Chapter 6 : Who needs protection and what regulations are required?

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Who Needs Protection?

It is important to remember what Golden said in his presentation to the commission of the European Committees in Luxemburg in 1983 on hypothermia, exposure, rescue and treatment. This is quoted in full. It is as true today as when he made the presentation nineteen years ago.

The above considerations emphasize the importance of a careful assessment of the overall nature of the threat before deciding on a solution to the problem. It is apparent that when one is considering the environmental problems associated with the European Offshore Oil and Gas industry one is dealing with a complex multifactoral problem with many interacting facets. Providing a solution to one facet alone is unlikely to solve the overall problem. There is a tendency in recent years to overemphasize the problem of general hypothermia, whereas the acute incapacitating problems of cold are much more likely to lead to death from drowning long before hypothermia may develop. By concentrating one’s efforts on providing protective clothing for the individual, in the endeavour to delay the onset of hypothermia following immersion, one is frequently embarking on a pathway which is not only economically expensive, but also involves such a degree of technical sophistication that is in danger of failing to function as designed when donned quickly in an emergency. As the majority of deaths following immersion occur in the early stages before hypothermia develops, preventative efforts should be directed toward providing protection against the short-term incapacitating effects of cold and protection against drowning.

Added to this important statement was the advice given by Tipton in 1993 (Reference 156). In his paper, he recommended that the process of providing protective equipment for an individual should start with the identification of all the hazards. If more than one hazard exists then the different pieces of equipment developed for protection against each of these hazards should be regarded as components of a larger system; these components should complement each other and operate as one integrated survival system to be specified and rated accordingly.

Aside from the military requirement, there are basically eleven categories of occupations which fall into three groups that need protection. Many of these people need similar equipment but with modifications depending on their specific trade. Before proceeding it is important to identify these groups. In order to explain the logic for placing these occupations into three groups, some recent accidents are quoted.

Group l: Constant Wear Suit 0.25 Clo or 0.75 Clo insulation?

Group l

  • Harbour / river pilots
  • FRC operators
  • Helicopter pilots and pilots of lightcraft flying over large expanses of cold open water
  • Helicopter passengers
  • Professional fishermen and fish farm operators
  • Professional / offshore yachtsmen
  • Recreational boaters and skidoo operators
  • Those working close to or over water without fall arrest (i.e. bridge construction workers)

First, there are those people who require a constant wear suit that can be worn continuously for an eight hour shift with no problem and minimal discomfort. Probably most at risk are fishermen. A typical accident is quoted below. If rescue is potentially close at hand and the survivors can be rescued within 90 minutes, then a very good light weight 0.25 immersed Clo dry suit can be designed for them.

Fisherman killed when herring seiner capsizes: Six crewmen survive accident. (The Chronicle Herald, 3 October 2000)

A herring seiner’s captain died Sunday night when he and six crewmen were tossed into the water after their boat capsized off Yarmouth under the strain of a full load of fish. A seventh crewman watched in horror from a nearby power skiff as the 21-metre Flying Swan out of Wedgeport turned over in a matter of seconds 53 kilometres south of Yarmouth.

The same logic can be applied to the profession of harbour or river pilots as demonstrated in the accident below.

Two crew missing after tugboat sinks. (Globe & Mail, 24 October 2001)

Detroit. Two crew members were missing after a tugboat that delivered mail and pilots to passing Great Lakes freighters rolled over and sank in the Detroit River early yesterday, the US Coast Guard said. Two others, both Canadian freighter pilots, were rescued. The accident occurred as the tug J.W. Westcott ll was taking two pilots to the Sidsel Knutsen, a Norwegian tanker carrying gasoline, said Coast Guard Lieutenant-Commander Brian Hall.

The third case of an FRC operation quoted below is a case where the detail is not specific enough to draw conclusions because the time in the water is not stated, nor is the type of suit, i.e. a wet or dry suit. This is a good case to demonstrate that the operators must be given some options on the suit they choose, depending on potential rescue time and water temperature. In this case, the potential for death from cold shock or swimming failure within the first few minutes of immersion was high, therefore the minimum requirement would be a dry 0.25 Clo suit. However, if rescue could not be guaranteed within 90 minutes, a dry 0.75 Clo suit must be substituted.

Two die as U.S. Coast Guard vessel flips. (The Halifax Herald, 25 March 2001)

A U.S. Coast Guard boat patrolling the Niagara River along the U.S. – Canada border capsized and two of the four crewmen died Saturday after floating for hours in the icy waters of Lake Ontario. "A four-foot (1.2 metre) wave hit the bow of the boat, swamping it and flipping it over" said Adam Wine, chief petty officer at the Coast Guard’s Buffalo station. The 6.5 metre, rigid-hull inflatable was found floating bow up along the lake shore about 1.5 kilometres east of the mouth of the river, and the crewmen were rescued soon after midnight about five kilometers northeast of the river, Wine said. River conditions had been choppy Friday night, with waves of about half-a-metre and occasional swells as high as one metre. The crew was supposed to report in every half-hour but never did, and a multi-jurisdictional search by air and sea began about two hours after the boat had left port. The rescue was hampered by heavy snow. A fire rescue boat located and rescued the four men, but it was not clear how long the crew had been in the water.

The fourth accident quoted below illustrates that aircrew other than military aircrew flying over large expanses of cold water also need protection. This unprotected pilot disappeared off the Grand Banks of Newfoundland. It is only speculation how death occurred, but is likely from cold shock as the cabin rapidly filled with water. This could have been compounded by injury that precluded jettisoning the door to escape. Therefore, such professions also require a comfortable constant wear suit. The decision to wear the lightweight 0.25 immersed Clo will be made on whether rescue can be guaranteed within 90 minutes, or a liferaft can be boarded, otherwise a 0.75 Clo suit is required.

Sea search on for downed pilot: Florida man ditches after two-seater’s engine fails. (The Sunday Herald, 23 September 2001)

Air and sea searches are underway for a Florida man whose small aircraft went down in waters not far from the Hibernia oil platform, some 370 kilometres east of St. John’s. The man who was flying a common route for light aircraft from St. John’s to the Azores, radioed at about 6:30 a.m. that the only engine of his two-seater Cessna 172 had failed and he was ditching into the ocean. It’s believed that he had no liferaft and that he wasn’t wearing a survival suit. The seas were about a metre high, the winds light at about 30 kilometres per hour and the water temperature about 13° C . Searchers said visibility was good.

The standard that currently applies to Group l requires the immersion suit to have 0.75 immersed Clo of insulation. Because the 0.75 Clo suit can be hot and uncomfortable in air, it can, in some cases be either ignored and not donned, or incorrectly secured. It is important to note that the wearer must know why and when to wear the suit, how to wear the suit and the dangers of allowing leakage. Otherwise, as demonstrated in the next paragraph, the suit will not protect the person. Investigation into whether the survivors or casualties in the Super Puma Cormorant A accident in 1992 (Reference 2) had their immersion suits correctly donned is covered in vague terms casting some doubt that this was so. The majority appear to have been correctly fitted, with the central zip up to at least three inches from the top. Evidence suggested that a majority also had the hood up when the accident occurred. The suit worn by casualty assigned the code NS2 was the only one which was positively identified as having taken in a significant amount of water. The suit was partially unzipped, but it was not possible to determine if it had been like this at the time of impact. The report continued as follows:

The sea temperature was 7° C and the wave height was estimated to be 8-11 metres. After hitting the water, the helicopter immediately inverted, floated briefly and then sank. Unfortunately, only 12 of the occupants, 10 passengers and 2 crew, were able to escape and subsequently six of these were recovered from the water dead. The remainder, 5 passengers and 1 crew, survived to be rescued 40- 85 minutes after the accident. Some of these survivors reported later that they had been in the water with their immersion suits partially unzipped, although they had not been aware of any leakage occurring inside. Rescuers also described finding bodies with their suit partially undone and full of water. Similarly, the divers who recovered the 5 victims from the wreckage confirmed that they were also wearing their immersion suits partially unzipped.

It would appear that in the quest to protect from hypothermia, we have to some degree overprotected this constant wear Group l occupational workers. For the future, providing the immersion suit is tested as an integrated system with the lifejacket, then immersion suits approved to the new draft ISO / FDIS 15027-3 should be applicable to this group:

Class A: Test subjects exposed for a time of 6 hours to water less than 2° C .

Class B: Test subjects exposed for a time of 4 hours to water less than 2° C .

Class C: Test subjects exposed for a time of 2 hours to water less than 5° C .

Class D: Test subjects exposed for a time of 1 hour to water less than 5° C or test subjects exposed for a time of 2 hours to water less than 15° C .

This gives the operator the choice of system for their environment.

Specifically for the fishermen’s outfit, the original UK work was commendable, the fishermen’s suit offers the greatest challenge to the designers, it has progressed somewhat with the new PVC and urethane coated fabrics and manufacturers are striving to make the suits to match the industries, i.e. the lobster fisherman requires a different suit from the scallop fisherman. The first step is to write a new standard for them that insists that all parts of the suit are positively buoyant. However, it still has a long way to go. The solution to many of the problems now for all the suits is not dependent on the clothing manufacturers, but on the organic chemists and fabric designers, much more funding is required by them before we can make the next technology leap forward.

Group ll: Ship Abandonment Immersion Suits

Listed below are the two occupations that require a ship abandonment suit of 0.75 immersed Clo insulation.

Group ll

  • Professional crew of maritime shipping companies inshore / offshore
  • Crew of offshore oil rigs

The second group comprises all those who work on the water for a profession and face the possibility of having to abandon ship. Their normal working clothes are standard industrial work dress. In the event of the requirement to abandon ship, they don a 0.75 Clo insulated immersion suit, or what is currently called a ship abandonment suit, within one minute. The following examples demonstrate that it works if worn and the penalties for not wearing it.

On 16 January 1998 en route from Rotterdam to Montreal, the Flare broke in two in severe weather conditions and sank 45 miles south west of Saint Pierre et Miquelon. Only four seamen were rescued. Sgt. Isaacs, the SAR technician who conducted the rescue reported that four men were alive and clinging to the top of a lifeboat. Three were severely hypothermic due to inadequate clothing (body core temperature was recorded as 26º to 28° C ), but the fourth had donned every item possible before abandonment and was in very good shape. Twentyone seamen died from a combination of drowning and hypothermia. All bodies that were rescued were lightly clothed, most were not wearing shoes or socks. In this case, if the seamen had worn a good ship abandonment immersion suit, they would have likely survived. A good example of the effectiveness of the ship abandonment suit was in the case of the deckhand from the Patricia MacAlister accident who donned his immersion suit (Reference 161). He was picked up several hours later in the Gulf of St. Lawrence, whereas the five other tug crew did not leave time to do this and likely died from drowning produced by cold shock. There are several other accidents on the Canadian and American coastline where ship abandonment survival suits would have been beneficial. (Marine Electric (1983), Charlie (1990), Protektor 1991, Gold Bond Conveyor (1993)). There is no question that immersion suits protect people from the four stages of immersion in cold water, but they are not an absolute guarantee.

B.C. fishing boat sinks, killing two (The Sunday Herald, October 28, 2001)

Victoria – Two men died but two others survived after a Comox, B.C., fishing boat sank in heavy seas off the northern tip of Vancouver Island. Crew member Beauchamp Englemark, 27, of Comox resident, was the first of the Kella-Lee’s four-member crew to be found. He was clad in a survival suit when rescuers pulled him aboard the coast guard vessel John P. Tully about 7:30 Friday. The body of one crew member, also wearing a survival suit, was found about noon Friday and the body of a third, not wearing a survival suit, was recovered about 3 p.m. The fourth man, in a survival suit and in a lifeboat, was spotted just before 4 p.m. and plucked out of the frigid water in good condition about 5:15 p.m.

Why one of the two men died in the fishing accident off British Columbia while wearing an immersion suit is not known. It could be that the suit was not secured correctly and flooded, it could be the flotation angle in the water was poor and the man drowned from inhaling a wave, or he could have died from cardiac arrest. Until we educate the investigators to ask the correct questions and to teach the pathologists what testing and examination to conduct, it is only possible to second guess the causes of death.

As emphasized in the paragraph above on the Group l occupations, good training is equally essential for the Group ll occupations. All personnel who work on or over water should know the dangers of sudden cold water immersion, where to find and how and when to don the immersion suits. In the very recent accident, that occurred in January, 2002, it does not appear that there were enough immersion suits on board, and no one bothered to don them either. The 14 crew had a very lucky escape.

Sailors tell of harrowing rescue in storm. (The Globe and Mail. January 29, 2002)

Sailors who scrambled off a ship in the middle of a raging North Atlantic snowstorm say a broken pump caused their vessel to fill rapidly with water. The captain of Sjard, a German-owned, dry-bulk carrier, said he and 13 other crewmembers climbed aboard a lifeboat, strapped themselves in and launched it overboard after a bilge pump malfunctioned Sunday. Mr. Scharbatke said none of the men donned the three survival suits that were aboard the vessel. Mr. Scharbatke said that although weather conditions during the rescue operation were awful, with roiling seas, winds of more than 90 kilometres an hour, snow and 5° C water temperatures, no one panicked as they abandoned ship and waited in the lifeboat for help to arrive.

If one considers that prior to 1945 there were only rudimentary immersion suits in existence, and prior to 1983, there were basically no immersion suits commercially available for ship abandonment, then the IMO standard has served well to implement their availability. By and large, the suits are very good for protection against hypothermia. All credit should be given to the researchers, industry and financial backers in achieving this. A study by Brooks et al (2001) (Reference 31) on 357 students attending a Basic Survival Training Course at Survival Systems Training in Dartmouth, Nova Scotia showed that there was general satisfaction with the suits and confidence that they could survive. The problem of interface with the lifejacket is still present. Understanding the length of time it takes to revise the standard, it is probably best to leave it alone. The next step for this group is the development of a new integrated suit system standard, an effective, self-righting test using a manikin, and a re-enforcement that a good training program is necessary. The exciting news is that Shell, the Shark Group and the University of Portsmouth, UK have now produced and are using the first generation of such a system.

Group lll: Passenger Immersion Suit Systems

Group lll

  • Passenger of cruise ships operating in water below 15° C
  • Passengers of small tourist vessels (whale watching etc.)
  • Passengers of year-round ferries (i.e Nova Scotia to Newfoundland and Digby to Saint John, etc.)
  • Passengers of ferries in the spring and fall (i.e. Great Lakes and west coast, etc.)

The third group of people who require protection who so far have been totally omitted are tourist passengers of cruise ships, passengers on ferries crossing large expanses of cold water, i.e. Digby, Nova Scotia to Saint John, New Brunswick; Sydney, Nova Scotia to Newfoundland; Yarmouth, Nova Scotia to Bar Harbour or Portland, Maine; passengers on Great Lakes ferries; passengers on ferries off the west coast in spring, fall and winter; and a whole range of smaller vessels that conduct whale watching, fishing trips etc., both inshore and offshore. For them, the primary threat is drowning from cold shock and swimming failure. One has to survive the first two stages of immersion before becoming hypothermic. If rescue is slow, then obviously hypothermia and post rescue collapse become a serious threat. It cannot be emphasized too much that getting out of the water, or even half out of the water is the key to survival. Remaining immersed is very, very dangerous. The objective for the future is to have ships fitted with all dry evacuation systems, so that the survivor either never gets wet, or only wet for a short time. However, technically to achieve this is not easy, particularly under high degrees of list. The Estonia accident is a good example where in spite of the list, a considerable number of people made it to the upper deck. One witness stated that from his part of the ship, at least 100 people made it to the upper deck. They all theoretically should have survived, yet many as we so tragically saw from the statistics of the second World War died in the survival phase. We seem to have forgotten this lesson.

Around that time some were passing lifejackets from hand to hand and people were trying to put them on as best they could…a man was standing composed and assured trying to calm those who were frightened. He arranged a human chain to distribute lifejackets from an open container. He saw that everyone got a lifejacket and also instructed and helped passengers to put them on.

Many of these were to die in the cold water. If everyone had been given an immersion suit, there would have been an improvement from the 852 casualties (Reference 43).

How should these people be protected? There is a simple solution to this problem. Currently, these passengers are each issued a large bulky SOLAS approved inherently buoyant lifejacket. Anyone making their way from a cabin to the upper deck for abandonment when the ship is listing or flooding has an impossible task to do this when wearing one of these or trying to drag it behind them along the companion ways, stairwells and stairs. The idea now being introduced in Europe comes from the method used to protect naval personnel in a ship abandonment. In the Navies, each sailor is provided with a belt on which is hung two small pouches. One contains a lifejacket and the other contains a once-only quick-don immersion suit. On the upper deck, just prior to abandonment, the lifejacket is unbuttoned from the pouch, unrolled, placed over the head and orally inflated, nothing could be so simple. Then the second pouch is unbuttoned, the suit unrolled and donned over the lifejacket and sealed at the neck by the drawstring. The person is then physically prepared against drowning from cold shock and swimming failure. In the short term, the suit provides protection for approximately one hour from hypothermia in the water and once in the liferaft virtually indefinitely.

The concept for passengers on ferries or cruise ships etc. can be very similar. It is very important to refer to the lifejacket and immersion suit as an integrated immersion suit system, and it should be certified as such against a performance standard. The reason for this is that if this does not occur, a standard will be written around a certain system and leaves little flexibility for improvement and innovation. An immersion suit and lifejacket developed as one system, tightly packed on a belt or jacket (allow the manufacturer to come up with the design), should be provided in each cabin for each occupant. In addition, there should be 100% additional systems located on the upper deck, instead of the conventional lifejackets. The system should not be tested against a lifejacket or an immersion suit standard, but against its own performance standard. This should also be simple. It should:

  • Protect from cold shock and swimming failure
  • Protect from hypothermia in 5° C water for 2 hours (basically the ISO Class C standard)
  • Protect from hypothermia in a liferaft for 24 hours
  • Protect the oronasal cavity and prevent drowning
  • Be self-righting in 5 seconds from a face down position in turbulent conditions
  • Be easy to don
  • Be easy to use to climb into a liferaft form the ocean
  • Should fit all sizes of male and females

The reason why it should be tested against a new performance standard is to get away from such concrete ideas that an inflatable lifejacket must be dual chambered. In fact, if a manufacturer can design a puncture proof single chambered inflatable element within the immersion suit system that incorporated one or two layers of the suit itself, then this is a positive step forward in design. Canada has the opportunity to lead the world in developing and implementing such a performance standard and Canadian industry could develop the new system.

Quick-don immersion suits and simple inflatable lifejackets as described above are now commercially available. Therefore, in the short term (2–3 years), simple quick don immersion suits should be required on all vessels carrying Group lll personnel. In the event of very small vessels and lack of stowage, then all passengers must wear an inflatable lifejacket particularly if the water temperature is below 15° C . Once the integrated suit system standard is developed and equipment commercially available (3-5 years), then this system should be required on all vessels carrying Group ll personnel. The issue of how much insulation is required in the system is difficult to answer because it depends on so many factors. The author would like to see 0.75 immersed Clo value suits on every vessel, but practically and economically this probably is not feasible. The majority of people die in the first four minutes of immersion and therefore to get the best value for money, save the most lives and help operators to comply, a simple 0.25 immersed Clo dry suit which can be packed tightly and needs minimum maintenance is the way ahead.

Current Regulations

Currently, written in English, there appear at least 11 sets of regulations ratified or in draft pertaining to immersion and related suits. There must be others that remain in confidential files of different maritime and offshore oil industry health and safety committees. These are:

  • Canadian General Standards Board. Marine Abandonment Immersion Suit Systems. CAN / CGSB -65.16-99. (Reference 34)
  • Canadian General Standards Board. Helicopter Passenger Transportation Suits. CAN / CGSB - 65.17-99. (Reference 33)
  • Canadian General Standards Board. Marine Anti- Exposure Work Suit. CAN / CGSB -65.21-95.
  • US Coast Guard Department of Transportation. Life Saving Equipment. Part 160 Chapter 1 of 46 CFR . (Sub-part 171 – Immersion Suits, Sub-part 174.-Thermal Protection Aids.) Consolidated Edition 2001.
  • IMO SOLAS . Chapter lll. Lifesaving Appliances and Arrangements.
  • IMO International Life-Saving Appliance Code 1997.
  • Civil Aviation Authority. Helicopter Crew Members Immersion Suits. Specification No. 19, Issue 1. 15 April 1991.
  • Air Standardization Coordination Committee. ASCC Standard 61/12 (Methodology for Evaluation of Anti-Exposure Clothing in Cold Water Immersion Using Human Subjects)
  • Final draft pr EN ISO FDIS 15027-1-3 Immersion Suits: Part 3: Test Methods. 26/08/1999.
  • Draft Issue 2 JTSO -XXX Helicopter Crew and Passenger Integrated Immersion Suits for Operations to or from Helidecks in a Hostile Sea Area.
  • Personal Protection of Helicopter Passengers in the Event of Ditching. Shell Health, Safety and Environment Committee. February 1996.

Highly commendable is the fact that the only industrial standards that appear to be publicly available have been produced by the Shell group of oil companies.

Generally speaking, there is very little difference in each of the regulations. The next step is for us to apply what we have learned from these standards and introduce a new standard for an integrated immersion suit system. However, not as in the case of the draft JTSO integrated immersion suit, to write the standard around a system that has already been developed.

The personnel in Group l who require a constant wear suit should be offered a standard which gives them a choice depending on their environmental conditions. The draft ISO standard is a good basis for a start because it offers four levels of protection. However, it should be used as a guideline for the integrated suit system standard.

The personnel in Group ll with their 0.75 immersed Clo suit are well protected from all four stages of the immersion incident with the current standards. With hindsight, it is now realized that there is a problem with the lifejacket self-righting these suits.

However, taking the overall situation into consideration, the suits are good and to date no one has demonstrated to the author that anyone has perished as a result of the incompatibility between immersion suit and lifejacket. More likely, they have perished because ship abandonment type immersion suits were not carried or not donned. The standard should be retained until a new integrated standard is developed.

The personnel in Group lll are currently unprotected. As a matter of urgency, in the short term (2 years), operators should provide passengers in vessels operating in water below 15° C with the quick-don Navy style immersion suit. This is commercially available in Canada. In the long term (5 years), a new integrated immersion suit standard should be developed for them. For operators who read this report and think that the introduction of a quick don suit will be a waste of time and money for them, this is not the case. This will be a huge step forwards in the protection of their passengers and it should not be difficult to modify their in service suits to the new specifications, or grandfather them for say another five years.

Future research should involve the development of simple, cheap validated flotation and thermal manikins to do this. Confidential work which is currently underway makes the author believe that in less than two years this will be achievable. Then it will only be required to represent the thinnest and tallest subjects for the thermal test. This will mean human testing will only have to be done in cold water for radical improvements in current systems or entirely new concepts. All the remainder of suit testing can be done using a manikin. For the flotation manikin, again depending on funds, and the will to get on with the job, this could be achieved in five years.

Summary of Chapter 6

This chapter discusses who needs protection, what regulations are in place and what regulations are missing.

  • The first consideration must be a careful assessment of the overall nature of the threat before deciding on a solution. Providing a solution to one facet alone is unlikely to solve the problem.
  • In the attempt to delay hypothermia, one is frequently embarking on a pathway, which is not only economically expensive, but involves such a degree of sophistication in suit design that it may fail when donned quickly in an emergency.
  • As the majority of deaths following immersion occur in the early stages 1 and 2 before hypothermia develops, preventative measures should be directed toward providing against the short term incapacitating effects of cold and protection from drowning.
  • There are thirteen professional categories who require either a constant wear suit (Group l), a ship abandonment suit (Group ll) or a passenger immersion suit (Group lll)
  • Some of the professions in Group l have been overprotected with 0.75 immersed Clo. They should be offered alternative suits with insulation ranging from 0.25-0.5 Clo based on the draft ISO standard where four levels of insulation are prescribed.
  • Group ll professionals are well protected with their 0.75 immersed Clo suit, but a new integrated suit standard should be developed to include the lifejacket. This will solve the problem of inability of current lifejackets to self right humans wearing high buoyancy suits.
  • Group lll passengers sailing in water below 15° C are unprotected. In the short term, operators should provide them with the Navy style of inflatable lifejacket and quick don immersion suit. In the long term, a new integrated passenger immersion suit standard should be written.
  • The key factors involved in the development of an integrated immersion suit system are listed.
  • A list of the current immersion suit standards is included.

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