While the replacement of non-compliant on-load release hooks in conventional lifeboats is now well underway, identical hooks fitted in rescue boats may go unnoticed as they are not subject to the same regulations. The Gard P&I Club has issued loss Prevention Circular to address important issues regarding the on-load release hooks.
On-load release hooks in rescue boats
SOLAS and the LSA Code require every conventional lifeboat, including those used as rescue boats, to be fitted with release hooks with off-load and on-load capabilities. However, there is no such requirement in place for boats used solely for rescue purposes where a single fall and hook system in combination with a suitable painter, is used for launching.
Many manufacturers prefer to deliver an off-load release hook for the single fall of a rescue boat, while others do not. Using on-load release hooks for this purpose, carries the same risk of accidental release as using the hooks that have been installed in conventional lifeboats up until now. But while all on-load release hooks in lifeboats must be recertified or replaced before 1 July 2019, on-load release hooks fitted in rescue boats are in principle not subject to the amended LSA Code. These ‘older types’ of on-load release hooks fitted in rescue boats therefore constitute an unnecessary risk to the crew during emergency training and rescue operations, a risk that can easily be eliminated by ensuring that all on-load release hooks comply with the revised LSA Code.
Some flag States have issued specific requirements for ships flying their flag to this effect:
On 24 June 2015, the Maritime Administrator of the Republic of the Marshall Islands issued Technical Circular No 20: “On-load Release Mechanisms for Rescue Boats” which sets out the requirements for ships registered under its flag to ensure that on-load release hooks fitted in rescue boats comply with the regulations applicable to conventional lifeboats. The Marshall Island Administrator permits the replacement of on-load release hooks in rescue boats with suitable off-load hooks, as permitted under paragraph 5.1.1.1. of the LSA Code.
The US Coast Guard, in their CG-ENG Policy Letter No.01-14 of 4 March 2014, requires that on-load release hooks in both lifeboats and rescue boats are evaluated in accordance with MSC.1/Circ.1392.
Formal crew training and certification
SOLAS requires that each ship shall have onboard a sufficient number of crew members, being deck officers or certificated personnel, to launch and handle its lifeboats and rescue boat. For manning of lifeboats in particular, it is a requirement under SOLAS Reg.III/10 that: “A deck officer or certificated person shall be placed in charge of each survival craft to be used” and that a second-in-command shall be nominated as well. Still, some accident reports imply that crew members involved in the actual launching and handling of lifeboats when the accident happened were not deck officers or formally certificated person.
SOLAS III/3 further defines a certificated person as “a person who holds a certificate of proficiency in survival craft issued in accordance with the requirements of the STCW Code”. However, the STCW Code sets out only the minimum standards required for the training of crew by stating that certificated personnel must have knowledge of survival crafts and their launching appliances. There is no mention of any training requirements related to the specific type of release and retrieval systems fitted on each lifeboat or rescue boat. It is also a fact that some training institutions use older second hand boats. We understand that in some countries people are even trained in open lifeboats with off-load release hooks – a type of boat/hook that is only permitted used in ships built before 1 July 1986.
A crew member that has obtained a “Certificate of proficiency in survival craft, rescue boats and fast rescue boats” from a recognised training institution, has demonstrated sufficient competence and knowledge enabling him to, in general terms, take charge of a survival craft or rescue boat during and after launch. Additional onboard training will therefore be equally important in order to ensure that relevant crew members are properly trained to operate the type of lifeboat and rescue boat carried on board their ship of employment.
Recommendations
The Gard P&I Club advises operators who have not yet started the process of documenting compliance with SOLAS III/1.5 start the preparatory work as soon as possible and note the following:
- After the next scheduled dry-docking, but no later than 1 July 2019, ships keels laid before 1 July 20143 shall have onboard either a:
- Factual Statement from the manufacturer, documenting that ‘compliant’ hooks have been subject to their overhaul examination (ref. MSC.1/Circ.1392 items 16-17); or
- Statement of Acceptance from the flag State documenting that the complete retrofit process for ‘non-compliant’ hooks have been subject to their approval and witnessing (ref. MSC.1/Circ.1392 item 26).
2. The amendments to the SOLAS requirements for on-load release hooks represent important safety improvements and should also be applied to hooks fitted in boats used solely for rescue purposes as well as hooks fitted in lifeboats onboard ships not subject to the requirements of SOLAS III/1.5, e.g. ships operating in domestic trade
3. With the STCW Code stating only the minimum requirements for crew training, ship operators should ascertain that relevant crew members receive sufficient onboard training enabling them to safely operate the type of lifeboat and rescue boat carried on board their ship of employment.
Source: The Gard P&I Club
