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Interim Recommendation issued to: Australian Maritime Safety Authority

Recommendation details
Output No: IR19970173
Date issued: 06 February 1998
Safety action status: Closed
Background:

SUBJECT: NON-SLIP SURFACES ON SHIP HELICOPTER LANDING SITES

OCCURRENCE SUMMARY:

The Hughes 500 helicopter had been chartered to transfer two crewmembers and their luggage from shore to the ship "Karoo", a bulk ore carrier, at anchor near Mackay. After an uneventful flight, the pilot landed the helicopter on the port side of cargo hatch number seven. The steel cargo hatch, designated as the ship's helicopter landing site (HLS), had a smooth painted surface. The cargo hatch peaked in the centre and sloped down 0.85 degrees to both port and starboard sides. The pilot positioned the helicopter so that the tail rotor protruded over the port side edge of the hatch. In this position, the helicopter was under the influence of a crosswind from the left front quarter. The pilot reduced the engine power to idle, friction-locked the cyclic and collective controls, and locked the anti-torque pedals. He then left the cabin to supervise the disembarkation of the passengers and remove their luggage. After the passengers disembarked, the helicopter commenced to slide slowly downslope towards the edge of the cargo hatch.

The pilot ran from the right to the left side of the helicopter and attempted to unlock the anti-torque pedals and climb aboard. As he did so, the nose of the helicopter lifted when it weathercocked left into the 25-kt south-easterly wind. The helicopter, with the pilot partly on board, slid off the hatch and fell 3 m onto the main deck, landing inverted on raised piping which ran along the length of the deck. The pilot fell between the hatch and the piping and was saved from injury by two steel posts supporting the pipe system.

ANALYSIS:

A factor in this accident was that the ship's HLS did not have a non-slip surface. When the weight in the helicopter was reduced following disembarkation of the passengers, the smooth hatch surface, combined with the helicopter's centre of gravity movement, resulted in the helicopter slipping on the hatch. The steel hatch had a smooth, painted surface which was not non-slip. Fortunately, no injuries resulted from this accident, but the potential for serious injury or death to personnel was clearly evident.

Factors in ship-helicopter transfers that may increase the risk of helicopter and personnel slippage include:

(a) operations are conducted in varied weather conditions;

(b) operations are conducted on ships that are under way

(c) sea spray or dew on HLS surfaces reduces the coefficient of friction of the surface;

(d) ship helicopter landing sites are subject to unpredictable movement due to the pitch and roll of the ship;

(e) some hatch covers used as a HLS may have significant camber either fore and aft or athwartships; and

(f) operations are conducted at night.

MARITIME LEGISLATION

Marine regulations recommend the provision of non-slip surfaces for ship HLSs but do not mandate their provision.

Within the marine environment, the Australian Maritime Safety Authority - Marine Orders deals with safety issues relating to helicopter operations on ships operating in Australian territorial waters.

MARINE ORDERS

Marine Orders, part 57, Issue 2 - Helicopter Operations, makes provisions for and in relation to:

(a) The protection of the health and the security from injury of persons engaged in the loading and unloading of ships; and

(b) the safety of persons, including pilots, going on or coming from, or on board, ships,

in connection with transfer operations by helicopter.

Marine Orders part 57 states that requirements for safe arrangements for transfer operations by helicopter are regarded to have been met if arrangements, equipment, instructions and training comply with:

(a) the Australian Code of Safe Practice for Ship-Helicopter Transfers, published by AMSA; or

(b) the International Chamber of Shipping Guide to Helicopter/Ship Operations to the extent that it is not inconsistent with (a).

AUSTRALIAN CODE OF SAFE PRACTICE FOR SHIP-HELICOPTER TRANSFERS

The Australian Code of Safe Practice for Ship-Helicopter Transfers applies to all routine transfers of personnel or goods by helicopter to or from ships while under way or at anchor. It does not apply to fixed or floating structures, or vessels employed in the offshore oil or gas industry.

Section 3 of the code deals with the HLS and states the following:

"The HLS should have a non-slip surface."

Appendix 1 states the following:

"All paint used within the limit of the clear zone of an HLS or the manoeuvring zone of an HWA [helicopter winching area] should be such as to provide a non-skid surface whether wet or dry".

These statements do not clearly affirm that it is mandatory for a ship HLS to have a non-slip surface. The word "should" indicates a recommendation for the HLS to have a non-slip surface but does not mandate it.



INTERNATIONAL CHAMBER OF SHIPPING'S, "GUIDE TO HELICOPTER/SHIP OPERATIONS"

The International Chamber of Shipping's, "Guide to Helicopter/Ship Operations", when dealing with the provision of HLS surfaces, states the following:

"Section 4.5 Areas to be used by the helicopter landing gear or by personnel should have anti-slip surfaces even when wet".
"Section 4.2.4 The aiming circle (Touch Down Zone) should be completely covered with a matt anti-slip surface".

This publication is a guide and is not intended to be binding. Shipping companies, ships' masters and officers, helicopter operators and aircrew are all responsible for acting in accordance with relevant national regulations and company instructions.

It therefore does not appear compulsory under marine legislation for a ship HLS to have a non-slip surface.

MARINE PILOT TRANSFERS EXEMPTION

Section 4 of the Code of Safe Practice provides an exemption from section 3 for marine pilot transfers and states the following:

"Helicopter-ship operations solely for the purpose of effecting the transfer of a marine pilot may be exempted from the provisions of [Section] 3 subject to the following:

(i) A clear area of deck exists which must be no less than twice the main rotor diameter and preferably 2D wherever possible.

(ii) The helicopter pilot brings the aircraft to a hover clear of the ship's side and then hover-taxis to the landing position or the ship's master and the helicopter pilot agree that the landing may be safely made in another manner.

(iii) Sea and weather conditions are such that the ship's master and the helicopter pilot agree that the operation may be carried out safely and in accordance with flight rules, Civil Aviation Regulations and the flight operations manual".

Correspondence received from operators conducting helicopter marine pilot transfers has described situations where the helicopter has begun to slide whilst on the deck of a vessel during embarkation and disembarkation of marine pilots. When the helicopter begins to slide, the only option available is to become airborne. This situation, particularly at night, puts at risk the lives of those disembarking or embarking as well as the helicopter crew and the ship's crew.

Marine pilot transfer operations are no different from other ship-helicopter transfer operations in that the helicopter lands on the HLS and transfers a passenger. Marine pilot transfers are usually performed with the ship under way. The danger to passengers, the helicopter crew, and the ship's crew is still present if the helicopter slips on the designated HLS.

Many ship HLSs apparently do not have a non-slip surface. A non-slip surface on a ship HLS reduces the risk of the helicopter slipping with the pitch or roll of the ship. Additionally, a non-slip surface on the ship HLS reduces the risk of injury through personnel slipping on the deck.

CIVIL AVIATION LEGISLATION

The Civil Aviation Regulations - Orders and Guidelines, does not deal with the surface texture of a ship HLS. The landing area, size and requirements are referred to in Civil Aviation Advisory Publication (CAAP) 92-2 (1) - Guidelines for the establishment and use of helicopter landing sites (HLS). These guidelines do not address the provision of a non-slip surface.

SHIP-HELICOPTER TRANSFER OPERATORS

Operators conducting ship-helicopter transfers approve ship-based HLSs in accordance with their operations manual and guidelines laid down in CAAP 92-2 (1). No consideration is required to be given by the operator to the non-slip nature of the helicopter landing site when approving the site for their operations.

SAFETY DEFICIENCY

Many ship HLSs being used for ship-helicopter transfers are not equipped with non-slip surfaces. The requirement for a non-slip surface on ship HLSs is not mandated in marine legislation, although it is recommended.

Helicopter landing sites used for marine-pilot transfer operations are exempted from the recommended non-slip surface under certain conditions.

It is not a requirement for helicopter operators to consider the non-slip nature of the ship HLS surface when approving or surveying the HLS for their operations. There is no requirement in operations manuals for operators to only use a HLS with a non-slip surface.

Output text

The Bureau of Air Safety Investigation recommends that the Australian Maritime Safety Authority:

(a) make it mandatory for all ship helicopter landing sites to have a non-slip surface;

(b) make changes to the publication "Ship - Helicopter Transfers, Australian Code of Safe Practice" to clearly reflect this requirement; and

(c) check compliance with this requirement during ship inspections.

IR970174 also refers and was addressed to the Civil Aviation Safety Authority.

Initial response
Date issued: 31 March 1998
Response from: Australian Martime Safety Authority
Action status: Closed - Accepted
Response text:

Thank you for your letter of 6 February 1998 advising of the Bureau's interim recommendation IR970173.

As the recommendation has far reaching consequences for the operation of marine pilot transfers by helicopter, on 24 February 1998 I requested a meeting with officers of the Bureau to discuss the recommendation prior to responding formally to your letter.

On Thursday 26th March 1998 I met with [name supplied] and [name supplied] of the Air Deficiency Section and discussed the recommendation in depth. At this meeting it was possible to fully explore all options and explain to the investigators the practical problems that the Australian Maritime Safety Authority (AMSA) could foresee with full implementation of the recommendation.

AMSA is fully committed to ensuring safe procedures in all areas of maritime operations and for this reason will endeavour to implement your interim recommendation to the maximum extent possible taking into account practical considerations. Comments on specific areas of the recommendation are as follows.

(a) make it mandatory for all ship helicopter landing sites to have a non slip surface;

Marine Orders Part 57 (Helicopter operations) makes it mandatory for the master of a ship not to permit the transfer of persons and goods between helicopter and ship unless certain arrangements, equipment, instructions and training have been provided. The Marine Orders further amplify this requirement by stating that arrangements, equipment, instructions and training that comply with the Australian Code of Safe Practice for Ship-Helicopter Transfers or the International Chamber of Shipping Guide to Helicopter/Ship Operations will be regarded as meeting the requirements. The Code and Guide both state that helicopter landing sites should have a non slip surface.

(b) make changes to the publication "Ship - Helicopter Transfers, Australian Code of Safe Practice" to clearly reflect this requirement,

Maritime legislation is moving away from prescriptive type requirements towards more responsibility being placed upon the operator to conduct operations safely within a safety regulatory framework. The framework provides the operator with guidance on how to comply with safety requirements but does not rule out other appropriate measures that provide the same level of safety. This of course places a heavy duty of responsibility on the operator to be able to demonstrate that any departure from the guidelines provides at least the same level of safety as if the guidelines were fully complied with. For this reason AMSA would be reluctant to change the present Code of Safe Practice to make it more prescriptive.

(c) check compliance with this requirement during ship inspections.

Unfortunately for a number of reasons this recommendation is not practical. For any ships using helicopter transfer for pilot boarding the inspection would be after the fact and would not assist in ensuring compliance. The majority of ships do not have dedicated HILS's and masters can state that they do not normally undertake helicopter operations and if they intended to do so would then prepare the landing site accordingly.

Regardless of the foregoing comments AMSA believes that the reports received by BASI and our own intelligence suggests that there may be a concern in the area of safe ship/helicopter operations and the full compliance with safe operating practices by those involved. In order to comply with the spirit of your recommendation and in order to address the possible non compliance by operators with the Code of Safe Practice AMSA intends to take the following action.

A Marine Notice will be issued advising masters, owners, agents and marine pilots of the specific occurrence and other reported incidents associated with the lack of a non slip surface on shipboard helicopter landing sites. The notice will advise that the provision of a non slip surface for helicopter landing sites is considered to be of paramount importance in ensuring the safety of ship/helicopter operations and that all ships will be expected to take appropriate action to ensure that a non slip surface is provided for the helicopter landing site prior to allowing such operations to be conducted.

Agents for ships proceeding to Australia will be requested to bring this notice to the attention of masters prior to arrival at the first Australian port and marine pilot providers will be advised that AMSA expects them to advise ship masters of this requirement in their initial contact with the ship. A copy of the Marine Notice will be forwarded to BASI as soon as it is promulgated. A copy of Marine Orders Part 57 together with the Australian Code of Safe Practice for Ship-Helicopter Transfers will be forwarded to the publishers of "Guide to Port Entry" which is an international publication widely used by a majority of the world's shipping.

I trust that these measures, together with the present regulations, satisfy the requirements of the interim recommendation.

I would finally like to express my appreciation to the officers of your Bureau for their cooperation in meeting with me and taking time to discuss the recommendation in detail. I was impressed with their practical approach to operational safety considerations and the courtesy extended to me in allowing a full exploration of the issues from the AMSA point of view to be undertaken.

Further correspondence
Date issued: 25 May 1998
Response from: Australian Martime Safety Authority
Response status: Closed - Accepted
Response text:

Marine Notice - non-slip surfaces for helicopter landing sites (HILS) on ships

On 31 March 1998 [name supplied] wrote to you regarding action to be taken by AMSA following BASI interim recommendation IR970173.

As advised, this Authority has issued a Marine Notice advising masters, ship owners, agents and marine pilots of the importance of providing a non-slip surface on HLS's and of the occurrence of the relevant accident and other similar reported incidents.

 
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Last update 01 April 2011