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.
In 1986 it became mandatory for hooks fitted in conventional lifeboats onboard ships to have on-load release mechanisms. Since that time, lifeboats and rescue boats using on-load release hooks have been involved in a large number of accidents during mandatory emergency training on board ships. Various regulatory changes have been introduced over the years to reduce the frequency and consequences of such accidents, e.g. requirements for mandatory maintenance and service, and a relaxation of the requirement for seafarers to be onboard the lifeboats during test launch and retrieval, and in 2013, new requirements relating to an improved design of the on-load release hook itself entered into force.
However, the safety of lifeboats and rescue boats remains a concern. The new regulations addressing improvements in the design of on-load release hooks do not apply to older hooks fitted in boats used solely for rescue purposes. It is also worth noting that not all the reported accidents were solely the result of poor designs. Insufficient onboard procedures and crew competence have been identified as contributing factors in many lifeboat and rescue boat accidents.
In 2011 the IMO agreed a set of new and stricter safety standards for conventional lifeboats with on-load release hooks, also referred to as on-load ‘release and retrieval systems’. The main purpose of the new safety standard was to reduce the likelihood of the hooks being released by accident. The MSC89 adopted amendments to SOLAS III/1.5 (Res. MSC.317(89)) and the International Life-Saving Appliance (LSA) Code Chapter IV (Res. MSC.320(89)), as well as related guidelines for the evaluation of lifeboat release and retrieval systems (MSC.1/Circ.1392):
Lifeboat manufacturers have completed their re-evaluation and testing of existing hook systems, and an overview of compliant hook systems is available in the IMO Global Integrated Shipping Information System (GISIS) under the section ’Evaluation of Hooks’. If an existing hook has not been tested and is not found in GISIS, the hook is non-compliant and must be replaced.2
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 184.108.40.206. 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.
The process of renewing non-compliant on-load release hooks may be time-consuming as it requires the involvement of both the lifeboat manufacturer and the ship’s classification society and there may be a strain on their respective resources as the deadline looms. Although the hooks in use are now becoming safer and better, the number of different hook types is also growing and different types of hooks may require different operational skills.
Members and clients who have not yet started the process of documenting compliance with SOLAS III/1.5 are therefore advised to start the preparatory work as soon as possible. The following should be noted:
1) 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:
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. The ship’s flag State may also have specific requirements for on-load release hooks other than those fitted in conventional lifeboats.
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. And – once a new or modified hook is fitted onboard - the relevant ship specific procedures should be reviewed and additional training of operating crew undertaken. The hook manufacturer should be approached for clarification of the correct use of the systems if necessary.
Fall prevention devices (FPDs), either a locking pin through the cheek plates of the hook or a sling between the davit fall blocks and an attachment point of the hooks, may be used as an interim risk mitigation measure until compliant hooks are fitted (see MSC.1/Circ.1327). However, the use of FPDs can introduce additional operational risks, and it is important that the ship’s operating crew is familiar with the operation of the FPD fitted to the lifeboat on their ship. The procedure to follow when using an FDP should be readily available onboard and the crew should receive relevant training.
1 Meaning “the first scheduled out of water survey of the ships bottom” in accordance with MSC.1/Circ.1445.
2 See also Gard Alert “Replacing lifeboat on-load release and retrieval systems” of 2 July 2014, Loss Prevention Circular Review and new approval of lifeboat hooks of November 2011 and the article “SOLAS amendments concerning lifeboat release hooks and retrieval systems” of August 2011.
3 Lifeboats installed prior to 1 July 1986 may not require action as certain older hook designs that pre-date the SOLAS requirement for on-load release are not considered to be subject to SOLAS Regulation III/1.5.
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