OSHA Region 10 Guide to Jurisdication

Someone posted a copy of this for me, I thought it would be useful information for others in the industry.

 

MSC.1/Circ.1206/Rev.1 11 June 2009

Following are important points pertaining to maintenance and tests on lifeboats. For information and discussion purposes only.

Responsibility
6 The company*
is responsible for servicing and maintenance on board its ships in
accordance with SOLAS regulation III/20 and for the establishment and implementation of health, safety and environment (HSE) procedures covering all activities during servicing and maintenance.
7 The personnel carrying out servicing and maintenance are responsible for the performance of the work as authorized in accordance with the system specified in paragraph 10.
8 The above personnel are also responsible for complying with HSE instructions and procedures.
9 Service providers carrying out the thorough examination, operational testing, repair and overhaul of lifeboats, launching appliances and on-load release gear should be authorized in accordance with MSC.1/Circ.1277.

Notes:
1 The setting and maintenance of release gear are critical operations with
regard to maintaining the safe operation of the lifeboat and the safety of
personnel in the lifeboat. All inspection and maintenance operations on
this equipment should therefore be carried out with the utmost care.
2 No maintenance or adjustment of the release gear should be undertaken
while the hooks are under load.
3 Hanging-off pennants may be used for this purpose but should not remain
connected at other times, such as when the lifeboat is normally stowed and
during training exercises.

4 The release gear is to be examined prior to its operational test. 
The release gear is to be re-examined after its operational test and the dynamic winch
brake test. 
Special consideration should be given to ensure that no damage has occurred during the winch brake test, especially the hook fastening.

2.6 Operational test of off-load release function:
.1 position the lifeboat fully waterborne;
.2 operate the off-load release gear;
.3 reset the on-load release gear; and
.4 recover the lifeboat to the stowed position and prepare for operational readiness.
 
Note:
Prior to hoisting, check that the release gear is completely and properly reset. The final turning-in of the lifeboat should be done without any persons on board.

2.7 Operational test of free-fall lifeboat release function:
.1 engage the simulated launching arrangements as specified in the manufacturer’s operating instructions;
.2 the operator should be properly seated and secured in the seat location from which the release mechanism is to be operated;
.3 operate the release mechanism to release the lifeboat;
.4 reset the lifeboat in the stowed configuration;
.5 repeat procedures referred to in .2 to .4 above, using the back-up release mechanism, when applicable;
.6 remove the simulated launching arrangements; and
.7 verify that the lifeboat is in the ready to launch stowed configuration.

3 DYNAMIC WINCH BRAKE TEST
3.1 Annual operational testing should preferably be done by lowering the empty boat. When
the boat has reached its maximum lowering speed and before the boat enters the water, the brake
should be abruptly applied.
3.2 The five-year operational test should be done by lowering the boat loaded to a proof load
equal to 1.1 times the weight of the survival craft or rescue boat and its full complement of
persons and equipment, or equivalent load. When the boat has reached its maximum lowering
speed and before the boat enters the water, the brake should be abruptly applied.
3.3 Following these tests, the brake pads and stressed structural parts should be re-inspected.
Note:
In loading the boat for this test, precautions should be taken to ensure that the stability of the
boat is not adversely affected by free surface effects or the raising of the centre of gravity.


4 OVERHAUL OF ON-LOAD RELEASE GEAR
Overhaul of on-load release gear includes:
.1 dismantling of hook release units;
.2 examination with regard to tolerances and design requirements;
.3 adjustment of release gear system after assembly;
.4 operational test as per above and with a load according to SOLAS regulation III/20.11.2.3;
and
.5 examination of vital parts with regard to defects and cracks.
 
Note:
Non-destructive examination (NDE) techniques, such as dye penetrants (DPE),
may be suitable.

2 Purpose and scope
The purpose of these Guidelines is to provide a basic outline of essential steps to safely carry out simulated launching. These Guidelines are general; the lifeboat manufacturer’s instruction manual should always be consulted before conducting simulated launching. Simulated launching should only be carried out with lifeboats and launching appliances designed to accommodate it, and for which the manufacturer has provided instructions. Simulated launching should be carried out under the supervision of a responsible person who should be an officer experienced in such procedures.

VERIFICATION OF DEFICIENCY CORRECTIONS

BY: JOHN W. DAVIS, PE for the Crane Certification Association of America (CCAA)

It is often very difficult for surveyors to decide on a suitable way to verify deficiency corrections. Some aspects of correction verification are defined by safety regulations or consensus standards. In many instances, however, the decision is left to the best judgment of the surveyor based on a reasonable concern for safety and defensibility. If an accident should occur which brings into question the effectiveness of the safety survey, documentary records are the most certain way to show that the survey and follow up verifications have been diligently accomplished.

The decision frequently involves financial considerations. It is often necessary to make another on-site inspection. Sometimes it’s necessary to assemble adequate test weights and witness the load test. Occasionally the crane may have been moved to another, more distant location. Regardless of the obstacles and financial burdens, the cost of an accident trumps the additional survey costs every time. The best answer to this dilemma is a contract or proposal that specifies how the additional costs will be invoiced.

One of the most difficult issues that plagues the surveyor is how long delinquent deficiencies can remain uncorrected. How long is too long? Should he remind the client of the need to address deficiencies? How often? It’s clear that hazardous conditions must be corrected before the crane can be returned to service. The dilemma arises with deficiencies that are not immediately hazardous. Such things as labels, decals, placards, and worn or damaged components are examples of deficiencies that may not be immediately hazardous. Withholding the certificate of compliance usually motivates the user to make the corrections expeditiously. However, in those jurisdictions that do not require a certificate, some surveyors use a written follow up
reminder system at 30-60-90 day intervals with appropriate warnings regarding potential consequences of noncompliance.

Another difficult issue is by what means should correction verification be achieved. Under what circumstances is a functional/load test needed? Is an inspection of the corrections required in all cases? Is a signed statement or signed off deficiency report by the user sufficient? Do copies of purchase documents provide sufficient proof of corrections? Here again the surveyor is faced with a judgment call for which there is no single correct answer. If structural repairs due to wear or damage of load bearing members (other than hoist ropes) are done, a 100% load test is required. This test should load the repaired member(s) at 100% capacity and should b e appropriately documented.

Finally, there is the issue of what form of documentation should be used to memorialize the verification of the deficiency corrections. Should the functional test be described and data recorded? Should the verification be integrated into the check list or deficiency report? Is a photo or phone call sufficient for non hazardous deficiencies? The answers to these questions depend on the judgment of the surveyor. Functional/load tests should always be documented with an appropriate statement as to the reason for the test and a brief description of the test itself. Many surveyors integrate a sign-off column in the deficiency report; the-sign off should be dated. Sometimes a photo or a completed work order constitutes sufficient verification. The use of this method is a judgment call by the surveyor and depends on the relationship between the surveyor and the crane user.

Effective procedures and good record keeping are at once burdensome and necessary. The extra time required to develop and execute suitable procedures, especially for correction verification, takes time away from productive activity. Record keeping is usually considered to be unproductive and the surveyor tends to minimize the function as much as possible. However, both of these functions are essential elements in the management of risk and provide evidence of quality service and the appropriate standard of care expected of the crane surveyor.