IMO LARGE PASSENGER SHIP SAFETY. Submitted by the United Kingdom as co-ordinator of the Correspondence Group. COMSAR 7/10/1 and COMSAR 7/10/INF.

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1 INTERNATIONAL MARITIME ORGANIZATION E IMO SUB-COMMITTEE ON RADIOCOMMUNICATIONS AND SEARCH AND RESCUE 7th session Agenda item 10 COMSAR 7/INF.5 8 November 2002 ENGLISH ONLY LARGE PASSENGER SHIP SAFETY Annex to the report of the Correspondence Group: passenger ship operators questionnaire Submitted by the United Kingdom as co-ordinator of the Correspondence Group Executive summary: Action to be taken: Paragraph 4 Related documents: SUMMARY COMSAR 7/10/1 contains the report of the correspondence group established by COMSAR 6 to consider the radiocommunications and search and rescue issues identified for its attention by the Large Passenger Ship Safety Working Group of the Maritime Safety Committee. This paper contains the results of a questionnaire distributed to passenger ship operators to assist the correspondence group in its work. COMSAR 7/10/1 and COMSAR 7/10/INF.4 Introduction 1 The Large Passenger Ship Safety Working Group ( the Working Group ), meeting during the seventy-fourth session of the Maritime Safety Committee, developed, as part of its work plan, a matrix of objectives and tasks which identified aspects of large passenger ship safety to be further considered by the Working Group and by appropriate Sub-Committees. The COMSAR Sub-Committee was tasked to consider the radiocommunications and search and rescue (SAR) aspects and, at its sixth session, established a correspondence group to do so. 2 The correspondence group, using the Working Group s tasking as a guide, developed a questionnaire for distribution to industry, to help inform the group s work. The questionnaire and the responses received are annexed to this paper. 3 Discussion of points raised in the responses is to be found in the relevant sections of COMSAR 7/10/1. An introduction to the questionnaire philosophy, and thanks to contributors, are at COMSAR 7/10/1, paragraph 7.6. For reasons of economy, this document is printed in a limited number. Delegates are kindly asked to bring their copies to meetings and not to request additional copies.

2 - 2 - Action requested of the Sub-Committee 4 The Sub-Committee is requested to note the contents of this paper. ***

3 CORRESPONDENCE GROUP QUESTIONNAIRE This questionnaire was distributed to passenger shipping companies mostly based in or operating from the United Kingdom, on a non-attributory basis to encourage open discussion. The introduction to the questionnaire was as follows: Large Passenger Ship Safety Working Group SAR & radiocommunications aspects An international correspondence group has been established by IMO s Sub-Committee on Radiocommunications and Search and Rescue (COMSAR) to consider the items relevant to its work identified by the Maritime Safety Committee (MSC) s Large Passenger Ship Safety Working Group. The correspondence group is being co-ordinated by the United Kingdom. Its members include France, Germany, Singapore, Sweden, the United States, the United Kingdom, and the International Council of Cruise Lines. The correspondence group s terms of reference are at annex. Its main aim is to evaluate recovery and rescue techniques and equipment and propose measures as appropriate. It is agreed that the remit covers both cruise and ferry operations, and existing as well as future large ships. You are invited to assist the group in its work by completing the following questionnaire. The more detail you are able to provide, the more valuable your contribution will be but all responses will be very welcome. Your answers will be collated and published in the group s report to COMSAR at the end of the year. Specific comments will not be attributed to you unless you request it. You will be identified only as a contributor unless you wish to remain anonymous, in which case please tick the box at the end of the questionnaire. To allow time for collation, please return the questionnaire by 30 September The questionnaire should be returned, and any other comments or queries addressed, to: David Jardine-Smith tel: +44 (0) Emergency Response Liaison Officer fax: +44 (0) Maritime and Coastguard Agency dave_smith@mcga.gov.uk Bay 1/04, Spring Place 105 Commercial Road Southampton SO15 1EG UK On behalf of the correspondence group, many thanks. The questionnaire itself was closely based on the correspondence group s terms of reference. The responses received are listed under each of the eleven questions posed. The text alternates between italic and normal font as an indication of where one response ends and another begins. Not every responder answered every question. In order to maintain the non-attributory basis of the exercise, some answers have been slightly edited but all substantive comment remains as it was received.

4 Page 2 1 The group has been tasked to consider measures and techniques to transfer persons from survival craft and recovering persons from the water to other ships which may include the use of rescue boats, scramble nets, means of rescue, pilot boarding ladders, and helicopters. 1 What transfer & recovery measures and techniques do you use / recommend? How effective are these measures and techniques? In what way(s) might they be improved? We currently manage the following vessel types: high-speed wave-piercing catamaran (WPC) ro-ro passenger ferries, an tonne conventional freight ro-ro and a tonne ro-pax vessel. Our current arrangements for the transfer of persons from survival craft or recovery of persons from the water are as follows: Persons are recovered from the water to the WPCs by the vessels two inflatable rescue boats, launched by means of hydraulic cranes from stowed position at either quarter right aft. These boats have a crew of three when operated in this mode and a capacity of five persons. The casualty is brought aboard and disembarked by means of fixed evacuation steps cut into the port and starboard quarters some 6 metres forward of the transom. Injured survivors are either carried up a short staircase to the main vehicle deck and then transported by electrically powered lift to the main passenger deck for treatment or may be lifted in a helicopter cage-type stretcher (one carried) directly to this level by the rescue boat crane. Survival craft can be secured alongside the after steps port or starboard for the disembarkation of survivors, if necessary one of the vessel s own after liferafts can be deployed as a landing platform. The embarkation of survivors in this manner was successfully carried out in significant wave heights in excess of 2 metres during an incident in Earlier trials proved the utility of evacuation steps in even higher seas. The manoeuvrability of these vessels is such that the vessel is able to position itself alongside a stationary survival craft to effect the disembarkation. Helicopter winching operations have been successfully conducted to the open deck area at the after end of the Upper Passenger Deck, and occasionally Main Passenger Deck, at speeds of up to 40 knots. Such exercises have also taken place to the Main Passenger Deck aft (full speed) and the foredeck (slow speed only) of the smaller class. An evacuation exercise however highlighted potential difficulties with downdraught from the helicopter when liferafts are secured alongside. These vessels are able to accept a large number of survivors for a short time although large numbers of injured would tax the available resources aboard (the total ship s complement being between 22 and 30). These vessels also have relatively short endurance (between 10 hours and one hour at full speed depending on the stage of the voyage). 1 In considering task 1, the assessment includes completing the rescue by delivering the recovered persons to a place of safety.

5 Page 3 Possible enhancements for this role could include: larger rescue boats to handle more casualties (requiring larger cranes to operate them) with Jason s Cradle as a recovery aid; a second helicopter stretcher, to enable both cranes to be used simultaneously for the injured; and possibly on larger versions of these vessels a helicopter landing area. (This would result in a vessel similar to Joint Venture the Incat vessel currently being evaluated for military use by the US). As our vessel is adequately configured for her own needs, these modifications could not be justified - and in the case of a landing area would need a complete redesign of the vessel). With respect to the freight ro-ro, her ability to recover survivors from the water is limited. Her rescue boat is one of the two 36 person enclosed lifeboats which while adequate for the evacuation of the vessel is not optimised for recovery of large numbers of persons from the water. Recovery with a full complement of passengers in adverse conditions would be difficult. Embarkation ladders of rope construction of some 11 metres in height are provided for the two life-rafts carried port and starboard, and could be used with difficulty by able bodied survivors. A pilot ladder could also be rigged from a door at Main Vehicle Deck level (the main pilot boarding position) but operating the lifeboat to this position is difficult. A helicopter winching position is available abaft the bridge, and the vessel could accommodate a moderate number of casualties aboard for a short period (up to 24 hours with some difficulty). With a maximum crew number of 21 dealing with a large number of survivors would prove difficult. The ro-pax vessel is fitted with both a fast rescue boat and a semi-rigid rescue boat each with a capacity of 6 persons, both are suitable for recovery of persons from the water. Both are restricted to launching/recovery when the vessel is not making way. Operation of these boats with their single point launching systems from a vessel of high freeboard is difficult and masters are reluctant to commit to their use. In addition two partially enclosed lifeboats, each of 100 person capacity, are fitted, as well as a 10 person davit-launched raft on the starboard side for means of recovery. The combination of the two rescue boats and the Means of Rescue (MoR) raft simultaneously would be effective in relatively benign conditions but the robustness of the MoR raft for repeated use in recovery of a large number of survivors must be questioned. Only in ideal conditions could the use of one of the 100 person lifeboats as a lift, with survivors transferred from rescue boats or casualty s survival craft, be considered. The vessel has a helicopter winching area abaft the bridge where a helicopter could operate Wheels Light. Total crew of 37 would be stretched if two rescue boats, MoR raft, and helicopter operations / lifeboat lift were to be operated simultaneously especially when coupled with communications requirements, internal and external. If a suitable international standard single/dual point lifting system robust enough to handle lifeboats and rafts of the maximum dimensions were required to be fitted to all vessels over a

6 Page 4 certain size, (not practical for HSC but probably not necessary for WPC, see above), then recovery of the casualty s own survival craft to a disembarkation position aboard the receiving vessel would in theory be possible. Smaller rafts of up to 50 person (4 tonne) capacity, if suitably strengthened, could be fitted with such a system compatible for lifting fully laden by helicopters and landing on a receiving vessel. In both cases casualty s survival craft could then be jettisoned to enable further survivors to be received. To recover persons from the water the use of slings and Jason s Cradle type equipment are used and are reasonably easy to use, dependant upon the type of rescue craft being used. (Semi inflatable boats are easier in this regard than enclosed conventional type boats). To recover persons to the ship, the use of tender and rescue boats together with the use of ships side openings and platforms that are fitted to the majority of new cruise vessels is our preferred method. The effectiveness is satisfactory in good weather. In bad weather it may be more effective to use a helicopter. On the normal route of our vessels [WPCs on a short sea crossing] RNLI all-weather Lifeboats are less than two hours from the vessel. So it would be feasible to transfer persons from liferafts into RNLI or French Lifeboats. On one of our training exercises when we were able to deploy a Marine Evacuation System (MES) and liferaft, a Sea King helicopter attempted to lift a person from the liferaft. The canopy of the raft was destroyed by the downdraught of the helicopter and it was only by good luck that no-one was injured in the incident. [From the Master of a conventional ro-ro ferry:] Fast Rescue Craft (FRCs) and helicopters. Helicopters are always preferred as FRCs are weather-constrained. The transfer recovery methods available to us [a conventional ro-ro ferry] are primarily our MoR raft and secondary to this we can use a pilot ladder from the pilot doors 3 metres above the sea. Alternatively in calm seas the stern ramp could be used to board. In order to deploy the MoR raft it is necessary to launch or jettison our FRC as these both use the same davit. (It may be possible to transfer the boat to the adjacent liferaft davit using a union purchase type of arrangement.) In marginal weather conditions if the decision was made that the weather conditions were outside the safe operational envelope of the FRC (3 metres combined sea and swell), the only way to deploy the MoR would be to jettison or transfer the FRC. The FRC on board is the company standard 6.1m FRIR with a single 60hp outboard engine. We feel that such an engine is very underpowered for the task and does not offer the 100% redundancy afforded by a twin engine installation.

7 Page 5 Ways of improving these transfer and recovery measures include: Install a dedicated MoR davit. (Or look into motorising one of the liferaft davits.) Look into fitting a second 60hp engine on the FRC (or if the transom is found to be too narrow install a single 120hp). Review the installation of a manoverboard raft at the stern of the vessel to increase the casualty s survival time in the water. Transfer & recovery measures used are: MoR pilot ladder in ships with Gunport Door at main deck level davit-launched liferafts that remain engaged on the falls and therefore become a hoist lifeboats that remain engaged on the falls and therefore become a hoist deployment of MES (with ladder for climbing chute). All measures are subject to prevailing weather and swell. All except the MoR are subject to the mobility of those being recovered. The effectiveness of each type is also dependent upon whether we are recovering 1, 100, or Boats that can launch with 150 may only be able to be recovered with 12. Enhance the design of new davits to recover 66% of total. Transfer & recovery techniques recommended: tender platforms as fitted to large passenger ships, and shipside doors (pilot doors). Pilot ladders are slow and difficult to use in any sea state above 3. FRCs presently fitted to high-sided vessels (eg ro-ro ferries and passenger vessels) are dangerous to use. For effective use these need to be launched from close to the load waterline, as is the case with offshore industry vessels and naval vessels. Use of recovery systems such as the Jason s Ladder on lifeboats and FRCs would aid the recovery of people from the water. We currently use Tender Embarkation Platforms which hinge out of the ship s side about 1 metre above the sea. They allow direct access into the ship (via a watertight door) or up an accommodation ladder to a higher deck. We also use rescue boats for transfers. Pilot ladders and scrambling nets could also be used from various ship side doors. Helicopter winching is also a possibility.

8 Page 6 Tender platforms are very efficient, so long as the weather is not too rough. Rescue boats, pilot ladders etc fall into the same category. Helicopter operations are effective, but slower than the tender platforms. In addition they require a large number of the crew to ensure the safety of the ship during the transfers, which takes them away from other rescue duties. In what way(s) might they be improved? Given the freeboard of the ships, it is hard to see what could be done. 2 The group has been tasked to consider compatibility of ships of all types 2 for use as possible SAR facilities, specifically addressing:.1 Mooring alongside.2 Evacuation of persons.3 Transfer of assistance personnel (firefighters, medical personnel, etc).4 Transfer of persons. Please comment, giving specific examples wherever possible..1 Mooring alongside: Whilst it is possible for HSC to moor alongside a casualty there is a significant risk of damage to the vessel in anything but ideal conditions in particular due to different belting heights. None of our current WPCs carry either fenders or onboard gangways. With care a WPC could position her after evacuation steps alongside a passenger vessel s launch operating pontoon for transfer of passengers in good conditions. Neither of our conventional vessels carries fenders or accommodation ladders (vehicle deck ramps and link-span being used for access). Securing alongside would be difficult as would transfer of passengers in this situation..2 Evacuation of persons: Our vessels use a combination of MES (LSA) systems, liferafts, and inflatable rescue boats on the HSC to evacuate passengers, the ro-pax utilises a combination of Marin-Ark MES and boats while the freight ro-ro has a combination of boats and conventional liferafts. See previous question..3 Transfer of assistance personnel: Can be achieved by boat, to launch pontoon or directly if able to moor alongside. Transfer is more likely to be by helicopter if available..4 Transfer of persons: see above and previous question. The most suitable vessels for use as SAR facilities in the event of an accident to a large passenger vessel are warships of the Amphibious Squadron. The LPH, LPD, and LSL(D) types are all capable of operating Helicopters and landing craft: the latter two types could in certain conditions receive survival craft directly into a dock. They have large crews trained in fire 2 Task 2 should be considered in terms of existing and future ships of all types since other types of ships may be called on to assist in the recovery of persons from large passenger ships.

9 Page 7 fighting and damage control, good medical facilities and the ability to accommodate a significant number of survivors or to transfer them to other locations. Military HSC developments such as Joint Venture able to operate a number of large RIBs and operate with helicopters would also be of use due to their rapid speed of deployment from a nearby port. Other warship types would also be of use, as could other passenger vessels especially if their LSA handling equipment was compatible with that of the casualty..1 Mooring alongside. For rescue craft this is not such an issue as the majority of cruise vessels have numerous opening and platforms etc on the waterline that are used for tender operation, bunkering etc. I would not envisage a situation where one would contemplate taking a very large cruise ship alongside another vessel..2 Evacuation of persons. (It is assumed that here we are talking about the evacuation of persons from one of our ships to the shore.) All our vessels comply with the ICCL requirement to have a helicopter winching area. In addition there are numerous conventional means such as tenders and boats. In our company we ask for the lifeboats to be able to be recovered with 10 persons onboard. Again the provision of ships side openings at the water level assists here..3 Transfer of assistance personnel. The use of ships own equipment (tenders and boats) together with the ships side openings. Helicopter winching areas..4 Transfer of persons. See above. General note: Training of crew is of paramount importance. Recent incidents have shown that a welldisciplined and trained crew have ensured a safe and quick evacuation. Advantages are gained if there is direct evacuation of persons into the rescue craft in the stowed position. With regards to ships of other types, these have limited opportunity to provide assistance, as they are usually not well adapted to receive persons and provide direct assistance. They do however provide platforms of opportunity to SAR services. The WPCs would be good for providing rescue facilities due to the low freeboard to embark/disembark from small craft. However, due to the nature of our service, the range would be limited to approx 150 nautical miles from a bunkering station. With a large passenger vessel, with sheer sides and enclosed decks, it is not practical to moor alongside. Evacuation from this class of ferry [50,000 gt conventional ro-ro] is adequate. Transfer by helicopter is preferable. FRC capacity is very limited. Enclosed lifeboats are not suitable.

10 Page 8 Mooring alongside would be virtually impossible as this vessel is fitted with large sponsons. This vessel is fitted with a winch only helideck which would be of use for cross-decking casualties between ships in an emergency. In addition the combination of the FRC and MoR raft could be used to rescue a large number of casualties from the water. Another possibility would be to launch the ship s boats and bring casualties on board through the pilot doors. For an on-board emergency, the availability of the helideck to winch firefighters etc would be the obvious choice. To transfer persons between vessels the use of a helicopter for cross-decking would be the safest and fastest. If not practical, the use of our FRC to transfer the casualty to another vessel would be our next choice..1 Mooring alongside has many attractions..2 a) dry-shod transfer b) easy movement of infants and the infirm c) rapid transfer (if vessels compatible) d) providing fire fighting support e) possibility of feeding electrical power to casualty Mooring alongside is likely to cause structural damage because: a) bridge wings & lifeboats on ferries usually overhang the ship s side b) high-sided vessels rolling in a seaway will contact their upper works. To achieve mooring alongside, ships need to have Yokohama fenders available. Mooring to another vessel at sea is totally weather dependent..3 Transfer of assistance personnel is best by helicopter, launch or tug..4 Transfer of limited numbers of persons by helicopter (all weather) or tenders / tugs. A large number of persons would require facilities for hygiene, warmth / protection from the sun, food etc. It is likely that only another passenger ship would be best able to provide these. However, any stable platform would be preferable to remaining in the survival craft. Fitting ships with Dutch Cleats would be an advantage. SAR services could have supplies to drop from an aircraft..1 High-sided vessels cannot moor alongside without use of fenders not available midocean. If possibly available, the distance between the vessels would be impossible to safely bridge. Note: even tankers in ballast are high-sided and all vessels will have relatively high accommodation blocks.

11 Page 9.2 Evacuation needs to be fast, simple to deploy and operate, and safe. A modern MES (such as the RFD Marin-Ark) is effective at getting large numbers of people into survival craft quickly. However: we should never forget that the ship is the best lifeboat!.3 Helicopters are the only reasonable method for transferring assistance personnel, but are limited in range and weather parameters..4 In general (see.1 above) transfer will need an intermediate system (liferafts, lifeboats or FRCs) unless a very low freeboard vessel is available (an offshore supply vessel, etc)..1 Mooring alongside is not a good option for a cruise ship as it potentially puts all the people on the rescue ship at risk. The high freeboard means that decks and ship s side doors may not align which makes transfers difficult. In addition several modern cruise ships have boats which extend outside the line of the hull and which could be damaged when coming alongside another ship. It is only really feasible, in good weather, with a ship of similar design and where the ship being rescued poses no threat to the rescuing passenger ship..2 I assume that this refers to the ability to get survivors from one ship to another. In which case cruise ships, if the weather is reasonable, are able to deploy larger numbers of survival craft to conduct pick up operations, although it must be remembered that the ship needs to safeguard its own evacuation capability. Modern cruise ships are often fitted with FRCs or similar, which are effective..3 Cruise ships usually have well trained emergency response personnel, but it is questionable as to whether they would be transferred to other ships as they lack specialist expertise. Since numbers are small this would normally be done by rescue boat. It is unlikely that ships of other types would have large enough crews to allow this..4 I assume that this refers to the orderly transfer of people from one ship to another, rather than an evacuation. I do not understand where the question is leading. 3 The group has been tasked to evaluate techniques, fittings and equipment to recover survival craft. Please comment, giving specific examples wherever possible. Our vessels use a combination of single point lifting devices for rescue boats of various types, and conventional twin davits for lifeboats, all fitted with on/off load release. The davit-launched liferaft MoR system operates on a similar basis. There is no means for onboard recovery of our own large (50/100 person) rafts either conventional or MES, or survival craft from the casualty. As previously stated in Question 1, a standard Survival Craft Recovery System and a standard liferaft lifting system for recovery by helicopter could be beneficial but these developments are a long way off. Recovery of survival craft in anything other than perfect conditions is extremely hazardous. Fittings such as bowsing gear, hanging blocks etc are heavy, often unreliable and difficult to use. The use of foul weather pennants helps but in many cases is not easy and not practical.

12 Page 10 It is not practical to recover boats from other vessels as the hook arrangements, hook distances etc are all varying. Davits and winches are usually not rated for extra capacity in hoisting mode. All are dependent upon training, which currently take up a considerable amount of time, and is ship specific. The davit fitted to launch and recover the 7 person SOLAS boat is the only equipment provided to recover survival craft. All the survival craft fitted on our WPCs are inflatable liferafts that are not intended to be recovered. Enclosed, high freeboard lifeboats are not designed for recovery. FRCs are limited in size and capacity and also by weather conditions. This vessel s arrangement for recovering the FRC and MoR raft is using the dedicated davit and is a fast, simple recovery method. The vessel s four 84 person boats are not fitted with recovery pennants. However, the two 22 person boats do have recovery pennants should they have to be used as crash boats. Practically speaking to recover any type of lifeboat in an open seaway is virtually impossible. We have no provision for recovery of boats except our own, unless davit/boat size is the same. FRC recovery is still in its infancy but requires: boom buoyed painter fixed speed & heading of mother ship lee from mother ship. Lifeboat recovery: engaging falls only possible in calm conditions with no swell nylon recovery strops very effective in lifting boat clear of seaway boat can remain at embarkation level or be stowed using hanging-off pennants. Davit-launched liferafts: rafts from casualty might be recovered by ship s FRC davit once the FRC has been deployed. Specialist craft with universal lift/cradle required. Most practicable solution is to transfer persons via ship s MoR, etc. Present systems do not cover recovery of a large number of persons. Consideration should be given to one set of davits being able to easily recover a fully laden lifeboat. This would require increased capacity of the motor, and possibly better hook systems than on load / off load.

13 Page 11 Lifeboats: use of recovery pennants. FRCs: use of davits close to waterline with good heave compensation Rafts: onto high-sided vessels the only possible method is to use lifeboats as lifts. Low freeboard vessels may use scramble nets. There is no great debate here. Single point lifts are much safer, such as on rescue boats. However these are not practical for the current design of large lifeboats. If recovery is to be successfully conducted in a seaway, the system must be simple. Ships in general do not currently have the ability to recover a fully loaded survival craft, since size and arrangements (hook spacing etc) differ from ship to ship and there is no suitable lifting appliance. Also the size and weight of the boats are very different. Ships also often lack the deck space to land the boat or raft even if they can lift it. 4 The group has been tasked to consider the reliability of rescue equipment 3. Please comment, giving specific examples where possible. LSA MES: This simple and effective system deployable either from the bridge, by means of two pneumatic release units, or locally, has been in use on our vessels since All our current HSCs are fitted with this system. The system has proved effective in evacuating a large number of passengers in a short period of time. Some casualties in exercises (mainly lower leg fractures due to impact with submerged canister halves under floor of raft or the join between slide and raft) were initially experienced. Procedures modified to minimise risk of recurrence and evacuation exercises against the clock discontinued and replaced by demonstrations and slow time training for ship s crews. On balance a most effective system. (This is the preferred evacuation method for disabled passengers). Operation of conventional 50 and 100 person rafts to Fixed Evacuation Steps on either quarter of HSC. This concept has proved effective in exercises and the steps have been proved in practice to be an effective means of recovery of survivors from liferafts to the vessel and for persons from the water. Inflatable rescue boats with 30HP outboards are barely adequate for marshalling these 100 person rafts in moderate conditions, but have acceptable performance for MoB situations. The Hydraulic Hiab Crane launching system for these boats has proved satisfactory. Marin-Ark MES: System in use on ro-pax and felt to be adequate, not as effective as LSA system but chosen due to the high freeboard of the vessel. The system requires extensive crew training, as it is more complex in use than the LSA system. Manual operation of hydraulic pump for deployment in the event of emergency electrical power failure is slow. It will be interesting to see how system performs as it gets older. 3 In considering task 4, the reliability of shore based equipment should also be considered.

14 Page 12 Conventional lifeboats: 100 and 36 person types operated, difficulty anticipated in recovery in adverse conditions but expected to be effective for evacuation of vessel, preferred to Marin-Ark for evacuation of disabled passengers on ro-pax. There remain questions about the effectiveness of 36 passenger lifeboat on the freight ro-ro when in rescue-boat mode in adverse weather. In view of the number of casualties during drills and exercises with conventional lifeboats compared with the number of lives saved the questions raised by the United Kingdom Marine Accident Investigation Branch on their suitability and appropriateness need careful examination. Such are the concerns about such issues that Masters are reluctant to exercise the boats on more than the statutory minimum number of occasions with consequent effects on training of boat crews. Davit-launched 10 person raft as MoR: Some doubts about system especially whether it is sufficiently robust to undertake a series of recoveries. Conventional liferaft: 15 & 20 person throw overboard type fitted to ro-ro boarded by means of 11 metre ladder from upper vehicle deck. A far from ideal system provided as back up to conventional lifeboats, could be released to persons in the water if approaching a group of survivors, no means of recovery provided. 6 person Fast Rescue Boat: Serious concerns have been raised about single point launching systems, especially in vessels with high freeboard, after boat broached and capsized during exercise with vessel underway. Boat will now only be launched with vessel not making way. 6 person semi-rigid inflatable rescue boat: Performed effectively in rescue following incident to FRB above, same concern with single point launching system on high freeboard vessels. Jason s Cradle: A most effective system for the recovery of persons from the water into survival craft or direct onto low freeboard vessels. Generally we find equipment reliability is good. It is dependent upon a strict maintenance schedule. Problems are usually with new and untried technology. The less moving parts the better. As the rescue equipment fitted to our WPCs is inflatable liferafts, it is not normally possible to ascertain the reliability. However, usually just before the craft go to refit, one MES and liferaft are deployed for training purposes. To the best of my knowledge these have been deployed without problem. The SOLAS rescue boat is fitted with a two-stroke outboard motor which is exposed to the elements and therefore requires regular checks and servicing to maintain its reliability. Practice is conducted in enclosed waters only (weekly). Weekly engine maintenance. MoR & MES drill annually. Reliability: no comment. Ship s own rescue equipment in general is something that is throughout its life left exposed to the elements. Without constant attention it will quickly deteriorate, particularly in the case of open boats. The most reliable form of rescue equipment is that which requires no maintenance on board, and where training in its use can be undertaken in classroom conditions.

15 Page 13 This ferry group has had the following failures with lifeboats and davits during servicing and training: 6 serious accidents 5 accidents resulting in injury. The United Kingdom Marine Accident Investigation Branch have published 10 reports of serious accidents with lifeboats in the past 10 years. Without doubt, the single most dangerous item of rescue equipment relates to the release of the ship s own lifeboats On Load Quick Release systems are inherently dangerous and have caused more loss of life than lifeboats have saved since QR introduction. This is not a training issue: the equipment is ill-suited to the environment. FRCs are ill-conceived and present unacceptable risk to crew in some circumstances. Quality control issues are significant in liferaft equipment integrity due to servicing and packing weaknesses. Rescue equipment is generally reliable, but the on load / off load release mechanism is not. Launching arrangements for davit-launch rafts should be investigated further. Reliability of liferafts is an unknown quantity as the ship is unable to test them. Note that more people have been killed during training, maintenance, and repair of lifeboats than have been rescued by them! MES systems rely totally on correct repacking after servicing and all failures to date have been caused by packing errors. Need to ensure servicing stations are fully competent. Tender platforms and other equipment are reliable in everyday use. I see no reason why they should not be reliable if called upon in an emergency. I have no experience of shorebased equipment. 5 The group has been tasked to consider new concepts as well as adequacy of current requirements. This is a very broad tasking: the Group is seeking to identify new thinking. For example, are there proposals for radically new evacuation or transfer systems, and how do these compare with traditional systems? Are the current SOLAS requirements adequate in the context of increasing passenger complements and trading in remote areas, etc? Please comment. Standardised lifting arrangements for LSA: so boats/rafts with survivors aboard could be recovered to another vessel. Helicopter lifting arrangements for liferafts: so loaded rafts can be lifted directly to receiving vessel.

16 Page 14 Requirements for conventional boats questioned due to high incidence of casualties in drills against low number of lives saved. The single-point launching systems used for Fast Rescue Craft on high freeboard vessels needs to be reconsidered for the same reason. There is a real need for some out of the box thinking here. Current size limitations 150 persons are a limit both to innovation in the specific field of new concepts in LSA and in the development of new ship designs. The use of free fall lifeboats, pods, safe modules that break away from the mother vessel etc are all concepts that have potential advantages, however the current prescriptive framework in SOLAS prevents them being fully exploited. What is needed is a goal-based approach. The advantages would include that big groups could be handled at the same time, reduced numbers of survival craft, provision of better facilities etc. Traditional systems have not changed much in hundreds of years and we still have numerous reports of accidents. The current SOLAS requirements need to be updated to take these into account. The example of SOLAS Ch II-2 Reg. 17 should be examined as a possible way to achieve this. The MES slides and rafts fitted to the WPCs are modern. Consequently there are no proposals for change at present. Our vessels do not trade in remote areas. Unaware of new concepts and not aware of new proposals. There is no practice of mass evacuation of the ship using passenger volunteers in a seaway. The use of davit-launched liferafts as we have is a reliable if old system. Its disadvantages are that: 3 to 4 rafts are required to be launched from each davit inside 30 minutes; there is a high number of qualified persons required to operate the rafts, ie 18 CPSC certificates and 36 BSS certificates; the launching of the rafts itself involves lifting a 25 person raft and manually slewing the davit in and out followed by winding up the hook for each individual raft; the vessel s 18 liferaft davits require a high level of maintenance. New concepts need to be devised such as lowering the embarkation level and enclosing it. This company has proposed a novel system for its next generation of tonnage. This system comprises full Marin-Ark evacuation for 2200 passengers and crew. With no provision of lifeboats, infants and the infirm are evacuated separately via MoR / davit-launched liferafts. The greatest safety for passengers is in dry-shod evacuation via MES or Marin-Ark. Lifeboats present significant risk to passengers safety in deployment.

17 Page 15 Embarkation into lifeboats in the stowed position is an improvement in passenger ship evacuation. Future concepts might include high capacity rescue craft (PODS) lowered from within the accommodation block. Current requirements are too prescriptive and should allow for greater use of Marin-Ark or similar systems. The current limit of 150 persons to a boat requires review. In terms of conventional thinking the current system of boats and MES are about as good as we can get. More thought needs to be given to radical concepts, such as parts of the ship that can become survival craft and provide a safe haven for a large number of people, in relative comfort, for a reasonable amount of time. So that weather can moderate and suitable rescue facilities mobilised and brought on scene, where none exist. It is well known that the most hazardous time is the transition from ship to sea and vice versa. This needs to be engineered out. 6 The group has been tasked to advise the Maritime Safety Committee on medical issues related to SAR issues. In so doing, the group is to consider medical management practices including facilities, equipment, personnel qualifications and staffing levels. Tasks to be considered in accomplishing this objective with respect to large passenger ships include: 1. Pharmaceuticals carried on board 2. Training, certification and manning issues 3. Telecommunications equipment 4. Medical facility room equipment issues. Secondary medical facilities in the event of loss of primary facilities in the event of a casualty. Please comment. Current requirements considered adequate for our vessels, requirements for increased facilities on other vessels to assist with an incident to a large passenger vessel would not be justified. Standardisation of pharmaceutical requirements worldwide would be of assistance as flag States differing requirements cause problems with training and the use of medically qualified passengers to augment onboard medical team. Medical facility room equipment issues: current requirements deemed adequate, designated rather than dedicated facilities are considered appropriate for short voyages. Secondary medical facilities only appropriate for the largest vessels.

18 Page 16 As ICCL members we currently address all of the issues identified in our onboard procedures. See ICCL website for more information..1 Our craft carry pharmaceuticals to United Kingdom Category C Doctor s Bag Scale VII..2 The majority of the crew are first aid trained and the craft are always within a short distance of assistance..3 Craft are always within VHF range and normally even within range of mobile phone networks..4 Due to the above there are no designated medical facilities on board..1 Minimum levels of medical equipment insufficient for everyday medical emergencies..2 Every crew should have a number of medical first responders. Regular refresher courses are required..3 Communications are generally seen to be good..4 Ship s hospital adequate. Secondary hospital and medical stocks seen as cost-prohibitive..1 The pharmaceuticals carried on board which comply with the medical scales are generally speaking adequate for the requirements. One piece of equipment which is not included in the medical scales and which is now becoming increasingly common in industry ashore is the heart defibrillator. In order to be qualified and remain so however a refresher course is required annually. Such a piece of equipment would be extremely useful on a passenger vessel..2 Though the Pursers and some senior catering ratings on board undertake a First Responders course which is of a good standard there is, like the Ship Master s Medical course, no requirement for this course to be revalidated. The Ship Master s Medical course in the United Kingdom and Ireland is only 3 days long and is not very extensive in its scope or syllabus. In the past there was provision for candidates on this course to receive some hands-on training but this is no longer the case, leaving the course very theoretical. It would be a good idea for these elements to be reintroduced..3 Shore based medical facilities do not seem to have kept pace with the advances in telecommunications and technology which are available on board a modern ship; eg, advice by this would be of particular advantage in certain medical conditions where a photograph showing a medical problem or the scan of an ECG trace could be ed ashore for analysis or the availability to shipping of websites (or the provision of CD-ROMs) containing medical advice or information on drugs..4 Complying with the legal requirements only. We are currently developing a triage system for dealing with casualties. The company has a prerecorded tape to seek medical assistance from passengers: with 2000 passengers, doctors / nurses will always come forward. The company also has a central computer register of trained staff and a contingency plan for Pursers management of a multi-casualty incident. Medical advice and diagnosis is available via Satcom / internet / dedicated link.

19 Page 17 The ships have a First Aid Room equipped according to regulations. A Doctor s bag is held at the Information Office should the First Aid Room be lost. The ships have recently been equipped with defibrillators. Medical / pharmaceutical provisions are sufficient for the trade without being excessive. As regards large cruise ships all the above medical issues are well covered at present by operating companies, and are ahead of statutory requirements. Consideration should be given to adopting the ICCL medical standards..1 The standard medical outfit on large passenger ships needs to be augmented by additional medicines for paediatric purposes..2 Existing STCW95 requirements are adequate subject to effective refresher training..3 Existing modern telecommunications systems are sufficient to obtain specific medical advice. So-called telemedicine devices do not appreciably enhance diagnosis and treatment. Secondary medical facilities: the only reason for loss of the primary facilities would be fire, so secondary equipment should be limited to appropriate facilities to cater for fire victims, eg bandages, splints, resuscitator, burns dressings. ICCL member companies already have comprehensive Guidelines. The nature of the equipment and personnel used are adequate for the needs. We already have a secondary medical centre, with suitable standby equipment. We use UK Standards for Personnel, Pharmaceuticals, and Hospital Standards. 7 The group has been tasked to consider the ability and capability of ships to handle a large number of persons from large passenger ships ; ie, what problems arise in ships of any type when acting as additional SAR facilities and required to embark large numbers of rescued people? Please comment. HSC: When on passenger service these vessels are able to handle a significant number of persons and deliver rapidly to a nearby port, the facilities available would be dependent on number of own passengers carried. Potential problems are twofold: endurance and medical facilities. The first is a factor of the stage in the vessels voyage from its base, or refuelling, port. Endurance will vary between 10 hours to as little as one hour. The second problem is the lack of medical facilities and medical staff to deal with any casualties. There are no dedicated treatment facilities only a designated treatment area. Of the ship s complement, with the exception of the Master and Chief Officer both of whom are likely to be otherwise occupied, only the Cabin Manager is qualified to Management of Medical Care (MMC) standard, with the remainder only first aid trained.

20 Page 18 When on delivery voyage HSC complements of 11 to 12 persons do not include any cabin staff. While seating for a large number of passengers is available food and in particular water (max 5 tonnes) would cause problems within the first 24 hours. Control of a large number of survivors would also stretch crew resources. Ro-pax: A significant number could be embarked for a short period, dependent on own passenger load, catering resources would be stretched but could cope. With no doctor or nurse embarked medical resources would be stretched although passenger cabins could be requisitioned. Ro-ro: Crew of only 21 would be stretched and very limited additional accommodation available. Master and Chief Officer only crew with MMC course; others probably only basic first aid trained. Food/water should be adequate for a short stay (<12 hrs). Most suitable option appears to be another passenger ship or a warship (especially Amphibious Warfare vessels) or Auxiliaries, or the diversion of a fully crewed and fuelled HSC with no passengers. The numbers involved in a major incident would overwhelm most other ship types. The following are just some of the issues: Lack of public spaces and facilities Provisions Lack of crew to assist Lack of blankets and warm clothing Lack of know-how to handle large numbers of persons Lack of medical personnel For large cruise ships and ro-pax the best assistance would be from other similar ship types. Of course the best situation is to not have to evacuate in the first place. Our vessels are currently certificated for 420 passengers but have in the past been capable of carrying 600 passengers. Therefore even if on passage they should be capable of embarking extra people in an emergency. If used as an additional SAR facility, a large number of persons could be embarked. However, due to the nature of our service, the range of operation is restricted due to the limited amount of bunker space available. Fresh water supply would also be very limited.

21 Page 19 Most ships are unable to cope with a large number of survivors and may only be able to offer shelter and very limited medical treatment. Large ferries such as our own could easily cope. The problem would be in embarking large numbers from survival craft: the ship is totally unsuitable for such an operation. There would be no particular problems in handling large numbers of casualties from another large passenger vessel with the exception of the boarding arrangement. Our boarding arrangements would be as follows: Transfers from helicopters. In our case this would involve winching which would be slower than if the helicopter could actually land as the deck is not reinforced and the ship side hand rails are not collapsible. Smaller helicopters could be landed in dire circumstances. FRC & MoR combination; Reception of casualties onto the car deck via the pilot door & ladder; Reception of casualties via the stern ramp. (This would require ideal weather conditions.) This method was actually employed by mv ST PATRICK II to receive casualties from mv SALLY ALBATROSS in the Baltic. The casualties actually walked across ice and boarded over the stern ramp. In the ferry sector there would normally be other ferries in the locality to receive survivors. The host ferry would clear a lounge or lounges of her own passengers to create a segregated reception facility for survivors. Deep sea ships would not make suitable reception for large numbers of survivors, because of the difficulty of recovering passengers and the lack of warm, dry lounges. Vessels with the advantage of low freeboard access would be suitable for receiving limited numbers. But it generally requires passenger-carrying vessels to provide a safe refuge for large numbers of people. Other vessel types may be suitable for numbers of 100 or less. As a cruise ship operator we could accommodate a large number of persons. Problems other ships would encounter are: medication sanitation heat / sun protection warmth (supply of blankets, etc) It would be inappropriate to require all ships to cater for such an infrequent event. Coastal States should be equipped with survivor recovery packs to be helicoptered to ships.