Ladders for escape to sea

Page 1 of 6

Ladders for escape to sea

Offshore Information Sheet No. 10/2009
(Issued December 2009)

Contents
Introduction
Background
Matters to be considered if existing ladders are not to be maintained
Relevant legal requirements
References
Further information
Tables 1 and 2
Appendix A

Introduction
This sheet advises duty holders that a change in the means of descent to sea will normally comprise a material
change to the safety case , requiring submission of a revised safety case to HSE. In addition, for any such
change, a number of matters will need to be considered, to ensure continuing compliance with the Offshore
Installations (Prevention of Fire and Explosion, and Emergency Response) Regulations 1995 (PFEER). This
sheet provides guidance on these matters, where the intention is to replace ladders to sea with an alternative
means of descent to sea.

Background
Fixed ladders (which may include some associated gangways and/or stairways) to sea are often provided as part
of compliance with PFEER Regulation 16. Such ladders are subject to corrosion and wave impact, and there is
expense and risk involved in maintaining them. Some duty holders may consider not maintaining the ladders,
instead relying on alternative means of descent to sea. There are a number of matters which will need to be
considered to ensure continuing compliance with PFEER.
PFEER Regulation 16, and the Approved Code of Practice and Guidance1 for this regulation are given in
Appendix A. Other relevant PFEER Regulations are identified in Table 1.
Means of escape from an offshore installation normally comprises two elements: (1) a means of descent to sea
level, and (2) something which offers some protection from the elements and avoids the need to enter the sea
directly.
Means of descent to sea provided on UK offshore installations vary widely, depending on the installation and
circumstances. Such means may include fixed ladders, retractable ladders, stairways, liferaft davits, chutes
(typically Skyscape), and/or personal descender devices.
Liferafts are usually provided for protection from the elements and to avoid the need to enter the sea directly.

http://www.hse.gov.uk/offshore/infosheets/is10-2009.htm?ebul=offshore/jan-2010&cr... 27/01/2010

Ladders for escape to sea

Page 2 of 6

Historically, the means of descent provided have included knotted ropes or scramble nets. However, these are
not regarded as a suitable primary means of descent to sea, because not all persons working offshore will have
the physical capability to safely use them. HSE has not required these means of descent to be removed from
offshore installations, but it is necessary to provide other means of descent to satisfy PFEER Regulation 16.
Means of escape are provided as a back up system in case the arrangements for evacuation fail. Means of
escape are not required to provide the same level of protection from hazards as the evacuation system, and do
not necessarily include motive power or other means to enable persons to move quickly away from the
installation. Note that lifeboats, gangways between installations, and marine transfer systems are normally
provided as a means of evacuation, rather than a means of escape.

Matters to be considered if existing ladders are not to be maintained

1. To ensure continuing compliance with PFEER Regulation 16, ladders must continue to be maintained until
such time as a suitable alternative means of descent to sea is in place.
2. A change in the means of descent to sea will normally comprise a material change to the safety case.
Therefore, a revised safety case will need to be submitted and accepted by HSE before the ladders are
taken out of service or are allowed to deteriorate into an unacceptable condition.
3. The workforce should be consulted about the proposed change in the means of descent. In any event, the
safety representatives must be consulted in good time about the proposed revision to the safety case.
4. The justification for replacing ladders with some other means of descent will be specific to the installation.
Numerous factors can influence the decision, such as the risk levels on the installation, the size of the
workforce, the extent to which means of evacuation are available (which can influence the number of
persons who may require to escape), and the location of jacket legs in relation to the hydrocarbon hazards
(ladders on legs in the process area have reduced availability in the event of a hydrocarbon fire). PFEER
Regulation 5 requires the duty holder to carry out an assessment in relation to evacuation, escape,
recovery and rescue. The assessment should address the types, capacity, and locations of means of
escape to sea, and will need to be revised if the intention is to replace the ladders to sea with some other
means of descent to sea.
5. The revised PFEER Regulation 5 assessment should include an examination of whether the total package
of risk associated with the alternative means of descent to sea is less than or equal to the total package of
risk associated with maintaining ladders to sea. Risks which may contribute to the total package of risk are
(i) risk from use of the system in an emergency, (ii) risk due to potential unavailability of the system, (iii) risk
during training to use the system, and (iv) installation and maintenance risk. Replacing ladders with an
alternative means of descent to sea which leads to an increase in the total package of risk is not
acceptable.
6. If ladders are not to be maintained, a duty holder must be able to show that it is not reasonably practicable
to do so. Normally to do this the duty holder will need to carry out a cost benefit analysis (CBA), which
compares the costs of maintaining ladders with the residual risk reduction expected if ladders are provided.
Ladders should continue to be maintained unless it can be shown that these costs are disproportionate
compared with the risk reduction from retaining the ladders. When determining the costs and risks for
inclusion in the CBA, the duty holder should fully consider all reasonable alternative ways of continuing to
provide ladders to sea at minimum risk and cost. The alternatives might include, for example, the fitting of
fixed retractable ladders, or replacement of corroded ladders with pre-assembled modular ladders, or
provision of improved corrosion protection of existing ladders.
7. It is accepted that quantification of the above risks will require some broad assumptions and judgements offshore emergencies requiring use of escape systems are rare so there is little hard data on the
effectiveness of different means of escape. For illustrative purposes only, Table 2 provides an example of a
qualitative risk comparison between ladders to sea and personal descender devices. However, the CBA will
need to include some quantification of risk.
8. PFEER Regulation 16 requires that means of descent be available for all those persons on the installation
who may need to escape from the installation. This has implications both for the numbers and locations of

http://www.hse.gov.uk/offshore/infosheets/is10-2009.htm?ebul=offshore/jan-2010&cr... 27/01/2010

Ladders for escape to sea

Page 3 of 6

means of descent, and will depend on the numbers and likely locations of persons on the installation. The
number who may need to escape at any one time is likely to be less than the total POB, but the duty holder
will need to ensure appropriate access to sufficient means of descent to sea both for the largest groups
who may need to escape (mass escape) and for isolated individuals. For example, the largest group who
need to escape may be the full complement of a lifeboat which is found to be unavailable. In some cases, it
may be appropriate to provide two means of descent to sea, one for mass escape at specific locations, and
another more distributed means of escape for individuals.
9. The means of descent will need to deliver escapees to a point at which they can board a liferaft (assuming
that liferafts have been selected as the means of providing protection from the elements, and avoiding the
need to enter the sea directly).
10. If ladders are no longer in a safe condition, the duty holder must ensure that appropriate arrangements are
in place (i) to fully inform the workforce, (ii) to prevent use of the ladders, and (iii) to ensure that any
remaining parts of the ladders do not present a risk should they fall off.
11. In addition to the requirements related to PFEER Regulations 5 and 16, the duty holder must ensure that
the replacement means of descent complies with other relevant PFEER Regulations, as per Table 1.

Relevant legal requirements

Offshore Installations (Prevention of Fire and Explosion, and Emergency Response) Regulations 1995
(PFEER), Regulations 5, 6, 8, 14, 16, 18 and 19.
Offshore Installations (Safety Case) Regulations 2005

[2]

[1]

Regulation 14(2)

References
Prevention of fire and explosion, and emergency response on offshore installations Approved Code of Practice
and Guidance 2nd edition L65 HSE Books 1997 ISBN 0 7176 1386 0

Further information
Any queries relating to this information sheet should be addressed to:
Health and Safety Executive
Hazardous Installations Directorate
Offshore Division
Lord Cullen House
Fraser Place
Aberdeen AB25 3UB
Tel: 01224 252500
This information sheet contains notes on good practice which are not compulsory but which you may find
helpful in considering what you need to do

Tables 1 and 2
Table 1. PFEER Regulations applicable to the means of descent to sea
(See PFEER Regulations for precise wording)
PFEER Regulation

Relevance to means of descent to sea

5 Assessment

See main text of this Information Sheet.

http://www.hse.gov.uk/offshore/infosheets/is10-2009.htm?ebul=offshore/jan-2010&cr... 27/01/2010

Ladders for escape to sea

Page 4 of 6

PFEER Regulation

Relevance to means of descent to sea

6 Preparation for emergencies

Persons must be adequately trained in use of the means of descent.

Adequate written information must be provided about the means of descent.

8 Emergency response plan

The use of the means of descent must be adequately covered in the Emergency
Response Plan, and associated drills and exercises.

14 Muster areas etc

There must be safe access to escape points.

Designated escape points must be kept unobstructed, provided with adequate
emergency lighting, and marked with a suitable sign.

16 Means of escape

See main text of this Information Sheet.

18 Suitability of personal
protective equipment for use in
an emergency

This regulation places responsibility on the duty holder to provide suitable personal
protective equipment for use in an emergency.
The means of descent to sea and any protective clothing provided for use in an
emergency must be compatible.

19 Suitability and condition of

plant

The means of descent must be suitable for the purpose for which it is used or provided.
There must be arrangements to maintain the means of descent in efficient working
order and good repair.
It is expected the means of descent will be designated as a safety critical element, and
as such must be covered by a suitable written scheme for the systematic examination
by a competent and independent person (the ICP).

Table 2. Example of a qualitative risk comparison between fixed ladders and personal
descender devices
Risk

Ladder

Risk during use

Low risk, but persons could "freeze" or fall off

the ladder.

Personal descender devices

More complex to use, and greater scope for error in

use during emergency conditions. However, this risk
can be minimised by providing thorough training (and
Quick to use provided only a few persons need refresher training) for every person on board, including
to use the ladder.
visitors; such training to include practical use of the
descender unit by person wearing the installation
Simple to use, no training required (except for
survival PPE.
deployment of retractable ladders, if fitted).
More complex to use, and greater scope for error in
Escape takes place at fixed points, which can
use during emergency conditions. However, this risk
be suitably illuminated. It can be assured that
can be minimised by providing thorough training (and
some survival PPE and a liferaft will be
refresher training) for every person on board, including
available at those points. The standby vessel
visitors; such training to include practical use of the
will also be familiar with these points.
descender unit by person wearing the installation
survival PPE.
Not quite so quick to use as a ladder, but speed is
unaffected by number of persons escaping.
Potentially more doubt about location of escapees, and
less certainty of access to emergency lighting, survival
PPE, and liferaft, but these issues can be resolved if
descender stations are provided which include an
adjacent liferaft, survival PPE, identified descender
connection points, and emergency lighting. Also,
descender units should be equipped for painter
connection.

http://www.hse.gov.uk/offshore/infosheets/is10-2009.htm?ebul=offshore/jan-2010&cr... 27/01/2010

Ladders for escape to sea

Page 5 of 6

Risk

Ladder

Personal descender devices

Risk due to
unavailability of
means of
escape

Variable availability depending on (i) quality of

maintenance arrangements, and (ii) siting of
ladders in relation to hazards. An unrevealed
failure of a ladder is also possible.

Good availability, provided sufficient units are provided

in suitable locations.

Likelihood of non-availability can be reduced

by effective maintenance, and suitable location
of ladders.
Training risks

Very small.

There are training risks, but these can be made very

small by effective design and management of training.

Risks from
installation and
maintenance

There are risks from installation and

Very small.
maintenance, but these can be minimised by
good design (eg fit retractable ladders where
appropriate, eg fit modular alternative ladders,
eg maximise corrosion protection of ladder and
attachment points), and by good management
of maintenance activities.

Appendix A
Guidance and the Approved Code of Practice associated with PFEER Regulation 16
(taken from HSE Books document L65 Second Ed[3].)
PFEER Regulation 16 "Means of escape"
The duty holder shall provide such means as will ensure, so far as is reasonably practicable, the safe escape of
all persons from the installation in case arrangements for evacuation fail.

Guidance
The regulation requires the duty holder to provide means of escape so that persons may escape from the
installation in the event of the failure of the evacuation system in a catastrophic incident when a planned and
orderly evacuation cannot be achieved.
This paragraph explains some of the terms relevant to the regulation:
escape means the process of leaving the installation in an emergency when the evacuation system has
failed; it may involve entering the sea directly and is a 'last resort' method of getting persons off the
installation;
means of escape cover items which assist with descent to the sea, such as davit-launched life-rafts,
chute systems, ladders, and individually controlled descent devices; and items in which personnel can
float on reaching the sea, such as throw-over life-rafts.

Approved Code of Practice (ACOP)

Duty holders should select means of escape on the basis of their contribution to reducing the risks of those who
may have to escape from the installation to as low as is reasonably practicable. This means that duty holders
should give preference to means which offer some protection from the elements and avoid the need to enter the
sea directly. In addition, sufficient means of descent to the sea should be provided on all installations, including
fixed ladders or stairways, where reasonably practicable, and personal devices for controlled descent.
The duty holder should provide enough means of escape to ensure that they are available for all personnel who
may have to use them. Duty holders should also ensure that means of escape and any protective clothing
provided for use in an emergency are compatible.

http://www.hse.gov.uk/offshore/infosheets/is10-2009.htm?ebul=offshore/jan-2010&cr... 27/01/2010

Ladders for escape to sea

Page 6 of 6

Link URLs in this page

1. Offshore Installations (Prevention of Fire and Explosion, and Emergency Response) Regulations 1995
http://www.uk-legislation.hmso.gov.uk/si/si1995/Uksi_19950743_en_1.htm
2. Offshore Installations (Safety Case) Regulations 2005
http://www.uk-legislation.hmso.gov.uk/si/si2005/20053117.htm
3. L65 Second Ed
http://www.hse.gov.uk/pubns/books/l65.htm

http://www.hse.gov.uk/offshore/infosheets/is10-2009.htm?ebul=offshore/jan-2010&cr... 27/01/2010