4

Regulations and Best Practices Addressing Unique Offshore Wind Farm Worker Safety and Health Hazards

The committee’s task statement (see Box 1-2) calls on it to identify “unique risks” to the health and safety of offshore wind farm workers as compared with those of workers in oil and gas operations on the outer continental shelf (OCS) and “gaps or overlaps” in jurisdictional authority. As described in Chapter 2, the oil and gas and wind industries share many offshore hazards (see Table 2-1), but the overall risk to health and safety associated with oil and gas hazards is greater than that associated with offshore wind hazards. Chapter 2 also established that offshore wind turbines share designs and characteristics with land-based turbines and that the development of offshore wind farms involves many of the same tasks and hazards as that of land-based wind farms. Despite these similarities, wind turbines require additional features and modifications for operation in a marine environment. Furthermore, the offshore environment places the technician into a larger logistical system, one in which no individual can operate independently and one that requires additional training, extra equipment, vessel coordination, weather monitoring, and emergency response capabilities—all of which create hazards and risks beyond those encountered on land.

As discussed in Chapter 3, land-based wind farms and wind farms within state territorial waters fall under the regulatory authority of the Occupational Safety and Health Administration (OSHA) or OSHA-approved state programs. OSHA regulations and standards address many of the tasks and hazards associated with wind farm development, and industry can draw on them in developing the safety management system (SMS) required by the Bureau of Ocean Energy Management



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4 Regulations and Best Practices Addressing Unique Offshore Wind Farm Worker Safety and Health Hazards The committee’s task statement (see Box 1-2) calls on it to identify “unique risks” to the health and safety of offshore wind farm workers as compared with those of workers in oil and gas operations on the outer continental shelf (OCS) and “gaps or overlaps” in jurisdictional author- ity. As described in Chapter 2, the oil and gas and wind industries share many offshore hazards (see Table 2-1), but the overall risk to health and safety associated with oil and gas hazards is greater than that associ- ated with offshore wind hazards. Chapter 2 also established that offshore wind turbines share designs and characteristics with land-based turbines and that the development of offshore wind farms involves many of the same tasks and hazards as that of land-based wind farms. Despite these similarities, wind turbines require additional features and modifica- tions for operation in a marine environment. Furthermore, the offshore environment places the technician into a larger logistical system, one in which no individual can operate independently and one that requires additional training, extra equipment, vessel coordination, weather mon- itoring, and emergency response capabilities—all of which create haz- ards and risks beyond those encountered on land. As discussed in Chapter 3, land-based wind farms and wind farms within state territorial waters fall under the regulatory authority of the Occupational Safety and Health Administration (OSHA) or OSHA- approved state programs. OSHA regulations and standards address many of the tasks and hazards associated with wind farm development, and industry can draw on them in developing the safety management system (SMS) required by the Bureau of Ocean Energy Management 83

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84 Worker Health and Safety on Offshore Wind Farms (BOEM). However, the offshore work environment presents hazards and risks not encountered in land-based development, such as person- nel transfers between vessels and wind turbines, personnel transfers between helicopters and offshore structures, falls into water, and div- ing hazards. Furthermore, the characteristics of every offshore wind farm are slightly different—from layout to the marine conditions and environment—so optimal controls for hazards may vary accordingly. In identifying the major safety issues facing offshore wind personnel, the committee considered a broad range of possible hazards, includ- ing but not limited to the examples provided in the statement of task. Some of these examples—in particular, the use of elevators in a marine environment and the inclusion of fire suppression systems—are legiti- mate safety concerns that should be addressed in an SMS. However, the committee determined that they may pose less risk than originally thought; therefore, they are not discussed in as much detail as other hazards. This chapter begins with a short list of hazards, many of which are shared by land-based and offshore wind farms. The chapter then identi- fies relevant federal regulations and industry standards that could apply to each hazard. The second section discusses hazards that the commit- tee judges to be unique to offshore wind development and describes current regulations, standards, and industry best practices that offer controls for reducing risk. Hazards on Wind Farms Chapter 2 introduced many of the hazards that personnel confront dur- ing the wind farm life cycle. This section provides relevant regulations, standards, guidelines, or industry best practices that address or mitigate many of those hazards (see Table 4-1). The committee acknowledges that the lists of hazards and relevant regulations, standards, and guide- lines are not comprehensive and that certain sections may not be appli- cable to offshore construction or address unique offshore operations. In addition, inclusion of regulations and standards in the table is not an endorsement or recommendation by the committee; they are presented as a resource for BOEM and industry to draw on.

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TABLE 4-1 Potential Hazards on Offshore Wind Farms and Relevant Regulations Hazarda Relevant Regulations, Standards, and Best Practicesb Access by boat, personnel IMCA SEL 025, Guidance on the Transfer of Personnel to and from transfer, and helicopter Offshore Vessels access RenewableUK, Marine Safety Training Approved Training Standard, Issue 1, 2012 (training standard) RenewableUK, Guidelines for Onshore and Offshore Wind Farms: Health and Safety in the Wind Energy Industry Sector, Issue 1, 2010 RenewableUK, Vessel Safety Guide: Guidance for Offshore Renewable Energy Developers, April 2012 14 CFR 27: Airworthiness Standards: Normal Category Rotorcraft 14 CFR 29: Airworthiness Standards: Transport Category Rotorcraft FAA, Aeronautical Information Manual: Official Guide to Basic Flight Information and ATC Procedures, July 26, 2012 Confined space entry ANSI/ASSE Z117.1:2009—Safety Requirements for Confined Spaces 29 CFR 1910.146, Permit-Required Confined Spaces 33 CFR Chapter 1, Subchapter N (included in revisions), Outer Continen- tal Shelf Activities Crane and lifting operations API RP 2D—Operation and Maintenance of Offshore Cranes, 6th ed. API Specification 2C—Offshore Pedestal-Mounted Cranes, 7th ed. USACE EM 385-1-1, Section 16, Cranes and Hoisting Equipment IMCA SEL 019, Guidelines for Lifting Operations 46 CFR Subchapter I, Cargo and Miscellaneous Vessels 30 CFR 250, Subpart A, Oil and Gas Operations on the OCS 29 CFR 1926, Subpart CC, Cranes and Derricks in Construction HSE, United Kingdom, Lifting Operations and Lifting Equipment Regulations 1998 ASTM F1166-2007—Standard Practice for Human Engineering Design for Marine Systems, Equipment, and Facilities (Section 16.8 for design) Diving 46 CFR Chapter 1, Subchapter V, Part 197, Marine Occupational Safety and Health Standards USACE EM 385-1-1, Section 30, Diving Operations ADCI (2011), International Consensus Standards for Commercial Diving and Underwater Operations, 6th ed. U.S. Navy Diving Manual (2008), Revision 6 IMCA D 014, IMCA International Code of Practice for Offshore Diving IMCA D 019, Diving Operations in Support of Intervention on Wellheads and Subsea Facilities 29 CFR 1910, Subpart T, Commercial Diving Operations OSHA CPL 02-00-151, 29 CFR Part 1910, Subpart T—Commercial Diving Operations 29 CFR 1926, Subpart Y, Diving (continued on next page)

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86 Worker Health and Safety on Offshore Wind Farms TABLE 4-1 Potential Hazards on Offshore Wind Farms and Relevant Regulations (continued) Hazarda Relevant Regulations, Standards, and Best Practicesb Electrical safety on offshore NFPA 70E—Standard for Electrical Safety in the Workplace wind turbines and ANSI/ASSE A10.44:2006—Control of Energy Sources substations 33 CFR Chapter 1, Subchapter N, Part 142, Workplace Safety and Health IEC 61400-1: 2005, Wind Turbines—Part 1: Design Requirements 29 CFR 1910.147, Control of Hazardous Energy (Lockout/Tagout) 29 CFR 1910.269, Electric Power Generation, Transmission, and Distribution DNV-OS-J201(2009)—Offshore Substations for Wind Farms ASTM F1166-2007—Standard Practice for Human Engineering Design for Marine Systems, Equipment, and Facilities (Section 18.4) Emergency evacuation or 33 CFR 146, Emergency Evacuation Plan emergency egress 29 CFR 1910.38, Emergency Action Plans 29 CFR 1917.30, Emergency Action Plans 29 CFR 1918.100, Emergency Action Plans 29 CFR 1926.35, Employee Emergency Action Plans RenewableUK, Guidelines for Onshore and Offshore Wind Farms: Health and Safety in the Wind Energy Industry Sector, Issue 1: 2010 ANSI/ASSE A10.26:2011—Emergency Procedures for Construction and Demolition Sites Falls, working at heights, ANSI/ASSE Z359—Fall Protection/Arrest use of personnel lifts, ANSI/ASSE A10.32-2004—Fall Protection Systems rope access EN 353-1:2002, Personal Protective Equipment Against Falls from a Height ASTM F1166-2007—Standard Practice for Human Engineering Design for Marine Systems, Equipment, and Facilities (Section 18.8) 29 CFR 1926.500, Subpart M, Fall Protection RenewableUK, Lifts in Wind Turbines, Health and Safety, February 2011 ASME/ANSI A17.1, Safety Code for Elevators and Escalators EN 81: Safety Rules for the Construction and Installation of Lifts Fires in or on offshore wind 33 CFR Chapter 1, Subchapter N, Part 145, Fire-Fighting Equipment turbines and substations NFPA, Codes and Standards (e.g., NFPA 12—Standard on Carbon Dioxide Extinguishing Systems) NFPA 850: RP for Fire Protection for Electric Generating Plants DNV-OS-J201(2009)—Offshore Substations for Wind Farms (Section 6) Safety of Life at Sea Provisions GL Wind Technical Note Certification of Fire Protection Systems for Wind Turbines, Rev. 2, 2009 ed. BS EN 13565-2:2009—Fixed Firefighting Systems

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Regulations and Best Practices 87 TABLE 4-1 Potential Hazards on Offshore Wind Farms and Relevant Regulations (continued) Hazarda Relevant Regulations, Standards, and Best Practicesb Human factors health and ASTM F1166-2007—Standard Practice for Human Engineering Design safety issues (climbing, for Marine Systems, Equipment, and Facilities (multiple sections) awkward postures, extreme environmental conditions, inadequate physical and visual access, manual material handling) Human factors safety ASTM F1166-2007—Standard Practice for Human Engineering Design issues (pinch points, for Marine Systems, Equipment, and Facilities (Sections 14, 15, 17, 18) rotating equipment) AWEA, Recommended Practices for Design, Deployment, and Operation of Offshore Wind Turbines in the United States (2012) IEC 61400-1: 2005, Wind Turbines—Part 1: Design Requirements BS EN 50308, Wind Turbines: Protective Measures: Requirements for Design, Operation and Maintenance Slips and trips ASTM F1166-2007—Standard Practice for Human Engineering Design for Marine Systems, Equipment, and Facilities (Section 11) ASTM F1637-2010—Standard Practice for Safe Walking Surfaces 29 CFR 1910.21-30, Subpart D, Walking–Working Surfaces ANSI A1264.1, Safety Requirements for Workplace Walking/Working Surfaces and Their Access; Workplace, Floor, Wall and Roof Openings; Stairs and Guardrails Note: ADCI = Association of Diving Contractors International, Inc.; ANSI = American National Standards Institute; API = American Petroleum Institute; ASME = American Society of Mechani- cal Engineers; ASSE = American Society of Safety Engineers; ASTM = American Society for Testing and Materials; AWEA = American Wind Energy Association; BS = British Standard; CFR = Code of Federal Regulations; CPL = Compliance Directive; DNV = Det Norske Veritas; EN = European Norm; FAA = Federal Aviation Administration; GL = Germanischer Lloyd; HSE = Health and Safety Executive; IEC = International Electrotechnical Commission; IMCA = International Marine Contractors Association; OSHA = Occupational Safety and Health Administration; NFPA = National Fire Protection Association; RP = Recommended Prac- tice; USACE = U.S. Army Corps of Engineers. aThe hazards presented are not comprehensive, but the more typical hazards, as reported to the committee, are included. bThe regulations, standards, and best practices presented are not necessarily comprehensive, nor are they presented in a particular order. Certain sections of these documents may not be applicable to offshore construction or address unique offshore operations. Inclusion in the table is not an endorsement or recommendation by the committee; the table is presented as a resource for BOEM and industry to draw on. Appendix B of API RP 75 lists numerous industry codes, recommended practices, and standards that may also be considered relevant. Source: Generated by the committee.

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88 Worker Health and Safety on Offshore Wind Farms The following list provides a description of typical hazards. • Access by boat and personnel transfer: Personnel must be transferred from a shoreside facility to a transfer vessel and then from the trans- fer vessel to the wind turbine. Boat transfers introduce hazards while embarking on or disembarking from a vessel or structure, such as tripping and falling into the water and crushing (between vessel and structure). Helicopter transfers occur as well and introduce hazards such as tripping and falling, but the transfers will occur less fre- quently and are more likely during emergencies. Although helicop- ter crashes have the potential for more fatalities, in the opinion of the committee, boat transfers will occur more often along with the possibility of more lost time injuries—incidents that lead to days away from work. • Confined space entry: This hazard involves an area that is not con- tinuously occupied and has limited means of entry and exit but that is large enough to enter and allow performance of tasks. Examples of confined spaces include the hub and blades and areas inside the monopile or foundation. Confined spaces introduce hazards such as dangerous gases, oxygen-deficient atmospheres, poor ventilation, and limited movement, in addition to the difficulty of rescuing or evacuating injured personnel. • Crane and lifting operations: Large turbine components or heavy pieces of equipment must be lifted and moved. Hazards can include dropped objects, uncontrolled lifts, crushing, unbalanced vessels, crane failure, and collapse. • Diving: Underwater construction and inspection require diving, which is dangerous and demanding work. Most hazards involve working underwater with tools and experiencing changes in pressure while descending from or ascending to the surface. Uncoordinated opera- tions that lead to injuries to the diver are another hazard. • Electrical safety on offshore wind turbines and substations: Working with high-voltage systems that expose personnel to electrical energy involves such hazards as electrical shocks, electrical burns, arc flashes (burns and blasts), and electrocution.

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Regulations and Best Practices 89 • Emergency evacuation or emergency egress: An incident or accident, medical emergency, fire, or sudden weather event may require imme- diate evacuation of personnel. Hazards from evacuations are similar to other hazards mentioned here such as falls and vessel transfers. • Falls, working at heights, use of personnel lifts, rope access: Falls are one of the more common incidents in any workplace and can occur from any height. Working on a wind turbine introduces numerous poten- tials for falls during activities both within and outside the turbine. • Fires in or on offshore wind turbines and substations: Fire in a wind tur- bine or substation could expose workers to burns and smoke inhalation. • Human factors health and safety issues (climbing, awkward postures): Personnel climb ladders and confront prolonged kneeling and repetitive upper body movements, often in cramped spaces. These actions can lead to short-term sprains and fatigue as well as long- term injuries, particularly to backs and knees. Extreme environmen- tal conditions (e.g., heat, cold, and noise) can also negatively affect worker health and performance. Inadequate physical and visual access in and around equipment can encourage workers to assume awkward body postures or take unsafe shortcuts to complete a task. • Human factors safety issues (pinch points, rotating equipment): Person- nel working around moving mechanical parts can become entangled in the machinery or face contusions, lacerations, broken bones, and amputation. • Slips and trips: The marine environment introduces moving, clut- tered, uneven, or slick surfaces. Vessel movement, sea state, and weather conditions can cause personnel to slip or trip, which could lead to injuries. In the list above, the committee developed what it judges to be among the more expected, or typical, hazards of a wind farm project life cycle. Many of these hazards—such as confined space entry, crane and lifting operations, electrical injury, working at heights, fire protection, human factors safety issues, and slips and trips—are common to land-based wind farms and are addressed by federal regulations and industry consensus standards, examples of which are included in Table 4-1. The

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90 Worker Health and Safety on Offshore Wind Farms other hazards are unique to offshore wind farms and are discussed in the next section in more detail. Hazards UniqUe to oFFsHore Wind Farms The offshore work environment presents hazards, identified in Table 4-1, that are not encountered on a land-based facility. Among them are per- sonnel transfers, falls on the vessel or into water, diving hazards, and emergency evacuation. The following subsections discuss these hazards and identify standards and regulations that pertain to them. access by Boat and Personnel transfer Of the numerous hazards (see Table 4-1) associated with offshore wind farms, transferring personnel from a shoreside facility to the trans- fer vessel and then from the transfer vessel to the wind turbine poses significant risk. Throughout the life cycle of a wind farm, personnel require access to the wind turbines, and this access is provided mostly by boat. The oil and gas industry utilizes helicopters as a primary means of access to its offshore platforms. This mode of transportation is less likely to be used to access offshore wind turbines for routine opera- tions and maintenance because of the inability to land a helicopter on a wind turbine structure and the subsequent risks associated with lowering personnel from a hovering helicopter to the nacelle of a tur- bine. Some wind turbines may have helicopter pads installed on top of the nacelle, although this practice is not common. Helicopter transfer, despite being an option, is not regarded as the primary means of turbine access.1 The remainder of this subsection focuses on access by boat and the transfer of personnel. 1 Federal Aviation Administration regulations for helicopter operations are found in 14 CFR 27: Airworthiness Standards: Normal Category Rotorcraft and in 14 CFR 29: Airworthiness Stan- dards: Transport Category Rotorcraft. Additional information on offshore helicopter operations is found in the Federal Aviation Administration’s Aeronautical Information Manual: Official Guide to Basic Flight Information and ATC Procedures, July 26, 2012 (http://www.faa.gov/air_traffic/ publications/ATPubs/AIM/aim.pdf). Recommended practices for offshore helicopter operations are provided by the Helicopter Safety Advisory Conference and the Offshore Committee of the Helicopter Association International.

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Regulations and Best Practices 91 Personnel transfers are a necessary part of every visit to an offshore facility and pose routine, and potentially deadly, risks. On European wind farms, technicians are estimated to access an individual turbine at a rate of 10 to 20 “person-accesses” per year (Dalen and Jakobsson 2009),2 which translates into an industry total of many potential transfers, given that Europe alone reports more than 1,660 offshore turbines installed and connected at 55 wind farms as of December 31, 2012 (EWEA 2013). The safety of personnel transfers depends on many factors. The type of shore facility, the access site on the transfer vessel, the foundation and transition piece, and weather and sea conditions (waves, wind, and cur- rents) influence whether safe access or egress is possible and the type of access system or vessel used. To minimize risk and maximize efficiency, any type of transfer vessel will need to nose into place easily and quickly; rest safely in position at the transfer point; and transfer personnel and equipment quickly, safely, and reliably. Above all, any personnel transfer system should maximize safety and minimize complexity. Most of the various access systems involve a direct boat landing: the vessel docks at the turbine and maintains constant contact with the tran- sition piece or structure by using the thrust of its engine and friction from the bow fenders. Personnel then access the turbine by a ladder on the transition piece or on a walkway between the installation vessel and the transition piece. Ladders in excess of a certain height usually have a fall arrest system. As wave height increases, such a direct landing trans- fer becomes less safe and can cause unsynchronized movement between the vessel and the transition piece. This type of movement introduces hazards such as personnel falling backwards onto the transfer vessel or falling into the water; consequences include injury or death by hypother- mia, drowning, or crushing. Common industry controls for these haz- ards include wearing life jackets with personal locator beacons, wearing immersion suits, and knowing proper procedures for access and egress. Among other controls are training personnel in sea survival and test- ing new methods of transfer. Above all, anyone involved in the transfer operation—from vessel crew to transferee—should have the ability to 2 The authors define one “person-access” as an individual crossing from a boat to an offshore wind turbine.

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92 Worker Health and Safety on Offshore Wind Farms deem a transfer unsafe and to stop the transfer at any point. The subsec- tions that follow discuss some other industry guidelines for transferring personnel. Guidance from the Marine Industry Although the International Convention for the Safety of Life at Sea (SOLAS) offers basic safety principles for pilot transfer arrangements, most guidance on the transfer of personnel is provided by industry. The International Marine Contractors Association (IMCA) offers a guidance document for the safe transfer of personnel at sea, especially transfers between vessels and between vessels and offshore structures, through a variety of methods including crew boats and offshore support vessels (IMCA 2010). The guidance document recommends that all personnel involved in the transfer understand the transfer method. The docu- ment covers the topics of risk assessment, training and competence, responsibility, and communications. The following are among the main points: • Risk assessment: All personnel transfers are considered stand-alone events and require a formal risk assessment before the operation is started. Any risk assessment should consider such issues as the necessity and frequency of the transfers, environmental conditions (weather, wind speed, wave height, etc.), types of vessels used, avail- ability of personal protective equipment, simultaneous operations, and qualifications of the personnel involved. If issues or conditions change during an operation, proper management of change proce- dures should be in place to track concerns of risk. • Training and competence: All personnel involved in the transfer should be competent and should have appropriate training. The per- sonnel should understand the process and be able to explain the steps involved. • Responsibility: The roles and responsibilities of all personnel, espe- cially those supervising the process, should be clearly defined. IMCA considers the vessel master or the offshore structure manager to be responsible for the safe transfer of personnel. The final decision whether to transfer remains with the vessel or structure supervisor.

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Regulations and Best Practices 93 • Communications: All personnel involved in the transfer should estab- lish communication (both radio and visual) before the operation and maintain and verify communications throughout the process. The guidance document also discusses personnel transfers using small boats, larger crew boats, transfer baskets, and gangways or walkways (including hydraulic gangways). Although industry is beginning to rely on newer technology (discussed below) to conduct personnel transfers, the focus of this section is on transfers using larger crew boats. Crew boats should be seaworthy and appropriate for the sea and weather conditions. Crew boat personnel should be competent and should have received appropriate training; more important, they should be able to show this competency. Before the start of the voyage, all participants should be briefed on proper emergency procedures and available emergency equip- ment. Crew boats should have sufficient numbers of life vests and rafts, and personnel should know their location as well as the location of fire- fighting equipment and escape routes. In addition, any equipment trans- fers should be treated as separate operations, and equipment should be transferred separately from personnel. RenewableUK Guidelines and Standards The United Kingdom leads the world in offshore wind farm develop- ment (EWEA 2013) and leads in the development of worker health and safety practices. The trade association RenewableUK publishes multi- ple documents on a range of health and safety topics to guide indus- try by sharing best practices and lessons learned. Guidelines for Onshore and Offshore Wind Farms (RenewableUK 2010) summarizes current guidance on health and safety concerns arising during the life cycle of onshore and offshore wind farms and describes the most important issues relevant to industry health and safety. The guidelines cover topics similar to those addressed by the IMCA guidance document (discussed above), such as risk assessment and management of change, competence and training of personnel, and communication, but they go into more detail in discussing site access and egress during each phase. While the document does not address all possible health and safety risks during a wind project’s life cycle, it does recommend that appropriate policies and procedures for transferring personnel and equipment be developed

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Regulations and Best Practices 97 Commercial diving operations Commercial diving is dangerous and physically demanding work that can occur during underwater construction, welding, inspections, and repairs of a variety of structures such as offshore oil and gas rigs, bridges, piers, and ships. The hazards of diving operations for offshore wind farms occur during various phases such as foundation installa- tion, cable laying, and regular foundation inspections. During its infor- mation-gathering period, the committee was given to understand that remotely operated vehicles may be used in the future, especially for cable laying, but that commercial divers will be used for many tasks in shallow water.7 Divers face numerous health and safety hazards related to the diving itself and to working in an underwater environ- ment with tools or machinery: experiencing changes in pressure dur- ing descents to the seabed or ascents to the surface, wearing bulky and complex equipment, and being submerged for potentially long periods of time. Divers must contend with specific site conditions, such as tides and other seabed hazards, and with working in low light or in an artificial light environment. In addition, commercial divers must often work with heavy tools or machinery. The work requires experienced and well-trained people. All diving operations should be well planned and managed carefully throughout. The next subsection reviews the most relevant federal diving regulations that would apply to wind farm operations on the OCS. Commercial Diving and Federal Regulations Commercial diving operations from vessels and facilities that are inspected by the United States Coast Guard (USCG) are subject to the regulations contained in 46 CFR Chapter I, Subchapter V, Part 197, Sub- part B. Although these regulations are undergoing revision at the time of this report, Part 197 would apply to diving operations for offshore wind farms. The regulations require assignment of roles and responsibilities 7 J. Nielsen, Siemens, presentation to the committee, April 2012.

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98 Worker Health and Safety on Offshore Wind Farms for the vessel or facility, including designation of a person in charge (if not the vessel or facility master). Before each diving operation, the name of a diving supervisor is designated and provided to the person in charge. The diving supervisor is responsible for the health and safety of all div- ing personnel during an operation and must comply with all parts of the regulations. Subpart B (§§197.300 to 197.346) sets forth requirements for diving equipment and for first aid and medical treatment equipment. The responsibilities of the person in charge and of the diving supervisor are elaborated in §197.402 and in §197.404, respectively. The regula- tions require that the diving supervisor brief the diving team on relevant information about the operation including proper procedures, unusual hazards, and environmental conditions. All diving procedures are contained in the operations manual, which is prepared by the diving supervisor and provided to the person in charge before an operation. The operations manual explains the roles and responsibilities of dive team members, provides procedures and checklists for all safety and diving equipment used for specific diving modes, and discusses emergency procedures for potential sce- narios (see §197.420). The diving supervisor is required to inspect and test all diving equipment on a periodic basis and especially before a diving operation. The diving supervisor, overseen by the person in charge, is also required to maintain entries about every commercial diving operation in a logbook (required information is located in §197.482). OSHA has regulations for commercial diving under 29 CFR 1910, Subpart T (general industry standards) and under 29 CFR 1926, Sub- part Y (construction standards). Additional guidance from a recently published compliance directive (OSHA 2011) provides instruction for OSHA offices in establishing intervention and inspection programs and information for industry in ensuring compliance with diving standards. The OSHA commercial diving rules have not been revised recently and, in the opinion of the committee, are widely acknowledged to be out of date. The regulations in 29 CFR 1910 include requirements for diver experience and operational procedures and would apply to wind farm operations occurring within state waters. Minimum training require- ments and the condition that assignments be based on a diver’s experi-

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Regulations and Best Practices 99 ence are set forth in §1910.410. All dive teams require a person in charge with appropriate experience and training. A manual that contains the roles and responsibilities of the diving team and that describes the safety practices, equipment, and emergency procedures for all diving opera- tions must be developed and maintained. Predive procedures (§1910.421) should include an assessment of all the health and safety elements that occur during an operation, such as the proper number of team members for the dive, the diving mode and equipment used, dive site conditions, and emergency procedures. The regulations require inspection of all equipment and the briefing of team members on topics such as dive tasks, appropriate safety procedures for the operation, and hazards associated with the dive. Appropriate pro- cedures during the dive operation are listed in §1910.422. Entry into and exit from the water, communications, and the use of any power tools or equipment are included. Requirements for postdive procedures and decompression are provided in §1910.423, proper equipment pro- cedures are listed in §1910.430, and record keeping requirements are given in §1910.440. Other federal diving regulations include those of the U.S. Depart- ment of the Navy (USDON) and the U.S. Army Corps of Engineers (USACE). USDON publishes a comprehensive diving manual for naval personnel and the Navy’s permanent civilian employees. The Navy’s manual provides detailed diving requirements and procedures that are at least equivalent to the regulations in USCG’s 46 CFR 197 and in OSHA’s 29 CFR 1910, Subpart T, and could provide useful guid- ance. One example is the planning and operational risk management (ORM) process discussion in Chapter 6 (U.S. Navy 2008), which pro- vides techniques for managing the risks of diving operations. The five- step ORM process first identifies the hazards associated with a task and then determines the risk of the hazards, calculates and ranks the risks, implements controls to reduce or eliminate risks, and evalu- ates the controls to ensure that they have the desired effect. This pro- cess allows for corrective action and improvement if an implemented control does not work. USACE also has diving requirements in Sec- tion 30 of its Engineering Manual (EM) 385-1-1. The requirements are mandatory for all Department of Defense construction contracts

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100 Worker Health and Safety on Offshore Wind Farms and contractors conducting business with USACE and include such items as a safe practices manual, a dive operations plan, an activity haz- ard analysis, an emergency management plan, and minimum person- nel qualifications (USACE 2008). A revision of the EM 385-1-1 safety manual is expected in 2013. Industry Guidance and Commercial Diving Operations The Association of Diving Contractors International, Inc. (ADCI), has developed consensus standards that represent industry best practices for all types of underwater work for commercial diving operations (see ADCI 2011). Section 2 of the document lists minimum qualifications and medical and training requirements for personnel seeking work in commercial diving. The Commercial Diver Certification Program in Section 3 ensures that personnel have met uniform minimum duties and responsibilities with respect to a particular job category and have obtained a certification card that reflects their qualifications and com- petency. Personnel holding a valid ADCI commercial diver certification card are considered to be in compliance with the training requirements listed under 29 CFR 1910.410 (OSHA 2011). OSHA has stated that the contents of the ADCI consensus “document meet or exceed the requirements of 29 CFR Part 1910, Subpart T,” and for diving issues that OSHA regulations do not address, “OSHA recognizes ADCI stan- dards as the best established industry practice” (OSHA 2011, A-3). USCG also recognizes the ADCI standards as meeting or exceeding its regulations for commercial diving operations under 46 CFR 197. The remaining sections of the ADCI standards provide a broad list of requirements for commercial diving operations. For example, Sec- tion 4 defines the various diving modes and sets forth minimum per- sonnel and equipment requirements and operational guidelines for each mode. Operational procedures and guidelines for the safe practices manual, project plans, logbooks, job hazard analysis, and dive team brief are discussed in Section 5; emergency procedures and accident reporting are discussed in Section 7. IMCA provides another code of good practice for diving operations (IMCA 2007). Like the ADCI document, the IMCA code discusses and

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Regulations and Best Practices 101 defines the roles and responsibilities of personnel involved in the diving operation, the types and suitability of equipment for the operation, the necessary qualifications and training of personnel, the requirement of a project plan and risk management process, and the need for emergency plans. Diving logbooks, checklists, incident reporting procedures, and management of change procedures are all cited in the documentation and auditing of diving operations. Similarly, RenewableUK’s Guide- lines for Onshore and Offshore Wind Farms discusses the importance of planning and management during diving operations. Section 9.14.6 of the guidelines lists considerations that the diving project plan should include in a risk assessment (RenewableUK 2010). Summary Of the many hazards of wind farm development, diving operations are unique to offshore wind farms. Multiple agencies promulgate federal diving regulations, including USCG, OSHA, USDON, and USACE, but diving operations for offshore wind farms would need to comply with the USCG regulations in 46 CFR 197. The federal rulemaking process can be long and arduous, which is why USCG’s forthcoming revisions of diving regulations have taken several years. Although con- sensus standards can also take a long time to develop, industry stan- dards are updated—often a requirement—on a more regular basis and provide a good understanding of the industry’s knowledge base and best practices. For this reason, federal regulations have often lagged behind consensus standards, prompting both USCG and OSHA, in the case of diving, to reference the ADCI consensus standard as meet- ing or exceeding their requirements. The ADCI standards could there- fore provide a valuable resource to industry in developing BOEM’s required SMS. emergency evacuation The need for rapid and safe evacuation of personnel from potential or actual hazards is common to many work environments. Emergency evacuations occur in response to an incident or accident, a medical emer- gency, a fire, or a sudden weather event such as lightning. Procedures

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102 Worker Health and Safety on Offshore Wind Farms for emergency evacuations and measures for addressing emergency scenarios for all personnel and all tasks undertaken during a proj- ect life cycle are often documented in frameworks called emergency response plans, and as described in Chapter 5, general requirements for emergency response plans are given in many SMS standards. The following subsection reviews evacuation plans available in federal regulations; however, the required elements for the plans differ by source and may not be relevant to offshore wind farms. The second subsection below discusses evacuation plans originating from the off- shore wind industry. Federal Regulations and Emergency Plans In 33 CFR 146.140, USCG requires the operator of each manned facility on the OCS to develop an emergency evacuation plan (EEP). The EEP may apply to multiple facilities if the facilities are near each other. At a minimum, the EEP must have a record of change, a list of important contacts and primary responsibilities, a list of available communica- tion and weather forecasting equipment, a description of events requir- ing evacuations, and a list of means and procedures for implementing the evacuations. USCG must approve the EEP and must reapprove it when substantive changes are made. Emergency evacuation drills cor- responding to the EEP should occur on a regular basis and must be documented in a logbook. The EEP is for manned facilities and may not apply to offshore wind farms, although it could provide a template for future plans if offshore substations are manned or have emergency accommodations. OSHA’s emergency action plan (EAP), mandated by 29 CFR 1910.38, requires procedures for reporting emergencies and assigning evacu- ation routes, for accounting for employees after the evacuation, and for performing rescue and medical functions. A listing of employees who may need information about the EAP is necessary. The EAP also requires maintenance of an alarm system with a distinct signal and the training of employees in assisting in the safe and orderly evacuation of others. Employers must review the EAP with each employee covered by the plan. The regulations in 29 CFR 1917.30, 29 CFR 1918.100, and 29 CFR 1926.35 set forth elements that should be included in an EAP,

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Regulations and Best Practices 103 such as emergency escape routes and escape procedures, documented roles and responsibilities of personnel, an appropriate alarm system, and training. Industry Guidance and Emergency Evacuation In its Guidelines for Onshore and Offshore Wind Farms, RenewableUK recommends developing an emergency response plan (ERP) address- ing all emergency situations that may occur during the wind farm development process. However, all offshore renewable energy devel- opers and operators in the United Kingdom are required to formulate ERPs by using the Maritime and Coastguard Agency’s (MCA’s) emer- gency response cooperation plan (ERCoP) template8 and must submit their plans to MCA for approval before construction can begin. On the basis of the MCA template, Section 9.10 of RenewableUK’s guidelines discusses items and procedures recommended for inclusion in the ERP and develops “bridging” documents to the ERPs of any contractors (RenewableUK 2010). Early in the development of an ERP, operators must consider the distance from the offshore renewable energy site to emergency ser- vices and must assess the level of training needed by on-site personnel in carrying out the plan. Once ERP development is under way, all site plans and access points must be documented, and information must include the contact details of all personnel and vessels and the proce- dures for emergency communications. The roles and responsibilities of key personnel managing the ERPs must also be documented. Details must include all potential hazards and emergency situations encoun- tered, with documented procedures based on appropriate risk assess- ments. More detailed response procedures are required for events such as evacuations from the turbine, fires, falls into the water, and extreme sea or weather conditions. If emergency supplies and accommodations 8 MCA implements maritime safety policy in the United Kingdom. The MCA ERCoP template includes requirements for emergency response on offshore renewable energy installations and search and rescue helicopter operations. More information concerning the MCA template is avail- able at http://www.dft.gov.uk/mca/mcga07-home/shipsandcargoes/mcga-shipsregsandguidance/ mcga-windfarms/offshore-renewable_energy_ installations/dops_-_all-newpage-26.htm.

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104 Worker Health and Safety on Offshore Wind Farms are not provided in individual turbines, details and locations of nearby facilities that can provide assistance must be documented and weather monitoring capabilities provided. To ensure that all personnel are familiar with the ERP, regular training exercises are recommended. Personnel should understand emergency response arrangements and the chain of command during emergency situations. Their skill levels and competence are increased through safety drills, offshore survival training, and informational exchanges in which personnel are encouraged to discuss their views on health and safety. Personnel must understand the operational limits of vessels and equipment, and clear boundaries must be established for work stoppage during bad weather. If personnel are at risk of being stranded overnight, arrangements should include sleeping accom- modations, equipment, and survival rations. As mentioned above, Appendix 1 of the guidelines provides additional detail concerning emergency egress procedures and emergency accommodations on off- shore turbines and other structures. It contains flowcharts that provide recommended procedures for emergency situations such as accidents in the wind turbine or personnel stranded offshore by weather condi- tions. The flowcharts are only intended to provide a generic framework for addressing emergency situations but are adaptable to project- or site-specific scenarios. Summary Emergency response and prevention plans are a required element in most SMS standards. USCG requires the submission of an EEP for all manned facilities on the OCS, and OSHA requires employers to submit an EAP. Elements of both emergency plans could provide a resource for industry SMSs as required by BOEM and apply to offshore wind farms. Whether operators of offshore wind farms will be required to follow USCG regulations is unclear, since offshore turbines are unmanned. RenewableUK offers a more detailed ERP guideline—based on MCA’s emergency response template—that must address all emergency situ- ations that could occur during the wind farm development life cycle.

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Regulations and Best Practices 105 sUmmary disCUssion This chapter reviews the more common hazards associated with wind farm development and identifies relevant federal regulations and indus- try standards that may apply to each. The chapter explains three haz- ards that are unique to offshore wind development: personnel transfers, diving operations, and emergency evacuations. The committee was not in a position to catalog all relevant documents that might apply and acknowledges that the inventory is not comprehensive. Instead, the committee listed some of the applicable regulations and recognized best practices in health and safety that exist in the United States and inter- nationally as resources for BOEM and industry to draw on. Although the chapter cites many relevant federal regulations and industry stan- dards, the committee was unable to judge their efficacy. Such a task would require an in-depth review of each and time and resources far exceeding those available to the committee. In developing and apply- ing its SMS regulation, the committee expects that BOEM will require industry to follow existing consensus standards and best practices as they are revised. Unlike personnel transfers in the oil and gas industry, which rely heavily on helicopters, those for offshore wind facilities will occur more often by boat. The wind industry has shown an ability to develop and adopt new technologies for turbine access and transfers that can help to reduce risk and update best practices. USCG and OSHA have regu- lations that address diving hazards, but industry associations provide useful standards as well. Both OSHA and USCG acknowledge that the industry’s diving standards (those of ADCI), for the most part, meet or exceed applicable federal regulations. EEPs are a required SMS ele- ment, and both USCG and OSHA mandate plans for various industries, but elements from the federal regulations are for manned facilities and may not be relevant to offshore wind farms. RenewableUK’s guidelines document includes information on emergency evacuations pertaining to wind farms and is a good resource for industry. Although consen- sus standards take time to develop and therefore often lag behind the collective knowledge base of an industry, the standards and industry best practices—as in the case of diving standards—may often be more

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106 Worker Health and Safety on Offshore Wind Farms up to date and better reflect the knowledge of industry than do fed- eral regulations. Chapter 5 discusses published management systems in more detail and provides examples of important SMS elements that BOEM could reference in enhancing its SMS and in providing guidance to industry. reFerenCes Abbreviations ADCI Association of Diving Contractors International, Inc. EWEA European Wind Energy Association GWO Global Wind Organisation IMCA International Marine Contractors Association OSHA Occupational Safety and Health Administration USACE U.S. Army Corps of Engineers ADCI. 2011. International Consensus Standards for Commercial Diving and Underwater Operations, 6th ed. Houston, Tex. Dalen, G., and M. Jakobsson. 2009. Access to Offshore Windfarms. In Offshore Wind Power (J. Twidell and G. Gaudiosi, eds.), Multi-Science Publishing Co. Ltd., Brentwood, United Kingdom. EWEA. 2013. The European Offshore Wind Industry: Key Trends and Statistics 2012. http:// www.ewea.org/fileadmin/files/library/publications/statistics/European_offshore_ statistics_2012. Jan. Accessed Feb. 7, 2013. GWO. 2012. Global Wind Organisation Standard: Basic Safety Training (Onshore/ Offshore). http://www.ewea.org/policy-issues/health-and-safety/gwo-standards/. IMCA. 2007. IMCA International Code of Practice for Offshore Diving. IMCA D 014, Rev. 1. http://www.imca-int.com/documents/divisions/diving/docs/IMCAD014.pdf. IMCA. 2010. Guidance on the Transfer of Personnel to and from Offshore Vessels. IMCA SEL 025, IMCA M 202. http://www.imca-int.com/documents/core/sel/docs/ IMCASEL025.pdf. OSHA. 2011. 29 CFR Part 1910, Subpart T—Commercial Diving Operations. Directive CPL 02-00-151. http://www.osha.gov/OshDoc/Directive_pdf/CPL_02-00-151.pdf. RenewableUK. 2010. Guidelines for Onshore and Offshore Wind Farms: Health and Safety in the Wind Energy Industry Sector. http://www.renewableuk.com/en/publications/ index.cfm/guidelines-for-onshore-and-offshore-wind-farms. RenewableUK. 2012a. Approved Training Standard, Marine Safety Training (MST)— Vessel Transit and Transfer Standard, Issue 1: 2012. http://www.renewableuk.com/ download.cfm?docid=55C54586-393C-4239-9A1388D1EDD5894E.

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Regulations and Best Practices 107 RenewableUK. 2012b. Vessel Safety Guide: Guidance for Offshore Renewable Energy Devel- opers. http://www.renewableuk.com/en/publications/index.cfm/vessel-safety-guide. USACE. 2008. Safety and Health Requirements Manual, 2008 ed. Engineering Manual 385-1-1. Department of Defense, Washington, D.C. http://publications.usace.army. mil/publications/eng-manuals/EM_385-1-1_languages/EM_385-1-1_English_2008/ toc.html. US Navy. 2008. U.S. Navy Diving Manual, Volumes 1–5, Revision 6. Naval Sea Sys- tems Command, Washington, D.C. http://www.supsalv.org/00c3_publications. asp?destPage=00c3&pageId=3.9.