SAFETY BULLETIN

SB2/2023 AUGUST 2023

Extracts from
The United Kingdom
Merchant Shipping Potential failure of
(Accident Reporting and
Investigation) Regulations
2012 Regulation 5:
“The sole objective of a safety
Deutsche Schlauchboot GmbH (DSB) liferafts
investigation into an accident
under these Regulations
shall be the prevention of
serviced by Comfer Marin SL, Marin, Spain
future accidents through the
ascertainment of its causes
and circumstances. It shall
identified following the foundering of the fishing vessel
not be the purpose of such
an investigation to determine
liability nor, except so far Piedras (FD 528)
as is necessary to achieve
its objective, to apportion
blame.” south-west of Mizen Head, the Republic of Ireland
Regulation 16(1):
“The Chief Inspector on 1 June 2022
may at any time make
recommendations as to how
future accidents may be
prevented.”

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NOTE
This bulletin is not written with
litigation in mind and, pursuant to
Regulation 14(14) of the Merchant
Shipping (Accident Reporting
and Investigation) Regulations
2012, shall be inadmissible in
any judicial proceedings whose
purpose, or one of whose
purposes is to attribute or
apportion liability or blame.

© Crown copyright, 2023

See http://www. Recovered Piedras starboard liferaft
nationalarchives.gov.uk/doc/
open-government-licence for
details.

All bulletins can be found on

our website:
https://www.gov.uk/maib

For all enquiries:

Email: maib@dft.gov.uk
Tel: +44 (0)23 8039 5500
 MAIB SAFETY BULLETIN 2/2023
This document, containing safety lessons, has been produced for marine safety purposes only,
on the basis of information available to date.

The Merchant Shipping (Accident Reporting and Investigation) Regulations 2012 provide for the
Chief Inspector of Marine Accidents to make recommendations at any time during the course of
an investigation if, in his opinion, it is necessary or desirable to do so.

The Marine Accident Investigation Branch is carrying out an investigation into the foundering of
the fishing vessel Piedras (FD 528), 78 nautical miles south-west of Mizen Head, the Republic of
Ireland, on 1 June 2022.

The MAIB will publish a full report on completion of the investigation.

Captain Andrew Moll OBE

Chief Inspector of Marine Accidents

NOTE
This bulletin is not written with litigation in mind and, pursuant to Regulation 14(14) of the Merchant
Shipping (Accident Reporting and Investigation) Regulations 2012, shall not be admissible in any judicial
proceedings whose purpose, or one of whose purposes, is to apportion liability or blame.

This bulletin is also available on our website: www.gov.uk/maib

Press Enquiries: 01932 440015 Out of hours: 0300 7777878
Public Enquiries: 0300 330 3000
BACKGROUND
On 1 June 2022, the engine room of the UK registered stern trawler Piedras (FD 528) flooded
while fishing 78 nautical miles south-west of Mizen Head, the Republic of Ireland in Beaufort
force 3 winds and smooth seas. The crew of Piedras were unable to contain the flooding and
the skipper gave the order to abandon the vessel. The crew manually released the port liferaft
and pulled the painter, but it failed to inflate correctly. The starboard liferaft was successfully
launched by the same method. The crew used this liferaft to transfer to a nearby fishing vessel.
Piedras capsized and sank over 2.5 hours later.

INITIAL FINDINGS
MAIB’s investigation identified that Piedras was equipped with two 12-person SOLAS1 approved
liferafts manufactured by Deutsche Schlauchboot GmbH (DSB), a subsidiary of Survitec Group
Limited (Survitec).

The port liferaft carried on board Piedras was an LR97 model and the starboard liferaft was an
LR05 model. The annual certification2 for both liferafts had been issued by the marine liferaft
service station Comfer Marin SL (identity number 50826; previously 375), in Marin, Spain.
Comfer Marin SL had been accredited by Survitec as one of its approved liferaft servicing
agents.

It was not possible to determine the cause of the port liferaft’s failure to deploy correctly, as it
was not recovered after the accident. It was last observed drifting in an inverted orientation,
having apparently released from its canister and partially inflated (Figure 1).

Figure 1: The port liferaft, floating inverted and partially inflated

Subsequent examination by the MAIB of the SOLAS A3 pack in the recovered starboard liferaft
(Figure 2) found that:

● the first aid kit had not been replaced since it was supplied in 2007;

● the liferaft repair kit had expired in September 2008;

1 International Convention for the Safety of Life at Sea, 1974, as amended.

2 Merchant Shipping Notice 1873 Amendment No.1 (F) – The Code of Practice for the Construction and Safe Operation of
Fishing Vessels of 24m Registered Length and Over – stated that every inflatable liferaft must be serviced at intervals not
exceeding 12 months and in accordance with Marine Guidance Note 548 (M&F) Life-Saving Appliances – Inflatable SOLAS
Certificated Liferafts, Lifejackets, Marine Evacuation Systems and Repair of Inflated Rescue Boats – Servicing Requirements
and Approved Service Stations.
3 Refers to liferafts fully loaded with food and water rations, flares, and a first aid kit.
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● the torch batteries had expired in January 2010;

● all of the pyrotechnics had expired in March 2010; and

● all of the food and water supplies had expired in January 2012.

Figure 2: Examples of the expired consumable items in Piedras’s starboard liferaft

The starboard liferaft had not been correctly serviced since its manufacture in March 2007,
despite having been routinely certified by Comfer Marin SL.

Survitec conducted further investigations into DSB liferafts certified by Comfer Marin SL and
inspected a sample of liferafts that had been serviced by Comfer Marin SL during 2022, which
were found to have the following defects:

● gas cylinders had not been tested;

● inflation hoses had not been replaced, with some found to be in poor condition;

● emergency pack items such as flares, first aid kits and repair kits had passed their expiry
date;

● internal and external light batteries had passed their expiry date;

● canisters displayed original labels and had corroded strapping bands; and

● service record labels had not been completed.

Annual checks by the Capitanía Marítima de Vigo4 and routine audits undertaken by Survitec
before this accident had not identified any significant servicing issues with Comfer Marin SL.
Survitec has been unable to contact all potentially affected liferaft owners and operators and,
consequently, has been unable to fully assure all identified liferafts of concern. With a gas
inflation test being required at 5-yearly intervals5 Survitec recognised that a routine annual
service may not, on its own, highlight all the potential problems resulting from the significant
servicing issues identified.

4 Capitanía Marítima de Vigo is the local harbourmaster empowered by the Spanish government’s ministry for transport to
approve service stations.
5 IMO Resolution A.761(18) as referenced in Marine Guidance Note 548 (M&F).
2
SAFETY ISSUES
Safety issues identified during the initial stages of the investigation included:

● Both of the liferafts carried by Piedras exhibited deficiencies that were sufficient to raise
concerns relating to their servicing and certification; it is likely that these deficiencies
contributed to the failure of the port liferaft to function correctly during the abandonment of
the vessel.

● There is a risk that DSB liferafts certified by the service station Comfer Marin SL in Marin,
Spain might not function correctly when deployed.

MAIB ACTIONS
The MAIB has:

● Written to Survitec and highlighted the issues identified with the liferafts carried on board
Piedras and issued recommendations 2022/129 and 2022/130, as detailed below:

2022/129 Ensure that the corrective actions identified during the audit of its authorised
service station 375, in July 2022, are verified as completed and that there is an
appropriate level of oversight to confirm that the future servicing of liferafts by
this station is rigorous and in accordance with statutory requirements.

2022/130 Take urgent action, as appropriate, to provide assurance that all liferafts
serviced by the authorised service station 375 within the past 5 years are
fully functional and comply with statutory requirements. This should include
informing all affected customers of the potential risks that their liferafts may
not be compliant and of any immediate actions required to ensure their
effectiveness.

● Written to the Comisión Permanente de Investigación de Accidentes e Incidentes Marítimos

(CIAIM)6 to advise them of concerns regarding the servicing of the liferafts on board Piedras
and the possibility that other liferafts serviced by Comfer Marin SL may be similarly affected.

● Issued this safety bulletin to inform vessel owners and operators potentially affected by the
identified issues relating to liferafts serviced by Comfer Marin SL.

● Written to the Ministerio de Transportes, Movilidad y Agenda Urbana7 to ask it to assist

Survitec in identifying vessel owners and operators that have had DSB liferafts certified by
the service station Comfer Marin SL during the period from 1 January 2017 to 30 June 2022.

6 Comisión Permanente de Investigación de Accidentes e Incidentes Marítimos – Permanent Commission for the Investigation
of Maritime Accidents and Incidents. CIAIM are the Spanish marine safety investigation authority and have similar roles and
responsibilities to that of the MAIB.
7 The Ministry of Transport, Mobility and Urban Agenda (MITMA) is the Spanish government’s ministry for transport.
3
ACTIONS TAKEN BY OTHER ORGANISATIONS
Survitec Group Limited has:

● Conducted an audit of Comfer Marin SL in July 2022 and subsequently terminated its
approval of the station to act as a Survitec liferaft servicing provider.

● Issued Survitec Alert Service Bulletin 13/22 – A LR 07 liferaft: Immediate recall of liferafts
serviced by Comfer Marin SL – dated 17 November 2022 to its approved service stations in
support of the immediate recall of the 230 liferafts that had been certified by Comfer Marin
SL over the preceding 5 years.

● Contacted the Capitanía Marítima de Vigo to advise them of the alert service bulletin and
inform them that Comfer Marin SL is no longer an approved Survitec service agent.

● Undertaken an initial investigation of the issues identified by the MAIB by inspecting a

sample of liferafts serviced in 2022 by Comfer Marin SL and rectifying the defects found.

The Ministerio de Transportes, Movilidad y Agenda Urbana has:

Confirmed, through the Capitanía Marítima de Vigo, that Comfer Marin SL is no longer
authorised to operate as a liferaft inspection/service station.

RECOMMENDATIONS
Survitec Group Limited is recommended to:

S2023/103 Distribute a copy of this safety bulletin to all vessel owners and operators that have
had Deutsche Schlauchboot GmbH liferafts certified by the service station Comfer
Marin SL during the period 1 January 2017 to 30 June 2022 and continue to take
actions to urgently address recommendation 2022/130.

All vessel owners and operators that have had DSB liferafts certified by the service
station Comfer Marin SL during the period 1 January 2017 to 30 June 2022 are
recommended to:

S2023/104M Immediately contact their nearest approved Survitec liferaft service station to
arrange for the liferafts to be urgently reinspected and serviced to ensure they are
fully functional and comply with statutory requirements.

Safety recommendations shall in no case create a presumption of blame or liability

Issued August 2023