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PFEER AND THE DACON SCOOP

This was a contribution to the Nautical Institute magazine, Seaways, prompted by a lot of news coverage about BALPA and the Dacon Scoop.

At the 2009 Scottish TUC conference, BALPA (The British Airline Pilot’s Association) put forward a motion that the Dacon Scoop or other form of mechanical recovery should not be the primary means of recovery in all sea states if a helicopter ditches. This approach was supported by Nautilus whose representative said that “concerns over the potential for commercial pressures to be placed on pilots or shipmasters to operate helicopters or fast rescue craft in adverse conditions lie behind the questions over the existing arrangements.”

Of course people actually involved in this stuff know what it is all about, but mariners who are working in non-oil related activities, or in areas other than the North Sea may be wondering what on earth is going on.

In order to provide an understandable explanation it is necessary to briefly cover the history of the standby vessel in the UK. The requirement for these craft was initiated subsequent to the loss of the jack-up Sea Gem in 1965, as part of the Mineral Working Act, and as a result in the following years redundant “side draggers”, the traditional deep sea trawlers, could be seen drifting about on the location of all North Sea installations. After the Piper Alpha disaster its standby vessel, the “Silver Pit” was identified by Lord Cullen’s enquiry as not being up to the task, and in the years which followed the industry itself developed something called “The Green Code” which set survey standards for the standby fleet. As a direct result all the old trawlers disappeared and were replaced by more manoeuvrable craft, mainly old supply vessels. In 1992 the problems relating to the recovery of personnel from the water in rough seas were highlighted at Cormorant Alpha, when a helicopter engaged in transferring personnel from the platform to an accommodation unit fell into the sea with the loss of 11 lives. The master of the assigned standby vessel Seaboard Support and the master of the standby vessel from North Cormorant, Grampian Monarch, considered that the weather was too rough for them to launch their fast rescue craft, even though both vessels were provided with modern launch and recovery equipment and both conformed fully with the “Green Code”. It also became evident that even though they were able to manoeuvre close to some of the survivors, the men in the water were unable to help themselves, and despite all efforts they drifted away into the darkness.

 In time the voluntary code was replaced with formal survey requirements and activities, administered and carried out in the UK by the MCA (Marine and Coastguard Agency) In later years in an effort to improve their status the ships were re-named ERRVs (Emergency Response and Rescue Vessels), but although the acronym is used formally everywhere, it has never really caught on and they are generally still referred to as “standby vessels”.

Of course Piper Alpha also resulted in the initiation of the UK Safety Case Regulations in 1995 and soon after, in the enactment of the PFEER Regulations (The Prevention of Fire and Explosion and Emergency Response) Regulations, and DCR (the Design and Construction Regulations). The latter regulations remain in place today in exactly the same form even though the Safety Case Regulations themselves were revised and re-issued in 2006.

The PFEER Regulations and DCR make up what is to most an obscure area of the UK offshore legislation – that is, even more obscure than the Safety Case Regulations. The results of these different bits of legislation are the PFEER Assessment and the Verification Scheme, and the development of performance standards for activities and equipment. It appears to outsiders that the intent of the PFEER was to capture the bits of the former regulations which determined things such as the number of lifeboats, and the presence of a standby vessel, but which had been lost at the inception of the Safety Case Regs and the arrival of goal setting standards.

Regulation 4 of the PFEER Regulations requires that:

1.       The duty holder shall take appropriate measures with a view to: (a) protecting persons on the Installation from fire and explosion; and (b) securing effective emergency response.

The guidance to the regulation states that “protecting persons from fire and explosion” covers all the measures that may be needed to safeguard people from fire and explosions, i.e. inherent safety by design, preventive, detection, control and mitigation measures. Some of these “measures” might be covered by the presence of the standby vessel which would be in a position to rescue personnel from lifeboats or the sea in the event of evacuation or escape.

Regulation 17 goes further, specifically covering the arrangements for recovery and rescue of persons subsequent to evacuation or escape from the Installation, rescue of persons near the Installation and the taking of all such persons to a place of safety. The guidance for this regulation effectively adds to the list of major accidents requiring to be addressed specifically: (i) A person falling from the Installation during overside working and (ii) A helicopter ditching in the sea on take-off or landing.

Since this is a “goal setting” regulation it is up to the duty-holder of the installation to which the safety case is applied, to minimise the risks to their personnel, from major accidents and in the event of such accidents occurring, to maximise the possibility of them being recovered safe and well to “a place of safety”. And it is necessary here to add that the safety case regulations only apply within the 500 metre safety zone surrounding offshore installations, which effectively means that the risks considered in relation to helicopters are those which are present during take off and landing at oil rigs.

A typical North Sea ERRV on its way to work.

So where does the Dacon Scoop come in – and – you may ask, what is it anyway? In considering the risks from helicopter travel, specifically those relating to landing and take off, if the helicopter falls into the sea it must be possible for the passengers, who have hopefully escaped from the aircraft, to be rescued and taken to a place of safety within the time frame which is defined by the protective qualities of their survival suits and of course the temperature of the water.   The means of rescue does not have to be a ship, but up to now it always has been.

BP made a specific effort to move away from the conventional approach with its Jigsaw project back in 2000, proposing that a helicopter service, supported by platform based rescue craft ,would produce the same results as the seventeen standby vessels it then employed. Eventually the seventeen ships were replaced by two helicopters and four very large vessels which carry ARRCs (Autonomous Recovery Rescue Craft), themselves sufficiently well found to reach the beach from any point in the North Sea under their own steam.

The rest of the North Sea operators have struggled on with – their Dacon Scoops. Because the PFEER regulations are goal setting in part, it is necessary for the operators of offshore installations to be able to demonstrate that in almost all circumstances it is possible for the standby vessel to carry out an effective rescue in the event of a major accident or a person falling into the sea, or a helicopter crashing within the 500 metre safety zone. In fine weather this may not be difficult. The research that has been carried out seems to indicate that a protective flight suit with the addition of a number of layers of clothing beneath will keep a person in the water alive for two hours. Like duvet covers, flight suits have a “clo” rating and the objective is therefore to provide personnel with a suit with a clo rating of 1, which will keep some-one alive indefinitely.

Operators of multiple installations close together use the figure of two hours as a means of justifying “ERRV sharing” where a single vessel may look after several rigs. These ships are usually provided with daughter craft which can be launched to stand by one installation while the mother craft stands by another. This is particularly useful during helicopter flights where the helicopter lands at both installations.

So far so good, but when the weather turns nasty everything changes. It has become more or less the norm that in sea states greater than three and a half metres no-one will launch their fast rescue craft – well almost no-one - not because they are difficult to launch, but because they are difficult to recover. But according to the PFEER Regulations, if a helicopter crashes into the sea, some means of recovery should be provided, or else the flight should not take place. And while the simple answer would be to discontinue flights in higher sea states, this would result in complete chaos in Aberdeen airport, where hundreds of offshore workers are transferred one way or the other every day.

So the question of how to recover survivors of a helicopter crash from the sea in adverse conditions, is answered by the Dacon Scoop. The device is hung over the side of the ship on a crane and the ship is manoeuvred close to the floating survivor who is collected in the scoop. So –problem solved. Of course in order to demonstrate that all this stuff works, each standby vessel has to carry out validation trials showing that it can launch its FRC and recover people from the water within the time required by the performance standards, all of which rely in one way or another on the theoretical survival time of two hours. It also needs to demonstrate that its Dacon Scoop or other mechanical recovery device can carry out the task, and because no-one wants to be doing this work in adverse conditions it is necessary for the surveyors overseeing the trials to extrapolate the results to demonstrate that if it had been rougher, success would still have been achieved. So as far as the helicopter pilots are concerned this device has yet to prove itself in action, and even in trials the weather conditions under which it is tested are not actually those in which it is intended to be used.

But Dacon Scoop is not the only way. One of the alternatives is the Jigsaw vessel, and its ARRC. Since it is not necessary to recover the ARRCs they can be launched more unpleasant conditions than the standard FRCs, and once having rescued the personnel in the water they can set course for the beach. Another possible technique is that used by the Danish ERRV operator Esvagt, although not in the UK sector of the North Sea. Esvagt have approached the task in their own way, and have developed FRCs and launch/recovery systems which can be operated in very rough seas. They demonstrate this capability by carrying out their crew changes by FRC in virtually any weather conditions. It may come as something of a surprise that what prevents the technique from being used in the UK waters is health and safety legislation.

One of the Vector Jigsaw vessels with it's ARRC visible on the port side.

The thrust of BALPA’s motion would therefore appear to be to reduce the reliance on the Dacon Scoop as rescue means in adverse conditions, but it is difficult to see whether they would like an alternative to be made available or whether they would like to fly only in more benign conditions, and it may be worth remembering that this device would only be useful in any case, if the helicopter crashed into the sea in the immediate vicinity of an offshore installation. One of the two helicopter crashes, which occurred earlier this year, happened while it was on passage, and if the preliminary report from the AAIB was correct there was a catastrophic gearbox failure, which might have resulted in the rotor detaching. One assumes that it just plummeted into the sea. All the passengers and crew died. In fact more helicopter crashes occur while the aircraft are en route than when they are taking off or landing, and if one factors in the weather conditions which would be required for the Dacon Scoop to be needed one can see that it is only carried because in PFEER terms, a crash during landing or take-off is a “foreseeable event”, rather than being statistically likely.

Back in 1992, after the Cormorant Alpha crash, the AAIB recommended that some effort should be made to prevent helicopters inverting when they hit the water, but no progress has been made in this direction. Hence offshore personnel still have to undergo the frightening experience of taking part in a helicopter escape, which requires them to remain strapped into a helicopter body while it turns upside down in the training pool, before releasing themselves and swimming to the surface.  Many would think that if the aircraft were provided with sufficient buoyancy to keep them on the surface, the chances of rescue in the event of a crash would be enhanced. Research in this direction might be more rewarding than putting more time and money into finding an alternative to the Dacon Scoop, which would appear to be inevitable if BALPA have their way. 

Vic Gibson

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