Consultee

Sect. Ref

Comment

MCA comment

Alan Wright

UKMPG

3.0

Agree small benefit to carriage of defibrillators being carried, fear that the MGN may imply “best practice” not withstanding that individual operators might have to undertake their separate risk analyses.

There is no distinction made in the notice between the different vessels included under the term “Passenger Ship” (13 seater punt – QM2) Yet all operators are obliged to conduct a risk analysis.

Suggest then that where shore ambulances are available that classes 4, 5 and 6 passenger ship operators should not need to consider the installation of a defibrillator particularly given the limitations spelled out at Paras 3.1 – 3.2.

Suggest addition of a para 3.3 – “3.3  In view of these limitations, passenger ships operating in categorised waters or at sea on domestic voyages, where access to shore ambulance services is readily available are not required to carry defibrillators.

Mark Rayment,

Solent & Whiteline Cruises Ltd

Sandra Roberts,

Warsash Maritime Centre

1.0

3.0

Implies that defibrillators start the heart when in fact they do the opposite.  – Suggest re-wording required.

With regard to suitable familiarisation training, it should be made clear that this should be in accordance with the UK Resuscitation Council guidelines which state  “This training and re-training must be provided by appropriately qualified individuals, for example the resuscitation training officers, community defibrillation officers, medical or nursing staff, ambulance service trainers and other individuals such as first aid trainers accredited in AED training. Basic life support skills must also be taught, assessed and refreshed in accordance with current guidelines.”

Should be clarified that up to date and competent life support skills will be required along with knowledge on the use of the defibrillator. As there is no requirement for seafarers to re-fresh their STCW first aid training, skill retention will be poor in CPR.

M Colquhoun,

Resuscitation Council (UK)

Fully support the recommendations of the MGN.

Only point to be further qualified is the statement in 3.2 about the relatively low survival rate who are treated by the AED. See a need to offer a note of optimism that would justify the expenditure and training involved in equipping any site where substantial members of the public are present with AEDs.

Peter Pocock,

RYA Training Centre

1.1

3.2

The ‘A’ in AED stands for “Automated” or “Advisory”.

This negates the rest of the MGN.

Recent research has shown that a short period of compressions – only (90 seconds) prior to the first shock increases the survivability noticeably. This action increases the Coronary Perfusion Pressure (CPP) and provides the  heart muscle with the energy  required to re-convert to sinus rhythm following the shock. More background reading recommended before publication of the final notice.

Tim Springett,

Chamber of Shipping

3.1

3.2

4.1

Unable to support the recommendation to carry defibrillators on board ships or a statement that it is good practice to do so.

The suggestion that a defibrillator be installed where a likelihood exists of being used once in five years is a very conservative risk analysis and not appropriate, notwithstanding that this might be in line with practice on shore. (Would be interested to know how this is to be assessed.)  

Rather that stating that regular maintenance is required, suggest  re-wording to “Defibrillators and consumables should be tested and maintained in accordance with the manufacturer’s recommendations”.

Also the 6 month refresher training recommendation seems unrealistic. Concern that the time taken to provide such training is out of proportion with the benefits that it would accrue.

Modern defibrillators are designed for use by intelligent lay person, hence why they are often mounded in “break glass” boxes in shopping malls and railway stations.

Consider adding “Any patient whose heart has stopped would need to be transferred as rapidly as possible to a specialist care unit, even where the heart has been restarted using a defibrillator.”

A defibrillator is only an entry portal into a line of treatment and resuscitative measures, perhaps the emphasis of the MGN should be on that.

Suggest changing “may remain very ill” to “will remain very ill and will require continuous assistance etc.”

Concern over statement “it is the Master or Ferry operator to make suitable advance arrangements for this.”  Such a responsibility might increase the possibility of a company facing unwarranted legal proceedings. Would feel more comfortable if the final sentence were to end after the word “possible”.

Allan Graveson,

NUMAST

Support  the carriage of defibrillators on board passenger ships.

Would encourage the carriage of defibrillators on all vessels, particularly those in coastal waters where post incident support is immediately available.

Referring to the direction of this notice would suggest “and officers” is inserted after “masters”

In addition is it not the intention of the MCA to direct this notice to “passenger ferries and high speed craft” or to “Passenger ships”

Referring to the summary; reference is made to “UK passenger ferries and high speed craft” is it the intention or should this refer to passenger ships” or “UK passenger ferries and high speed passenger craft”?

Referring to Section 4.1, again to avoid potential confusion it is suggested that the term ferry operator be replaced by the term “vessel operator”.