You should be aware by now that with Phase 1 of Marine Order 504 in August last year included the risk assessment procedure of ‘Wearing of Lifejackets’ and must be included in your SMS for compliancy.
Your safety management system’s risk assessment and written procedures must consider when to wear lifejackets on board. Vessel owners also need to make sure lifejackets are readily available if needed.
What do I need to consider in my risk assessment?
You will need to consult with your master and crew (if you have crew) when you develop or review your risk assessment.
Some onboard operations where a person might need to wear a lifejacket:
Single person operations – how likely is it that the person will be able to get back onto the vessel after they have gone overboard? What if they are injured? How will they call for help (use of a EPIRB or PLB)? Will the vessel stop (kill switch with lanyard)?
Tender vessel operations – could they fall into the water when embarking/disembarking from the tender vessel? How far are they from the parent vessel and could someone else reach them in time if they do go overboard?
Vessel transfers – could they fall into the water during a vessel transfer? What if the weather conditions make the transfer more dangerous?
Night-time operations – will anybody know if they’ve fallen overboard? How long would it take to find them?
Working over the side of a vessel – could they lose balance and fall overboard? What if the sea conditions are rough? Is the rail height sufficient to prevent them from falling overboard?
Coastal bar crossings – does your state/territory have laws mandating lifejacket wear when undertaking coastal bar crossings? Is anybody on deck and not seated during a crossing?
Rail height – is the rail height sufficient to prevent a person from falling overboard? What about in rough weather? Is anyone working over the side of the vessel?
Emergency situations – have you included lifejacket wear in your emergency procedures where the possibility of ending up in the water is likely (e.g., collision, flooding, capsize)?
State/Territory law – does your state or territory have any mandatory requirements for lifejacket wear on a DCV (e.g., coastal bar crossings, vessels less than a certain length)? These need to be included in your risk assessment and written procedures.
AMSA requirements – Do you operate under an exemption (e.g., EX41 – unpowered barges) or certain parts of the NSCV (e.g., Part C1 – Wearing of lifejacket when on special purpose/ special working deck or Part G – non-survey vessel with basic flotation and not carrying life raft or dinghy) that have mandatory lifejacket wear requirements? These need to be included in your risk assessment and written procedures.
Embarking/disembarking – what is the risk of falling overboard when embarking/disembarking? Is there a gangway, and does it have handrails and a mounted safety net?
Inclement weather – is your vessel suited for operations in only certain weather conditions? Do you have sufficient rail height and non-slip decks to prevent a person falling overboard? Is it necessary for crew to be on deck in inclement weather?
Setting or retrieving gear e.g. fishing, mooring – how do you safely set and retrieve gear so that a person doesn’t fall overboard? Do you use a manual or mechanical system?
For commercial vessels, the national law requires you to be equipped with Safety of Life at Sea (SOLAS) or coastal lifejackets, depending on your operational area.
Lifejacket requirements:
If you have any queries about lifejackets, how to include them in your Risk Assessment and Procedures, please don’t hesitate to contact our office as we’re here to help.
Shorlink’s Recommendation
Consult with your skipper and crew about the risks of a person overboard event. If they are unsure, immediately conduct an emergency response training/drill session.
Have you considered all the risks and any mandatory requirements and updated your risk assessment to include lifejacket wear? If not, you need to do this immediately.
Based on your updated risk assessment, you must develop a written procedure for when a lifejacket must be worn which should be reflected in Section 7 of your Safety Management System (SMS).
If lifejackets are not worn, ensure they are readily available when needed and all onboard know where to retrieve them.
Tip
Like all safety gear maintenance and upkeep are critical. Our best tip is to regularly take out your lifejackets and ensure they are dry and not damaged in any way. If damaged replace them.
Secondly check the light (if fitted) to ensure it is in date and working correctly. Note that some lights may need moisture to activate them.
Lastly, make sure your skipper and crew are all well aware of the new legislation regarding lifejacket wear, and they adhere to your procedures.
If you require clarification or training, please feel free to contact our office on (07) 4242 1412.
