REPORTS OF SUB-COMMITTEES. Draft Guidance on the safe operation of oil pollution combating equipment. Note by the Secretariat SUMMARY

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1 E MARINE ENVIRONMENT PROTECTION COMMITTEE 67th session Agenda item June 2014 Original: ENGLISH REPORTS OF SUB-COMMITTEES Draft Guidance on the safe operation of oil pollution combating equipment Note by the Secretariat Executive summary: Strategic direction: 7.1 High-level action: Planned output: Action to be taken: Paragraph 4 SUMMARY This document sets out the revised draft text of the Guidance on the safe operation of oil pollution combating equipment, as agreed by PPR 1, for the Committee's consideration and approval Related documents: MEPC 60/19/1; MEPC 62/WP.14, MEPC 62/24; MEPC 64/8; OPRC-HNS/TG 11/3/2; OPRC-HNS/TG 16/3/3 and PPR 1/16 Introduction 1 MEPC, at its sixtieth session, approved the inclusion of an unplanned output on the development of Guidance on the safe operation and performance standards of oil pollution combating equipment in the work programme of the OPRC-HNS Technical Group and added this to the Group's agenda, for consideration at its eleventh session. 2 The development of this Guidance spanned over five sessions of the OPRC-HNS Technical Group and was completed at TG 16, when the Group decided to submit the final draft to PPR 1 for consideration with a view to forwarding it to MEPC 67 for approval and subsequent publication. 3 PPR 1 agreed to the draft Guidance on the safe operation of oil pollution combating equipment, as set out in the annex, and instructed the Secretariat to forward the text of the Guidance to MEPC 67, for consideration with a view to approval for publication.

2 Page 2 Action requested of the Committee 4 The Committee is invited to:.1 approve the draft text of the Guidance on the safe operation of oil pollution combating equipment, as set out in the annex; and.2 instruct the Secretariat to carry out any final editing and to prepare the document for publishing through the IMO Publishing Service. ***

3 Annex, page 1 ANNEX DRAFT GUIDANCE ON THE SAFE OPERATION OF OIL POLLUTION COMBATING EQUIPMENT Preface 1 Article 6.2(a) of the OPRC Convention requires that each Party shall establish a minimum level of pre-positioned oil pollution combating equipment commensurate with the risk involved. In addition, article 8.4 of the Convention calls for the development of standards for compatible oil pollution combating techniques and equipment through the Organization or other competent international organizations. 2 The Marine Environment Protection Committee, at its sixtieth session, having considered the proposal by the Islamic Republic of Iran to develop guidelines addressing the safe performance of oil pollution combating equipment, approved the inclusion of a new item in the work program and the agenda of the OPRC-HNS Technical Group on "Development of guidance on the safe operation and performance standards of oil pollution combating equipment". The OPRC Technical Group, having discussed this issue for several sessions, invited the Islamic Republic of Iran to further develop the "Guidance on the Safe Operation of Oil Pollution Combating Equipment". This guidance provides information on the identification, assessment and mitigation of the risks to the responders in transporting and operating oil pollution combating equipment, taking into account the lessons learnt by government and industry from the oil spill response operations over the past years. The guidance also provides best practices for the operation of equipment and reduction of injury to responders in oil spill response operations.

4 Annex, page 2 Chapter 1 Introduction Chapter 2 Definitions Chapter 3 Scope of guidance Table of contents Chapter 4 Technical guidance and best practices for response personnel 4.1 Hazard factors Direct primary risk factors Combating equipment and materials Equipment classification Oil pollution combating materials Indirect secondary risk factors Location of response operation Type of oil spilled Oil spill response options Level of knowledge and experience of response personnel Hazard association with collision and boom/wire under tension 4.2 Hazard identification 4.3 Risk assessment Hazard identification (HAZOP) method Frequency assessment method Consequence assessment method 4.4 Risk evaluation Risk prioritization Risk categorization 4.5 Risk mitigation Additional safety control 4.6 Risk assessment for oil pollution combating equipment 4.7 Best practices General requirements Personnel responsibilities Personal protective clothing and equipment Chapter 5 Documentation and reporting Bibliography Appendix 1 Appendix 2 Appendix 3 Appendix 4 Appendix 5 Risk assessment form Additional safety control Best practices for oil pollution combating equipment Reporting form for injuries from oil pollution combating equipment Safety checklist for oil pollution combating equipment

5 Annex, page 3 Chapter 1 Introduction 1.1 This guidance is aimed to provide technical guidance for the safe operation of oil spill combating equipment and materials to minimize risks encountered by the personnel involved in oil pollution response operations. Responding to oil spills is an activity that may be conducted in different locations and environments, and involves many different processes. Such operations make use of a combination of human resources, equipment and materials. 1.2 The safety of responders is of the most importance when conducting an effective oil spill response. Ensuring that procedures and response equipment as well as materials are safe is crucial. Currently there is no guidance available for the safe operation of oil spill response equipment. Analytical information from the National Institute for Occupational Safety and Health (NIOSH) for the Deepwater Horizon clean-up operations, indicated that 459 cases of injury occurred in 7 weeks during the operation, which included 14 shoulder injuries, 17 eye injuries, 21 neck injuries, 29 head/face injuries, 46 ankle/foot injuries, 54 knee/leg injuries, 59 back injuries, 76 arm/elbow injuries, 126 hand/finger injuries and 17 other cases (23 April to 20 June 2010). Moreover, the oil pollution combating operation for Erika (1999) led to 439 cases of backache, 317 cases of headache, 230 cases of skin irritation, 126 cases of eye irritation, 98 cases of breathing difficulty, and 91 cases of nausea and vomiting among the personnel involved in the operation (figures 1 and 2). Figure 1: Injuries resulting from oil pollution (Gulf of Mexico, 2010) Figure 2: Injuries resulting from M/T Erika oil pollution (France, 1999)

6 Annex, page Responder injuries bear significant financial costs to the administrators/operators. Some of the costs are obvious, such as sick pay for injured employees, whereas other costs are harder to identify. Nevertheless, this does not include some of the less obvious but more serious costs, such as the increase in insurance premiums, lost production, lost customer and even loss of reputation. In addition, some risk reduction measures can actually increase the efficiency of oil pollution combating operations. 1.4 Apart from using personal protective equipment, adequate knowledge of the possible hazards resulting from the operation of oil spill response equipment and materials and the way responders may encounter these hazards will enable responders to minimize the possible risks resulting from the mentioned factors to their health and safety in an oil spill combating operation. 1.5 Identifying these hazards and consequent risks and taking them into consideration not only protect the personnel from possible physical or psychological harm, but also increase the efficiency of response operations. Chapter 2 Definitions 2.1 Hazards or threats Hazards or threats are existing conditions which may potentially lead to an undesirable event. 2.2 Event An event is an occurrence that has an associated outcome. 2.3 Risk Risk is defined as the product of the frequency with which an event is anticipated to occur and the consequence of the event's outcome. Risk level is a qualitative or quantitative assessment of the risk. Risk = Frequency X Consequence 2.4 Controls Controls are the measures taken to prevent hazards from causing undesirable events. Controls can be physical (safety shutdowns, redundant controls, conservative designs, etc.), procedural (written operating procedures), and can address human factors (employee selection, training, supervision). 2.5 Frequency The frequency of a potential undesirable event is expressed as events per unit time. The frequency should be determined from historical data if a significant number of events have occurred in the past. 2.6 Consequence Consequence can be expressed as the number of people affected (injured or killed). 2.7 Likelihood A generic term covering either frequency or probability, depending on the analysis used.

7 Annex, page Risk mitigation Mitigating the risk of injury from the operation of oil pollution combating equipment. 2.9 Limitations Using an oil pollution combating equipment involves environmental and operational limitations. The limitations may be divided into different categories. Environmental limits and operational limits are the most common categories known so far. Understanding equipment limits by the response personnel will lead them to safer operation Environmental limits The environmental limits are those connected to the environment, e.g. temperature, sea state, inclines, space, time, life, noise and other limits Operational limits The operational limits are those connected to the operation, e.g. the intended use of the equipment; the maximum breaking load of the chains or ropes to be used during operation, the capacity, pressure, loads, range of fluids, substances, resistance, weight, etc. that might be involved; and the maximum noise allowance for the responders Emotion A physiological state of agitation or disturbance which can affect an individual's normal ability to perform required tasks Personal problem A problem that pre-occupies the emotion and reduces the ability to perform required tasks. Examples include physical disabilities, death or illness Injury Physical damage to the body, which causes a decrease in mental or physical abilities Mental illness Psychotic or erratic behaviour, depression, hallucination, unexplainable, or other forms of abnormal behaviour Fatigue A reduction in physical and/or mental capability as the result of physical, mental or emotional exertion which may impair nearly all physical abilities, including strength, speed, reaction time, coordination, decision-making or balance.

8 Annex, page 6 Chapter 3 Scope of guidance 3.1 This document provides technical guidance and best practices for the personnel involved in oil spill response operations with a view to minimizing the risk associated with the operation of oil pollution combating equipment. 3.2 This guidance also provides a uniform risk management approach for the identification, assessment, evaluation and control of the risk involved in the operation of oil pollution combating equipment. 3.3 In this guidance, the risk originating from different types of oil pollution response operations on shorelines and at sea, is identified and best practices for the safe operation of oil pollution combating equipment are provided accordingly. Chapter 4 Technical guidance and best practices for response personnel 4.1 Hazard factors The operation of oil pollution combating equipment can potentially pose health threats to those involved in the operation. These threats may result from direct factors (i.e. equipment) or indirect factors (i.e. location of operation, type of oil, option used for oil spill combating or insufficient knowledge and experience of the personnel). The type or intensity of these threats depends on the type of the equipment used for the operation. However, the intensity of these threats will be determined by a combination of factors such as the above-mentioned direct factors and indirect factors, during and after the operation. The definition and types of factors are set out below: Direct primary risks factors Combating equipment and materials Containment and recovery of oil at sea and onshore requires different equipment and materials, due to the various morphological, oceanographic and environmental conditions. These differences relate to the design, form, size, type and weight of the materials used in producing the oil spill response equipment. The existence of such differences complicates the range of risks from and hazards associated with the equipment used for combating oil spill. Although oil spill clean-up in certain conditions, such as on shorelines or in rivers or shallow waters, can be done with techniques, equipment and materials available at the scene, the equipment and materials normally used are those which are known to have wider performance and effectiveness in responding to different types of oil spills in differing conditions.

9 Annex, page Equipment classification.1 Containment devices: Booms are the most commonly used oil containment devices. There are many different types of boom to suit a variety of different needs and conditions. Even though all boom types are designed on the same principle, they are made of a variety of materials, and have differing features, dimensions and physical characteristics;.2 Recovery devices: Skimmers are the most popular oil recovery devices. A diverse range of skimmers are available to recover floating oil from the water surface. They have been developed to work under a variety of operating conditions. Generally, they are designed to work on a suction or adhesion basis. They follow different physical characteristics based on manufacturer design and its component materials;.3 Vessels and specialized vessels: Vessels play an important role in oil spill response operations. Vessels are used for storing and caring equipment and, in some cases they are also used for storing recovered oil at sea. Supply boats, tugs and buoy tender vessels are generally used in a response operation. There are also specialized vessels for oil recovery that are equipped with the necessary devices on board, in order to be able to collect and store oil on board in small quantities;.4 Temporary storage and handling facilities: The provision of safe and suitable temporary storage and handling facilities is crucial for the success of an oil spill response operation. There is a variety of temporary storage facilities that can be used to support recovery operation at sea or on shorelines. Vessel tanks, barges, towable floating tanks, drums and terrestrial fast tanks are the most recognized types of temporary storage facilities. Handling facilities consist mainly of oil lightering device, fixed, floating and submerged pumps;.5 Ignition devices: To conduct in situ burning of oil on water, ignition devices must be used;.6 Shoreline clean-up devices and accessories: There are different types of equipment that can be used for shoreline clean-up but are not especially designed for this purpose. Rakes, shovels, scrapers, dustbins, vacuum trucks and tanks, graders, bulldozers, tractors, high and low pressure cleaners, steam generators and electric generators are the most common types of shoreline clean-up devices;.7 Dispersants spraying devices: Dispersants can be applied from aircraft, helicopter, ships or individual small handheld pumps;.8 Communications devices; and.9 Pumps: Pumps are used for the transfer of oil from storage devices to the shore.

10 Annex, page Oil pollution combating materials Dispersants and sorbents are the most important materials used in oil spill clean-up operations Dispersants are chemical agents that alter the physical behaviour of oil on the sea surface. Dispersants are usually applied directly to the spilled oil by spraying from aircrafts, helicopters, ships or individual small handheld pumps Sorbents are materials used for either absorption or adsorption of oil at sea. Although they have similar functions, they are made from different materials and in different shapes Indirect secondary risk factors Location of response operations The location for conducting oil spill clean-up operations is one of the important factors in determining other parameters, e.g. type of equipment and number and level of trained personnel needed for the operation. The conditions and the specific characteristics of each geographical location will define the type of equipment to be used while conducting the clean-up, as well as any possible relevant hazards. The location conditions will also influence the required personnel's capacity and relative success of the operation Oil spills may occur in different environmental conditions and extend beyond these. Also clean-up operations may be conducted in different places, such as:.1 rivers;.2 estuaries;.3 creeks;.4 ports and harbours areas;.5 areas adjacent to oil handling facilities;.6 shoreline;.7 shallow waters; and.8 deep sea/open water The physical characteristics of the equipment needed change with the various environments they serve, namely, type, form, size and weight of such equipment are among the important characteristics that influence the choice and adequacy of equipment for each location and environment Type of oil spilled Both the OPRC Convention and MARPOL define oil as petroleum in any form, including crude oil, fuel oil, oil refuse and refined products.

11 Annex, page Initiating a proper response to an oil spill is partly dependent on identifying the type of oil spilled and thus determines the suitable equipment and materials required for clean-up Therefore, the possible hazards that might be posed to those personnel involved in the operation will be determined by the type of the oil spilt at sea as well as the decisions made as to the type of equipment and extent of application Oil spill response options With the exception of the "no action other than monitoring and evaluating the oil" option, the result of choosing each of the oil spill response options will expose response personnel to some level of risks from equipment or materials. Decisions on the best option for responding to pollution and determination of the types of equipment to be used during the operation would therefore define the extent and scope of the hidden risks to the personnel Considering recent technological developments, there are a number of oil spill response options available. The possible response options are as follows:.1 no action other than monitoring and evaluating;.2 containment and recovery of the oil at sea or/in other water bodies (rivers, harbours, etc.);.3 chemical dispersion of the oil at sea;.4 burning the floating oil at sea; and.5 shoreline clean-up Level of knowledge and experience of response personnel The level of knowledge and experience of personnel involved in the response operation can be considered as an indirect factor that defines an important proportion of risks associated with equipment. Oil spill combating operations make use of a combination of human resources, equipment, materials and vessels. Not every responder needs the same level of knowledge and experience. While onshore clean-up activities traditionally involves a large number of personnel mostly with basic skills, except a few managers and officers, and fairly simple equipment, operations conducted at sea require experienced personnel and specified equipment operated in a satisfactory manner Safety must be taken into account right from the design stage and must be kept in mind at all stages in the life cycle of the equipment: design, manufacture, installation, adjustment, operation, maintenance and eventual scrapping Personnel involved in response operations shall be fully familiar with the areas in which they may suffer harm from equipment. The most recognized sources of hazard are as follows:.1 materials;.2 handling;.3 ergonomic;

12 Annex, page 10.4 operating position;.5 control system;.6 moving parts;.7 errors of fitting;.8 extreme temperatures;.9 fire;.10 explosion;.11 noise;.12 vibrations;.13 emission of hazardous materials and substances;.14 trapped with equipment/in machine; and.15 cleaning of equipment Hazard association with collision and boom/wire under tension In order to prevent the collision of other ships with units involved in the pollution combating operation and/or booms and wires under tension, it is necessary to identify the high-risk area during the operation and prevent unrelated people and units from entering. The hazardous areas related to towing of barges/storage tanks or booms in order to move the oil slick are portrayed in figures. Figure 3: Hazardous area of wires under tension

13 Annex, page 11 Figure 4: Hazardous area in J configuration Figure 5: Hazardous area in U configuration Figure 6: Hazardous area in V configuration

14 Annex, page Hazard identification Before beginning any task, it is necessary that all the associated hazards and risks are thoroughly identified and evaluated. For oil spill combating, this is an important task due to the wide variation of potential activities and challenges to control the work sites. You must ask several questions:.1 where will the work be performed, in marshes, on the beach, inland waters, offshore, at docks or in work staging areas?.2 what type of oil pollution will the combating equipment be used for?.3 will the work be accomplished from vessels (small or large) or barges?.4 what part of the clean-up will your workers be involved in?.5 will they be monitoring the activities of others or will they be involved in actual clean-up activities?.6 what can go wrong? What are the possible consequences?.7 what types of protective clothing, P.P.E. and equipment will be required?.8 what hazards could occur and how likely would they occur?.9 who might be harmed by the identified hazards, and when?.10 what parts of the machine might cause harm to a person? and.11 who operates the machine, when, and why? Again remember foreseeable misuse including the possibility of using a machine by untrained persons, and persons who might be present in the workplace; not only machine operators, but also cleaners, security staff, visitors, and members of the public In general, hazards can arise from the spilled product itself and the chemicals involved in the response operations This guidance aims to identify the hazards of operating oil pollution combating equipment during: No. Hazard 1 Transportation

15 Annex, page 13 No. Hazard 2 Deployment at the oil recovery boom 3 Blowing up the oil recovery boom by air blower pump 4 Towing the oil recovery boom 5 Operating power pack 6 Equipment noise

16 Annex, page 14 No. Hazard 7 Operating the skimmer 8 Pumping the recovered oil 9 Operating high pressure cleaners 10 Manoeuvring aircraft

17 Annex, page 15 No. Hazard 11 Igniting and burning of oil at sea 12 Splashing and blowback of oil spill dispersant to personnel 13 Towing barges/floating tanks 14 Using absorbent materials 15 Working on trucks and with shoreline clean-up vehicles/equipment

18 Annex, page 16 No. Hazard 16 Working on shore at temporary storage facilities Consideration should be given to the possibility of entanglement, crushing, cutting from tools, sharp edges on the machine, stability of the machine, noise, vibration, chemicals, and emission of substances being processed. Other factors such as radiation also need to be considered, as well as burns from hot surfaces, or friction due to high speeds In the methods suggested for the safe operation of oil pollution combating equipment, the risks of working with the combating equipment in different locations. The different equipment utilized and several steps of combating are identified. The typical steps for offshore combating when mechanical methods have been chosen are as follows:.1 loading of equipment on to the trucks in stockpiles;.2 transportation of equipment to the shore or loading berth/jetty;.3 loading of equipment on a vessel/barge or boat;.4 transportation of equipment from loading point to the combating area;.5 deployment of the oil recovery boom including the blowing of inflatable type of boom;.6 towing of booms;.7 recovery of oil by skimmers;.8 collection of skimmers;.9 recovery of booms;.10 returning of equipment to the unloading point;.11 washing of equipment; and.12 returning of equipment to the stockpiles. 4.3 Risk assessment methods When the hazards of a system or process have been identified, the next step in conducting a risk assessment is to estimate the frequency at which the hazardous events may occur.

19 Annex, page 17 There are many different analysis techniques and models that have been developed to assist in conducting risk assessments. A key to any successful risk analysis is choosing the right method (or combination of methods) for the situation at hand. It should be noted that some of these methods (or slight variations) can be used for more than one step in the risk assessment process. The common risk assessment methods are listed as below: Hazard identification (HAZID) method.1 Hazard Identification (HAZID) technique;.2 Checklist analysis;.3 Hazard and Operability (HAZOP) analysis;.4 Failure Modes and Effects Analysis (FMEA); and.5 Contribution of "human factors" issues Frequency assessment method.1 Analysis of historical data;.2 Event Tree analysis (ETA);.3 Fault Tree analysis (FTA);.4 Common Cause Failure analysis (CCFA); and.5 Human reliability analysis Consequence assessment method To use a systematic method to determine risk levels, the Risk Assessment Process is applied. This process consists of three basic steps:.1 Hazard identification;.2 Risk analysis which includes frequency assessment and consequence assessment; and.3 Risk evaluation. The level of information needed to make a decision varies widely. In some cases, after identifying the hazards, qualitative methods of assessing the frequency and consequence are satisfactory to enable the risk evaluation. In other cases, a more detailed quantitative analysis is required. Once the likelihood (frequency/probability) and severity of risks have been considered, the precautions available should then be examined to determine their effectiveness. The level of risk can be calculated utilizing a two-dimensional matrix combining likelihood and consequence. Risk = Likelihood (Frequency) X Consequence

20 Annex, page Risk evaluation Once the hazards and potential risks or events have been identified, and the frequencies and consequences associated with these events have been estimated, the relative risks associated with the events can be evaluated. There are a variety of qualitative and quantitative techniques used to do risk evaluation. The common methods are: Risk prioritization In this technique, the analysis team identifies potential scenarios using structured hazard analysis techniques (e.g., HAZOP, FMEA). The analysis team subjectively assigns each scenario with a priority category based on the perceived level of risk. Priority categories can be: low, medium, high, very high Risk categorization In categorizing, the analyst must define the likelihood and consequence categories to be used in the evaluation and also define the level of risk associated with likelihood/consequence category combination. Frequency and consequence categories can be developed in a qualitative or quantitative manner. In this method, one can also categorize the level of risk for further decisions. 4.5 Risk mitigation The most effective way of managing risk is to eliminate it; however, this is not always possible and other options need to be considered. The least effective way of managing risk is to use personal protective equipment as a control method and this is an indication that the hazard is still present to some degree. When applying risk controls, the timescale that you apply may vary. The aim is therefore to control the highest rated risks first. Yet, it may be necessary to apply low level risk controls before high risk controls depending on the operating conditions of equipment and the weather conditions. Attention to the manufactures' recommendations and the use of precautionary measures before any action is taken is the primary objective of risk mitigation. In this guidance, control measures are suggested for each task in the steps for oil pollution combating Additional safety control When the level of risk is high and reducing it is impractical by current or normal measures, then one should be prepared for the hierarchy of safety actions to eliminate or reduce the risk. The main safety actions to control high risk tasks are as follows:.1 Elimination: When possible, the best method of dealing with a hazard is to eliminate it. Once the hazard has been eliminated, the potential for harm has been removed;.2 Replacement: Can the hazard source be replaced with less hazardous combating equipment? For example, aircraft can be replaced with a boat for spraying oil spill dispersant in foggy weather conditions;.3 Engineering controls: Installation of additional wheels for easier sliding of oil recovery booms during deployment;

21 Annex, page 19.4 Administrative: This can include training, installation of warning labels, safe work procedures, and site safety inspections/audits; and.5 Personal Protective Equipment: This can include lifejackets, safety harnesses, safety glasses/goggles, safety helmets, safety boots and gloves. The typical additional safety control is illustrated in appendix 2. In case the risk level is above 60 (identified as high-risk situations), additional safety control measures would be used, as mentioned in appendix Risk assessment for oil pollution combating equipment The method of Risk Assessment for oil pollution combating equipment introduced in this guidance is a combination of frequency, consequence and FMEA methods. Furthermore, in this method, hazard or risk and consequences effects to personnel from working on oil pollution combating equipment such as oil booms, skimmers, pumps, high pressure machines, floating tanks, etc., are identified. The Risk Assessment Process for working with oil pollution combating equipment is summarized in appendix Hazard identification depends on the amount of oil spilled at sea or on shorelines and the equipment needed, which may vary greatly The combination of consequence (severity) and frequency collectively define the risk. At the next step, risk value or the Risk Priority Number (RPN) should be categorized as Risk Assessment The advantages of this method are:.1 All steps of risk assessment can be viewed alongside each other;.2 It combines of qualitative and quantitative approaches, which can give the score for each level of frequency and severity; and.3 Depending on the location, type and amount of the oil spill, the response method used, and the equipment and facilities available, the hazard type and the level of risk can be different. Therefore, the table provided for risk assessment does not mention the score of each separate task and consequences to personnel. The safety officer or risk assessment analyst can choose any score from table 1 or table 2 to calculate the degree of severity or probability In this method, the risk priority value is calculated by multiplying the consequence or severity by the frequency or probability, which would be between 1 and 100, as follows:.1 1 x < 30: risks that are permitted to exist and can be controlled to prevent incidents from occurring. They are identified as Low Risk (LR);.2 30 x < 60: risks that are under control, but need to be reconsidered and lowered to permissible levels. They are identified as Moderate Risk (MR); and.3 60 x 100: risks that need to be eliminated or lowered to permissible levels. They are identified as High Risk (HR).

22 Annex, page The method for measuring the severity or consequence, which enables prioritization during risk assessment, is elaborated in the table below: Score Consequence Effect to the personnel 10 Danger without warning Death 9 Danger with warning Disablement 8 Very high Loss of the body parts, restricted duty, occupational illness 7 High Level 3 burns 6 Medium 5 Low Break or sprain, strain or injuries of muscles (which can be treated similar to level 2 burns) Contusions, level 1 burns, redness of skin, medical aid needed 4 Very low Very low effect to body, interim surgery, first aid needed 3 Negligible Abrasion, scrape of hand 2 Very negligible Small cuts 1 No effect No injuries or damage Table 1 Severity/consequence index Score Frequency risk/hazard Frequency per time 10 Danger without warning Regularly 9 Danger with warning Once a week 8 Very high Every 2 weeks 7 High Monthly 6 Medium Seasonally 5 Low Less than one year 4 Very low Annually 3 Negligible Every 1-5 years 2 Very negligible Every 5-15 years, accidental 1 No effect Rarely Table 2 Frequency/probability of risk After the risk assessment, it is necessary to make a judgment on whether the risk is acceptable or not. Where a risk is assessed as low, the risk of operation may be accepted. If the level of the risk is high, the risk must be eliminated or lowered and new options must be put in place with the aim of reducing the level of risk. The monitoring and review of risk assessments is a growing process which requires continuous improvement. 4.7 Best practices After the risk assessment has been completed and the action techniques have been determined for operational teams, the response team, especially the response equipment operators, need to pay sufficient attention to the health and safety considerations specified in contingency plans and also defined by equipment manufacturers. The best practices are therefore defined considering the response procedures and the equipment used in each oil spill response operation.

23 Annex, page 21 As mentioned in section 4.1, (Hazard factors), the main response methods are mechanical methods, spraying dispersants, in situ burning and beach clean-up. The mechanical method usually includes the use of mechanical equipment such as booms to contain the oil slick, as well as skimmers and pumps to recover and transfer the spilled oil from water surface. The best practices for this method need to be considered fully before, during and after using such equipment. Moreover, there are technical guidelines provided by equipment manufacturers, as well as checklists for their safe and optimal use by operational teams in order to prevent any danger and damage to the personnel and equipment involved. The proposed checklists include the safe operation methods for most oil spill response equipment available, and are intended to complement the items mentioned in the operation booklets provided for each separately. The importance of personal protective equipment and clothing is also recognized and some recommendations in that regard are provided in this section as well. Based on the requirements for the safe operation of oil spill combating equipment, the following safety issues are recommended: General requirements.1 Assess, manage and reduce the risks to responders which may arise from combating operations as low as reasonably practicable, so as to prevent everyone from coming to harm, to maintain a safe and healthy environment, and to reach minimum incident;.2 Enhance safety culture and share safety values with involved parties in the operation;.3 Report any incident, and take remedial actions to prevent their recurrence;.4 Provide adequate medical treatment for all personnel involved in the combating operations, and establish efficient hazard evacuation system at work areas;.5 Establish safety procedures and practices in all operations to work towards an incident free work place;.6 Ensure Risk Assessment has been completed before initiating operational activities;.7 Ensure all personnel working on the plant have received adequate facilities, equipment (including Personal Protective Equipment) and instructions which enable them to undertake their work in a safe manner;.8 Ensure that the operational facilities and working areas have been established in a safe manner; and.9 Make sure that measurement equipment for safe working (e.g. gas detection and flashpoint) are available and in operation. Before commencing a combating operation, it is necessary to ensure that all equipment and personnel are fully prepared in every respect. For this purpose, a checklist has been provided in Appendix 5 to this document.

24 Annex, page Personnel responsibilities It is necessary to select the "best man" who is trained, motivated and "fit to function" for the job, and ensure adequate additional training is given to all concerned personnel. Safety officer To facilitate the control of safety aspects in oil pollution combating operations, it is recommended that a proper person should be appointed as the safety officer. The safety officer is responsible for conducting safety procedures, risk controlling and accident or injuries reporting in all phases of the response operations. On-scene coordinator/commander The on-scene coordinator/commander is also responsible for implementing this safety Guidance. Contractors/volunteers The implementation of safe operation matters should be reflected in the contracts of the contractors/volunteers, as a line of responsibility at all times The application of safe operation policy is the direct responsibility of the on-scene coordinator and all employees and contractors/volunteers involved in its day-to-day application. For this purpose, the following are recommended:.1 Promote safety consciousness amongst employees, contractors/volunteers, and sub-contractors to prevent accidents and injuries;.2 Provide the best possible care in operation of combating equipment and facilities;.3 Continue to take a pro-active stance towards Health & Safety matters;.4 Make arrangements for elimination and mitigation of risk to health in connection with all operational activities;.5 Implement innovative measures to continuously improve safety practices;.6 Conduct effective safety training; and.7 To brief all personnel, in particular the new and inexperienced volunteers, of the subject of safety issues. This could be conducted by a short introductory course that includes safe working and the possible hazards associated with the oil spill response. Master of the oil pollution combating vessel/barge/boat The master is actually the safety operation representative on board the ship and is required to fulfil specific instructions and guidelines. In other words, the master holds the ultimate responsibility on board for matters affecting the safety of the operation, health and safety of crew and personnel.

25 Annex, page 23 All personnel Every person has a statutory duty to take reasonable care for the health and safety of themselves and also others who may be affected due to working on oil pollution combating equipment. With regard to the statutory duties imposed on their employer, they must cooperate with their employer to enable him/her to comply with the relevant statutory requirements, like the following:.1 No person shall intentionally or recklessly interfere with or misuse anything provided for the safe operation under the relevant statutory provisions;.2 All personnel shall wear or use appropriate safety equipment or clothing and use appropriate safety devices; and.3 All personnel shall report any injuries, accidents and damage to the equipment to their supervisor, irrespective of whether persons are injured or not Personal protective clothing and equipment Personal protective clothing and equipment are not substitutes for effective engineering control, safe working condition or sound work practices, but are provided to play an essential part in the protection of the workers. Their usage does not eliminate the hazards, but is an aid to controlling individuals' exposure to prevent/minimize injuries and adverse health effects. Personal protective equipment All Personal Protective Equipment (PPE) should be provided to direct employees on need basis and the company is responsible to provide necessary PPE to all its personnel. It is the responsibility of all individuals to take care of their PPE from damage All damaged PPE must be forthwith reported to the concerned immediate supervisor. All PPE must be of approved types and no modification is allowed to be made to the equipment.

26 Annex, page Types of PPE and its application Head protection Safety helmets must be worn in operational worksite at all times for protection against head injuries. Eye and face protection Approved eye or face protective equipment such as goggles and face shield must be worn when carrying out the tasks that might harm the eyes and face such as operation with high pressure machine. Body protection Overalls or long trousers or shirts must be worn with rubber aprons for protection against acid & chemical splashes. Leather aprons must be worn when handling molten metal or shielding against a heat source. Overalls should be worn at all time. Loose clothing should not be permitted at worksite. Hearing protection There are basically two types of ear protective equipment earmuffs and earplugs. These have to be worn when working in areas where there is excessive noise (above 85 db) for long term such as operation with power pack or air craft. Foot and leg protection Employees must wear safety shoes when working if there is danger of sparks or molten metal falling into the shoes. Respiratory protection Appropriate respirators should be worn when in contaminated atmosphere of gas, fumes or vapors. Such operation may occur when volatile oil spilled in hot weather in tropical zone. Approved type of air supply respirator must be worn when toxic gases are found. When airline mask is used and air is supplied from a compressor, measure shall be taken to ensure that oil, carbon dioxide, carbon monoxide and other contaminants are within the permissible limit. Self-supplied respirator must be used if the atmosphere is contaminated with highly toxic vapor or oxygen deficiency. Safety gloves Leather gloves are to be used for handling heavy equipment; rough material, loading and unloading pipe work, handling wire lines, slings and cables and also for welding. Cloth gloves afford adequate protection when handling pipe or other relatively smooth surface material. Chemical resistant rubber gloves are to be used when handling acids, alkalis or other corrosive chemicals. Personnel flotation devices Lifejackets or personal flotation devices (PFDs) must be worn if the depth of water is more than one meter The risks, causes and remedies for different cases are illustrated in details in appendix 3 of this Guidance. The persons involving in combating operation should pay attention to perform the recommendation of this Appendix in all steps of oil pollution combating operation.

27 Annex, page 25 Chapter 5 Documentation and reporting 5.1 Documentation and reporting is an important issue with regard to the implementation and promotion of this Guidance. The on-scene commander/coordinator or safety officer must make the required arrangements for documenting and reporting the hazards resulting from the oil spill response equipment during response operations. All parties involved in the oil pollution combating must be informed of the existence of such arrangements and be duly able to use them. 5.2 Operational personnel should be encouraged to report any risks, near-misses, injuries and illnesses resulting from the operation of oil pollution combating equipment or materials. These reports should be analysed to assess the working conditions with equipment or chemicals, so that actions can be taken by the safety officer to prevent similar risks, while considering the lessons to be learned from previous experience. The findings of the assessments and the results of the analyses will therefore be provided as beneficial feedback to the equipment manufacturers. 5.3 The collected forms showing the types and severity of injuries, as well as the connection between incident cause and equipment types are considered and analysed and the findings are employed as lessons to be learnt for future operations. 5.4 Hazards of the operation of equipment or exposure to chemicals, dispersants, commonly include, but are not limited to, the following: Hazard form equipment skin injuries electricity back and joint pains poisoning bone fractures hand and fingers eye, nose and throat irritation foot and leg headache burn 5.5 A typical hazard Exposure Reporting form is illustrated in appendix 4 to this Guidance.

28 Annex, page 26 Bibliography 1. IMO (2000), Marine Accident and Incident Investigation-Training Manual, IMO, London, U.K. 2. ABS (2000), Guidance Notes On Risk Assessment Applications for the Marine and Offshore Oil and Gas Industries, ABS, New York, USA. 3. IPIECA (2002), Oil Spill Responder Safety Guide, Volume 11, IPIECA, London, U.K. 4. IMO (2005), Manual on Oil Pollution, Section IV Combating Oil Spills, Edition 2005, IMO, London, U.K. 5. OHSAS (2007), Occupational Health and safety, 18001:2007 TUVNORD, OHSAS. 6. IMO (2000), Marine Accident and Incident Investigation-Training Manual, IMO, London, U.K. 7. Keivan Rod, N. (2009), Reducing Human Risks and Increasing Efficiency of Oil Spill Response Operation at Sea, Interspill 2009, Marseille, France. 8. NIOSH (2010), Report of BP Injury and Illness Data, Centers for Disease Control and Prevention, National Institute for Occupational Safety and Health, NIOSH. 9. NIOSH (2010), Reducing Occupational Exposures while Working with Dispersants during the Deepwater Horizon Response, Interim Information, update 07/02/2010, NIOSH. 10. IMO (2010), Manual on Oil Spill Risk Evaluation and Assessment of Response Preparedness, 2010 Edition, IMO, London, U.K. 11. OSHA (2010), Safety and Health Awareness for Oil Spill Clean-up Workers, Oil Spill Cleanup Initiative, Worker Education and Training Program, OSHA (6742). 12. OSHA (2001), Oil Spill Response: Training Marine Oil Spill Response Workers under OSHA's Hazardous Waste Operations and Emergency Response Standard, U.S. Department of Labor, OSHA AMSA (2011), Oil Spill Response Occupational Health and Safety Manual, AMSA, Canberra, Australia. 14. PMO (2012), Bandar Abbas Port Risk Assessment Booklet 2012, Ports and Maritime Organization, Shahid Rajaee Port, Iran. 15. NIOC (2012), National Iran Oil Company Risk Assessment for SBM in Qeshm Island, National Iran Oil Company, Iran. 16. Nerland, J. (2001), Norwegian Oil Spill Contingency and Risk Based Governmental Contingency Planning, Norwegian Pollution Control Authority (SFT), Horten, Norway.

29 Annex, page IMO (2005), Oil Pollution, Preparedness and Co-operation (OPRC), Level 3, Model Course, IMO, London, U.K. 18. ITOPF (2010), Use of Skimmers in Oil Pollution Response, Technical Information Paper, Canterbury, U.K. 19. The American Club, Shipboard Safety, Shipowners Claims Bureau Inc., American Steamship Owners Mutual Protection and Indemnity Association Inc. 20. Fingas, M. (2001), The Basics of Oil Spill Cleanup, Second Edition, Levis Publisher. 21. Cedre (2005), Using Dispersant to Treat Oil Slicks at Sea, Airborne and Ship borne Treatment, Response Manual, Cedre. 22. Cedre (2004), Oil Spill Waste Management, Operational Guide, Cedre

30 Annex, page 28 Appendix 1 Risk assessment form Risk Assessment Risk Evaluation Task Title Hazard Identified Cause of hazard Effect of hazard on the person Probability Consequences RPN LR MR HR Risk Mitigation Equipment falling on the person Incompetent person for lifting equipment Loss of body part Using competent crane operators Considering SWL of lifting system Using Personal Protection Tool (PPT) Transport of equipment (stockpile to/from) loading point Strain of body part Loading and lashing of equipment on Boat Equipment striking the person Incompetent person for lifting equipment by crane Damaged wires Loss of body part Using competent crane operators Strain of body part Considering SWL of lifting system Using PPT Standing away when loading and discharging Checking the wire before operation Using PPT Man overboard Improper securing of equipment Death 3 10 Using life jackets Proper securing of equipment Transportation by boat/vessel Equipment striking the person Improper securing of equipment Rough sea Injury to the person Using proper boats for transportation

31 Annex, page 29 Risk assessment form Risk Assessment Risk Evaluation Task Title Hazard Identified Cause of hazard Effect of hazard on the person Probability Consequences RPN LR MR HR Risk Mitigation Shoreline temporary oil storage Pumping oil from temporary storage to shore tank Shoreline manual cleaning/high pressure cleaner Vacuum lorry upsetting plastic lined pits Vehicle accident Person falling into the pits Heavy plastic bags falling Not considering accessibility for vehicle Not using safety marks Incompetent drivers Bags fragmenting during lift Damaged wire Very low effect on the body Eye injury Occupational illness Strain or sprain Face and eye injury Considering accessibility for vehicle Using safety mark Using competent drivers Using pits not deeper than 1.5 meters Using PPT Using approved bags Using PPT Using proper wires Electric shock Unapproved pumps Death Using approved pumps Level 3 of skin burns Using safety placards Using PPT Pipe/hose suddenly Improper coupling and Eye injury Using PPT uncoupling hydraulic pipe/hose Face injury Heat exhaustion Falling into water Insect bites Eye injury Skin injury Face injury Vehicle striking personnel Fatigue Long-term exposure to sunlight Not using PPT Fatigue Not using safety marks Loss of body part Using PPT Using enough water Conducting fatigue and stress recovery Following Threshold Limit Value (TLV) procedures Using safety marks Conducting fatigue and stress recovery Shoreline cleaning by vehicles

32 Annex, page 30 Risk assessment form Risk Assessment Risk Evaluation Task Title Hazard Identified Cause of hazard Effect of hazard on the person Probability Consequenc es RPN LR MR HR Risk Mitigation Treating injured personnel Operation of power pack Deployment and blowing of boom Injured personnel not treated appropriately Noise pollution Hydraulic pipe suddenly uncoupling Body parts caught in lines or cables during deployment Boom chamber breaking Blower pipe uncoupling Injuries not surveyed and treated appropriately Patient not transported safely to treatment facility Standing closer than allowable TLV Improper coupling and hydraulic pipe Poor seamanship Hydraulic failure Over-blowing or damage by sharp items Failure of coupling or pipe Increased injury to person being treated due to mistreatment and transport to health care provider Damage to hearing system Eye injury Face injury Level 1 burns Injury to personnel; Partial and/or permanent disability Very low effect to body Sprain, strain or muscular injuries Delivering first aid & treatment for injured personnel only by qualified personnel Taking all due care in the transport of patient en route and reporting to supervisor at final destination Following TLV manual Using PPT Using PPT Training personnel involved Following safety checklists Following safety manual and checklist Using PPT Not using back-handling blower pump when the higher blowing point is less than 50 cm from ground or boat deck Keeping the boom clear from sharp items Monitoring chamber pressure when blowing Checking connection before blowing

33 Annex, page 31 Risk assessment form Risk Assessment Risk Evaluation Task Title Hazard Identified Cause of hazard Effect of hazard on the person Probability Consequences RPN LR MR HR Risk Mitigation Skimmer falling on the person Damaged wires Incompetent crane operators Strains and sprain Body part breaking Using competent operator Keeping clear of crane operation area Using PPT Skimmer deployment Oil recovery Oil recovery and pumping Hydraulic pipe suddenly uncoupling Oil recovery pipe bursting Falling into barge hatch Fire Hydraulic pipe bursting Improper coupling and hydraulic pipe Damaged hoses Hose damaged by sharp items Safety placard uninstalling Not using safety clothes Oil contamination on barge Rough sea Smoking Unapproved equipment Damaged hoses Improper connections Skin injury Eye injury Eye injury Body part breaking Disablement Face injury Death Level 3 burns Body part breaking Level 1 burns Strain Checking coupling before operation Using PPT Checking the hose before operation Keeping clear of the hose Using PPT Installing safety placards Keeping clear of any oil on barge deck Following operation checklist for offshore response Considering safe sea condition for response Using PPT Observing smoking regulations Using approved equipment Keeping firefighting equipment available Keeping first aid available Avoiding keeping hydraulic pipes in sunlight for long Checking hydraulic pipe before operation

34 Annex, page 32 Risk assessment form Risk Assessment Risk Evaluation Task Title Hazard Identified Cause of hazard Effect of hazard on the person Probability Consequences RPN LR MR HR Risk Mitigation Skimmer collection Collection of oil recovery boom Oil leaking Incomplete drainage Skin injury Draining the hose before Eye injury collection Standing clear of crane operation area Skimmer falling Damaged wires Body part breaking Standing clear of crane operation Disablement area Using competent crane operator Incompetent crane Checking wire and lifting as crane operators SWL Body parts caught in lines or cables during the collection Hydraulic pipe suddenly uncoupling Oil splash on the person Body parts caught in lines or cables during Hydraulic pipe suddenly uncoupling Insufficient coordination between operator & other personnel Incompetent operators Hydraulic system malfunctioning Improper connection Damage Connection Not observing safety issues Body part breaking Strain Strain Skin injury Eye injury Keeping clear of boom reel Placing boom reel in proper position Not pulling boom by hand Using only necessary personnel Using PPT Checking coupling before operation Using PPT Considering wind direction Using PPT

35 Annex, page 33 Risk assessment form Risk Assessment Risk Evaluation Task Title Hazard Identified Cause of hazard Effect of hazard on the person Probability Consequences RPN LR MR HR Risk Mitigation Dispersion of OSD in working place No attention to safety precautions or wind direction Very low effect on body Using PPE Considering wind direction Spraying of OSD by boat Spraying of OSD by helicopter Spraying of OSD by airplane Crash OSD tank falling Crash Pilot's error Helicopter malfunctioning Improper securing Unapproved wires Pilot's error Airplane malfunctioning Death Injury Injury Death Injury Following safety and operational PM for airplanes Using competent pilots Providing training for pilots Using PPE Assessing rest cycle by supervisor Using PPE Using proper wire & securing Following safety and operational PM for airplanes Using competent pilots Providing training for pilots Using PPE Assessing rest cycle by supervisor

36 Annex, page 34 Appendix 2 Additional safety control Task Elimination Replacement Engineering Control Administrative Personnel Protection Equipment

37 Annex, page 35 Appendix 3 Best practice for oil pollution combating equipment A. Mechanical oil pollution combating 1. Shore transportation Item Hazard Cause Remedy 1 o Corroded wires o Loading higher than permissible weight o Loading by cranes or forklifts o Incompetent operator o Insufficient equipment lashing o Controlling wires before use o Considering permissible weight o Staying away from loading cranes or forklifts o Ensuring operator's skills o Controlling equipment lashing o Using PPE 2 Items falling from heights o Insufficient lashing o Controlling lashing 3 Items falling from trucks, etc. o Insufficient truck control o Ensuring driver's skills Items falling from trucks, etc.

38 Annex, page Loading onto vessel or barge Item Hazard Cause Remedy 1 o Insufficient equipment lashing o Items hitting personnel o People present near working cranes o Loading higher than permissible weight o Using PPE o Staying away from working cranes o Controlling cranes before use o Locating crane in proper position Chain snapping and items falling during loading 3. Transfer to the scene and back Item Hazard Cause Remedy 1 o Unfavourable weather/sea conditions o PPE, such as lifejackets not used o Personnel's fatigue o Considering weather forecasts o Considering wave and wind conditions on scene o Using PPE, such as lifejackets o Considering working hours Man overboard 2 o Sailing in shallow waters o Considering safety depth for sailing 3 Grounding o Lengthy exposure to direct sunlight o Avoiding exposure to direct sunlight o Providing drinking water and first aid o Using PPE, such as sunglasses 4 Sun and heatstroke o Insufficient equipment lashing o Controlling equipment lashing Equipment striking personnel

39 Annex, page Inflating and deploying booms Item Hazard Cause Remedy 1 o Ignoring safety requirements o Rough sea conditions & personnel's lack of balance o Heatstroke and dizziness o Observing safety requirements o Avoiding boom operation in rough sea conditions o Ensuring sufficient rest for personnel 2 Man overboard o Using portable back-pack blowers o Avoiding portable back-pack blowers in cases where the air inlet is lower than 50 cm from ground or deck Gasoline spilling on personnel during inflation 3 o Insufficient equipment lashing o Controlling equipment lashing Equipment falling overboard 4 o Slippery materials on the surface o Keeping deck surface dry & clean 5 Sliding o Ignoring safety distance o Operator's inability to control boom o Observing safety distance Boom hitting personnel 6 o Ignoring safety requirements o Using hands instead of necessary tools o Observing safety requirements Chain getting entangled to personnel's hands

40 Annex, page 38 Item Hazard Cause Remedy 7 o Naked fires, smoking or sparks o Avoiding naked fires, smoking or sparks 8 Explosion o Operator's inability to control boom o Ensuring suitable lashing of boom end o Using skilful operators o Keeping a few meters of boom on board with auxiliary tools Boom getting loose 9 o Inability to control boom on towing boat o Insufficient radio communication o Ensuring operator's skills o Maintaining sufficient radio communication & one channel as back-up Boom stretching and swaying too much 10 o Air leakage from boom inlet covers o Ensuring suitable coverage of boom inlets Air escaping boom chambers 5. Boom operations and oil slick transfer Item Hazard Cause Remedy 1 Man overboard during equipment handling o Insufficient attention to safety requirements o Insufficient attention to turbulence caused by helicopter while hovering above the scene o Personnel's fatigue o Observing safety requirements o Considering turbulence caused by helicopter o Using stanchions on board deploying ship o Using PPE, such as lifejackets o Ensuring sufficient rest for personnel

41 Annex, page 39 Item Hazard Cause Remedy 2 Ropes snapping & equipment falling overboard o Insufficient equipment lashing o Master's insufficient skill on towing boats o Insufficient radio communications o Insufficient attention to boat engine power o Insufficient attention to wind and current speed and direction o Insufficient coordination among involved units o Insufficient attention to boom location o Controlling equipment lashing o Ensuring master's skills o Ensuring sufficient radio communications o Considering boat engine power o Considering wind and current speed and direction o Ensuring sufficient coordination among involved units o Considering boom location 3 o Insufficient attention to boom pulley location during deployment o Using ropes longer than required o Fixing boom pulley in a suitable place o Using sufficient length of ropes Booms ropes getting entangled to propellers 4 o Lengthy exposure to direct sunlight o Avoiding exposure to direct sunlight o Providing drinking water and first aid o Using PPE, such as sunglasses Sun and heatstroke 5 o Sharp objects hitting boom o Other vessel hitting boom o Keeping sharp objects away from boom o Keeping safe distance among vessels and booms Boom chambers rupturing 6. Oil spill recovery Item Hazard Cause Remedy 1 o Insufficient attention to safety requirements o Observing safety requirements o Using PPE, such as lifejackets Man overboard during equipment handling

42 Annex, page 40 Item Hazard Cause Remedy 2 o Insufficient equipment lashing o Controlling equipment lashing 3 Equipment falling overboard o Slippery materials on the surface o Keeping deck surface dry & clean 4 Sliding o Personnel's fatigue o Ensuring sufficient rest for personnel o Using PPE, such as lifejackets Man overboard 5 o Naked fires, smoking or sparks o Avoiding naked fires, smoking or sparks Fire 6 o Insufficient attention to safety requirements o Observing safety requirements o Using PPE Personnel's skin contact with oily materials 7 o Insufficient attention to safety requirements o Observing safety requirements o Using PPE Personnel's eye contact with oily materials

43 Annex, page 41 Item Hazard Cause Remedy 8 o Insufficient attention to safety requirements o Observing safety requirements o Using PPE 9 Inhaling oily fumes o Barge storage tanks left open o Absence of warning signals o Keeping barge storage tanks closed o Providing sufficient warning signals Personnel falling into barge storage tanks 7. Boom recovery and returning equipment to stockpile Item Hazard Cause Remedy 1 o Insufficient attention to safety requirements o Observing safety requirements 2 Man overboard during equipment handling o Insufficient equipment lashing o Controlling equipment lashing 3 Equipment falling overboard o Slippery materials on the surface o Keeping deck surface dry & clean Sliding

44 Annex, page 42 Item Hazard Cause Remedy 4 o Personnel's fatigue o Ensuring sufficient rest for personnel o Using PPE, such as lifejackets 5 Man overboard o Naked fires, smoking or sparks o Avoiding naked fires, smoking or sparks Fire 6 o Insufficient attention to safety requirements o Observing safety requirements o Using PPE Personnel's skin contact with oily materials 7 o Insufficient attention to safety requirements o Observing safety requirements o Using PPE 8 Personnel's eye contact with oily materials o Insufficient attention to safety requirements o Observing safety requirements o Using PPE 9 Inhaling oily fumes o o -Operator's inability to control boom o -Insufficient attention to safety requirements o -Ensuring sufficient training on boom operation and safety distance o -Observing safety o requirements Boom getting loose

45 Annex, page 43 Item Hazard Cause Remedy 10 o -Insufficient knowledge about boom operation o -Presence of too many people near boom recovery area o -Using hands for reeling back the boom o -Observing safety requirements o -Using experienced personnel o -Using sufficient number of personnel o -Using auxiliary tools chains getting entangled to arms/legs 8. Equipment washing, repair and maintenance Item Hazard Cause Remedy o Slippery materials on the surface o Keeping deck surface dry & 1 clean 2 Sliding o Naked fires, smoking or sparks o Using hot water for washing o Avoiding naked fires, smoking or sparks o Keeping fire-fighting equipment available 3 Fire o Insufficient attention to safety requirements o Observing safety requirements o Using PPE 4 Personnel's skin contact with oily materials o Insufficient attention to safety requirements o Observing safety requirements o Using PPE Personnel's eye contact with oily materials

46 Annex, page 44 Item Hazard Cause Remedy o Insufficient attention to safety o Observing safety requirements 5 requirements o Using PPE 6 Inhaling oily fumes o Operator's inability to control boom o Insufficient attention to safety requirements o Ensuring sufficient training on boom operation and safety distance o Observing safety requirements 7 Boom getting loose o Insufficient knowledge about boom operation o Presence of too many people near boom recovery area o Using hands for reeling back the boom o Observing safety requirements o Using experienced personnel o Using sufficient number of personnel o Using auxiliary tools 8 Chains getting entangled to arms/legs o -Insufficient equipment lashing o -Controlling equipment lashing 9 Equipment falling Burns from hot water or steam o -Insufficient attention to safety requirements of equipment washing o -Misconnection of hot water hose o -Corrosion of hot water hose o -Using PPE, such as safety goggles o -Using proper hoses o -Controlling hot water hose connections o -Keeping first aid equipment available

47 Annex, page 45 B. Chemical oil pollution combating 1. Dispersant spraying from aircraft or helicopter Item Hazard Cause Remedy 1 Main or rear rotor striking personnel o Insufficient attention to safety requirements o Approaching helicopter when signaled by helicopter crew o Maintaining safety distance with helicopter o Passing the helicopter from the front o Bending over when passing near the helicopter o Keeping first aid equipment o available o Discharging static charge before landing o Observing flight safety requirements o Fire fighting team standing by on scene o Using PPE o Earth cable connection while refueling o Observing flight safety requirements o Ensuring sufficient radio communication o Continuous training on aerial maneuver o Using flight PPE o Observing permissible flight hours for crew o Flight in favorable conditions o Keeping first aid/fire-fighting equipment available 2 Fire o Static charge when landing o Refueling with engines running o Earth cable not connected while refueling 3 Aircraft or helicopter crashing o Insufficient radio communication o Flight crew's fatigue o Flight in unfavorable conditions and low visibility o Low flight without autopilot o Insufficient coordination between flight crew and pilots 4 o Using improper wires or connections o Inefficient lashing o Using proper wires or connections o Controlling wires and connections o Avoiding operation in crowded areas Dispersant tank falling 5 Dispersant spilling on personnel o Dispersant tank leakage o Operation in crowded areas o Insufficient attention to wind direction o Insufficient radio communications o Ensuring sufficient radio communication o Controlling tank before flight o Ensuring safety distance from crowded areas o Considering wind direction o Using PPE

48 Annex, page 46 Item Hazard Cause Remedy 6 o Low flight in crowded areas o Insufficient radio communications o Ensuring sufficient radio communication o Ensuring safety distance from crowded areas o Using PPE, such as lifejackets Personnel falling into the water 2. Dispersant spraying from vessels Item Hazard Cause Remedy 1 o Non-standard hoses and connections used in dispersant spraying equipment and system o Using standard hoses and connections in dispersant spraying equipment and system, with sufficient resistance against pressure o Continuous inspection Hose rupturing or connections breaking 2 o Non-standard or corroded hoses and connections used in dispersant spraying equipment and system o Wind blowing on scene o Vessel swaying during operation o Ensuring proper place for dispersant nozzles o Considering wind direction o Using PPE Dispersant spilling on personnel, due to wind blowing, hose rupturing or connections breaking C. In situ burning Item Hazard Cause Remedy 1 o Insufficient attention to wind direction o Insufficient attention to safety requirements o Using PPE o Considering wind direction o Observing safety requirements Fire starting materials spilling on personnel

49 Annex, page 47 Item Hazard Cause Remedy 2 o Insufficient attention to wind direction o Insufficient attention to safety requirements o Using PPE o Considering wind direction o Observing safety requirements o Keeping fire-fighting equipment available 3 Fire, involving personnel o Incomplete burning of hydrocarbons o Staying at a reasonable distance upwind o Considering wind direction Inhaling thick smoke 4 o Extensive heat o Using PPE Fire resistant boom bursting 5 o Working under extensive heat conditions o Using PPE o Providing drinking water and first aid o Observing permissible working hours Sun and heatstroke D. Shoreline clean-up Item Hazard Cause Remedy 1 o Rocky shore clean-up o Using PPE, such as safety straps Personnel falling from height

50 Annex, page 48 Item Hazard Cause Remedy 2 o Working under extensive heat conditions or direct sunlight o Personnel's fatigue o Using PPE o Providing drinking water and first aid o Observing permissible working hours 3 Sun and heatstroke o o -Driver/operator's insufficient skills o -Operating in crowded areas o -Personnel's fatigue o -Providing warning signals in the operation area o -Using skillful personnel o -Observing permissible working hours 4 5 Clean-up equipment hitting personnel Burns from hot water or steam o Insufficient attention to safety requirements of equipment washing o Misconnection of hot water hose o Corrosion of hot water hose o Insufficient attention to safety requirements o Using PPE, such as safety goggles o Using proper hoses o Controlling hot water hose connections o Keeping first aid equipment available o Considering items mentioned on MSDS1 o Using PPE o Keeping first aid equipment available 6 Dispersant spilling on personnel o Insufficient attention to safety requirements for working with hands o Considering health recommendations o Using PPE o Keeping first aid equipment available Animals biting personnel 1 MSDS: Material Safety Data Sheet

51 Annex, page 49 E. Temporary storage on shoreline Item Hazard Cause Remedy 1 o Insufficient warning signals and lighting (for night operation) o Providing warning signals and lighting o Making pits maximum 1.5 meter deep Personnel falling into storage pits 2 o Insufficient warning signals and lighting (for night operation) o Driver's insufficient skill o Providing warning signals and lighting o Using skillful drivers 3 Equipment falling into storage pits o Corroded wire or plastic bags o Loading higher than permissible weight o Non-skillful operator o Controlling wires before use o Observing permissible weight o Ensuring operator's skills o Using PPE 4 Plastic bags containing recovered oil falling o Using electric pumps o Using PPE o Avoiding electric pumps Electric shock from pumps 5 o Using electric pumps o Using PPE, fire fighting and first aid available o Avoiding electric pumps Fire 6 o Insufficient attention to safety requirements for temporary storage o Considering health recommendations Hand cuts