Boat Drills - 5 Considerations for Alternate Compliance Programs

On June 30, 2019, a tragic accident occurred in the Gulf of Mexico when a lifeboat fell approximately 75 feet into the water while it was being recovered during a regularly scheduled maintenance and training exercise.

Last week the USCG issued a Marine Safety Information Bulletin on July 24, 2019 (MSIB 19-04) which recommended that all owners, operators and masters take immediate steps to ensure the proper training of personnel in the inspection, maintenance and operation of their lifeboats.

In particular, MSIB 19-04 encourages industry to review USCG policy guidance on alternate means of complying with the requirement to conduct practice launches every 90 days. The USCG revised its policy on October 31, 2016 as a means to improve safety and avoid accidents during lifeboat drills.

Virtual Marine has pioneered the use of simulators to improve lifeboat safety since the deployment of our first systems 12 years ago. In our experience there are 5 key aspects to consider when implementing alternative compliance programs for lifeboat drills.

  1. Emergency Drills are still performed. An alternate compliance program does noteliminate lifeboat drills. Lifeboat coxswains must still participate in regular emergency drills by responding to alarms, controlling musters, reporting to the emergency control station, and performing any other duties they are required to perform. The main difference under an alternate compliance program is that the preparation and launching of the boat; release of hooks; maneuvering in the water; and, operating onboard systems is removed from the drill and delivered through a separate 'intermediate training' program. [Click here to review Guidelines on Alternative Methods for Lifeboat Drills on MODUs (MSC.1/Circ.1486)]

  2. Hands-on training is still required. Intermediate training programs must be delivered with lifeboat systems the same as, or substantially similar to, those carried onboard the facility. The near simultaneous operation of the hook release mechanism, brake release wire, throttle and steering at the point of touchdown in a wave is learned by feel and demands hands-on training. Likewise, maneuvering a boat - especially in a seaway - is a complex coordination of throttle and helm which also requires hands-on training. Our research has found that programs based on methods which do not incorporate hands-on training cannot effectively maintain the competence of a lifeboat coxswain. [click here to review a copy of our research report]

  3. Shifting the location of training does not eliminate the risk. The primary risk in lifeboat training is an accidental release of the hooks while the boat is out of the water. Training accidents with lifeboats have occurred at sea and in port. Lifeboats are designed as lifesaving appliances capable of operating under the most extreme emergency conditions; in an emergency they will save your life. Lifeboats, however, are are not designed as training devices; mistakes can be fatal. Simulation was officially recognized by the International Maritime Organization as a valid training method for lifeboat coxswains in 2012. Since that time, simulation training has been authorized by leading Flag States and Oil and Gas Regulators and approximately 1,000 coxswains were trained using lifeboat simulators in 2018. [Click here to view copies of the Transport Canada reports which determined that simulation training was acceptable for lifeboat operations]

  4. Training must be realistic to be effective. Launching boats into a calm harbour does notgive the necessary realism to prepare lifeboat coxswains for an emergency. Recommendation #34 of the El Faro report issued by the US NTSB in December 2017 sends a clear signal to industry that the training for lifeboat coxswains must include enhanced training in launching boats in heavy weather. IMO's Recommendations for the training and certification of personnel on mobile offshore units (Resolution A.1079(28)) recommends the use of simulation to train personnel for "lifeboat launching in rough seas". Our research shows a dramatic difference in error-free launch rates in rough seas between those trained under realistic operational conditions and those whose training was based on repetitive training under calm conditions.

  5. Alternate compliance programs using approved simulators are more efficient. Companies who have incorporated simulation into their alternate compliance programs are reporting savings as high as 40% when compared to conventional training using boats in a harbour. The main savings comes from the elimination of travel and accommodation costs since a simulation based alternate compliance program can be delivered at a location convenient to the client; including onboard the installation. Another source of efficiency is the automation of the training to allow on-demand simulation training. We have observed some installations performing more than 1,000 practice launches in a year using an automated onboard system. Individualized training eliminates the inefficiencies associated with waiting for your turn to drive in a boat filled with other students.

The most recent accident in the Gulf of Mexico has occurred in the context of repeated efforts by the International Maritime Organization (IMO) to reduce the risks associated with lifeboat drills through amendments to the Safety of Life at Sea Convention (SOLAS); amendments to the Mobile Offshore Drilling Unit (MODU) Code; and the issuance of a series of safety circulars outlining safety precautions to be taken when conducting lifeboat drills. [Click here for links to the relevant documents]

The USCG policy letter cited in MSIB 19-04 incorporates much of the guidance issued by IMO and indicates that facilities may use alternate means to ensure crew competence including the use of simulation as described in MSC.1/Circ.1486. [Click here to review of a copy of D8(ocs) Policy Ltr 04-2016]

The use of simulation in lifeboat training has been extensively tested and is proven to be a more effective, more efficient and safer training method.

Match the tool to the job. Use lifeboats for evacuation. Use simulators for training.

Anthony Patterson

President and CEO Virtual Marine Technology Inc.

Virtual Marine