Are you sure your lifeboats are ready to go?
Article published in the Regulator Issue 2:2015
During 2014, almost 8% of notifications to NOPSEMA reporting damage to safety-critical equipment concerned Totally Enclosed Motor Propelled Survival Craft (TEMPSC) lifeboats.
One particular incident recently notified to NOPSEMA exemplifies the vital role of an appropriate program of lifeboat inspection and testing in assuring the effectiveness of emergency preparedness arrangements at a facility. The notification related to a safety drill in which a lifeboat was launched and manoeuvred away from the facility under power. Workers quickly recognised that the lifeboat was taking in seawater through a failed deluge pump fitting on the engine and the boat was safely recovered. NOPSEMA notes that had the lifeboat not been tested in the water this failure may not have been detected until an actual emergency launch. The consequences of such an event could clearly be tragic.
Lifeboats are a primary means of abandonment at most manned facilities in the offshore petroleum industry. Facility operators are required, through their safety management system, to provide assurance that lifeboats are at all times ready for safe evacuation of the facility. This assurance, achieved through planned inspections, testing, training, and drills, must extend to the watertight integrity of the lifeboat’s hull, the performance of its water deluge system and the performance of the propulsion and steering systems under load. An effective assurance program must credibly test these elements at an appropriate frequency.
Mobile offshore drilling unit (MODU) operators may be aware of the recent publication Guidelines on alternative methods for lifeboat drills on MODUs (MSC.1/Circ.1486) issued by the International Maritime Organisation (IMO). The guidelines reinforce the testing and maintenance requirements of earlier IMO circulars and stipulate mandatory training requirements. However, the guidelines also provide an alternative pathway to complying with the existing MODU Code. The MODU Code stipulates three-monthly launching and manoeuvring of the lifeboat in the water. If this alternative pathway is followed a MODU’s lifeboats may not be fully tested in the water for a substantial period of time, potentially up to five years.
Facility operators must ultimately ensure that adequate testing of watertight integrity, deluge operations, and propulsion and steering is undertaken to ensure that evacuation risks are reduced to a level that is as low as reasonably practicable (ALARP). Reliance on the application of Guidelines on alternative methods for lifeboat drills on MODUs (MSC.1/Circ.1486) may not achieve this result. NOPSEMA inspectors monitor operators compliance with the legislation in this area by checking the fitness of facility evacuation equipment during OHS inspections at facilities. NOPSEMA will consider taking enforcement action where operators are unable to demonstrate an adequate assurance program is being implemented.
NOPSEMA is developing guidance on this topic that will be published in due course.