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

Safety notice: 01/2006 (revised)
Issue date: April 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This notice replaces Safety Notice 01/2006 which is now withdrawn.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.

Entry into lifeboats by various personnel is necessary in order for a duty holder to discharge duties under a number of Statutory Provisions:

Mechanical technicians and third-party specialist lifeboat contractors require entry for lifeboat maintenance activities - Provision and Use of Work Equipment Regulations 1998 (PUWER), Regulation 5;
Lifeboat crew or other competent persons must conduct periodic preparedness checks and inspections – PUWER Regulations 6 and 7;
Lifeboat crew, and all personnel expected to use TEMPSC in the event of abandonment of the installation, require periodic access for familiarisation, and as part of realistic emergency exercises and drills for training purposes – Offshore Installations (Prevention of Fire and Explosion and Emergency Response) Regulations 1995 (PFEER), Regulation 6(2)(a) and PUWER Regulation 9;
The duty holder must ensure that such arrangements are made… as will ensure so far as is reasonably practicable that all persons should be able to evacuate the offshore installation safely and reach a place of safety – PFEER Regulation 15. All persons need to be familiar with entry into the installation's lifeboats, seating and restraint systems within them, and launching procedures.

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) to reflect the requirements of the (PFEER) Regulation 15, for alternate means of evacuation to protect against the elements and foreseeable effects of the emergency. 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)

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:

Review the specification and state of maintenance of on-load LRRS in use on TEMPSC davit-launching systems on their installations against modern – more inherently safe – designs to establish whether they are SOLAS Regulation III/1.5 compliant [see IMO Global Integrated Shipping Information System (GISIS) list of compliant and non-compliant Lifeboat LRRS]. This should form part of their risk assessments under Regulation 3(1) of the Management of Health and Safety at Work Regulations 1999 (MHSWR) and Regulation 5(1) of PFEER. Detailed analysis of both routine and non-routine lifeboat operations should identify and assess the risk of premature or unexpected release. The reviewed assessment and its findings should be recorded. The duty holder may be able to justify - by exception - why replacement or modification of non-compliant LRRS might not reasonably be practicable [An example might be an installation within months of the end of its field life];
Where on-load LRRS need replacement or modification; identify an appropriate timescale for doing so. Replacement or modification would need to be carried out by a competent organisation and with reference to Original Equipment Manufacturer certification documentation, inspection of the equipment, further testing, etc., as necessary. For installations subject to marine regulations, it will be necessary to obtain flag-state acceptance of any modifications to the lifeboats, and for all TEMPSC, a review of type-approval may be required. Where change to an inherently safer hook release system is deemed necessary, the timescale identified should reflect the safety-critical nature of the issue.

and,

Identify and implement interim precautions (considering the selection and fitting of FPDs, training and Control of Work systems and/or other arrangements) which ensure that entry necessary for training, familiarisation/drills, and for inspection and maintenance activities can be conducted in a safe manner, until necessary replacement or modification of on-load release systems can be effected.

The duty holder should discuss lifeboat on-load release mechanisms with the Independent Competent Person (ICP), and should take account of the views of the ICP as to the suitability of the lifeboat for the options available.

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

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

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:

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 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. 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 duty holders 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).
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:
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
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 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:

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.

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:

IMO have imposed the date for which all vessels to be compliant as 1st July 2019. However there is no such time limit for installations which are not SOLAS compliant. Dutyholders are expected to take early action to identify any Lifeboat LRRS which does not meet the LSA Code standard and put risk reduction processes in place to enable the duties as described in para 3 of this document to be performed.
The circular describes the procedure for replacement of non-compliant lifeboat release and retrieval systems and requires vessel operators to submit detailed engineering analysis to an Approving Authority. In the case of installations which are not SOLAS compliant the Dutyholder would be expected to…

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:

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 on board 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 (See IMO MSC/Circ.1326 – Clarification of SOLAS Regulation III/19)

Water-level access to the lifeboat may not be possible from an offshore installation, but the principle above is correct in that duty holders 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 duty holders 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).

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

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 )
Lifeboat Incident Survey 2000 Results from a Joint Industry Survey carried out by OCIMF, INTERTANKO and SIGTTO
Results of a survey into lifeboat safety Oil Companies International Marine Forum (OCIMF) July 1994
UK Marine Accident Investigation Board (MAIB).
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
A guide to the Offshore Installations (Safety Case) Regulations 1992. Guidance on Regulations L30 (Second edition) HSE Books 1998 ISBN 0 7176 1165 5
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
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
Lifeboat Safety Guidelines E&P Forum June 1995
Information sheet on Testing of TEMPSC release gear HSE Offshore Division.
Code for the construction and equipment of mobile offshore drilling units ('MODU Code') Consolidated Edition IMO 2001