| Number | Author/ Organisation | Comment | Response |
1. | US Coastguard | Suggested that ‘Fall Preventer Device’ be abbreviated to FPD | Agreed. Document redrafted |
2. | US Coastguard | Suggested that training establishment include FPD in practical exercises | Agreed. Section 6 redrafted to take account of this comment |
3. | Industry Lifeboat Group | Suggested that ‘in an emergency be removed from 3.2.1 (v) | Agreed. The pin should not be left in when conducting a drill or emergency. |
4. | Industry Lifeboat Group | Suggested that ‘Therefore, on-load release systems were seen to offer benefits’ be removed in 1.2. | Disagree. It must have been seen at the time by the IMO that on-load release offered benefits otherwise they would not have been made mandatory and this needs to be said. The IMO is currently discussing whether this was the right way to go. However, it is not the purpose of this MGN to pre-empt any decisions yet to be made at the IMO. |
5. | Industry Lifeboat Group | Suggested that ‘they have a tendency to’ be changed to ‘they are designed to’ in 1.5 | Agreed. Current wording was not clear enough |
6. | Industry Lifeboat Group | Suggested that the wording ‘Any unauthorised modifications to either the lifting appliance or lifeboat may invalidate the approval and may lead to the ship being detained. is too negative and may put owners off using FPD. | Agreed. Document redrafted to reflect what would probably happen; which is that the equipment would be retested rather that the ship being detained. |
7. | Industry Lifeboat Group | Suggested that in 3.3 the term ‘strops’ are included and that chains should not be used because of the issue of shock loads. | Agreed. Document redrafted to take account of this comment. |
8. | Industry Lifeboat Group | Suggested that in 3.3.1.3 ‘before the boat is hoisted clear of the water’ should be included. | Agreed. Document redrafted as this adds clarity |
9. | Industry Lifeboat Group | In 3.3 it was pointed out that davits and lifeboats are routinely subject to shock loadings on every lowering as the davits hit the deck. | Agreed. Document redrafted |
10. | Industry Lifeboat Group | Suggested that the FPD should not be removed once the boat is stowed. This will add an extra action in the event of an emergency - an action that could easily be forgotten in the heat of the moment. | It was not possible to resolve this issue during the consultation so ship’s Masters and owners have been given the option. It is hoped that this issue can be resolved at the IMO |
11. | Industry Lifeboat Group | Suggested that in 3.4 the following be added ‘consideration should be given to modification, to include the fitting of attachment points such that the boat can be used with FPD. Any such modification shall be in accordance with the approvals mentioned in 3.1 above’. | Agreed. This addition should encourage the fitting of FPD |
12. | Industry Lifeboat Group | Suggested that FPD should be fitted at all times when there is a risk of falling. That is, with unstable hooks, all the time except when waterborne. Furthermore, this must include emergency use and will, if followed as a procedure | See point 10 for first part of the suggestion. There may be some instances with particular types of ships that FPD cannot be used in an emergency so this issue has been left open. It is hoped that this issue can be resolved by the IMO. It is accepted that there is a risk not fitting FPD at all times but this issue can not be resolved by the UK alone. The UK believe that the risk would be far higher if this MGN was not published and, instead, the issue be left to await a decision at the IMO. |
13. | Industry Lifeboat Group | Is this strictly correct in UK? The LOLER regulations, which as a statutory instrument are mandatory, do not make any exemption for lifeboats (despite the (poor) advice of the MGN that goes with the LOLER regulations). There is no other statute in existence that covers the lifting of personnel and in LOLER it is expressly forbidden unless the measures for preventing falling are robust (Reg. 7). In LOLER the definition of Lifting Equipment is “any equipment that can lift a load” and then a Load is defined and expressly includes personnel. LOLER applies to British ships and all other ships in British waters. | There is no intention in this MGN to interpret the LOLER regulation; that is for the courts not the MCA. It is agreed that this point needs to be clarified and the comment is meant to refer to SOLAS requirements not UK domestic regulations.The risk would be far higher if this MGN was not published and the issue left to await a decision as to which regulations should apply to FPD. |
14. | Industry Lifeboat Group | It is not beyond the wit of man to design an FPD that can be operated from within the boat via a gland similar to the sterngland of a boat. Such measures should be encouraged. Otherwise this is a let-out that could result in compound tragedy in an emergency such as Piper Alpha. Dropping from a great height is not an acceptable alternative to frying in the water, despite the peculiar conclusions of the ALEXANDER KIELLAND debacle. | Agreed in part. Yes, there should be designs for FPD that can be used in a boat. It may well be possible to design types that only require simple modifications.The text has been drafted in 3.1.7 to encourage lifeboat/hook designers to consider this option. |
15. | Industry Lifeboat Group | Shore training should be training for shipboard operations, irrespective of their good record. What the seafarers learn at such times should prepare them exactly for what they find on a ship | Agreed.Text amended. |
16. | Industry Lifeboat Group | Could the reference to harbour pins in para 2.1 be confused with on load release hook locking pins? | Note added in text to clarify. |
17. | Industry Lifeboat Group | I would prefer to see no mention of maintenance strops in this paragraph or in the MGN. | Agreed.Maintenance strops are for a different purpose, which is to connect the lifeboat to the davit head during maintenance. Mentioning them in this MGN could lead to confusion. Document redrafted to remove references to maintenance. |
18. | Industry Lifeboat Group | In 4.1 vi the lifeboat is lowered to the water when it is in the water. | Agreed.Text amended |
19. | Industry Lifeboat Group | It is suggested that text should be added in 4.1 vii to say that the FPD should be removed | See point 10 and 12. |
20. | Industry Lifeboat Group | It has been pointed out that the following statement is incorrect. Some deaths in this accident were attributed to the fact that the lifeboat falls were not long enough to reach the water and that the lifeboat had no means of release when the weight of the lifeboat was on the hook and falls. Therefore, on-load release systems were seen to offer benefits. | The Norwegian report on the incident in question does not recommend the use of on-load hooks. However, this was the reason IMO pursued on-load hooks and the text does say 'were seen to offer benefits.' There are other benefits to the on-load such as when there is weight on the falls and hooks due to current or tide or there is a significant sea running preventing the hooks being released. It should be pointed out that the main purpose of this MGN is to prevent deaths during drills which has been the main problem since the on-load system was introduced and not to get into the on-load/off-load debate. The text has been amended to illustrate that there is still some debate on this point. |
21. | Industry Lifeboat Group | Several comments high-light that if this MGN states that if the hooks are safe if maintained and serviced properly why is IMO designing a new one. | The purpose of the MGN is to prevent deaths of seamen conducting drills and exercises when the equipment fails. The fact is that hooks and their associated release mechanisms are failing and people are being killed or injured. |
22. | Industry Lifeboat Group | In an emergency it is essential that FPDs are not used, for if they are required to be disconnected, it is necessary for at least one person to remove his seat belt and open the hatch (in potentially very adverse conditions), with very high risks associated. A further problem could arise with the possibility that Mariners will make no attempt to use lifeboats considering them a danger to evacuation as they have been instructed about dangerous release hooks during training. | This issue could not be resolved as some respondents are insisting they are and others that they are not used in an emergency. There are pros and cons to both approaches so it has been decided for the purposes of this MGN to leave the decision to the ship’s master and operators of the ship as they are best placed to decide what is best for the ship and the safety of the crew. It is hoped that this issue can be resolved at the IMO. Mariners are already concerned about using lifeboats fitted with on-load release hooks. The use of FPD will hopefully restore confidence in the system when training. |
23. | International Lifesaving Appliance Manufacturers’ Association | A strict procedure for stowage of the safety strops should be in place, to prevent the locking pin being inserted in the hook in a real emergency situation. | The same applies here as in 22 above as this issue could not be resolved so the decision has been left to the Master and operator of the ship. |
24. | International Lifesaving Appliance Manufacturers’ Association | If the crew have forgotten to remove the pins/strops, and the hooks had already been operated, it would not be possible to release the boat from the falls. | This is not strictly true as once the boat is in the water and the weight is off the fall the hooks and FPD |
25. | International Lifesaving Appliance Manufacturers’ Association | Although release systems and life boats can be separately certified the release gear is an integrated part of the prototype certificate of the lifeboat. | If this comment seems to be indicating that no change can be made to approved equipment covered by SOLAS chapter III or (for example) Annex VI of MARPOL without going though a full prototype test. This is clearly not the case. Once the equipment has been installed on the ship, as long as any changes to equipment have been accepted by the Administration or Recognised Organisation (RO), acting on their behalf, to still be in compliance with SOLAS or MARPOL and appropriate documentation has been issued then the appropriate international certificates can be issued. It should not be forgotten that All type approval certificates must be issued by or on behalf of an Administration. |
26. | International Lifesaving Appliance Manufacturers’ Association | Please note that testing strops to 7 times the SWL will render the strops unusable. This test is to prove that the strop material has a safety factor of 6 against break. This test is not for all strops ! | This is an issue of terminology as there was no intention to test every strop to 6 or 7 times the SWL. To clarify this the text has been amended. |
27. | International Lifesaving Appliance Manufacturers’ Association | All our current information on LOLER states that this does not apply to Shipping | The LOLER regulations apply to all lifting gear fitted to UK registered ships. The MGN refers to these regulations as they provide clear instructions on the inspection of such equipment. Why reinvent the wheel? |
28. | International Lifesaving Appliance Manufacturers’ Association | When the lifeboat is in its stowed position the strops should never be fitted and stowed so that they are readily accessible | As this issue could not be resolved because there are pros and cons to both approaches it has been decided to give ship owners and masters the option of using either method until this issue can be resolved at the IMO. Once this issue has been resolved the MGN will be amended as required. |
29. | International Lifesaving Appliance Manufacturers’ Association | The boat should always be in the water. On-load release can be adequately and much more safely demonstrated with the keel of the lifeboat remaining in the water. | Agreed. 4.1 (vi) has been redrafted to make it clear that it is only the FPD that are removed when the boat is just touching the water. The on-load capability is only tested when the boat is fully waterborne. |
30. | International Lifesaving Appliance Manufacturers’ Association | Paragraph 6.1 will cause confusion. We have to strive for unambiguous requirements and must not allow any exceptions. If FPD’s are made mandatory for training all vessel types need to be addressed. FPD’s should be used for training no exceptions are required. | Agreed. Text re-drafted after consultation with training providers |
31. | Industry Lifeboat Group | Still have concerns about paragraph 3.1.2. Although clearly unintended, some may interpret (or be otherwise advised/led to believe by an OEM) that the fact that original release gear is replaced will invalidate the type approval and therefore, the vsl may be detained as, in the first line of the paragraph above, it states “No modification of a lifting appliance or lifeboat may be undertaken…..”. Given our experiences of meeting so many difficulties and obstructions when proposing the installation of Safelaunch into lifeboats, as a direct replacement of unsafe release gear, we feel that the above paragraph ought perhaps be further amended. We predict that when reading the above paragraph in its current form, relatively simple ‘replacement of release gear’, will to some readers, be constituted as a modification to a lifeboat. | Agreed. Redrafted, this is also in line with point 6. There is no reason why equipment can not be upgraded as long as replacement equipment is tested to verify that structural integrity is maintained and it still operates as intended. It should be pointed out that the purpose of this MGN is to provide guidance on the fitting of FPD. The type approval process is already covered in the UK Marine Equipment regulations and the associated MSN’s. |
32. | Industry Lifeboat Group | Our concerns remain with this 3.1.3, mainly as set out above. The obvious implication of the NB having to make contact with the OEM will be that they will suggest that the proposed changes are NOT acceptable – thus leaving us in a similar situation as we have now. We understand that the final paragraph may help to clarify the situation (ref my points) but wonder if the matter may be referred to in a separate paragraph, thereby drawing attention to it in a more proactive manner. | Agreed. Redrafted to make a clear distinction between modifying the equipment such as drilling holes or welding and replacing a whole system component.The object of this MGN is to encourage ship owners to fit FPD or new improved systems for lifeboat release systems, not to put barriers in their way. |
33. | Industry Lifeboat Group | What happens if 2.1 (v) is not readily achievable | If the design of the lifeboat makes it unsafe to remove a particular type of FPD then they should not be fitted. |
34. | Industry Lifeboat Group | It is difficult to imagine implementing 3.1.4 for 24 boats on a single cruise ship. This does not seem reasonable | This paragraph only covers where an existing hook is drilled or modified to incorporate a pin. It does not include strops, slings or where the equipment is up- graded by the manufacturer or a different approved system is fitted. Cruise ships still have the option of fitting strops or slings or having the hook system replaced with a new system, which does not require modification. |
35. | RED ENSIGN GROUP | In 3.3.1.2 use LSA language for type of material. | Agreed. Text amended |
36. | RED ENSIGN GROUP | In 3.4.1 if there’s way to ensure that persons cannot fall from a ladder, I’m not aware of it. | The text requires that adequate measures are taken. If there is any problem in providing such measures do not use a ladder. However , the present text does not discourage the use of ladders which it should so text has been amended. |
37. | RED ENSIGN GROUP | In 3.3.3 (iv) Why is it an absolute requirement for pins to be design so that they cannot be connected the wrong way but not for strops | Agreed. Text amended |
38. | RED ENSIGN GROUP | In 4.1 (i) there is no procedure yet for on-load systems to be used without FPD. | Agreed but see comment. The intention is that the new IMO hook would fail safe in the closed position and not need a FPD so the MGN has been written to reflect that. |
| Comments of a purely editorial nature have not been included. |