The UK Maritime and Coastguard Agency (MCA) has recently published a revised Code of Safe Working Practices for Seafarers. While the changes made have sadly not incorporated any reference to yachts, nor a yacht-specific section, there is a lot of extremely useful information that has been added that superyacht crew may wish to familiarize themselves with. In light of some of the recent incidents relating to crew in the superyacht sector, one of the most relevant changes has perhaps been the improved guidance on risk assessment.

Put simply, the risk assessment process identifies hazards present in a work undertaking, analyses the level of risk, considers those in danger and evaluates whether hazards are adequately controlled, taking into account any measures already in place. The new code lists that risk assessments should:

•    Correctly and accurately identify all hazards;
•    Identify who may be harmed and how;
•    Determine the likelihood of harm arising;
•    Quantify the severity of the harm;
•    Identify and disregard inconsequential risks;

•    Record the significant findings;
•    Provide the basis for implementing or improving control measures;
•    Provide a basis for regular review and updating.

“Potential language difficulties should be taken into account,” the Code advises. “Temporary staff or those new to the [vessel] who are not fully familiar with the safety management system or other operational details should be considered where relevant. Other seafarers who should be given special consideration include young persons and pregnant seafarers.”

The Code adds that any risk assessment must address risks to the occupational health and safety of seafarers. Advice on assessment in relation to using personal protective equipment, manual-handling operations and using work equipment is given in Chapters 8, 10 and 18. In addition, specific areas of work involving significant risk, and recommended measures to address that risk, are covered in more detail in later chapters of the Code.
“The assessment of risks must be ‘suitable and sufficient’, but the process need not be overcomplicated,” the Code continues. “This means that the amount of effort that is put into an assessment should depend on the level of risks identified and whether those risks are already controlled by satisfactory precautions or procedures to ensure that they are as low as reasonably practicable. The assessment is not expected to cover risks that are not reasonably foreseeable.

“There are no fixed rules about how risk assessment should be undertaken. The assessment will depend on the type of ship, the nature of the operation, and the type and extent of the hazards and risks. The intention is that the process should be simple, but meaningful. The relevant legislation regarding risk assessments should be referred to when deciding on what methodology will be employed. There is a requirement that seafarers must be informed of any significant findings of the assessment and measures for their protection, and of any subsequent revisions made.”

The Code instructs that it is therefore advisable that copies of an risk assessments are carried on board each vessel and that there is a process for regular revisions to be carried out. In particular, the risk assessment must be reviewed and updated as necessary, to ensure that it reflects any significant changes of equipment or procedure or the particular circumstances at the time, e.g. the weather or level of expertise of those carrying out the task.

“Risk assessment should be seen as a continuous process. In practice, the risks in the workplace should be assessed before work begins on any task for which no valid risk assessment exists,” the Code concludes. The full PDF of the Code, with more advice on how to carry out effective risk assessments, can be read here.

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