Revision notes: Working over the side

Introduction

Working over the side involves tasks performed outside the conventional guardrails of a vessel, often at height, and carries inherent risks. This practice is regulated by the UK Maritime and Coastguard Agency (MCA) to ensure the safety of crew members.

Key Legislation and Codes

  1. Merchant Shipping and Fishing Vessels (Health and Safety at Work) Regulations 2006 (S.I. 2006/2184):
    • Equipment used for lifting persons must be designed specifically for that purpose.
    • Systems must comply with BS/EN Standards and be tested, certified, and approved.
  2. MGN 578 (M) Amendment 2 - Use of Overside Working Systems on Commercial Yachts, Small Commercial Vessels, and Loadline Vessels:
    • Provides guidance on the installation, testing, and maintenance of overside working systems.
    • Emphasizes the need for systems to be installed according to manufacturer’s instructions and maintained regularly.
  3. Port Marine Safety Code:
    • Promotes safe practices in port marine operations.
    • Encourages risk assessment and safety management systems.

 

Useful Publications

  • Code of Safe Working Practices for Merchant Seafarers (COSWP) 2024 Edition
  • Merchant Shipping and Fishing Vessels (Health and Safety at Work) Regulations 2006 (S.I. 2006/2184)
  • MGN 578 (M) Amendment 2 - Use of Overside Working Systems on Commercial Yachts, Small Commercial Vessels, and Loadline Vessels
  • Port Marine Safety Code

Best Practices

  1. Risk Assessment:
    • Conduct a thorough risk assessment before any overside work.
    • Identify potential hazards and implement control measures.
    • Consider environmental factors such as weather conditions, sea state, and visibility
  2. Personal Protective Equipment (PPE):
    • Use appropriate PPE such as harnesses, helmets, gloves, and non-skid shoes.
    • Ensure all equipment is inspected and in good order.
  3. Training and Supervision:
    • Only trained personnel should perform overside work.
    • Supervision by experienced crew members is essential.
  4. Emergency Procedures:
    • Have rescue boats and lifebuoys ready for immediate deployment.
    • Ensure all crew members are aware of emergency procedures.

Environmental Considerations

  • Minimize environmental impact by following best practices for waste management and pollution prevention.

Code of Safe Working Practices (COSWP) Recommendations

  • Follow COSWP guidelines for working aloft and over the side, ensuring compliance with safety regulations.
  • Implement a safety management system (SMS) to manage risks and promote a safety culture on board.
  • Regularly review and update safety procedures to reflect changes in regulations and best practices.

 

Main Risks and Mitigating Actions

  1. Risk: Falling Overboard
    • Mitigation: Use safety harnesses and lifelines attached to secure anchor points. Install guardrails and safety nets where possible.
  2. Risk: Drowning
    • Mitigation: Ensure that all personnel working over the side wear life jackets. Have rescue boats and lifebuoys ready for immediate deployment.
  3. Risk: Adverse Weather Conditions
    • Mitigation: Check weather forecasts and avoid working over the side during adverse weather conditions such as high winds, rough seas, or poor visibility. Postpone work if necessary.
  4. Risk: Equipment Failure
    • Mitigation: Regularly inspect and maintain all safety equipment, including harnesses, lifelines, and scaffolding. Ensure that equipment is in good working condition before use.
  5. Risk: Falling Objects
    • Mitigation: Secure all tools and equipment to prevent them from falling. Use tool lanyards and ensure that work areas above are clear of loose items.
  6. Risk: Communication Breakdown
    • Mitigation: Establish clear communication protocols. Use radios or other communication devices to maintain contact between the person working over the side and the supervisor.
  7. Risk: Medical Emergencies
    • Mitigation: Ensure that first aid kits are readily available and that personnel are trained in first aid. Have clear emergency procedures in place and conduct regular drills.
  8. Risk: Inadequate Supervision
    • Mitigation: Ensure that work over the side is always supervised by a competent person who can intervene if necessary.

Conclusion

By following a structured permit to work process and implementing effective risk mitigation measures, the safety of personnel working over the side can be significantly enhanced. Compliance with UK MCA legislation and best practices, as outlined in the Code of Safe Working Practices (COSWP) and other relevant guidelines, is essential to maintaining a safe working environment.