Response to FROG-6 Testing with the DPC in Brazil

Following the recent Frog-6 testing performed in July 2019 according to DPC requirements, we were notified that the Frog-6 transfer carrier could not be homologated as it does not comply with one clause, article 7.5.3 of NORMAM-05 Annex 4-A. We were advised that we can submit our rationale and perspective which DPC’s comission would review before reaching its final decision regarding the re-homologation of FROG-6.

Reflex Marine is very supportive of DPCs efforts to introduce improved standards offshore Brazil and we believe NORMAM-05 Annex 4-A is an important step forward for the industry.

We attest that even without compliance to article 7.5.3, Frog-6 is fit for purpose and safe for use. Furthermore, we have concerns that the application of Article 7.5.3 may not support objectives to safeguard passengers, and if interpreted in a very literal manner it could reduce safety of a personnel transfer basket. 

Reflex Marine has 27 years’ experience in the design, verification and operation of the crane transfer devices. Reflex Marine was the first company to design capsules based on a comprehensive database of actual transfer incidents. This approach allowed Reflex Marine to the design the world’s first transfer capsules which include protected seated positions, safety harnesses, spring suspension systems (offering spinal injury protection) and immersion protection.  Reflex Marine was also the first company to validate biomechanical impact risks with full scale type testing with accelerometer instrumentation against aviation and automotive impact data. Its capsules are used to perform over one million passenger transfers each year and it has now achieved 8 years without a lost time incident associated with one of its products.

As indicated in the previous submission immersion events are rare in crane transfers activities.  Guarding features such as fall protection and impact protection are considerably more important to the safety and welfare of passengers than flotation features. However, we recognise passenger concerns relating to immersion, so the immersion performance of carriers is treated very seriously.  For this reason, we wish to raise some specific concerns relating to Article 7.5.3.

We have also developed our own guidance for immersion events and advise passengers to remain in the capsule to await rescue. This reduces the risk of passengers drowning or being lost at sea during an immersion event. For this reason, the stability of the capsule in all sea-states is important.

NORMAM-05 Annex 4-A

Article 7.5.3 of NORMAM-05 Annex 4-A states, "When the basket is in a stable condition, the water level in its interior measured against the seats shall not be less than 100 mm below the seat of each occupant in any loading condition". Reflex Marine wishes to challenge the application of this Article for the following reasons:

1. Reflex Marine assumes that the intent of clauses in Annex 4-A relating to buoyancy performance are to ensure protection in the event of unplanned incident or emergency situations.  It is therefore considered reasonable to expect the device to provide similar protection from drowning to an emergency flotation device such as life-jacket.
   
   
2. NORMAM-05 Mod 10 Section 0315 defines that for a life-jacket the distance between the waterline and the airway should be a minimum of 120 mm.  The current design of the Frog-6 already provides a minimum of 371 mm (for 5th percentile female) clearance.  Rigid application of Article 7.5.3 will increase this height by a further 315 mm which will have negligible effect on the comfort or safety of passengers in an immersion scenario.
   
   
3. The Frog-6 is designed to perform in sea-states of up to 3.5m Hs. Therefore, its stability when immersed in harsh weather is essential to the safety performance of the carrier.  The current Frog-6 design provides a very high self-righting restoring force from all angles of immersion and in all sea-states.  A rigid interpretation of article 7.5.3, requiring passenger positions to be raised relative to the water line would considerably reduce or eliminate the restoring force, making the device more prone to capsize and increasing the risk of drowning.
   
   
4. Frog-6 has been designed and tested to self-right from 180 degrees immersion; this test was witnessed by DPC in Dec-2013. The Frog-6 Design Dossier Sect 8.5.4 provides a record of the capsule fully self-righting in 9 seconds.  In all scenarios the Frog-6 will float with all three exits above the waterline.
   
   
5. It should be noted that should passengers be required to abandon any carrier they will only have the protection provided by a lifejacket. This may be airway clearance of 120mm above the waterline in case if class I lifejackets, or undefined airway clearance in case of class IV lifejackets.  Abandonment should not be required with the Frog-6 since it provides a highly stable floating platform in all weather conditions.
   
   
6. Article 4.1.3.2 states – It must have self-straightening capacity when it is inclined up to 35 degrees with respect to its vertical axis. In the view of Reflex Marine for carriers operating in sea-states greater than 1m Hs self-righting from at least 90 degree is advisable.  This would also account for situations where a carrier enters the water at an angle much greater than 35 degrees.  For example, if a carrier is dragged off the vessel due to a loss of station keeping.

For the reasons stated above we believe that the rigid application of Article 7.5.3 would compromise the objective of Clause 3.4 which states “Man-riding basket – equipment that, through its hoisting, is capable of safely transferring people between vessels, platforms, support facilities and port facilities.” 

The Frog-6 provides a very safe transfer performance, and in the unlikely event of immersion it will protect passengers in all sea-states, even beyond its recommended operating envelope of 3.5m Hs.

Reflex Marine Ltd

The re-homologation process is still ongoing, and Reflex Marine are awaiting the final decision on approval from the DPC. We will keep our clients informed of any updates or further information as it becomes available. Our current information from the DPC is that units currently in service in Brazil will continue to be allowed until a final verdict has been delivered.