Is the number of lifeboatmen based on the total number of lifeboats onboard or on the number of lifeboats needed for 100% coverage of persons onboard (POB), since these types of units are required to maintain redundancy in lifeboat capacity?
Short answer: It is based on 100% coverage (but could vary/be increased by the Flag State Administration). Let’s take a further look…
Foreign-flagged units are pretty straightforward in that the Safe Manning Document sets the number of lifeboatmen required by the Administration. Many administrations base this off of the total number of lifeboats onboard.
Let’s look at some of the applicable cites to see the intent/how the minimum number would be determined:
2009 MODU 14.10.5 requires certificated persons to be placed in command AND second-in-command of EACH lifeboat. Based on this cite, each lifeboat is required to have 2 lifeboatmen (note that this is not based on the capacity of the lifeboat, but is a straight 2-per lifeboat requirement). A typical drillship example with 6 lifeboats provided, 3 on each side (100% POB coverage on each side), would need 12 lifeboatmen based on the wording in this cite. The majority of Administrations choose to use the formula of 2 lifeboatmen multiplied by the total number of lifeboats to obtain the required number of lifeboatmen to list on their Minimum Safe Manning documents.
But wait, 2009 MODU 14.10.4 requires sufficient certificated persons onboard to launch and operate the survival craft TO WHICH PERSONNEL ARE ASSIGNED. 2009 MODU 14.10.5 works in concert with 14.10.4. This puts an interesting twist to our ‘typical’ drill ship example, and the station bill will need to be consulted to determine the appropriate number of lifeboatmen based on the boats to be used. A typical drillship meets the design and equipment requirements of 100% capacity on each side (2009 MODU 10.3.1) with 3 lifeboats on each side, but common practice across the industry is to assign personnel to the 4 fwd lifeboats as their primary abandonment location/station.
Some examples of lifeboatmen numbers that would meet the intent in our drillship example, in accordance with 2009 MODU 14.10.4 & 14.10.5:
• 3 lifeboats assigned (100% POB coverage), port or starboard boats (depending on scenario) = 6 lifeboatmen required
• 4 fwd lifeboats assigned (exceeds 100% POB coverage, but personnel are assigned to 4 boats) = 8 lifeboatmen required
2014 SOLAS III/10.4 helps to check the intent and is a little clearer than the MODU Codes, as it uses “each survival craft to be used” in the certificated person(s) requirement.
Essentially, an Administration that requires 12 lifeboatmen would cover most any muster/abandonment assignments scenario on our typical drillship example. If an Administration requires only 6 lifeboatmen on our example, the station bill/abandonment station assignments should reflect that arrangement (6 lifeboatmen wouldn’t be sufficient if the 4 fwd boats were being utilized).
Note: If an Administration requires more lifeboatmen than the station bill/boat assignments require, the number stipulated on the Minimum Safe Manning document MUST be adhered to. If the station bill/boat assignments require more than the Administration stipulates, the required number set forth in the applicable MODU code must be complied with.
1989 MODU 14.9.5 and 14.9.4 are the same as the 2009 MODU cites discussed above.
The MODU Code (1979) does not specifically address the requirement related to manning of survival craft and the requirement will be stipulated by the Administration on the Minimum Safe Manning document. Note that ‘emergency procedures’ are located within Chapter 10 of the 79 Code, compared to Chapter 14 of the 89 & 09 Codes.
U.S. requirements follow a similar approach for MODUs. 46 CFR 109.323(c) requires a person to be placed in charge of each survival craft TO BE USED. §323(c)(1) requires them to be trained/certificated for those duties and §323(c)(2) requires the second-in-command for lifeboats permitted to carry MORE THAN 40 persons (41 POB and higher). Note that the biggest difference is that the lifeboat capacity determines when the second lifeboatman is required.
As supplementary guidance to the regulations, CG Marine Safety Manual Vol III/B.2.B.2.f discusses lifeboatmen and when/how many are required and uses the statement “each survival craft to be used” as well. This specific MSM cite is for mechanically-propelled vessels of 100 GRT or more, but is referenced as footnote 15 in B.2.O.1 (MODU sample manning).
Conclusion: Both IMO and U.S. requirements are aimed at providing lifeboatmen for the boats needed to accommodate evacuation of the persons onboard (100% of POB capacity), not providing lifeboatmen coverage for the redundant boats.