US BSEE Helideck A-NPR / Bell 430 Tail Strike
The Bureau of Safety and Environmental Enforcement (BSEE) issued an Advance Notice Of Proposed Rulemaking on Helideck and Aviation Fuel Safety for Fixed Offshore Facilities on 24 September 2014. BSEE explain:
Although the Federal Aviation Administration (FAA) has broad authority regarding helicopter-related safety issues and onshore and offshore flight safety, BSEE has the lead responsibility for safety of helidecks and aviation fuel storage and handling on fixed offshore facilities, while the USCG [US Coast Guard] has the lead responsibility for helidecks and aviation fuel handling on floating offshore facilities.
BSEE’s regulations are in 30 CFR Part 250.
BSEE is seeking comments on whether to incorporate in its regulations certain industry and international standards for the design, construction and maintenance of offshore helidecks, as well as standards for aviation fuel quality, storage and handling.
BSEE cite studies by both the Helicopter Safety Advisory Conference (HSAC), who publish Gulf of Mexico (GOM) focused helicopter safety data annually on their website, and a Centers for Disease Control and Prevention (CDC) study in 2013.
In their accompanying press release, BSEE state:
We know that transportation accidents account for the majority of fatalities on the OCS [Offshore Continental Shelf], and that helicopter-related accidents are a significant concern” said BSEE Director Brian Salerno. “We are looking at our regulations to ensure that the aviation related areas over which we have jurisdiction have the benefit of rigorous safety standards.”
The CDC found that helicopter accidents were responsible for 49 fatalities out of a total of 128 in the US offshore industry between 2003 and 2010. The significance of transport safety is also highlighted in the OGP safety data for 2013 (for global offshore and onshore oil and gas operations), where air transport formed the largest category of fatalities (all helicopter related).
BSEE discuss some of the existing sources of standards and practices/regulations in other countries and want feedback on the following issues:
(1) In addition to the statistical reports and summaries described in this notice, what other relevant, reliable data on accidents or other safety issues related to helicopters, helidecks, or aviation fuel systems on fixed offshore facilities should BSEE consider before deciding whether to propose any new regulations?
(2) Which existing domestic or international standards or guidance documents, if any, related to planning, design, construction, inspection, maintenance and/or use of helidecks on fixed offshore facilities should BSEE consider incorporating by reference in its regulations? What would the potential cost impacts be if BSEE incorporated, and required compliance with, such documents?
(3) Which domestic or international standards or guidance for aviation fuel quality, storage, or handling should BSEE consider incorporating in its regulations for fixed offshore facilities? What would the potential cost impacts be if BSEE incorporated, and required compliance with, such documents?
(4) If you think that BSEE should consider incorporating any existing standards for helidecks or aviation fuel systems, please identify any specific provisions in those standards that BSEE should not incorporate, or that BSEE should modify or supplement before incorporation.
(5) If you are a fixed offshore facility owner or operator, please describe how you currently address any existing industry or other standards regarding safety of helidecks and aviation fuel systems.
(6) What differences between fixed and floating offshore facilities should BSEE consider with regard to whether any existing standards that apply to floating offshore facilities should be incorporated by BSEE for applicability to fixed offshore facilities? How important is it that requirements for helidecks and/or aviation fuel systems on fixed and floating offshore facilities be consistent?
(7) What provisions, if any, of USCG’s regulations for helidecks on MODUs (46 CFR parts 108 and 109) should BSEE consider in developing any helideck regulations for fixed offshore facilities?
(8) If, as an alternative to requiring facilities to comply with specific standards, BSEE required owners or operators of fixed offshore facilities to develop aviation-related safety plans demonstrating how they would ensure safe helicopter, helideck, and aviation fuel management operations, how should BSEE ensure the adequacy of, and compliance with, such plans?
(a) For example, should BSEE or an accredited third party or some other entity conduct audits of such plans to verify the adequacy and proper implementation of the plans?
(9) If BSEE proposes to incorporate any existing industry standard or prescribe any other requirements forhelideck lighting, what helideck perimeter lighting properties (e.g., specific color, brightness) should we incorporate or otherwise require?
(10) If BSEE decides to apply any new regulatory standards for helideck design or construction, and for aviation fuel systems, to all existing helidecks and fuel systems on fixed OCS facilities, even if that required retrofitting existing helidecks or aviation fuel systems, what types of costs would existing facilities potentially incur?
(11) What structural, technical or economic issues related to the aging of existing offshore facilities and helidecks should BSEE consider when deciding how to improve aviation-related safety on fixed OCS facilities?
(12) Are you aware of any potential risks from helicopter engines ingesting methane or other gases vented from a fixed OCS facility and, if so, how should BSEE address those potential risks?
Bell 430 Tail Strike
As if to emphasise the importance of helideck safety and standards, on the same day, the US National Transportation Safety Board (NTSB) issued the probable cause for a Chevron operated Bell 430 accident where the helicopter suffered a helideck tail rotor strike on landing. The NTSB report that:
The pilot reported that she was making a normal approach to the oil platform. Both cranes were shut down on the oil platform, and she received a green deck for landing. The helicopter was over the landing circle when she turned the helicopter’s tail and felt a severe shudder. She immediately landed and shut down the helicopter. The examination of the helicopter and landing platform revealed that the tail rotor blades had struck a handrail on the east crane davit, which resulted in substantial damage to the tail rotor gearbox and drivetrain.
The National Transportation Safety Board determines the probable cause(s) of this accident to be: The pilot’s failure to maintain tail rotor clearance from a handrail on a crane davit on an oil platform during landing.
In this case the NTSB make no recommendations or provide any other useful detail. However, Aerossurance has previously covered NTSB recommendations made earlier in September on offshore gas venting.
UPDATE 23 October 2015: BSEE gave a presentation to the Helicopter Safety Advisory Conference (HSAC) on methane venting risks to helicopters. The supporting report (prepared under their Aviation Safety Support Services contract) is here.
UPDATE 17 April 2017: An example of a tail rotor strike on structure adjacent to a helideck and a subsequent heavy landingwas recorded on 15 April 2017 when Sikorsky S-92A PR-CHR, operated by CHC affiliate BHS, on a floating installation off Macae, Brazil:
Other Helideck Safety Resources
- Helideck Safety Alerts: Refuelling Hoses and Obstructions
- NTSB Recommendations on Offshore Gas Venting
- Mind the Handrail! – Walk-to-Work Helideck Hazard
- Passive Fire-Retarding Helideck Designs
- Troublesome Tiedowns
- Helideck and Helicopter Egress Training Facilities
- Wrong Deck Landings
- FOD and an AS350B3 Accident Landing on a Yacht in Bergen
Aerossurance regularly assists oil and gas companies and vessel operators review and update their helideck procedures and adverse weather policies, examine helideck structural integrity issues and provide independent assurance of helideck readiness.