SPECIAL
REPORT
310
Worker Health and
Safety on Offshore
Wind Farms
TRANSPORTATION RESEARCH BOARD
OF THE NATIONAL ACADEMIES
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
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
Transportation Research Board Special Report 310
Subscriber Categories
Safety and human factors, marine transportation
Transportation Research Board publications are available by ordering individual publications 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 individual affiliation with TRB. Affiliates and library subscribers are eligible for substantial discounts. For further information, contact the Transportation Research Board Business Office, 500 Fifth Street, NW, Washington, DC 20001 (telephone 202-334-3213; fax 202-334-2519; or e-mail TRBsales@nas.edu).
Copyright 2013 by the National Academy of Sciences. All rights reserved.
Printed in the United States of America.
NOTICE: The project that is the subject of this report was approved by the Governing 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 Institute of Medicine. The members of the committee responsible for the report were chosen for their special competencies and with regard for appropriate balance.
This report has been reviewed by a group other than the authors according to the procedures approved by a Report Review Committee consisting of members of the National Academy of Sciences, the National Academy of Engineering, and the Institute of Medicine.
This study was sponsored by the Bureau of Safety and Environmental Enforcement of the U.S. Department of the Interior.
Cover photograph: Offshore Wind Services B.V., managed by Workships Contractors B.V. Used with permission.
Typesetting by Circle Graphics.
Library of Congress Cataloging-in-Publication Data
National Research Council (U.S.). Transportation Research Board. Committee on Offshore Wind Farm Worker Safety, author.
Worker health and safety on offshore wind farms / Committee on Offshore Wind Farm Worker Safety.
pages cm — (Transportation research board special report; 310)
ISBN 978-0-309-26326-9
1. Offshore wind power plants—Employees—Health and hygiene—United States.
2. Offshore wind power plants—United States—Safety measures. 3. Offshore wind power plants—Safety regulations—United States. I. National Research Council (U.S.). Transportation Research Board. II. Title. III. Series: Special report (National Research Council (U.S.). Transportation Research Board); 310.
TK1541.N38 2013
363.11'933392097309168—dc23
2013016731
THE NATIONAL ACADEMIES
Advisers to the Nation on Science, Engineering, and Medicine
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 mandate 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 examination 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 Institute 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 Academy’s purposes of furthering knowledge and advising the federal government. Functioning 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, conducted within a setting that is objective, interdisciplinary, and multimodal. The Board’s varied activities annually engage about 7,000 engineers, scientists, and other transportation 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 administrations of the U.S. Department of Transportation, and other organizations and individuals interested in the development of transportation. www.TRB.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-
tional health and safety, safety management, epidemiology and industrial 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, maintenance, and decommissioning. The committee compared the hazards of offshore oil and gas operations with those of offshore wind farm operations, 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 situation, 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 definition 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 recognized 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 environment 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 maintenance hazard than previously thought. Also, the committee recognized that offshore wind turbines are usually unmanned and may require a
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1 See the Canadian Centre for Occupational Health and Safety website (http://www.ccohs.ca/oshanswers/hsprograms/hazard_risk.html).
design approach to firefighting different from that of offshore oil platforms. 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 environmental management system (SEMS) and an SMS are similar but not interchangeable. 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 Standardization (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 standards, 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 assessing 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 follows represents the consensus opinions of the committee members and presents the committee’s findings and recommendations on the jurisdictional 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 provided 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,
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 following individuals:
• Robert LaBelle, Acting Deputy Director, BSEE, DOI;
• John Cushing, Senior Technical Advisor, BSEE, DOI;
• Dean McKenzie, Safety and Health Specialist, OSHA, U.S. Department 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, American 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 Renewable Energy, GE Power and Water (committee member);
• Michael A. Silverstein, Assistant Director for Industrial Safety and Health (retired), Washington State Department of Labor and Industries (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 Americas, Siemens Energy;
• 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 Corporation (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 committee 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 prepublication web posting; Jennifer Correro, who proofread the typeset pages; and Javy Awan, Director of Publications, under whose super vision 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 diligent 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;
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 University, 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 committee 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 Environmental Management Systems. Transportation Research Board of the National Academies, Washington, D.C. http://www.trb.org/Publications/Blurbs/167249.aspx.
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 |
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 |
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 |
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 |