of motion compensated gangways have an inspection and maintenance regime in place to ensure that it is maintained in an efficient state, in efficient working order and in good repair.

Vessel owners and operators that are responsible for the safe condition of a motion compensated gangway must have a suitable inspection and maintenance regime in place to ensure that it is maintained in an efficient state, in efficient working order and in good repair such that it will remain safe for your employees or persons not in you employment to use.

Guidance

• Offshore health and safety law
• Managing risks and risk assessment at work
• Equipment and machinery safety

Relevant legal documents

• The Health and Safety at Work etc. Act 1974 (Application outside Great Britain) Order 2013
• The Health and Safety at Work etc. Act 1974. General duties of employers to their employees and General duties of employers and self-employed to persons other than their employees
• The Management of Health and Safety at Work Regulations 1999. Regulation 3: Risk Assessment
• The Provision and Use of Work Equipment Regulations 1998. Regulation 4: Suitability of work equipment, Regulation 5: Maintenance, Regulation 6: Inspection and Regulation 11: Dangerous parts of machinery
• The Work at Height Regulations 2005