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Guidance
SECTION 1: INTRODUCTION AND ACKNOWLEDGEMENTS 2
1
Introduction Acknowledgements
The guidance contained in this document was produced Step Change in Safety would like to thank several
by the combined efforts of a cross-industry working group individuals from a wide range of companies and
set up in late 2001. The group facilitated an analysis of organisations who gave resources and time to developing
current practices in loading lifeboats for the purposes of these guidelines. Particular acknowledgement for valuable
drills, reviewed current legislation & guidance, carried out contribution to the members of the companies and
a full risk assessment and concluded with the production organisations listed below:
of this guidance on best practice.
Aker Kvaerner
This publication is not intended to be a mandate on Amerada Hess
industry. It is intended to guide dutyholders in adopting Bluewater
best practice when loading lifeboats for the purpose of
BP
drills. Where alternative methods can, through risk
assessment, or the provision of particular safety systems, Britannia Operators Limited
be shown to offer an equally effective solution, there is no Chevron Texaco
reason why they should not be adopted. Conoco Phillips
Exxon Mobil
Whilst every effort has been made to ensure the accuracy
of the information contained in this publication, neither Halliburton
Step Change in Safety, nor any of its members will assume Health & Safety Executive
liability for any use made thereof. KCA Deutag
Maersk Contractors
Marathon
Shell
Smith Rea Energy Ltd
Sparrows Offshore Services
Statoil
Step Change OIM’s Network
Step Change Elected Safety Rep’s Network
Step Change Safety Professionals and Advisers Network
Survival Craft Inspectorate Ltd
Talisman
Transocean
Total E&P UK
UKOOA
Universal Sodexho
2
Purpose and Deliverables Overview
The purpose of the Step Change Lifeboat Loading & This Step Change publication is the final deliverable from
Launching Work Group*, and the expected deliverables/ the Lifeboat Loading & Launching Work Group. It
outcomes from the group, were agreed at the outset as represents what the Group have agreed as best practice in
follows :- relation to the loading & launching of lifeboats during drills.
• Produce guidance / proposals on cross industry “ best The Group consisted of representatives from installation
practice “ for the loading of lifeboats during drills. operators, contracting companies, Step Change networks,
• Understand current legislation and guidance the Regulator, UKOOA and other specialists.
documentation. This guidance commences with a review of current
• Review technical integrity issues around lifeboats, davits legislation and technical guidance as it relates to lifeboat
and associated maintenance pennants. drills. It then describes the group’s review of technical
• Gain understanding of current cross industry “drivers” for integrity issues around lifeboats, davits and the use of
loading lifeboats. maintenance pennants. This is then followed by a
discussion of cross-industry “drivers” for the loading of
• Create Risk model to demonstrate factors affecting lifeboats during drills.
loading lifeboats with personnel during emergency drills.
A key component of this guidance (and a foundation stone
for the recommendations) was a cross-industry risk
assessment undertaken during September 2002. This risk
assessment is summarised herein.
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Introduction • The Management of Health & Safety at Work Regulations
1999 (MHSWR) and its associated ACoP and guidance
The present situation on lifeboat legislation is complicated (HSE Books L21 2000).
by the interaction between offshore installation legislation
(under the Health and Safety at Work etc Act 1974) and The above legislation applies to fixed installations, and to
maritime legislation (under IMO and SOLAS), since some mobile installations on station.
offshore installations can be subject to both regimes
PFEER and the associated ACoP include the following
depending on what they are doing at any given time.
requirements:
However, as far as possible, the Regulators try to avoid a
situation where duty holders have to comply with two • A “PFEER” assessment has to be carried out.
different sets of parallel requirements.
• The assessment should include the selection of
Also new legislation has appeared in recent years which appropriate means of evacuation [eg lifeboat system]
has a bearing, such as the Lifting Operations and Lifting including type, capacity and location.
Equipment Regulations 1998 (LOLER), and the need for a • There has to be a sufficient number of people on the
verification scheme under the Offshore Installations and installation competent to undertake emergency duties
Wells (Design and Construction etc) Regulations 1996 and operate relevant equipment.
(DCR), since duty holders normally designate the lifeboat
• Everyone on the installation has to be provided with
system as a safety critical element. As well as maritime
adequate instruction and training in the appropriate
legislation, further health and safety legislation which has a
action to take in an emergency.
bearing on lifeboats includes the Provision and Use of
Work Equipment Regulations (PUWER). • There has to be an emergency response plan. Each
person on the installation has to be given such
This guide concentrates mainly on legislation as it applies notification of its contents as are sufficient for them.
to offshore installations but, as some installations are also
• Arrangements have to be made to ensure, so far as is
classed as ships under certain circumstances, a brief
reasonably practicable, the safe evacuation of all
mention is made of this, in particular requirements under
persons.
IMO SOLAS (The International Convention for the Safety of
Life at Sea). • The lifeboat and associated plant has to be so
constructed as to be suitable for the purpose for which it
Lifeboat legislation (offshore installations) is provided.
Equipment and its use on UK offshore installations is • The lifeboat and associated plant has to be maintained in
subject to the Health and Safety at Work etc Act 1974 an efficient state, in efficient working order and in good
(HSWA), and, where an installation is also classed as a repair.
ship, to IMO and Merchant Shipping requirements. • A suitable written scheme has to be prepared and
operated to ensure that relevant plant on the installation
Sources of specific legislation and guidance applying to
[eg the lifeboat system] is subject to systematic
the lifeboat system (lifeboat and davit) on an offshore
examination by a competent and independent person.
installation include:
Work done to comply with this requirement may
• The Offshore Installations (Prevention of Fire and contribute to the SCR verification scheme.
Explosion and Emergency Response) Regulations 1995
The lifeboat system is normally classified as a safety
(PFEER) and the associated ACoP (Approved Code of
critical element. SCR requires a verification scheme to
Practice) and guidance (HSE Books L65 1997).
ensure that a safety critical element is suitable and remains
• The Offshore Installations (Safety Case) Regulations in good repair and condition. The verification scheme will
1992 (SCR) and its associated guidance (HSE Books contribute to ensuring compliance with PFEER.
L30 1998).
4
MHSWR includes a requirement that employers undertake Regulation 20 covers “Operational readiness, maintenance
risk assessments for work activities [such as a lifeboat drill] and inspections”. This includes the requirements for;
for the purpose of identifying the measures which need to operational readiness; maintenance; maintenance of falls;
be put in place to prevent accidents and to protect people spares and repair; weekly inspections; monthly
against accidents. inspections; servicing of inflatable liferafts, inflatable
lifejackets, marine evacuation systems and inflated rescue
Lifeboat legislation (offshore installations boats; periodic servicing of hydrostatic release units,
operating as a ship) marking of stowage locations and; periodic servicing of
launching appliances and on-load release gear.
This Step Change guide is not intended to cover maritime
legislation in detail. However, as some floating installations
will also, at times, be classed as ships, a brief overview of
SOLAS requirements will be provided, in so far as they
relate to lifeboats.
The strategy which was adopted by the Step Change Work • The load path of the suspended boat is designed to take
Group was to; identify all European manufacturers of the full load of the boat plus the POB complement.
lifeboats and obtain information from them and; to review • Drills should be regularly undertaken to familiarise
literature pertinent to lifeboat operations (in particular personnel with mustering and loading the boat.
lifeboat drills).
• On davit launched boats one manufacturer
recommended not fitting maintenance pennants during
Lifeboat OEM Study drills because they felt that there was a danger of them
being left in place in error, or of becoming stuck if the
The lifeboat OEM (Original Equipment Manufacturers)
boat lowered.
study was undertaken by members of the Work Group and
it achieved the following:- • On GRP hulls, ultra violet from sunlight can degrade the
structure but this typically would be in excess of 10 years
• All European manufacturers of lifeboats were identified from new and could be as much as 35 years.
and an approach made to ask for information.
The Work Group debated these points and they are
• Information was sought in writing and technical
considered further in the Risk Assessment (Section 6) and
clarification achieved through discussions.
the SADIE Alert (Appendix 1).
• Responses were collated and the findings fed back to
the Work Group.
Literature Review
The following manufacturers participated in this study:-
Relevant literature, which was reviewed and discussed by
• Schat Harding the Work Group, was as follows:-
• Survival Craft Inspectorate • Safety Alerts from SADIE (102, 254, 274, 357), HSE
• Safety Systems International (1/96), IMCA (05/02), IADC (02-31).
6
Strategy adopted by Work Group Conclusions from User Study
The strategy which was adopted by the Step Change Work The Working Group collated the results from the
Group was to use a questionnaire based approach, questionnaires received and the following conclusions
involving as many offshore installations as possible, to elicit were drawn:-
information on current practices for loading lifeboats for the
purposes of drills. • A survey response of 22 out of 140 represented a low
response rate hence caution needed to be exercised
about the validity of the results.
Lifeboat User Study
• One manufacturer dominated the responses.
The lifeboat user study was undertaken by members of the
• Only 18% of those who responded (4 responses)
Work Group and it achieved the following:-
admitted to fully loading the lifeboats for the purposes of
• 120 questionnaires were issued. drills and all of these stated that they used maintenance
pennants during these drills.
• 29 responses were received of which 22 were usable.
• The rationale for the load rating of maintenance pennants
• Lifeboat types covered in the 22 responses were;
was unclear across the survey population, with a number
Watercraft (ie Schat Harding) (18), Verhoef freefall (1),
of inconsistencies being evident.
Norsafe (1), Balmoral (1) and Welin Lambie (1).
• A number of other inconsistencies were evident from the
The key questions asked were as follows:- responses. These included; the use and configuration of
maintenance pennants, the policy for load testing, the
• Should lifeboats be fully loaded for the purposes of drills?
procedures for load path inspections, the load ratings of
• When loading lifeboats for drills, should the maintenance the davits etc.
pennants be fitted?
The Work Group debated these responses and they
• How do you inspect/maintain the load path?
became a core focus for discussions at subsequent
• What is the Safe Working Load (SWL) of your Working Group meetings. The key issues were then
maintenance pennants? debated and evaluated at the cross-industry risk
assessment, the outcomes of which are presented in
Section 6 of this guide and in the SADIE Alert (Appendix 1).
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Background to Risk Assessment • Process description (ie how would the Risk Assessment
be conducted)
Once the Work Group had gathered the data on current
systems and operational practices, it was agreed that a • Risk brainstorm (in groups)
risk assessment should be undertaken to evaluate risks
• Risk classification
associated with loading lifeboats for the purposes of drills,
and to weigh these against the benefits offered by the • Risk review
drills.
• Risk comparison
The process which was recommended by the group was to
arrange a professionally facilitated one-day workshop with • Brainstorm alternative solutions (pair-wise comparison)
as wide a representation as possible present. This would
• Rank alternative solutions
include operators of fixed and mobile installations,
designers, OIM’s, Safety Representatives, Coxswains, the • Discussion and close
Regulator, manufacturers etc.
Outcomes from Risk Assessment
Overview of Workshop Workshop
The Risk Assessment workshop was held at Aker-Kvaerner 1. Risk Brainstorming/classification
offices on Thursday September 26th 2002. A wide cross-
section of people was present with over 30 participating The risk classification exercise involved the allocation of
(list can be found on Step Change website). The Risk risks identified by all workshop participants to appropriate
Assessment was facilitated by Pat McIntosh of Smith Rea categories on a 5 x 5 risk matrix (probability vs
Energy Ltd who was also responsible for producing a clear consequence). Three themes were assessed:-
analysis of the outcomes. The Work Group are grateful for
his help. • Risks in an emergency evacuation where no lifeboat drills
have been undertaken by the crew.
The deliverable from the risk assessment workshop was
stated to be “Create a risk model to demonstrate factors • Risks in an emergency evacuation where fully loaded
affecting loading lifeboats with personnel during lifeboat drills have been undertaken by the crew.
emergency drills”. • Risks associated with full crew loading of lifeboats during
It was agreed that the scope of the risk assessment should drill exercises.
cover “The risks involved with the loading and launching of These are shown in Diagrams 1, 2 and 3 respectively.
lifeboats for the purposes of drills and maintenance. This
should include both davit launched lifeboats (with and Diagram 1 represents the risk position where asset crews
without maintenance pennants in place) and freefall are involved in an emergency evacuation without having
lifeboats”. previously been involved in any form of drill or lifeboat
loading training.
Structure to Risk Assessment Diagram 2 represents the impact of current lifeboat drills
The structure of the day was as follows:- on the base case (no drills) scenario.
3 Muster list - loading Communication – command Injury to personnel entering Uncontrolled panic Serious injury to personnel
Moderate numbers not controlled and control weaknesses boat under pressure (Davit) Panic attack by
passenger (s)
2
Minor Minor injury to personnel
1 Discomfort to
Insignificant personnel
3 Muster list - loading Communication - command Panic attack by Serious injury to personnel
Moderate numbers not controlled and control weaknesses passenger (s)
Injury to personnel entering
boat (davit)
1 Discomfort to
Insignificant personnel
3 Serious fall while boarding Over-winching into davit after Serious injury to personnel
Moderate F/F lifeboat exercise
Batteries left on – not Over loading maintenance
available on demand pennants
Lifeboat left ‘out of service’
after drill - pennant
2 Boat lowering to sea Trips and falls ‘Lift up’ hatches fall on crew Minor injury to personnel
Minor Hazards of connecting safety Wet, slippery surfaces during loading
pennants during drills Sudden movement of lifeboat Restricted headroom
Nipped fingers & general Crew panic due to
difficulty in fitting pennants claustrophobia
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2. Alternative drill exercises
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AN EVALUATION OF ALTERNATIVES TO DRILL PRACTICES
Legend
Much Stronger (MS) Evidence is available to indicate that the column ‘A’ value measure is strongly dominant over the row ‘1’ value measure
Stronger (S) Experience and judgement favour the column ‘A’ value measure over the row ‘1’ value measure
Weaker (W) Experience and judgement favour row ‘1’ value measure over the column ‘A’ value measure
Much Weaker (MW) Evidence is available to indicate that the row ‘1’ value measure is strongly dominant over the column ‘A’ value measure
★ Strong preferences
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AN EVALUATION OF ALTERNATIVES TO DRILL PRACTICES
★
Re-introduce boats into FOET MS N S MS N N S N S 20.1%
Legend
Much Stronger (MS) Evidence is available to indicate that the column ‘A’ value measure is strongly dominant over the row ‘1’ value measure
Stronger (S) Experience and judgement favour the column ‘A’ value measure over the row ‘1’ value measure
Weaker (W) Experience and judgement favour row ‘1’ value measure over the column ‘A’ value measure
Much Weaker (MW) Evidence is available to indicate that the row ‘1’ value measure is strongly dominant over the column ‘A’ value measure
★ Strong preferences
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3. Analysis of Results - The Benefit of Drills DIAGRAM 7 - OVERALL RISK PROFILE (RISK vs
BENEFIT) WHEN PARTIALLY LOADING
The safety risk associated with each of the drill strategies
LIFEBOATS FOR DRILLS
was calculated using the impact and likelihood ranges
defined on the risk matrices. An industry accepted formula
for assessing the aversion to multiple fatalities was then
used to combine the consequence impacts onto a
consistent scaling. Using this scale the safety risk for each
drill strategy was evaluated and compared. Whilst it was
not possible to confidently predict the exact evacuation
risk level associated with each strategy (ie those who have
experienced loading in drills and those who have not), it
was possible to produce a comparison against a range of
possible outcomes.
5. Analysis of Results - Paired Preference
DIAGRAM 6 - EVACUATION RISK BETWEEN Exercise
CREWS WHO HAVE EXPERIENCED LIFEBOAT
LOADING AND THOSE WHO HAVE NOT The paired preference exercise (Diagram 4) demonstrated
a strong preference for the following options in relation to
Evacuation Risk davit launched lifeboats :-
Total Risk -
Evacuation
• Undertaking fully loaded drills onshore.
Probability
• Lifeboat loading drills provide a significant reduction in 1) Offshore Induction to include familiarisation with lifeboat
evacuation risk loading for all persons coming on to the installation
• Training exercises carried out offshore on installation (subject to maximum POB of 5 at any one time with boat
survival craft expose crew members to risk suspended on falls, maintenance pennants optional).
• The evacuation risk reduction achieved by offshore drills 2) Offshore drills (boat suspended on falls, maintenance
is greater than the risk experienced due to offshore drills pennants optional) to include familiarisation with lifeboat
loading subject to maximum POB of 5 at any one time.
• Alternative methods for achieving crew training are
preferred to the offshore drills option 3) Fully loaded drills to be carried out only in an
unsuspended state ie not over water and with boat
• Further risk reduction can be achieved by optimising
solidly supported either on the deck or in other suitable
crew training methods
hard landing area (or onshore).
The Work Group discussed the key points in these
conclusions. It was agreed that the key improvement lay in 7. SADIE Alert
optimising crew training methods to achieve further risk The final outcome of the Group’s work, and in particular the
reduction. The group discussed whether or not lifeboats risk assessment, was the issue of a SADIE Alert on 24th
should be fully loaded during drills and, if not, what should April 2003. This is shown in Appendix 1 of this guide.
be the maximum allowable number in the boat? It was
agreed that the practice recommended in the final SADIE
Alert (5 POB maximum) should be formally endorsed.
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Loading of Lifeboats 5. Notwithstanding (3) and (4) above, when a Duty Holder
during Drills (revised) has decided to permit lifeboats to be loaded to their full
capacity then a full written risk assessment must be
Publication Date: 24/04/2003 carried out and justification should be provided by way
of outlining the benefits to be achieved, identifying the
Abstract: This notice updates a previous SADIE alert (254) safety measures in place and confirming that these are
and it makes recommendations for the loading of lifeboats suitable to ensure the safety of the personnel involved.
with personnel and for the use of maintenance pennants All personnel must be in agreement with this.
during drills.
6. When carrying out the above assessment it is
Activity Location: Lifeboats (davit launched, freefall). incumbent on the Duty Holder to take account of the
number, type and integrity of the various securing
Activity Type: Emergency exercises/drills.
devices and measures which may be put in place.
Keywords: Lifeboat, exercise, loading personnel, These differ in extent and effectiveness dependant on
maintenance pennants. the type of launching appliance and the specific
devices available on each installation.
Background: Lifeboats have been involved in a number of
serious/fatal incidents during maintenance operations 7. For davit launched life-boats, maintenance pennants
and drills (eg see SADIE 102) when the boat has may be fitted at times when persons are in the lifeboat
inadvertently fallen into the sea. The following but this is at the discretion of the Company on whose
recommendations for loading lifeboats with personnel, Installation the lifeboat is located and it is dependent
and for the use of maintenance pennants during drills, on the activity being undertaken.
have been made for the continued practice of lifeboat
Note: for maintenance activity such as the testing of
drills among crews. These recommendations reflect the
release gear the fitment of maintenance pennants would
outcomes of a risk assessment. These outcomes will be
be mandatory.
published, along with others from the work of the Step
Change Lifeboat Loading & Launching Work Group, in a Contact: Robert Hirst, Total E&P UK, 01224 297891, E-
Step Change Guidance document during 2003. mail: robert.hirst@total.com
Recommendations: Or Step Change in Safety: 01224 881272, e-mail:
info@stepchangeinsafety.net
1. Individuals should be offered the opportunity to
become familiar with lifeboats during offshore induction
and by means of regular drills, however:-
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ACoP Approved Code of Practice MAIB Marine Accident Investigation Branch
BOSIET The Basic Offshore Safety Induction and OCIMF Oil Companies International Marine Forum
Emergency Training
OEM Original Equipment Manufacturer
DCR The Offshore Installations and Wells
OIM Offshore Installation Manager
(Design and Construction) Regulations
1996 PFEER The Offshore Installations (Prevention of Fire
Drill(s) An event to practice and train for an and Explosion and Emergency Response)
emergency response also known as an Regulations 1995
‘exercise’ POB Personnel On Board
Duty Holder The company responsible for the operating PUWER Provision and Use of Work Equipment
of the installation Regulations 1998
FOET Further Offshore Emergency Training Regulator The Health and Safety Executive Offshore
F/F Freefall lifeboat Safety Division
GRP Glass Reinforced Plastic Risk A system used for the identification of the
Assessment hazards associated with a particular
HSE Health and Safety Executive activity, assessing the risks and identifying
the controls / precautions required to
HSWA Health and Safety at Work Act 1974
mitigate the risk
IADC International Association of Drilling
SADIE Safety Alert Database Information
Contractors
Exchange
IMCA International Maritime Contractors
SCR The Offshore Installations Safety Case
Association
Regulations 1992
IMO International Maritime Orgainsation
SOLAS International Convention for the Safety Of
LOLER Lifting Operations and Lifting Equipment Life at Sea
Regulations 1998 SWL Safe Working Load
LSA Code Merchant Shipping Life Saving Appliances
TEMPSC Totally Enclosed Motor Propelled Survival
Regulations
Craft
MCA Maritime and Coastguard Agency
UKOOA United Kingdom Offshore Operator’s
MHSWR Management of Health and Safety at Work Association
Regulations 1999
16
GRAMPIAN
P • O • L • I • C • E
website www.stepchangeinsafety.net
email info@stepchangeinsafety.net
telephone 01224 881272
fax 01224 882350
address P.O. Box 10406
Aberdeen AB12 3YL