Recommendation M05-03

Reassessment of the Responses to Marine Safety Recommendation M05-03

Standards for testing rigid and inflatable liferafts

Background

At about 1700 Atlantic daylight time, on 25 June 2003, the fishing vessel Silent Provider left Canso, Nova Scotia, in fair weather and visibility, and headed for Petit-de-Grat, Nova Scotia. Approximately one hour later, smoke was seen coming from the engine room doorway. The fixed halon fire smothering system in the engine room was discharged, but did not appear to bring the fire under control. The crew broadcast a Mayday and then deployed the rigid life raft, an Ovatek 4, into the water.

After donning their immersion suits, the two-member crew entered the water and attempted to board the rigid life raft. When the first crew member entered the life raft, a significant amount of water was shipped inside, and the life raft rolled onto its side. Concerned about his safety, the crew member exited the life raft. After several unsuccessful attempts to board and stabilize the craft, the crew decided to remain in the water and use the rigid life raft as a flotation device.

Approximately one hour after abandoning the Silent Provider, the two crew members, suffering from mild hypothermia, were rescued by the fishing vessel Cape Ryan. The Silent Provider later burned to the waterline and sank.

Life rafts are often used under environmental conditions that are substantially more challenging than calm water pool testing. Canadian standards (TP 7321, TP 11342), which are derived from IMO standards, for testing life rafts call for critical tests such as swamping, righting, stability, and boarding to be done in isolation one from the other and under calm conditions. The investigation revealed that, although the rigid life raft passed individual tests related to stability, swamped condition, boarding, and righting, when used under realistic conditions, the life raft did not function as expected. Although performance-based testing is applied to life rafts in the aviation industry, such a practical demonstration of life raft capability in actual service conditions is not required for life rafts carried on Canadian vessels.

The Board concluded its investigation and released report M03M0077 on 13 September 2005.

TSB Recommendation M05-03 (September 2005)

The Board was concerned that life rafts are being certified without full consideration of realistic service conditions such as boarding or stability with water inside the life raft or boarding while in waves, and that Canadian and international standards for testing and certification of rigid and inflatable life rafts are not sufficiently performance-based, thus placing passengers and crews at undue risk. Therefore, the Board recommended that

the Department of Transport develop and implement performance-based standards to ensure that all life rafts deployed on Canadian vessels are capable of operating in severe marine conditions and, further, encourage the International Maritime Organization to adopt a parallel approach internationally.
TSB Recommendation M05-03

Transport Canada's response to Recommendation M05-03 (November 2005)

The Minister of Transport notes the recommendation. Transport Canada (TC) will continue to actively work with the International Maritime Organization (IMO) to improve the testing and performance criteria of all survival craft. Currently work at IMO is focused on improving the testing criteria for lifeboats and release mechanisms, as this has been a concern internationally and domestically.

TC is working on improving standards for survival craft in a number of areas:

As noted in the report, TC has presented findings at the Design and Equipment Sub-committee at IMO that indicate that the use of 75Kg as the weight used for test subjects in prototype testing of survival craft is not truly representative of today's seamen. In light of this fact Canada proposed that the mass of an average test subject be increased to 90kg as being more representative of modern anthropometric parameters. TC has subsequently submitted a paper on a related agenda item and will continue to work with other members for changes to the size of test subjects at Fire Protection Sub-Committee in January 2006.

TC has recently carried out testing on lifeboat release mechanisms in an effort to identify weaknesses in the testing protocol. TC will continue to work on improving the international standards for release mechanisms.

TC is planning to carry out research regarding thermal requirements of life rafts. The current IMO standards specify a need for insulated floors and canopies in life rafts without specifying the value of thermal protection required. This research will assist in improving the performance criteria of life rafts.

TSB assessment of Transport Canada's response to Recommendation M05-03 (January 2006)

As was noted in the investigation report into this occurrence, survival in emergency situations at sea depends to a large extent on survival equipment performing as intended. Consequently, it is essential that the standards for testing life rafts–rigid or inflatable–measure performance in relation to anticipated use and, ideally, under actual service conditions. Presently, this is not the case. The Board's recommendation therefore called on TC to not only develop and implement performance-based standards to ensure that all life rafts deployed on Canadian vessels are capable of operating in severe marine conditions, but to encourage IMO to adopt a parallel approach.

Other than those actions concerning life raft standards already noted in the investigation report, the response by TC indicated that the department is planning to carry out research regarding thermal requirements. There is no indication in the response of any other domestic initiative under consideration or being taken regarding life raft-related testing and performance criteria for operating in more severe marine conditions.

Although there is no indication in the response by TC that, internationally, improvements in the life raft-related testing and performance criteria are being addressed, TC is working at the international level through IMO to further improve the testing and performance criteria of survival equipment. The development of goal or performance-based standards is well underway within IMO in addressing a variety of maritime matters, such as lifejackets, evacuation guidance systems, voyage data recorders and ship construction. Furthermore, a correspondence group of the IMO Sub-Committee on Ship Design and Equipment (48th session, 21-25 February 2006) will be expected to prepare performance requirements for survival craft used on future passenger ships.

The response is considered Satisfactory in Part.

Transport Canada's response to Recommendation M05-03 (November 2006)

TC's update, dated November 2006, indicated it will continue to work with the IMO to improve the testing and performance criteria of all survival equipment. TC is working on improving standards for survival craft in a number of areas, including: proposed to IMO that the mass of an average test subject be increased to 90 kg; continue to work with other members for changes to the size of test subjects at the Fire Protection Sub-Committee in January 2006; continue to work on improving the international standards for release mechanisms for lifeboats; to carry out research regarding thermal requirements of life rafts. The current IMO standards specify a need for insulated floors and canopies in life rafts without specifying the value of thermal protection required.

TSB reassessment of Transport Canada's response to Recommendation M05-03 (November 2006)

TC's update provided no information to indicate that improvements in the life raft-related testing and performance criteria are being addressed to ensure that life rafts deployed on Canadian vessels are capable of operating in actual service conditions. However, TC is working internationally to further improve performance testing and approval standards of survival equipment: including measures to prevent accidents with lifeboats, compatibility of life-saving appliances and test standards for extended service intervals of inflatable life rafts.

Therefore, the assessment remains Satisfactory in Part.

Transport Canada's response to Recommendation M05-03 (June 2008)

TC's update, dated June 2008, indicated that TC is working on improving standards for survival craft in a number of areas, including a proposal to IMO that the mass of an average test subject be increased to 90 kg; work continues with other members for changes to the size of test subjects at the Fire Protection Sub-Committee; work continues to improve the international standards for release mechanisms for lifeboats; to carry out research regarding thermal requirements of life rafts.

The current IMO standards specify a need for insulated floors and canopies in life rafts without specifying the value of thermal protection required.

TC is currently engaged in scientific data collection regarding the thermal performance requirements for life rafts. Following this data collection TC will address current shortcomings in Life Saving Equipment Regulations and at IMO.

TSB reassessment of Transport Canada's response to Recommendation M05-03 (September 2008)

No substantial change to address the safety deficiency since the last assessment.

Therefore, the assessment of the response remains at Satisfactory in Part.

Transport Canada's response to Recommendation M05-03 (March 2010)

TC's update, dated March 2010, indicated that it is working on improving standards for survival craft in a number of areas, including a proposal to the Fire Protection Sub-Committee at the IMO that the mass of an average test subject be increased to 90 kg. Work also continues to improve the international standards for release mechanisms for lifeboats as well as to carry out research and data collection regarding thermal performance requirements of life rafts. Following this data collection, Transport Canada will address current shortcomings in the regulatory regime, as well as at the International Maritime Organization, as the current International Maritime Organization standards specify a need for insulated floors and canopies in life rafts without specifying the value of thermal protection required.

TSB reassessment of Transport Canada's response to Recommendation M05-03 (March 2010)

Work continues on improving standards for survival craft in a number of areas, including a proposal to the Fire Protection Sub-Committee at the IMO that the mass of an average test subject be increased to 90 kg. Work also continues to improve the international standards for release mechanisms for lifeboats as well as to carry out research and data collection regarding thermal performance requirements of life rafts. Following this data collection, Transport Canada will address current domestic and international shortcomings regarding standards that do not specify the value of thermal protection for insulated floors and canopies in life rafts.

Therefore, the assessment of the response remains Satisfactory in Part.

Transport Canada's response to Recommendation M05-03 (December 2010)

TC's update in December 2010 indicated that it has submitted a proposal to the Fire Protection Sub-Committee at the International Maritime Organization that the mass of an average test subject be increased to 90 kg. Work also continues to improve the international standards for release mechanisms for lifeboats as well as to carry out research and data collection regarding thermal performance requirements of life rafts. Following this data collection, TC will address current shortcomings in the regulatory regime, as well as at the International Maritime Organization, as the current International Maritime Organization standards specify a need for insulated floors and canopies in life rafts without specifying the value of thermal protection required.

TSB reassessment of Transport Canada's response to Recommendation M05-03 (March 2011)

As this initiative is ongoing, and there has been no substantial change to address the safety deficiency since the last assessment, the assessment of the response remains Satisfactory in Part.

Transport Canada's response to Recommendation M05-03 (December 2011)

Transport Canada is using international standards and continues to work at the IMO level to improve the performance of life-saving equipment including survival crafts.

The manufacturer of the life raft in question (Ovatek) has taken steps to reduce the likelihood of similar incidents occurring. Following the incident, TC and the manufacturer conducted tests with successful results, the TSB report refers to the actions taken by the manufacturer regarding familiarization with this type of life raft, including an updated user manual and other safety information.

Recent changes resulting from IMO work include increasing the weight of persons for survival craft testing. This was adopted following a paper submitted by Canada. Other improvements for the performance of life rafts include changes to the standard for inflation system, improved requirement for boarding ramps, among others.

As for life raft performance in general there are currently no plans at the International level for further development of testing for lack of evidence of operational issues in severe marine conditions.

TSB reassessment of Transport Canada's response to Recommendation M05-03 (March 2012)

Transport Canada's response addresses one specific type of rigid life raft, whereas the recommendation refers to the development and implementation of performance based standards for all life rafts. TSB acknowledges the various improvements to the existing standards (including increasing the subject test weights) but there was no indication that the standards would be performance based.

TC indicated that there is no evidence that there are operational issues with life raft deployment in severe marine conditions. However, TC agreed to review the occurrences originally cited in the TSB report M03M0077; Estonia (1994), Hili-Kum (1995), and Sleipner (1999).

Notwithstanding, TC has indicated that it does not intend to take further action at the international level on this recommendation. There has been no substantial change to address the safety deficiency posed by life rafts that are not performance tested and there is no evidence that TC intends to undertake further initiatives in this regard; therefore, the assessment of the response remains Satisfactory in Part.

Transport Canada's response to Recommendation M05-03 (December 2012)

Transport Canada believes that this recommendation has been met by way of the following actions:

  1. All life rafts for use on Canadian vessels must meet the criteria listed in Schedule VIII of the Life Saving Equipment Regulations. Among the criteria is a weather test prescribed in Subsection 1(1) which reads "Every life raft shall be constructed so as to be capable of withstanding exposure for 30 days afloat in any sea condition." This condition has been adopted from the LSA Code Chapter IV Section 4.1.1.1.
  2. The manufacturer of the life raft in question has taken steps to reduce the likelihood of similar incidents occurring. Following the incident, TC and the manufacturer conducted tests with successful results; the TSB report refers to the actions taken by the manufacturer regarding familiarization with this type of life raft, including an updated user manual and other safety information.
  3. Changes resulting from IMO work include increasing in the weight of persons for survival craft testing. This was adopted following a paper submitted by Canada (copy attached). Other improvements for the performance of life rafts include changes to the standard for inflation system, improved requirement for boarding ramps, among others.
  4. Currently, there is an ongoing effort to improve life raft performance through the IMO's Goal-Based Guidelines on Framework of Requirements for Ships' Life-saving Appliances referenced in Section 6 of the Sub-committee on Ship Design and Equipment's Report to the Maritime Safety Committee (DE 56/25) dated 28 February 2012. For example Annex 2 of the Goal-based Guidelines mentions: 5.1.3 The six categories for functional requirements will be as follows: 3 Performance means required functions for respective systems under adverse environmental conditions expected to be encountered by the ship at sea.

Transport Canada will continue to work at the IMO level to improve the performance of life-saving equipment including survival crafts.

TSB reassessment of Transport Canada's response to Recommendation M05-03 (March 2013)

Transport Canada's response indicates that it has gauged the international community and supports the IMO initiative to improve life raft performance. Despite the life raft weather test required in the Life Saving Equipment Regulations, there have been no further TC initiatives to develop or implement performance-based standards. Therefore, the assessment of the response remains Satisfactory in Part.

Transport Canada's response to Recommendation M05-03 (April 2018)

The International Maritime Organization's Ship Systems and Equipment (SSE) sub-committee is currently engaged in the development of goals, functional requirements and expected performance criteria for SOLAS Chapter III life-saving appliances and arrangements. Once the expected performance requirements for survival craft have been determined, Transport Canada will confer with other member states and evaluate if there is a further need to review the expected performance standards with regards to severe marine conditions.

TSB reassessment of Transport Canada's response to Recommendation M05-03 (June 2018)

Transport Canada's response indicates that after the IMO has developed various criteria to improve the survival craft performance requirements, it will confer with other member states and evaluate if there is a further need to review the expected performance standards with regards to severe marine conditions.

Therefore, the Board considers the response to the recommendation to show Satisfactory Intent.

Next TSB action

The TSB will continue to monitor action taken by TC regarding this recommendation to address the safety deficiency identified.

The deficiency file is Active.