MARINE GUIDANCE NOTE

MGN 553 (M+F)
13 December 2017

Use of Equipment to Undertake Work Over the Side on Commercial Yachts, Small Commercial Vessels and Loadline Vessels

Notice to all Shipowners, Masters, crew and Ship surveyors

This note should be read with the Code of Safe Working Practices for Merchant Seafarers and the Regulations referred to in Annex 1.

This Note replaces Marine Guidance Note MGN 422 (M).

Summary

This Marine Guidance Note provides guidance on the use of "rail and trolley" and similar systems for undertaking "overside" work on yachts and other vessels. The main points are:

Annex 1 lists the following Regulations which are relevant to overside working:

Annex 2 gives details of the testing and operating procedures.

Annex 3 contains the requirements for single person systems.

1. Introduction

1.1 The use of single point safety "rail and trolley" systems is becoming more prevalent on vessels, especially mega-yachts. These allow crew members to work outside conventional guardrails for cleaning and maintenance purposes on yachts and other vessels. There have been a number of accidents using substandard equipment of this type. Also there has been evidence that the manufacturers' instructions on their use are not being followed. The purpose of this notice is to give guidance on their use.

1.2 Most consist of two travellers linked in tandem that can be separated if necessary into independent units. These are fitted to a metal track rail which allows the travellers to glide along it. There is the option of having more than one traveller on the rail. However, many of these systems have been designed, and installed, for the sole purpose of sail handling and not for supporting workers working over the side of the vessel.

1.3 It is a requirement of the Merchant Shipping and Fishing Vessels (Health and Safety at Work) (Lifting Operations and Lifting Equipment) Regulations 2006 (S.I. 2006/2184) that equipment which is used for lifting persons must be designed for the purpose. It is not acceptable to use a work station harness or a bosun's chair attached to a rail and trolley system designed for sail handling to enable window cleaning or other overside maintenance to be undertaken.

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2. Installation

2.1 A newly installed rail and trolley system used should be tested, certified and approved to a recognised European Union standard for fall protection equipment (EN 795:2012; Class D (or any subsequent revision) and should display the CE Mark. (EN 795:2012; Class D revises, expands upon and replaces EN 795:1996, referred to in MGN 422(M).)

2.2 More information on these requirements is contained in Annex 2.

2.3 EN795:2012 is supported by a Technical Specification - CEN TS 16415: Personal Fall Protection Equipment Anchor Devices Recommendations for anchor devices for use by more than one person simultaneously; which addresses multiple simultaneous users.

2.4 The requirements for single person systems are contained in Annex 3.

2.5 Where it is proposed to use a rail and trolley system or other system (i.e. a system already fitted) that has not been specifically designed for supporting crew members over the side, its use for overside work is not permitted without written confirmation having been received from the manufacturer, preferably by means of a certificate, that use for such purposes is permissible including any conditions attached to its use for that purpose.

3. Operation

3.1 Prior to permitting the work the employer should ensure that all alternative means for carrying out the work are considered.

3.2 Before use of the equipment the employer should ensure that:

3.3 Rail and trolley systems for working overside should not be used whilst the vessel is underway.

3.4 These systems are designed to be used with the appropriate Personal Protective Equipment(PPE) e.g. harnesses, lanyards, fall arresters and other devices.

3.5 On systems referred to in paragraph 2.1 there is a single attachment on each traveller designed to accommodate a single line such as a harness. One of the travellers is fitted with a locking device. The device which locks the traveller in position along the track rail must ONLY be disengaged from the track rail while the user is changing position. Once the user is in position, the locking MUST be re-engaged to hold the car in position and limit the user's movement along the track rail.

3.6 The user must NEVER rely on only one attachment point for personal protective equipment. The working harness should be attached to one traveller and a fall arrestor or other safety device to the other. A third traveller could be used to attach work tools.

3.7 More guidance can be found in the Code of Safe Working Practices for Merchant Seafarers (COSWP) Chapter 8; Personal Protective Equipment and Chapter 17; Work at Height.

3.8 The use of systems for overside work that do not meet the requirements of either paragraphs 2.1 and 2.2 above or fail to provide instructions in the use of such equipment in accordance with paragraph 3.1 above, could potentially place the employer of the crew, and also the master, in breach of their obligations under relevant Merchant Shipping Health and Safety legislation and render them liable to prosecution and a fine for non-compliance. Further information on relevant legislation is set out in Annex 1.

3.9 The rail and trolley system should never be used to hold fenders or tenders alongside the vessel, as this could lead to dynamic loading on the rail and trolley system which could lead to damage or failure of the rail or trolley.

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4. Maintenance

4.1 Where systems meeting the requirements of either paragraphs 2.1 or 2.2 above are used for overside work, relevant information regarding the maintenance and testing of such systems should be obtained from the system manufacturer. Such information is to be in written form and a copy of it is to be kept on board the vessel to which it applies.

4.2 Anchor devices which have been installed and certified to EN 795:1996 are still valid.

4.3 Existing anchor devices conforming to EN 795:1996 only if repaired and maintained to EN795:1996 standards can be retested to the EN795:1996 standards however should the system be designed to a previous standard such as EN795:1996 and has been modified or changed in anyway this should be considered as a new installation and tested to the latest revision such as EN795:2012. Any new products should be tested to the latest requirements set out in EN 795:2012 (or any subsequent revision).

4.4 More information on the testing of these systems is contained in Annex 2.

More Information

Seafarer Safety and Health Branch
Maritime and Coastguard Agency,
Bay 2/27
Spring Place,
105 Commercial Road,
Southampton,
SO15 1EG.

Tel : +44 (0) 203 8172503
e-mail: mlc@mcga.gov.uk.
Website Address: www.gov.uk/government/organisations/maritime-and-coastguard-agency
General Inquiries: infoline@mcga.gov.uk
File Ref: MC122/6/0026
Published: November 2017 - Please note that all addresses and telephone numbers are correct at time of publishing.
© Crown Copyright 2017

Safer Lives, Safer Ships, Cleaner Seas

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ANNEX 1

MERCHANT SHIPPING LEGISLATION RELEVANT TO OVERSIDE WORK

The following provisions of Merchant Shipping Legislation are relevant to overside work. However only the main points especially relevant to the use of selection of rail and trolley systems are listed. In order to meet the requirements of the legislation completely it will be necessary to comply fully with all the requirements of this legislation.

1. Merchant Shipping and Fishing Vessels (Health and Safety at Work) Regulations 1997 (S.I. 1997/2962) as amended

The regulations covered by sections 2 to 4 below apply to shipowners in respect of seafarers as well as to employers in respect of workers.

2. Merchant Shipping and Fishing Vessels (Provision and Use of Work Equipment) Regulations 2006 (S.I. 2006/2183)

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3. Merchant Shipping and Fishing Vessels (Lifting Operations and Lifting Equipment) Regulations 2006 (S.I. 2006/2184)

4. Merchant Shipping and Fishing Vessels (Health and Safety at Work) (Work at Height) Regulations 2010 (S.I. 2010/332)

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ANNEX 2

PROTECTION AGAINST FALLS FROM HEIGHT - ANCHOR DEVICES - REQUIREMENTS AND TESTING

1. Anchor devices or fixed rail devices fitted on vessels must comply with EN 795:2012 Class D (or subsequent revision).

2. Tests should be carried out on a sample of the medium to which the anchor devices, in this case the traveller and bar, is attached. Each test should be repeated at the extremity and intermediate anchor and at a joint.

3. A static test with a weight of 12kN should be applied for a period of 3 minutes. The device should suffer no permanent deformation of more than 10 mm.

4. A dynamic test consists of a 100 kg mass being dropped so that it generates a fall-arrest load of 9kN. The anchor device shall not release the test mass. Increase the test mass to 300 kg for 3 minutes. The mass is held clear of the ground

5. Precise descriptions of the required tests can be found in EN 795:2012 (or subsequent revision).

6. Diagram 1 is an example of a traveller showing its construction.

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ANNEX 3

REQUIREMENTS FOR SINGLE PERSON SYSTEMS

1. The system used should be tested, certified and approved to EN 795:2012, Class D (or any subsequent revision). This ensures the system has passed tests for general requirements, static (1200kg for 3 minutes) and dynamic (9Kn + 3Kn static for 3min) tests and corrosion resistance.

2. The system, full-body safety harness and fall arrester should carry the CE Mark (or ANSI) and comply with EN standards.

3. The systems described are to carry no more than one person and total weight (person, clothes and tools) should not exceed 100kg.

4. Trackways may be fitted at any orientation between horizontal facing down (0°) and vertical (90°) if this brings the shackle in contact with the car.

5. Stainless steel countersunk through-bolts (i.e. without a nut) to be utilised at a maximum 100mm spacing and in accordance with the manufacturer's requirements. Equivalent arrangements could also be considered. Alternative fixing options for steel or aluminium hulls MUST be appropriate to the hull design, proof tested as per Annex 2 and installed to manufacturers recommendations. Full details of the installation including method of anchorage and supporting technical documentation (fixing certification) must be issued on completion of every installation; other materials wouldrequire doubling plates to achieve equivalent strength.

6. Drawings of proposed installation to be submitted to the MCA, Class or the Certifying Authority, as appropriate for approval.

7. Installation testing to be witnessed by MCA, Class or Certifying Authority, as appropriate. This is to test whether the track comes away from the base when a load is applied.

8. Where fastenings are not through steelwork, the static and dynamic tests to be repeated on a sample. This sample should not be off the yacht or vessel.

9. We recommend that if you want to be compliant with EN795:2012 the installationneeds to be test as stated below:

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