SUBJECT: NON-SLIP SURFACES ON SHIP HELICOPTER LANDING
SITES
OCCURRENCE SUMMARY:
The Hughes 500 helicopter had been chartered to transfer two
crewmembers and their luggage from shore to the ship "Karoo", a
bulk ore carrier, at anchor near Mackay. After an uneventful
flight, the pilot landed the helicopter on the port side of cargo
hatch number seven. The steel cargo hatch, designated as the ship's
helicopter landing site (HLS), had a smooth painted surface. The
cargo hatch peaked in the centre and sloped down 0.85 degrees to
both port and starboard sides. The pilot positioned the helicopter
so that the tail rotor protruded over the port side edge of the
hatch. In this position, the helicopter was under the influence of
a crosswind from the left front quarter. The pilot reduced the
engine power to idle, friction-locked the cyclic and collective
controls, and locked the anti-torque pedals. He then left the cabin
to supervise the disembarkation of the passengers and remove their
luggage. After the passengers disembarked, the helicopter commenced
to slide slowly downslope towards the edge of the cargo
hatch.
The pilot ran from the right to the left side of the helicopter
and attempted to unlock the anti-torque pedals and climb aboard. As
he did so, the nose of the helicopter lifted when it weathercocked
left into the 25-kt south-easterly wind. The helicopter, with the
pilot partly on board, slid off the hatch and fell 3 m onto the
main deck, landing inverted on raised piping which ran along the
length of the deck. The pilot fell between the hatch and the piping
and was saved from injury by two steel posts supporting the pipe
system.
ANALYSIS:
A factor in this accident was that the ship's HLS did not have a
non-slip surface. When the weight in the helicopter was reduced
following disembarkation of the passengers, the smooth hatch
surface, combined with the helicopter's centre of gravity movement,
resulted in the helicopter slipping on the hatch. The steel hatch
had a smooth, painted surface which was not non-slip. Fortunately,
no injuries resulted from this accident, but the potential for
serious injury or death to personnel was clearly evident.
Factors in ship-helicopter transfers that may increase the risk of
helicopter and personnel slippage include:
(a) operations are conducted in varied weather conditions;
(b) operations are conducted on ships that are under way
(c) sea spray or dew on HLS surfaces reduces the coefficient of
friction of the surface;
(d) ship helicopter landing sites are subject to unpredictable
movement due to the pitch and roll of the ship;
(e) some hatch covers used as a HLS may have significant camber
either fore and aft or athwartships; and
(f) operations are conducted at night.
MARITIME LEGISLATION
Marine regulations recommend the provision of non-slip surfaces
for ship HLSs but do not mandate their provision.
Within the marine environment, the Australian Maritime Safety
Authority - Marine Orders deals with safety issues relating to
helicopter operations on ships operating in Australian territorial
waters.
MARINE ORDERS
Marine Orders, part 57, Issue 2 - Helicopter Operations, makes
provisions for and in relation to:
(a) The protection of the health and the security from injury of
persons engaged in the loading and unloading of ships; and
(b) the safety of persons, including pilots, going on or coming
from, or on board, ships,
in connection with transfer operations by helicopter.
Marine Orders part 57 states that requirements for safe
arrangements for transfer operations by helicopter are regarded to
have been met if arrangements, equipment, instructions and training
comply with:
(a) the Australian Code of Safe Practice for Ship-Helicopter
Transfers, published by AMSA; or
(b) the International Chamber of Shipping Guide to Helicopter/Ship
Operations to the extent that it is not inconsistent with
(a).
AUSTRALIAN CODE OF SAFE PRACTICE FOR SHIP-HELICOPTER
TRANSFERS
The Australian Code of Safe Practice for Ship-Helicopter Transfers
applies to all routine transfers of personnel or goods by
helicopter to or from ships while under way or at anchor. It does
not apply to fixed or floating structures, or vessels employed in
the offshore oil or gas industry.
Section 3 of the code deals with the HLS and states the
following:
"The HLS should have a non-slip surface."
Appendix 1 states the following:
"All paint used within the limit of the clear zone of an HLS or
the manoeuvring zone of an HWA [helicopter winching area] should be
such as to provide a non-skid surface whether wet or dry".
These statements do not clearly affirm that it is mandatory for a
ship HLS to have a non-slip surface. The word "should" indicates a
recommendation for the HLS to have a non-slip surface but does not
mandate it.
INTERNATIONAL CHAMBER OF SHIPPING'S, "GUIDE TO HELICOPTER/SHIP
OPERATIONS"
The International Chamber of Shipping's, "Guide to Helicopter/Ship
Operations", when dealing with the provision of HLS surfaces,
states the following:
"Section 4.5 Areas to be used by the helicopter landing gear or by
personnel should have anti-slip surfaces even when wet".
"Section 4.2.4 The aiming circle (Touch Down Zone) should be
completely covered with a matt anti-slip surface".
This publication is a guide and is not intended to be binding.
Shipping companies, ships' masters and officers, helicopter
operators and aircrew are all responsible for acting in accordance
with relevant national regulations and company instructions.
It therefore does not appear compulsory under marine legislation
for a ship HLS to have a non-slip surface.
MARINE PILOT TRANSFERS EXEMPTION
Section 4 of the Code of Safe Practice provides an exemption from
section 3 for marine pilot transfers and states the
following:
"Helicopter-ship operations solely for the purpose of effecting
the transfer of a marine pilot may be exempted from the provisions
of [Section] 3 subject to the following:
(i) A clear area of deck exists which must be no less than twice
the main rotor diameter and preferably 2D wherever possible.
(ii) The helicopter pilot brings the aircraft to a hover clear of
the ship's side and then hover-taxis to the landing position or the
ship's master and the helicopter pilot agree that the landing may
be safely made in another manner.
(iii) Sea and weather conditions are such that the ship's master
and the helicopter pilot agree that the operation may be carried
out safely and in accordance with flight rules, Civil Aviation
Regulations and the flight operations manual".
Correspondence received from operators conducting helicopter
marine pilot transfers has described situations where the
helicopter has begun to slide whilst on the deck of a vessel during
embarkation and disembarkation of marine pilots. When the
helicopter begins to slide, the only option available is to become
airborne. This situation, particularly at night, puts at risk the
lives of those disembarking or embarking as well as the helicopter
crew and the ship's crew.
Marine pilot transfer operations are no different from other
ship-helicopter transfer operations in that the helicopter lands on
the HLS and transfers a passenger. Marine pilot transfers are
usually performed with the ship under way. The danger to
passengers, the helicopter crew, and the ship's crew is still
present if the helicopter slips on the designated HLS.
Many ship HLSs apparently do not have a non-slip surface. A
non-slip surface on a ship HLS reduces the risk of the helicopter
slipping with the pitch or roll of the ship. Additionally, a
non-slip surface on the ship HLS reduces the risk of injury through
personnel slipping on the deck.
CIVIL AVIATION LEGISLATION
The Civil Aviation Regulations - Orders and Guidelines, does not
deal with the surface texture of a ship HLS. The landing area, size
and requirements are referred to in Civil Aviation Advisory
Publication (CAAP) 92-2 (1) - Guidelines for the establishment and
use of helicopter landing sites (HLS). These guidelines do not
address the provision of a non-slip surface.
SHIP-HELICOPTER TRANSFER OPERATORS
Operators conducting ship-helicopter transfers approve ship-based
HLSs in accordance with their operations manual and guidelines laid
down in CAAP 92-2 (1). No consideration is required to be given by
the operator to the non-slip nature of the helicopter landing site
when approving the site for their operations.
SAFETY DEFICIENCY
Many ship HLSs being used for ship-helicopter transfers are not
equipped with non-slip surfaces. The requirement for a non-slip
surface on ship HLSs is not mandated in marine legislation,
although it is recommended.
Helicopter landing sites used for marine-pilot transfer operations
are exempted from the recommended non-slip surface under certain
conditions.
It is not a requirement for helicopter operators to consider the
non-slip nature of the ship HLS surface when approving or surveying
the HLS for their operations. There is no requirement in operations
manuals for operators to only use a HLS with a non-slip
surface.
The Bureau of Air Safety Investigation recommends that the
Australian Maritime Safety Authority:
(a) make it mandatory for all ship helicopter landing sites to
have a non-slip surface;
(b) make changes to the publication "Ship - Helicopter Transfers,
Australian Code of Safe Practice" to clearly reflect this
requirement; and
(c) check compliance with this requirement during ship
inspections.
IR970174 also refers and was addressed to the Civil Aviation
Safety Authority.
Thank you for your letter of 6 February 1998 advising of the
Bureau's interim recommendation IR970173.
As the recommendation has far reaching consequences for the
operation of marine pilot transfers by helicopter, on 24 February
1998 I requested a meeting with officers of the Bureau to discuss
the recommendation prior to responding formally to your letter.
On Thursday 26th March 1998 I met with [name supplied] and [name
supplied] of the Air Deficiency Section and discussed the
recommendation in depth. At this meeting it was possible to fully
explore all options and explain to the investigators the practical
problems that the Australian Maritime Safety Authority (AMSA) could
foresee with full implementation of the recommendation.
AMSA is fully committed to ensuring safe procedures in all areas
of maritime operations and for this reason will endeavour to
implement your interim recommendation to the maximum extent
possible taking into account practical considerations. Comments on
specific areas of the recommendation are as follows.
(a) make it mandatory for all ship helicopter landing sites to
have a non slip surface;
Marine Orders Part 57 (Helicopter operations) makes it mandatory
for the master of a ship not to permit the transfer of persons and
goods between helicopter and ship unless certain arrangements,
equipment, instructions and training have been provided. The Marine
Orders further amplify this requirement by stating that
arrangements, equipment, instructions and training that comply with
the Australian Code of Safe Practice for Ship-Helicopter Transfers
or the International Chamber of Shipping Guide to Helicopter/Ship
Operations will be regarded as meeting the requirements. The Code
and Guide both state that helicopter landing sites should have a
non slip surface.
(b) make changes to the publication "Ship - Helicopter
Transfers, Australian Code of Safe Practice" to clearly reflect
this requirement,
Maritime legislation is moving away from prescriptive type
requirements towards more responsibility being placed upon the
operator to conduct operations safely within a safety regulatory
framework. The framework provides the operator with guidance on how
to comply with safety requirements but does not rule out other
appropriate measures that provide the same level of safety. This of
course places a heavy duty of responsibility on the operator to be
able to demonstrate that any departure from the guidelines provides
at least the same level of safety as if the guidelines were fully
complied with. For this reason AMSA would be reluctant to change
the present Code of Safe Practice to make it more prescriptive.
(c) check compliance with this requirement during ship
inspections.
Unfortunately for a number of reasons this recommendation is not
practical. For any ships using helicopter transfer for pilot
boarding the inspection would be after the fact and would not
assist in ensuring compliance. The majority of ships do not have
dedicated HILS's and masters can state that they do not normally
undertake helicopter operations and if they intended to do so would
then prepare the landing site accordingly.
Regardless of the foregoing comments AMSA believes that the
reports received by BASI and our own intelligence suggests that
there may be a concern in the area of safe ship/helicopter
operations and the full compliance with safe operating practices by
those involved. In order to comply with the spirit of your
recommendation and in order to address the possible non compliance
by operators with the Code of Safe Practice AMSA intends to take
the following action.
A Marine Notice will be issued advising masters, owners, agents
and marine pilots of the specific occurrence and other reported
incidents associated with the lack of a non slip surface on
shipboard helicopter landing sites. The notice will advise that the
provision of a non slip surface for helicopter landing sites is
considered to be of paramount importance in ensuring the safety of
ship/helicopter operations and that all ships will be expected to
take appropriate action to ensure that a non slip surface is
provided for the helicopter landing site prior to allowing such
operations to be conducted.
Agents for ships proceeding to Australia will be requested to
bring this notice to the attention of masters prior to arrival at
the first Australian port and marine pilot providers will be
advised that AMSA expects them to advise ship masters of this
requirement in their initial contact with the ship. A copy of the
Marine Notice will be forwarded to BASI as soon as it is
promulgated. A copy of Marine Orders Part 57 together with the
Australian Code of Safe Practice for Ship-Helicopter Transfers will
be forwarded to the publishers of "Guide to Port Entry" which is an
international publication widely used by a majority of the world's
shipping.
I trust that these measures, together with the present
regulations, satisfy the requirements of the interim
recommendation.
I would finally like to express my appreciation to the officers
of your Bureau for their cooperation in meeting with me and taking
time to discuss the recommendation in detail. I was impressed with
their practical approach to operational safety considerations and
the courtesy extended to me in allowing a full exploration of the
issues from the AMSA point of view to be undertaken.
Marine Notice - non-slip surfaces for helicopter landing sites
(HILS) on ships
On 31 March 1998 [name supplied] wrote to you regarding action
to be taken by AMSA following BASI interim recommendation
IR970173.
As advised, this Authority has issued a Marine Notice advising
masters, ship owners, agents and marine pilots of the importance of
providing a non-slip surface on HLS's and of the occurrence of the
relevant accident and other similar reported incidents.
