SPECIAL
                                                                                REPORT
                                                                      310

Worker Health and
Safety on Offshore
           Wind Farms

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TRANSPORTATION RESEARCH BOARD
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SPECIAL REPORT 310 Worker Health and Safety on Offshore Wind Farms

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MARINE BOARD Chair*: Michael S. Bruno, Stevens Institute of Technology, Hoboken, New Jersey Chair**: Thomas M. Leschine, University of Washington, Seattle Vice Chair: James C. Card (Vice Admiral, U.S. Coast Guard, retired), Maritime Consultant, The Woodlands, Texas Steven R. Barnum, Hydrographic Consultation Services, Suffolk, Virginia Jerry A. Bridges, Bridges Group International, LLC Mary R. Brooks, Dalhousie University, Halifax, Nova Scotia, Canada Stephen M. Carmel, Maersk Line Limited, Norfolk, Virginia Edward N. Comstock, Raytheon Company, Sudbury, Massachusetts Elmer P. (Bud) Danenberger III,** Consultant, Reston, Virginia Jeanne M. Grasso,** Blank Rome LLP, Washington, D.C. Stephan T. Grilli, University of Rhode Island, Narragansett Douglas J. Grubbs, Crescent River Port Pilots Association, Metairie, Louisiana John M. Holmes, Port of Los Angeles, San Pedro, California Donald Liu, NAE, Marine Consultant, Willis, Texas Richard S. Mercier, Texas A&M University, College Station Edmond J. Moran, Jr., Moran Towing Corporation, New Canaan, Connecticut Ali Mosleh, University of Maryland, College Park George Berryman Newton, Jr., U.S. Arctic Research Commission, Marstons Mills, Massachusetts Karlene H. Roberts, University of California, Berkeley (Emerita) Peter K. Velez, Shell International Exploration and Production, Inc., Houston, Texas John William Waggoner, HMS Global Maritime, New Albany, Indiana *Term of service completed October 2012. **Beginning November 2012. TRANSPORTATION RESEARCH BOARD 2013 EXECUTIVE COMMITTEE OFFICERS Chair: Deborah H. Butler, Executive Vice President, Planning, and CIO, Norfolk Southern Corporation, Norfolk, Virginia Vice Chair: Kirk T. Steudle, Director, Michigan Department of Transportation, Lansing Division Chair for NRC Oversight: Susan Hanson, Distinguished University Professor Emerita, School of Geography, Clark University, Worcester, Massachusetts Executive Director: Robert E. Skinner, Jr., Transportation Research Board

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Special RepoRt 310 Worker Health and Safety on Offshore Wind Farms Committee on Offshore Wind Farm Worker Safety TRanspoRTaTion ReseaRCh BoaRD OF THE NATIONAL ACADEMIES Transportation Research Board Washington, D.C. 2013 www.TRB.org

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Transportation Research Board Special Report 310 Subscriber Categories Transportation Research Board Special Report 310 Safety and human factors, marine transportation Subscriber Categories Transportation Research Board publications are available by ordering individual publi- Safety and human factors, marine transportation cations directly from the TRB Business Office, through the Internet at www.TRB.org or national-academies.org/trb, or by annual subscription through organizational or indi- Transportation Research Board publications are available by ordering individual publi- vidual affiliation withthe TRB Business Office, through the Internet at www.TRB.org or cations directly from TRB. Affiliates and library subscribers are eligible for substantial discounts. For further information, contact the Transportationorganizational or Busi- national-academies.org/trb, or by annual subscription through Research Board indi- ness Office, 500 Fifth TRB. Affiliates and library subscribers(telephone 202-334-3213; vidual affiliation with Street, NW, Washington, DC 20001 are eligible for substantial fax 202-334-2519; or e-mail TRBsales@nas.edu). Transportation Research Board Busi- discounts. For further information, contact the ness Office, 500 Fifth Street, NW, Washington, DC 20001 (telephone 202-334-3213; Copyright 2013 by or e-mail TRBsales@nas.edu). fax 202-334-2519; the National Academy of Sciences. All rights reserved. Printed in the United States of America. Copyright 2013 by the National Academy of Sciences. All rights reserved. NOTICE: TheUnited Statesis the subject of this report was approved by the Governing Printed in the project that of America. Board of the National Research Council, whose members are drawn from the councils of the National Academy of Sciences, the National Academy of Engineering, and the NOTICE: The project that is the subject of this report was approved by the Governing Institute of Medicine. Research Council, whose members are drawn from the councils Board of the National The members of the committee responsible for the report were chosenNational special competencies and with regard for appropriate balance. and the of the for their Academy of Sciences, the National Academy of Engineering, Institutereport has been reviewed by of group other than the authors according to the This of Medicine. The members a the committee responsible for the report were procedurestheir specialby a Report Review Committee consisting of balance. of the chosen for approved competencies and with regard for appropriate members Nationalreport has of Sciences, the by a group other thanEngineering, according to the This Academy been reviewed National Academy of the authors and the Institute of Medicine.approved by a Report Review Committee consisting of members of the procedures Nationalstudy was sponsored by the Bureau of Safety andEngineering, andEnforcement This Academy of Sciences, the National Academy of Environmental the Institute of the U.S. Department of the Interior. of Medicine. This study was sponsored by the Bureau of Safety and Environmental Enforcement Cover photograph: Offshorethe Interior. B.V., managed by Workships Contractors B.V. of the U.S. Department of Wind Services Used with permission. TypesettingCongress Graphics. Library of by Circle Cataloging-in-Publication Data Library of Congress Cataloging-in-Publication Data National Research Council (U.S.). Transportation Research Board. Committee on Offshore Wind Farm Worker Safety, author. National Research Councilon offshore wind farms Research Board. Committee on Worker health and safety (U.S.). Transportation / Committee on Offshore Wind Offshore Wind Farm Farm Worker Safety. Worker Safety, author. Worker health and safety on offshore wind farmsspecial report ;on Offshore Wind pages cm — (Transportation research board / Committee 310) Farm Worker Safety. ISBN 978-0-309-26326-9 1. Offshore wind power plants—Employees—Health report ; 310) pages cm — (Transportation research board special and hygiene—United States. 2.ISBN 978-0-309-26326-9 Offshore wind power plants—United States—Safety measures. 3. Offshore wind power plants—Safety regulations—United States. I. National hygiene—United (U.S.). 1. Offshore wind power plants—Employees—Health and Research Council States. 2. Offshore wind power plants—United States—Safety measures. 3. Offshore wind Transportation Research Board. II. Title. III. Series: Special report (National Research power plants—Safety regulations—United States. 310. Council (U.S.). Transportation Research Board) ; I. National Research Council (U.S.). Transportation Research Board. II. Title. III. Series: Special report (National Research TK1541.N38 2013 Council (U.S.). Transportation Research Board) ; 310. 363.11'933392097309168—dc23 TK1541.N38 2013 2013016731 363.11'933392097309168—dc23 2013016731

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The National Academy of Sciences is a private, nonprofit, self-perpetuating society of distinguished scholars engaged in scientific and engineering research, dedicated to the furtherance of science and technology and to their use for the general welfare. On the authority of the charter granted to it by the Congress in 1863, the Academy has a man- date that requires it to advise the federal government on scientific and technical matters. Dr. Ralph J. Cicerone is president of the National Academy of Sciences. The National Academy of Engineering was established in 1964, under the charter of the National Academy of Sciences, as a parallel organization of outstanding engineers. It is autonomous in its administration and in the selection of its members, sharing with the National Academy of Sciences the responsibility for advising the federal government. The National Academy of Engineering also sponsors engineering programs aimed at meeting national needs, encourages education and research, and recognizes the superior achievements of engineers. Dr. Charles M. Vest is president of the National Academy of Engineering. The Institute of Medicine was established in 1970 by the National Academy of Sciences to secure the services of eminent members of appropriate professions in the examina- tion of policy matters pertaining to the health of the public. The Institute acts under the responsibility given to the National Academy of Sciences by its congressional charter to be an adviser to the federal government and, on its own initiative, to identify issues of medical care, research, and education. Dr. Harvey V. Fineberg is president of the Insti- tute of Medicine. The National Research Council was organized by the National Academy of Sciences in 1916 to associate the broad community of science and technology with the Acad- emy’s purposes of furthering knowledge and advising the federal government. Function- ing in accordance with general policies determined by the Academy, the Council has become the principal operating agency of both the National Academy of Sciences and the National Academy of Engineering in providing services to the government, the public, and the scientific and engineering communities. The Council is administered jointly by both Academies and the Institute of Medicine. Dr. Ralph J. Cicerone and Dr. Charles M. Vest are chair and vice chair, respectively, of the National Research Council. The Transportation Research Board is one of six major divisions of the National Research Council. The mission of the Transportation Research Board is to provide leadership in transportation innovation and progress through research and information exchange, con- ducted within a setting that is objective, interdisciplinary, and multimodal. The Board’s varied activities annually engage about 7,000 engineers, scientists, and other transporta- tion researchers and practitioners from the public and private sectors and academia, all of whom contribute their expertise in the public interest. The program is supported by state transportation departments, federal agencies including the component administra- tions of the U.S. Department of Transportation, and other organizations and individuals interested in the development of transportation. www.TRB.org www.national-academies.org

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Committee on Offshore Wind Farm Worker Safety James C. Card, United States Coast Guard (retired), The Woodlands, Texas, Chair Thomas J. Lentz, National Institute for Occupational Safety and Health, Cincinnati, Ohio Gerald E. Miller, G. E. Miller and Associates, Tucson, Arizona Edmond J. Moran, Jr., Moran Towing Corporation, New Canaan, Connecticut Jakob Nielsen, Siemens Energy Transmission, Hamburg, Germany James W. Platner, Center to Protect Workers’ Rights—Center for Construction Research and Training, Silver Spring, Maryland Jennifer L. Schneider, Rochester Institute of Technology, Rochester, New York Robert E. Sheppard, Energo Engineering, Houston, Texas Michael A. Silverstein, University of Washington School of Public Health, Olympia Brian Walencik, GE Power and Water, Schenectady, New York David H. Wegman, University of Massachusetts, Lowell (emeritus), Auburndale, Massachusetts Transportation Research Board Staff Mark S. Hutchins, Study Director

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Preface In April 2011, the Bureau of Ocean Energy Management, Regulation, and Enforcement (BOEMRE) had just received the results of a study by the Marine Board of the National Research Council (NRC) focusing on the structural safety of offshore wind turbines (see TRB 2011). By that time, the first offshore wind farms in the United States had been planned for areas along the East Coast, the Gulf of Mexico, and the Great Lakes. Therefore, BOEMRE felt a sense of urgency in meeting its mandate for enhancing and enforcing safety regulations. The agency’s perception was that offshore wind farms would soon be under construction; that skilled workers would be required to build, operate, and repair them; and that health and safety rules would need to be in place to protect the workers. The rules governing this work would need to be equivalent to those regulating work on land-based wind farms and offshore oil and gas platforms. By requiring an operator to submit a description of a safety management system (SMS), the U.S. Department of the Interior’s (DOI’s) Bureau of Ocean Energy Management (BOEM)—formerly BOEMRE—has preempted the Occupational Safety and Health Administration (OSHA) from enforcing its health and safety regulations. Although BOEM has jurisdiction over regulating all renewable energy development activities on the outer continental shelf (OCS) and requires an SMS, the agency recognized that the requirements are vague and need updating. In August 2011, BOEMRE (now BOEM) requested that the Marine Board conduct a study to assess the agency’s approach for regulating the health and safety of wind farm workers on the OCS. Appointed by NRC, the study committee consists of 11 members from industry, academia, and government with expertise in occupa- vii

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viii Worker Health and Safety on Offshore Wind Farms tional health and safety, safety management, epidemiology and indus- trial hygiene, human factors, offshore engineering and construction, and wind energy development. Biographical sketches of the committee members appear at the end of this report. The committee met five times over a 12-month period and carefully examined the hazards associated with all aspects of offshore wind farm construction, operations, mainte- nance, and decommissioning. The committee compared the hazards of offshore oil and gas operations with those of offshore wind farm opera- tions, examined jurisdictional responsibility, and investigated the role of SMSs in addressing the hazards confronting workers on offshore wind farms. In approaching its charge, the committee initially needed to address the meaning of such terms as “hazard” and “risk,” which the statement of task (see Box 1-2) used inconsistently. In an effort to clarify this situ- ation, the committee first obtained insight from the occupational safety and health field, where a “hazard is any source of potential damage, harm or adverse health effects on something or someone under certain conditions at work.”1 The committee also recognized that the defini- tion of risk varies among disciplines; however, the committee ultimately adopted the concept of risk from the engineering discipline that views workplace risk as the product of the probability and the consequence of a hazardous event. During its deliberations, the committee identified hazards and recog- nized existing regulations, standards, and best practices (listed in Table 4-1) that could address each hazard. Some specific issues provided as examples in the statement of task—such as elevators in a marine envi- ronment and the inclusion of fire suppression systems—were suggested before the committee had a chance to identify the major safety issues involving offshore wind personnel. While these issues are a concern, they are not discussed in as much detail as other hazards. For example, the committee learned that elevators or service lifts may be less exposed to the corrosive marine environment and may present less of a mainte- nance hazard than previously thought. Also, the committee recognized that offshore wind turbines are usually unmanned and may require a 1 See the Canadian Centre for Occupational Health and Safety website (http://www.ccohs.ca/ oshanswers/hsprograms/hazard_risk.html).

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Preface ix design approach to firefighting different from that of offshore oil plat- forms. As such, mandating active (or installed) fire suppression systems in offshore wind turbines may not be necessary and, in fact, may increase the number of maintenance trips that technicians must take to a turbine. The committee’s review of DOI’s current regulatory frameworks for offshore worker health and safety revealed that a safety and environmen- tal management system (SEMS) and an SMS are similar but not inter- changeable. Both focus on reducing the risk of occupational injuries, illnesses, and fatalities by using management systems like those found in health and safety standards [for example, American National Standards Institute (ANSI) Z10] and International Organization for Standardiza- tion (ISO) quality and environmental management programs (see the ISO 9000 series and the ISO 14000 series). SEMS, as defined in American Petroleum Institute (API) Recommended Practice (RP) 75 (API RP 75), unlike SMS, emphasizes the management of environmental impacts. The committee examined the elements of many available SMS stan- dards, including applicable aspects of SEMS, to determine which could be used as a model for BOEM’s SMS. The recently completed Marine Board study (see TRB 2012) on assess- ing the effectiveness of a SEMS aided the committee in understanding the role and scope of an SMS. European nations have developed dozens of offshore wind farms over the past 15 years, and the committee looked to their experience for health and safety guidance. The report that fol- lows represents the consensus opinions of the committee members and presents the committee’s findings and recommendations on the juris- dictional issues involved in offshore wind farm development and the adequacy of current DOI health and safety regulations. ACkNOWLEDGMENTS The committee acknowledges John Cushing, Timothy Steffek, Zachary Clement, Lori Medley, and the other staff members of the Bureau of Safety and Environmental Enforcement (BSEE) and BOEM who pro- vided insight into the responsibilities and workings of the two agencies and its predecessors, BOEMRE and the Minerals Management Service. The work of the committee was facilitated by the thoughtful advice and background information provided by all of the presenters at its meetings,

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x Worker Health and Safety on Offshore Wind Farms other individuals with relevant technical expertise, and government and industry officials who were consulted during the course of the study. The committee received presentations and briefings from the follow- ing individuals: • Robert LaBelle, Acting Deputy Director, BSEE, DOI; • John Cushing, Senior Technical Advisor, BSEE, DOI; • Dean McKenzie, Safety and Health Specialist, OSHA, U.S. Depart- ment of Labor (committee liaison); • Paul Shannon, Dam Safety Branch Chief, Federal Energy Regulatory Commission; • James D. Lawrence, Offshore Specialist, United States Coast Guard (USCG); • Michele Mihelic, Manager, Labor, Health, and Safety Policy, Ameri- can Wind Energy Association; • Richard Wright, Chief, Safety and Occupational Health, United States Army Corps of Engineers; • Ronald Beck, Chief, Energy and Facilities Branch, First Coast Guard District, USCG; • Daniel Hubbard, USCG; • Jakob Nielsen, Head of Environment, Health, and Safety Offshore, Siemens Energy Transmission (committee member); • Holly Hopkins, Senior Policy Advisor, API; • Brian Walencik, Environment, Health, and Safety Leader for Renew- able Energy, GE Power and Water (committee member); • Michael A. Silverstein, Assistant Director for Industrial Safety and Health (retired), Washington State Department of Labor and Indus- tries (committee member); • Thomas L. Sutton, Associate Director of the Wind Energy Center, Kalamazoo Valley Community College; • Jerome F. Kaiser, Technician and Environment, Health, and Safety Specialist, GE Power and Water; • Nathan A. McMillin, Environment, Health, and Safety Manager, GE Power and Water; • John E. Chamberlin, Environment, Health, and Safety Manager, Siemens Wind Power; • Casper Kvitzau, Commercial Head of Offshore Projects in the Ameri- cas, Siemens Energy;

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Preface xi • Sean R. Grier, Senior Electrical Engineer, Duke Energy; • Jeff Moser, Construction Division Safety Manager, Weeks Marine; • Kevin Pearce, Senior Vice President, Engineering and Development, Arcadia Windpower; • Kevin McSweeney, Manager, Safety and Human Factors Group, ABS Corporate Technology; • Edmond J. Moran, Jr., Senior Vice President, Moran Towing Corpo- ration (committee member); and • Gerald E. Miller, G. E. Miller and Associates (committee member). This study was performed under the overall supervision of Stephen R. Godwin, Director, Studies and Special Programs, Transportation Research Board (TRB). The committee gratefully acknowledges the work and support of Mark S. Hutchins, who served as study director and assisted the committee in the preparation of its report. The commit- tee also acknowledges the work and support of Suzanne B. Schneider, Associate Executive Director of TRB, who managed the review process; Norman Solomon, who edited the report; Janet M. McNaughton, who handled the editorial production; Juanita L. Green, who managed the production; Jennifer J. Weeks, who prepared the manuscript for pre- publication web posting; Jennifer Correro, who proofread the typeset pages; and Javy Awan, Director of Publications, under whose supervision the report was prepared for publication. Amelia Mathis, Mai Q. Le, and Claudia Sauls arranged meetings and provided administrative support to the committee. The committee extends its sincere gratitude to the dili- gent and capable staff of the National Academies. Without their efforts and support, producing the report would not have been possible. This report was reviewed in draft form by individuals chosen for their diverse perspectives and technical expertise, in accordance with procedures approved by NRC’s Report Review Committee. The purpose of this independent review is to provide candid and critical comments that will assist the institution in making its published report as sound as possible and to ensure that the report meets institutional standards for objectivity, evidence, and responsiveness to the study charge. The review comments and draft manuscript remain confidential to protect the integrity of the deliberative process. The committee thanks the following individuals for their review of this report: Kenneth Arnold, K. Arnold Consulting, Inc., Houston, Texas;

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xii Worker Health and Safety on Offshore Wind Farms Rear Admiral Millard S. Firebaugh (U.S. Navy, retired), University of Maryland, College Park; Ralph Marshall, ExxonMobil; Roger L. McCarthy, McCarthy Engineering, Palo Alto, California; Melissa A. McDiarmid, University of Maryland School of Medicine; Kevin P. McSweeney, ABS Corporate Technology, Houston, Texas; Brian Naughton, New West Technologies, LLC, Washington, D.C.; John S. Spencer, National Transportation Safety Board (retired), Conroe, Texas; and David J. Wisch, Chevron Energy Technology Company, Houston, Texas. Although these reviewers provided many constructive comments and suggestions, they were not asked to endorse the committee’s findings or recommendations, nor did they see the final draft of the report before its release. The review was overseen by Robert A. Frosch, Harvard Univer- sity, and by Susan Hanson, Clark University. Appointed by NRC, they were responsible for making certain that an independent examination of this report was carried out in accordance with institutional procedures and that all review comments were carefully considered. Responsibility for the final content of this report rests entirely with the authoring com- mittee and the institution. James C. Card, Chair Committee on Offshore Wind Farm Worker Safety REFERENCES Abbreviation TRB Transportation Research Board TRB. 2011. Special Report 305: Structural Integrity of Offshore Wind Turbines: Oversight of Design, Fabrication, and Installation. Transportation Research Board of the National Academies, Washington, D.C. http://www.trb.org/Publications/Blurbs/165263.aspx. TRB. 2012. Special Report 309: Evaluating the Effectiveness of Offshore Safety and Envi- ronmental Management Systems. Transportation Research Board of the National Academies, Washington, D.C. http://www.trb.org/Publications/Blurbs/167249.aspx.

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Acronyms and Abbreviations Acronyms and abbreviations used in the report are listed below. ABS American Bureau of Shipping ACP Alternative Compliance Program ADCI Association of Diving Contractors International, Inc. AIHA American Industrial Hygiene Association ALARP as low as reasonably practicable ANSI American National Standards Institute API American Petroleum Institute ASSE American Society of Safety Engineers ASTM American Society for Testing and Materials (now known as ASTM International) AWEA American Wind Energy Association BAST best available and safest technology BLS Bureau of Labor Statistics BOEM Bureau of Ocean Energy Management (after October 1, 2011) BOEMRE Bureau of Ocean Energy Management, Regulation, and Enforcement (May 19, 2010, to October 1, 2011) BSEE Bureau of Safety and Environmental Enforcement (after October 1, 2011) BWEA British Wind Energy Association (RenewableUK since 2004) CFR Code of Federal Regulations COP construction and operations plan CVA certified verification agent CZMA Coastal Zone Management Act of 1972 xiii

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xiv Worker Health and Safety on Offshore Wind Farms DNV Det Norske Veritas DOE U.S. Department of Energy DOI U.S. Department of the Interior EA environmental assessment EAP emergency action plan EEP emergency evacuation plan EIS environmental impact statement EPAct Energy Policy Act of 2005 EPRI Electric Power Research Institute ERCoP emergency response cooperation plan ERP emergency response plan ESP electric service platform EWEA European Wind Energy Association FDR facility design report FERC Federal Energy Regulatory Commission FIR fabrication and installation report FR Federal Register GAP general activities plan GL Germanischer Lloyd GOM Gulf of Mexico GW gigawatts GWEC Global Wind Energy Council GWO Global Wind Organisation HFE human factors engineering HSE Health and Safety Executive (United Kingdom) IEC International Electrotechnical Commission ILO International Labour Organization IMCA International Marine Contractors Association IMO International Maritime Organization INC incident of noncompliance ISM International Safety Management ISO International Organization for Standardization KPI key performance indicator MCA Maritime and Coastguard Agency MMS Minerals Management Service (before May 19, 2010) MOA memorandum of agreement

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Acronyms and Abbreviations xv MOC management of change MOU memorandum of understanding MW megawatts NAE National Academy of Engineering NAICS North American Industry Classification System NEPA National Environmental Policy Act NFPA National Fire Protection Association NIOSH National Institute for Occupational Safety and Health NOTLC National Offshore Training and Learning Center NRC National Research Council NREL National Renewable Energy Laboratory NTL notice to lessees NVIC Navigation and Vessel Inspection Circular OCS outer continental shelf OCSLA Outer Continental Shelf Lands Act of 1953 OHSAS Occupational Health and Safety Assessment Series ONRR Office of Natural Resources Revenue (collection arm of former MMS, after October 1, 2010) OORP Office of Offshore Regulatory Programs OREI offshore renewable energy installation OREP Office of Renewable Energy Programs ORM operational risk management OSHA Occupational Safety and Health Administration OWA offshore wind accelerator PINC potential incident of noncompliance PPE personal protective equipment PSM process safety management PtD prevention through design RP Recommended Practice RUK RenewableUK (BWEA before 2004) SAP site assessment plan SCADA supervisory control and data acquisition SEMP safety and environmental management program SEMS safety and environmental management system SIMOPS simultaneous operations SMS safety management system

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xvi Worker Health and Safety on Offshore Wind Farms SOLAS Safety of Life at Sea TA&R Technology Assessment and Research program TRB Transportation Research Board TSMS towing safety management system USACE United States Army Corps of Engineers USCG United States Coast Guard USCOP United States Commission on Ocean Policy USDON U.S. Department of the Navy Z-PINC personal safety potential incident of noncompliance

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Contents Executive Summary 1 1 Introduction 5 Study Objective and Charge 13 Organization of This Report 17 2 Hazards of Wind Farms 19 Wind Energy Turbines 19 Wind Farms 23 Summary Discussion 41 3 Jurisdiction over and Regulation of Worker Health and Safety 44 Relevant Federal Agencies 45 Federal Jurisdiction for Wind Farm Worker Health and Safety 64 Other Federal Agencies 66 State OSHA Programs and Regulations in Nonfederal Waters 68 Regulatory Approaches: Prescriptive and Goal-Based 69 Worker Health and Safety Guidance from Other Sources 72 Summary Discussion 78

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4 Regulations and Best Practices Addressing Unique Offshore Wind Farm Worker Safety and Health Hazards 83 Hazards on Wind Farms 84 Hazards Unique to Offshore Wind Farms 90 Summary Discussion 105 5 Enhancing Health and Safety Through Safety Management Systems and Design 108 Safety Management Systems 108 BOEM’s SMS Regulations 109 Important Elements for SMSs 111 Safety and Environmental Management System 119 Factors That Shape and Support SMSs 122 Role of Design in Worker Health and Safety 133 Summary Discussion 136 6 Findings and Recommendations 139 Study Committee Biographical Information 152