NAVIGATION RISK ASSESSMENT - WHITSTABLE OYSTER FARM

MARINE MANAGEMENT ORGANISATION

NAVIGATION RISK ASSESSMENT - WHITSTABLE OYSTER FARM

Report Number: 19UK1572 Issue: Issue 03 Date: 25-03-2020

MARINE AND RISK CONSULTANTS LTD

Report No: 19UK1572 Issue No: 02

Commercial-in-Confidence NRA - Whitstable Oyster Farm

Marine Management Organisation i

MARINE MANAGEMENT ORGANISATION

NAVIGATION RISK ASSESSMENT - WHITSTABLE OYSTER

FARM

Prepared for: Marine Management Organisation

Lancaster House

Hampshire Court

Newcastle upon Tyne

NE4 7YJ

Author(s): i.

ii.

Authorised By:

Date Release Prepared Authorised Notes

17-Jan-2020 Draft A Draft A – Issued for Comment

07-Feb-2020 Issue 01 Issue 01

11-03-2020 Issue 02 Issue 02 – Re-issued following comment.

25-03-2020 Issue 02 Issue 03 – Re-issued following comment.

Marine and Risk Consultants Ltd

Marico Marine

Bramshaw

Lyndhurst

Hampshire

SO43 7JB

United Kingdom

Tel. + 44 (0) 2380 811133

25 March 2020



Marine Management Organisation ii

EXECUTIVE SUMMARY

This Navigation Risk Assessment has been prepared by Marine and Risk Consultants Limited on behalf

of the Marine Management Organisation to assess the navigation risk associated with the Whitstable

Oyster Fishery Company operated oyster farm.

WOFC carries out activities on the foreshore in Whitstable Bay under Article 4 of the Marine Licensing

(Exempted Activities) Order 2011, as amended in 2019. Part 3, Article 13(2)(c) sets out that the

exemption does not apply ‘to any such deposit that causes or is likely to cause obstruction or danger

to navigation’. An NRA was therefore undertaken to determine the level of risk to navigation deposits

made under the exemption may represent.

In the absence of AIS data, consultation provided the primary source of data input. Stakeholder

consultation identified the primary vessel types operating in vicinity of the oyster farm to be;

sailboards, kayaks dinghies, sailing yachts, paddle boards and jet skis; and primary concerns in relation

to navigation risk pertained to the obstruction and danger to leisure water users.

Incident data was additionally provided to supplement stakeholder feedback and inform the NRA.

Assessment of incident data revealed that the historic incident rate is low with up to 20 navigationally

significant incidents noted within the provided incident data between 2016 and 2019.

The assessment of navigation risk was undertaken in-line with International Maritime Organisation

Formal Safety Assessment methodology and updates the 2017 NRA.1. While the risk assessment

recognises that the deposits made do represent a hazard to navigation, the NRA identified that the risk

posed remains As Low As Reasonably Practicable or Low and therefore, broadly acceptable.

A review of the efficacy of mitigation measures which were recommended but largely unadopted from

the 2017 NRA was undertaken, and those that remain pertinent have been adapted and their future

adoption recommended. A number of new possible additional risk control measures were also

identified, informed by stakeholder consultation and the baseline risk assessment, aimed at further

reducing the residual risk, and efforts should also be made to adopt them, if practicable.

1 17UK1322_MCA_WhitstableOyster_NRA



Marine Management Organisation iii

CONTENTS

Executive Summary ................................................................................................................................. ii

Contents iii

Abbreviations .......................................................................................................................................... v

1 Introduction .................................................................................................................................. 1

2 Reference Documents and Guidance ........................................................................................... 2

3 Background ................................................................................................................................... 3

3.1 Whitstable .......................................................................................................................... 3

3.2 Canterbury City Council ...................................................................................................... 3

3.3 Tidal Information ................................................................................................................ 5

4 Project Description ....................................................................................................................... 6

4.1 Oyster Farming and Use of Trestles .................................................................................... 6

4.2 Whitstable Oyster Fishery Company .................................................................................. 6

5 Existing Navigation Profile .......................................................................................................... 10

5.1 Yacht and Dinghy Sailing ................................................................................................... 10

5.2 Sailboarding ...................................................................................................................... 10

5.3 Paddling Activities ............................................................................................................ 11

5.4 RNLI .................................................................................................................................. 11

5.5 Commercial Vessel Activity .............................................................................................. 11

5.6 Public Slipway ................................................................................................................... 11

6 Impact Identification .................................................................................................................. 12

6.1 Stakeholder Consultation ................................................................................................. 12

6.2 Incident Data .................................................................................................................... 22

7 Embedded Risk Controls ............................................................................................................. 24

8 Risk Assessment Methodology ................................................................................................... 25

8.1 Hazard Categories............................................................................................................. 25

8.2 Methodology .................................................................................................................... 27

9 Navigation Risk Assessment Results ........................................................................................... 30

9.1 Baseline Assessment Results ............................................................................................ 30

9.2 Possible Additional Risk Control Measures ...................................................................... 31

9.3 Residual Assessment Results ............................................................................................ 33

10 Conclusions and Recommendations ........................................................................................... 34

10.1.1 Obstruction ............................................................................................................ 34

10.1.2 Danger to Navigation ............................................................................................. 34



Marine Management Organisation iv

FIGURES

Figure 3-1: Whitstable Harbour and WOFC Trestle Area. ....................................................................... 4

Figure 4-1: Whitstable Oyster Trestle – Source: WOFC. ......................................................................... 7

Figure 4-2: Pole and Line Activity – Source: WBC ................................................................................... 7

Figure 4-3: Whitstable Oyster Layout ..................................................................................................... 8

Figure 4-4: WOFC withies / special mark. ............................................................................................... 9

Figure 4-5: Beach signage ....................................................................................................................... 9

Figure 8-1: Frequency/Consequence Chart. ......................................................................................... 28

TABLES

Table 2-1: Reference Documents ............................................................................................................ 2

Table 3-1: Example Tidal Flow Rates – 16th December 2019 - 1°21.23'N 0°55.50'E .............................. 5

Table 6-1: Stakeholder Consultation ..................................................................................................... 13

Table 6-2: Navigation Accidents (2016 to 2019). .................................................................................. 22

Table 7-1: Embedded Risk Controls ...................................................................................................... 24

Table 7-2: Possible Additional Risk Control Measures Identified in 2017 NRA .................................... 24

Table 8-1: Vessel Types Identified for Assessment ............................................................................... 25

Table 8-2: Hazard Categories. ............................................................................................................... 26

Table 8-3: Hazard Frequency Descriptors. ............................................................................................ 27

Table 8-4: Consequence Descriptors. ................................................................................................... 28

Table 8-5: Risk Matrix. .......................................................................................................................... 29

Table 9-1: Ranked Baseline Hazard Log ................................................................................................ 30

Table 9-2: Recommended Possible Additional Risk Control Measures ................................................ 31

Table 9-3: Ranked Residual Hazard Log ................................................................................................ 33

ANNEXES

Annex A Baseline Navigation Risk Assessment – Hazard Log ........................................................A-1

Annex B Residual Navigation Risk Assessment – Hazard Log........................................................B-1

Annex C Stakeholder Consultation Minutes..................................................................................C-1

Annex D Incident Data .................................................................................................................. D-1

Annex E 2017 NRA Assessed Layout.............................................................................................. E-1



Marine Management Organisation v

ABBREVIATIONS Abbreviation Detail

AIS Automatic Identification System

ALARP As Low as Reasonably Practicable

CCC Canterbury City Council

CD Chart Datum

FSA Formal Safety Assessment

HW High Water

ICW In Collision With

IMO International Maritime Organization

Kt Knot (unit of speed equal to nautical mile per hour, approximately 1.15 mph)

LW Low Water

M Metre

MACAA Marine and Coastal Access Act

Marico Marine Marine and Risk Consultants Ltd

MCA Maritime and Coastguard Agency

MEG Marine Environment Group

ML Most Likely

MMO Marine Management Organisation

Nm Nautical Mile

NRA Navigation Risk Assessment

RIB Ridged Inflatable Boat

RNLI Royal National Lifeboat Institute

RYA Royal Yachting Association

SUP Stand Up Paddle board

TH Trinity House

WBC Whitstable Beach Campaign

WC Worst Credible

WH Whitstable Harbour

WOFC Whitstable Oyster Fishery Company

WSC Herne Bay and Whitstable Water Safety Committee

WYC Whitstable Yacht Club



Marine Management Organisation 1

1 INTRODUCTION

This Navigation Risk Assessment (NRA) has been prepared by Marine and Risk Consultants Limited

(Marico Marine) on behalf of the Marine Management Organisation (MMO) to assess the navigation

risk associated with the Whitstable Oyster Fishery Company (WOFC) operated oyster farm.

WOFC carries out activities on the foreshore in Whitstable Bay under the Marine Licensing (Exempted

Activities) Order 2011, as amended in 2019, which, under Article 13, applies:

(a) to the deposit of any shellfish, trestle, raft, cage, pole, rope or line in the course of the

propagation or cultivation of shellfish;

(b) to a removal activity or dredging activity carried on for the purpose of moving shellfish within

the sea in the course of its propagation or cultivation.

The following activities, as identified within Part 3, Article 13 are not exempt under Article 4:

(a ) to any such deposit made for the purpose of disposal;

(b ) to any such deposit made for the purpose of creating, altering or maintaining an artificial reef;

or

(c ) to any such deposit that causes or is likely to cause obstruction or danger to navigation.

An NRA2 was undertaken to assess the impact of the WOFC site on safe navigation in 2017, since which

time, further deposits have been made increasing the footprint of the oyster farm considerably (Annex

E). As such, the MMO has requested Marico Marine undertake a further review to establish the change

to the navigation risk profile in light of Marine Licensing (Exempted Activities) Order 2011, Part 3,

Article 13(2)(c). This NRA, therefore, updates the 2017 NRA.

Please note, this NRA is concerned with hazards relating to navigation by vessels only and does not

consider non-navigational hazards including those related to health and safety of marine operations

such as; slips, trips and falls, or those hazards which are not directly related to navigation, except

where they can be a consequence of a navigation hazard. Any related health & safety and

environmental concerns should be separately assessed.

2 17UK1322_MCA_WhitstableOyster_NRA




2 REFERENCE DOCUMENTS AND GUIDANCE

The NRA has been conducted based on the Formal Safety Assessment (FSA)3 approach to risk

assessment utilising stakeholder/expert judgement to determine risk levels. Applicable guidance and

input data and documents that informed the assessment of risk is given within Table 2-1.

Table 2-1: Reference Documents

Document Reference Description

Guidance

IMO (2018) Revised Guidelines for

Formal Safety Assessment (FSA) MSC-

MEPC.2/Circ.12/Rev.2

IMO Formal Safety Assessment Guidance.

Marine and Coastal Access Act 2009

(MACAA)(Section 66(1))

Licensable marine activities.

Marine Licensing (Exempted Activities)

Order 2011 as amended (Article 13)

Exemption 13 of the amended order covers the deposit

and removal of any: shellfish, trestle, cage, pole, rope,

marker or line in the course of propagation and

cultivation of shellfish when certain conditions are met.

Reference / Input Documents

17UK1322_MCA_WhitstableOyster_NRA Whitstable Oyster Navigation Risk Assessment (2017)

3 IMO (2018) Revised Guidelines for Formal Safety Assessment (FSA) MSC-MEPC.2/Circ.12/Rev.2




3 BACKGROUND

3.1 WHITSTABLE

Whitstable is a small fishing harbour on the north-east Kent coast which has become a popular seaside

destination for many holiday makers and recreational water space users including; yachts, dinghies,

paddleboards, kayaks, jet skis and sailboarders, most of which are organised by local clubs or small

commercial enterprises for hire of equipment.

Several commercial vessels operate within the harbour including; aggregate vessels operating from a

dedicated berth which accepts vessels up to 95m in length once a month; fishing vessels; oyster farm

support vessels and tourist day trip vessels. There is no pilotage service into the harbour.

Along the foreshore to the east and west of the harbour, there are public and private slipways,

including a dedicated Royal National Lifeboat Institution (RNLI) facility (Figure 3-1).

3.2 CANTERBURY CITY COUNCIL

Canterbury City Council manages the foreshore from the high-water mark to 300 metres offshore,

except for the area owned and operated by the WOFC. The council has byelaws allowing them to

control vessel speed in the area they manage. A speed limit of 8 knots applies to the area marked by

yellow buoys situated 150m from the high-water mark. The Council is also responsible for the

maintenance of the public slipway and for environmental protection of the foreshore.


Report No: 19UK1572 Commercial-in-Confidence Issue No: 02 NRA - Whitstable Oyster Farm

Figure 3-1: Whitstable Harbour and WOFC Trestle Area.




3.3 TIDAL INFORMATION

Whitstable Has a tidal range of 4.8 metres with mean high-water springs of 5.17m and mean low-

water springs of 0.40m above Chart Datum (CD). The flood tidal stream has a maximum rate of

approximately 2.5 knots in a westerly direction across the foreshore and then returns in a north

easterly direction. The tidal limitations at Whitstable are such that visiting commercial ships, with the

exception of fishing vessels, must wait until high-water before any approach to the harbour is made.

The foreshore to the west of the harbour has a shallow gradient from the high-water mark and is

exposed for up to 3 hours of each tidal window with a bottom type of soft mud and shingle.

Table 3-1: Example Tidal Flow Rates – 16th December 2019 - 1°21.23'N 0°55.50'E

Time Direction Spring Rate (kt) Neap Rate (kt)

-06h - 0.0 0.0

-05h 229° 0.8 0.5

-04h 238° 1.2 0.8

-03h 237° 0.9 0.6

-02h 230° 1.1 0.7

-01h 236° 1.0 0.6

HW 050° 0.2 0.1

+01h 046° 1.1 0.7

+02h 041° 1.5 1.0

+03h 033° 1.3 0.8

+04h 027° 0.8 0.5

+05h 024° 0.4 0.3

+06h 020° 0.1 0.1




4 PROJECT DESCRIPTION

4.1 OYSTER FARMING AND USE OF TRESTLES

Traditional methods of oyster farming involved oyster spat being sown on the foreshore and then

dredged by boat once the oysters matured. Modern and commonly adopted methods of oyster

farming involve trestles placed intertidally (to provide periodic wetting and drying) which are used to

hold mesh bags in which the oysters are grown. Trestle designs vary depending on location and are

generally fabricated from timber or steel. The mesh bags commonly remain in place under their own

weight or are secured to the trestles by rubber banding or lashing where local hydrodynamics and/or

wave conditions are more onerous.

The spat is left to grow with the bags being periodically rotated and oysters re-sorted into the bags of

larger mesh size until they have matured to a suitable size whereupon the oysters are cleaned and

prepared for sale. The duration of taking a seeded oyster to full marketable size takes approximately

three years.

4.2 WHITSTABLE OYSTER FISHERY COMPANY

In addition to activities at Seasalter and Faversham (approximately 3 nm from Whitstable), WOFC

owns the foreshore land at Whitstable with oyster trestles first placed on the foreshore in 2009. WOFC

cultivates Crassostrea gigas, or ‘Rock Oysters’, a non-native European oyster species on the trestles

which are accessed by quad bike or boat, depending upon the tide.

WOFC imports prefabricated steel re-bar trestles from France to a specified design. The trestles are

0.75m in height, approximately 1m long and 0.5m wide and arranged in rows anchored to the

foreshore as shown in Figure 4-1. Due to bags moving in strong north-easterly conditions, vertical steel

rods which extend approximately 0.2m above the trestle surface have been utilised to retain the mesh

bags in situ with rubber banding and strapping. It is noted that following completion of the 2017 NRA,

the steel rods have been bent over at the top to lessen the consequence of a contact to both people

and vessels (Section 7).

Since 2015, and since the previous NRA was undertaken WOFC has increased the quantity of trestles

on the foreshore to approximately 1,500 trestles.




Figure 4-1: Whitstable Oyster Trestle – Source: WOFC. Since undertaking the 2017 NRA, WOFC has also additionally adopted a pole and line cultivation

method, an approach that combines wooden posts with lines and cages. This suspension cultivation

method, is located to the north of the site and as of September 2019 was comprised of four sets of four

rows occupying an area of approximately 36 x 125m (Figure 4-3). The wooden posts are submerged

beneath the surface and protrude higher than the trestles at a height of approximately 1.5m.

Figure 4-2: Pole and Line Activity – Source: WBC



Figure 4-3: Whitstable Oyster Layout




The trestle array is currently marked by withy navigation markers (vertical sticks) which have been

placed at the corner of each trestle block Figure 4-4. It is noted that the withies become submerged

at high tide and are therefore not always visible. Unlit special marks (Figure 4-4) have additionally

been placed around the trestle array as displayed in Figure 4-3.

Figure 4-4: WOFC withies / special mark.

WOFC has installed signs on the foreshore at Whitstable on groynes and public notice boards warning

of the presence of the Oyster Farm. It is noted, however, that signage pertains to the earlier assessed

layout and has not been updated to reflect subsequent layout changes.

Figure 4-5: Beach signage




5 EXISTING NAVIGATION PROFILE

Stakeholder consultation (Table 6-1) identified that the primary vessel types operating in the vicinity

of the oyster farm are: sailboards, kayaks dinghies, sailing yachts, paddle boards and jet skis. Further

information regarding navigation uses of the area is detailed in Sections 5.1 to 5.5.

5.1 YACHT AND DINGHY SAILING

WYC is based 100m from the West Quay of Whitstable Harbour. The club has an active membership

of approximately 600 and is also a Royal Yachting Association (RYA) Training Centre. The yacht club is

home to approximately 200 sailing dinghies, catamarans (stored ashore) and yachts which are moored

in the nearby drying marina. Sailing vessels are launched from the foreshore and the WYC slipway at

all states of tide and either sail within the corridor bounded by the harbour wall and trestles or proceed

through this corridor to more open water (Figure 3-1).

Organised sailing occurs from mid-March to mid-December, with racing taking place every weekend

and every other Wednesday throughout. In the winter the yacht club would expect an average of 20

boats participating in each event, whereas in the summer this level can rise to 60 boats with WYC

hosting events attended by visitors. The training school teaches children and adult novices to sail on a

regular basis with approximately 15 sailing boats with three or four support / safety boats per training

session.

Sailing activity commences from the slipway at most states of the tide, with the safety boats only able

to launch until approximately 90 minutes before low-water. Neither the yacht club nor Whitstable

Harbour have mooring facilities for visiting yachts and any visitor will normally anchor offshore and

access the beach by tender. Due to the shallow nature of the foreshore larger yachts would not be

expected to visit Whitstable.

5.2 SAILBOARDING

WYC has a proportion of members involved in sailboarding. The club also informed during the

consultation process that there are many locals and visitors to the area who are not members of the

club that are also engaged in sailboarding. Sailboarders prefer to sail along the fore shore fairly close

to land in case they get into trouble.




5.3 PADDLING ACTIVITIES

Paddling occurs year-round and includes: kayaks and Sand-Up-Paddleboards (SUPs). Due to the nature

of the craft type, users tend to remain close to the shoreline in shallow water. Storage facilities are

provided by WYC for kayaks, sail boards and other water sports equipment.

5.4 RNLI

The RNLI is based in a purpose-built structure close to the West Quay at Whitstable Harbour. The

lifeboat is a B-class Atlantic 85 Rigid Inflatable Boat (RIB) which has a draft of 0.53m and is launched

by a tractor and trailer using the slipway. The station receives approximately 50 callouts per year,

normally to distressed fishing vessels further offshore or to assist members of the public in difficulty

on the beach on the eastern side of the harbour.

5.5 COMMERCIAL VESSEL ACTIVITY

Due to the depth of water the harbour has limited commercial activity with maximum length and

draught restrictions of 90m and 4.3m respectively. There is a fishing fleet of approximately 16 vessels

based at Whitstable with fishing activity located away from the harbour at the nearby North Kent

windfarms. Commercial shipping activity is limited with one working berth inside the harbour for a

vessel importing aggregate approximately 30 times a year. It is also noted that the Waverley paddle

steamer visits up to three times annually. No commercial vessel activity is experienced to the west of

the harbour.

5.6 PUBLIC SLIPWAY

The public slipway is used by visitors, predominantly in the summer season, for most vessel types

except sailboarders who prefer the beach to access the water.




6 IMPACT IDENTIFICATION

6.1 STAKEHOLDER CONSULTATION

To establish the impact of the trestles on water space users an understanding of floating craft activity

in the area, a site visit including consultation with local stakeholders was undertaken between

Wednesday 9 and Thursday 10 October 2019. In the absence of Automatic Identification System

(AIS) data, consultation provided the primary source of data input to the NRA.

Table 6-1 provides the list of consultees that participated in stakeholder consultation and the primary

key impacts identified.

Full consultation minutes are listed in Annex C.




Table 6-1: Stakeholder Consultation.

Organisation Key Comments / Navigation Concerns

NRA Response NRA Reference

Local

Whitstable Harbour (WH)

• WH is aware that a sail-boarder has been hurt on the trestles.

• Incident data received from Whitstable Beach campaign.

Annex D

Section 6.2

• Consultees asked to advise on historic incident rates. Annex C

Section 6.2

• Risk of craft unable to manoeuvre properly being set onto trestles damaging the craft and injuring persons. Persons could also get trapped under the trestles.

• Risk of loss of life considered in the assessment of consequence in the worst-case scenario in accordance with IMO FSA methodology.

Annex A

Table 8-4

• Damage to property considered in the assessment of consequence in accordance with IMO FSA methodology.

Annex A

Table 8-4

• Spikes on top of the trestles have been bent over which could cause an entrapment issue.


Annex A

Table 8-4

• Removal of vertical steel rods included as a possible additional mitigation measure to lower the consequence to human life should they contact the trestles.

Annex A

Annex B

• Some yellow buoys indicating an 8-knot speed (council by law) limit have been removed by WOFC and not replaced.

• WOFC advised that 8-knot speed limit buoys were removed as the line ran through the middle of the farm and as it was considered they might attract water users to the site increasing risk.

Annex C






• WOFC recommended to seek advice from THLS with

regard to replacement

Table 9-2

• Contact with navigation buoys assessed independently.

Annex A

Canterbury City Council (CCC)

• Between HW and LW trestles are not clearly visible.

• Review of marking and lighting recommended as a possible additional risk control measure.

Table 9-2

Annex A

Annex B

• Risk of craft unable to manoeuvre properly being set onto the oyster farm trestles.

• Hazard of contact with trestles and pole and line activity, including as a result of mechanical failure or poor weather, assessed for all vessel types.

Annex A

Table 8-2

• Some yellow buoys indicating an 8-knot speed (council by law) limit have been removed by WOFC and not replaced.

• WOFC advised that 8-knot speed limit buoys were removed as that line ran through the middle of the farm and as it was considered they might attract water users to the sight increasing risk.

Annex C

• WOFC recommended to seek advice from THLS with regard to replacement

Table 9-2


Annex A

• Water users now operate closer to each other.

• Collision hazards assessed for all vessel types.

Annex A

Table 8-2






• In the past the Oyster company had worked with the council to manage the area and employed a public relations officer, however, that has stopped recently.

• Promulgation of information included as a

recommended possible additional risk control measure.

Table 9-2

Whitstable Yacht Club (WYC)

• Dinghy’s, sailboarders, paddle

boarders, kayaks, swimmers, jet- skis, and yachts operated by club members of all abilities.

• All reported active vessel types assessed for each identified hazard category.

Table 8-1

Table 8-2

• Non-navigational activities are outside of the scope of this NRA. Health & safety and environmental concerns should be separately assessed.

-

• Sailboarders have to go a long way offshore to practise their activities forcing them to operate in rougher sea conditions.

• Hazard of sinking / capsize assessed for all vessel types. Annex A

Table 8-2 • Noted that sailboarders could choose to launch east or west of site

• Vessels offshore cannot take a straight line back to the beach in an emergency sailing around the oyster farm can be almost a mile.

• Hazard of sinking / capsize assessed for all vessel types. It is noted that even in worst case scenario, detour is considerably less than one mile, but hazard acknowledged and assessed as above.

Annex A

Table 8-2

• Activities are closer to each other due to reduced available space.

• Collision hazards assessed for all vessel types.

Annex A

Table 8-2






• At LW there is a risk that the craft involved in club activities could get set onto the trestles damaging craft and potentially injuring persons. Persons could also get trapped under the trestles.


Annex A

Table 8-2


Annex A

Table 8-4


Annex A

Table 8-4

• Also noted that at low- water most of the site dries out, so hazard frequency greatly limited by tidal conditions.

Section 3.3

• Yellow buoys indicating 8-knot speed limit have been removed and not replaced.

• WOFC advised that 8-knot speed limit buoys were removed as that line ran through the middle of the farm and as it was considered they might attract water users to the sight increasing risk. WOFC will replace these if required.

Annex C

• Contact with navigation buoys assessed independently. Annex A

Whitstable Beach Campaign (WBC)

• No life-saving equipment on the beach or signs warning of the danger of the oyster farm.

• Promulgation of information, which includes ensuring signs and notices relating to the site are properly maintained and updated, included as a recommended possible additional risk control measure.

Table 9-2






• Yellow buoys indicating 8-knot speed limit have been removed and not replaced.

• WOFC advised that 8-knot speed limit buoys were removed as that line ran through the middle of the farm and as it was considered they might attract water users to the sight increasing risk.

Annex C

Table 9-2 • WOFC will replace these if required. recommended to

seek advice from THLS with regard to replacement


Annex A

• Withies do not show at all states of tide.

• Review of marking and lighting in consultation with Trinity House, which includes the recommendation of permanent beacons at the seaward end of the site included as a recommended possible additional risk control measure.

Table 9-2

Annex A

Annex B

• Risk of vessels drifting into oyster farm and potential for entrapment under trestles.


Annex A

Table 8-4


Annex A

Table 8-4

• Leisure users operate closer together due to a reduction in available sea-room.

• Collision hazard assessed for all vessel types.

Annex A

Table 8-2






• Metal spikes have been bent

over, rather than removed.

• Removal of vertical steel rods included as a possible additional mitigation measure to lower the consequence to human life should they contact the trestles.

Table 9-2

Annex A

• No public consultation occurred prior to expansion and instalment of new trestle design (pole and line activity).


Annex A

Table 8-2

Marine Environment Group (MEG)

• The Withies used to mark the trestles cannot be seen at HW.

• Review of marking and lighting included as a recommended possible additional risk control measure.

Annex A

Annex B

• Mostly Kayaks, swimmers and walkers (at low-water) that collide with the trestles.

• Kayaks (and other non-powered recreational activity) have been assessed independently.

Table 8-1

• Non-navigational activities are outside of the scope of this NRA. Health & safety and environmental concerns should be separately assessed.

-

National

Maritime and Coastguard Agency (MCA)

• The site has grown significantly (perhaps four-fold) since the previous NRA, including a further extension offshore.

• Restrict Further Expansions to the north-east included as a recommended possible additional risk control measure.

• Review of Marking and Lighting included as a recommended possible additional risk control measure within which it is recommended that changes to the layout and subsequently buoyed area should be carried

Table 9-2






out following consultation with Trinity House and other appropriate stakeholders.

• The local yacht club runs dinghy

races and utilises nearby areas for training. Race areas should be confirmed with WYC.

• Whitstable Yacht Club included as consultee.

Table 6-1

Annex C

• Further information pertaining to WYC race areas requested.

Annex C

• Access to slipways in event of an emergency for recreational users.

• Recreational slipways are all clear of the WOFC site. Figure 3-1

• Emergency Response Plan drafted in consultation with the RNLI.

Table 9-2

• The potential for continued

expansions into the future.

• Restrict Further Expansions to the north-east included as a recommended possible additional risk control measure.

Table 9-2

• Changes to the layout and subsequently buoyed area should be carried out following consultation with Trinity House and other appropriate stakeholders included as a recommended possible additional risk control measure.

Table 9-2

• The presence of multiple cultivation methods and the risk posed by the new pole and line structure.

• Remove Pole and Line Activity included as a


Table 9-2

• Maintaining SAR access to the site.

• Emergency Response Plan drafted in consultation with the RNLI.

Table 9-2






Trinity House (TH)

• Promulgation of the correct maritime safety information and charting would have been stipulated [if formal licence application was required].

• Promulgation of existing information has been included as a recommended possible additional risk control measure.

Annex A

Annex B

• Charting of the site and buoyage has been included as a recommended possible additional risk control measure.

Table 9-2

Annex A

Annex B

• Only the area with trestles should be marked by buoyage, not the full site and the ends of the trestles within the main area identified by withies or smaller pellet type buoys.

• Review of marking and lighting included as a


Annex A

Annex B

• Seaward end of trestles should

be marked with permanent beacon rather than withies.

• Review of marking and lighting included as a recommended possible additional risk control measure.

Table 9-2

Annex A

Annex B

• UKHO should be notified of the

area of the fishery and the position of the buoyage.

• Charting of the site and buoyage included as a recommended possible additional risk control measure.

Table 9-2

Annex A

Annex B






• Marking of the proposed additional site has not yet been confirmed. Trinity House has tried to correspond with WOFC but not had a response. Any future changes to the buoyed area should only be carried out following consultation with Trinity House and other appropriate stakeholders.

• Review of marking and lighting, which includes the

need for changes to the buoyed area to be agreed in consultation with Trinity House, included as a recommended possible additional risk control measure.

Table 9-2

Annex A

Annex B

• No incidents have been reported to Trinity House directly.

• Incident data received from Whitstable Beach campaign.

Annex D

Section 6.2

• Consultees asked to advise on historic incident rates.

Annex C

Section 6.2




6.2 INCIDENT DATA

Marico Marine requested information about incidents that have occurred in vicinity of the trestles to

inform the identification of impacts. The RNLI and Maritime and Coastguard agency had no incident

data for the oyster farm area.

Some information was provided by WBC and Herne Bay and Whitstable Water Safety Committee

(WSC) which is listed within Annex D. Much of the feedback provided includes witness accounts of

near-misses and failures to observe the buoyed area denoting the hazard. Accounts of actual incidents

leading to damage / injury / physical contact were additionally received. Table 6-2 highlights

navigationally significant incidents that were reported to have occurred between 2016 and 2019.

Table 6-2: Navigation Accidents (2016 to 2019)4.

Item Year Incident Type Vessel Type WOC Structure

Source: WBC

1 2016 Contact Barge under tow Trestles

2 2017 Contact Recreational Marker Buoy

3 2017 Contact Yacht Trestles


5 2017 Power Failure Power Boat Trestles

6 2017 Capsize Yacht Outside of Buoyed Area

Source: WBC – Comments submitted to Secretary of State

7 2018 Contact / Capsize Yacht Trestles

8 2018? Contact Sailboarder Trestles

9 2018 Contact Sailboarder Trestles

10 2019 Contact Sailboarder Trestles


4 Please note, due to lack of detailed incident data which was obtained from differing sources, there is potential for duplication. Incidents

identified within Table: 6-2, therefore, serve as an indication of the types and frequency of incidents rather than an absolute representation

of the incident profile.




Item Year Incident Type Vessel Type WOC Structure

Source: WSC

12 Unknown Contact Recreational Trestles

13 Unknown Contact Yacht Trestles




17 Unknown Contact Recreational (unknown) Trestles

18 Unknown Contact Recreational (unknown) Trestles

19 Unknown Contact Barge under tow Trestles

20 Unknown Contact Barge under tow Trestles




7 EMBEDDED RISK CONTROLS

Embedded risk controls are those assumed to be in place in the baseline NRA. Embedded risk controls

that apply to the baseline NRA are identified within Table 7-1.

Table 7-1: Embedded Risk Controls

Number Risk Control Risk Control effect

1

Redesign

It is noted that following completion of the 2017 NRA, the steel rods have been bent at top to lessen the consequence of a contact to both people and vessels.

A number of risk controls were recommended within the 2017 NRA, however, were largely not

implemented, or have fallen into abeyance. Table 7-2 summarises the measures that were proposed

in the 2017 NRA and their implementation status.

Table 7-2: Possible Additional Risk Control Measures Identified in 2017 NRA

ID Measure Description Status

1

Redesign

Remove the vertical steel rods from the trestles

Not fully implemented – steel rods bent at top.

2

Relocate Buoyage

Move the special marker buoys closer to the hazard

Not fully implemented – buoys to the west do not mark the western boundary. It has been reported that buoys to the south west were removed and not replaced.

3

Inform users

Inform all local users of the trestle locations

Not fully implemented - • Signage installed however, not

maintained (Figure 4-5)

• Consultation indicates local representatives including CCC were not consulted prior to expansion.

• Site extent and buoyage un-charted.

4

Train rescue craft Provide training opportunities to the RNLI

Not implemented

5

Mark the area Use higher withies to mark the extent of each trestle row

Not implemented – rejected due to tendency for withies to bend in stronger currents and become submerged.




8 RISK ASSESSMENT METHODOLOGY

8.1 HAZARD CATEGORIES

Following the identification of key vessel types in Section 5, vessels were grouped into four main

vessel categories for the purpose of risk assessment as detailed within Table 8-1.

Table 8-1: Vessel Types Identified for Assessment

Vessel Group Example Vessel and activity types

Small Recreational vessel Kayak, SUP, sailboarding, Kite surfing

Small Sailing vessel Sailing dinghy, yacht

Small Powered vessel RHIBs, small powered pleasure craft, jet ski, RNLI, workboats

Commercial vessel Aggregate barge, general cargo vessel, fishing vessels, tugs

Vessel categories were then combined with key navigation hazard categories to establish a list of

individual hazards for assessment. In total, 18 individual hazards were identified as described in Table

8-2.




Table 8-2: Hazard Categories.

Hazard Cat ID

Hazard Category

Hazard Detail Hazard Ref

Vessels Assessed

1

Contact

Trestles

1 Small recreational vessel

2 Small sailing vessel

3 Small powered craft

4 Small commercial craft

Pole and Line Structure





Buoy





2

Collision

13 Recreational vessel ICW Recreational vessel

14 Recreational vessel ICW Commercial vessel

15 Commercial vessel ICW Commercial vessel

3

Grounding

16 Recreational vessel

17 Commercial vessel

4 Sinking / Capsize 18 Recreational Vessel




8.2 METHODOLOGY

The Marico Marine developed risk assessment tool, Hazman II, has been utilised to undertake the NRA

based on the Formal Safety Assessment methodology as adopted by the International Maritime

Organization (IMO).

IMO guidelines define a hazard as “something with the potential to cause harm, loss or injury, the

realisation of which results in an accident.” The potential for a hazard to be realised (frequency, Table

8-3) can be combined with an estimate or known outcome (consequence, Table 8-4) to establish the

risk. Risk can, therefore, be assessed using a frequency and consequence matrix (Figure 8-1).

The definitions of frequency and consequence have been adapted to be relevant to the local

conditions and users.

Table 8-3: Hazard Frequency Descriptors.

Scale Description Definition Operational Interpretation

F5

Frequent

An event occurring in the range once a week to once a month

One or more times in 1 month

F4

Likely

An event occurring in the range once a month to once every 6 months

One or more times in 6 months

F3

Possible

An event occurring in the range once every 6 months to once a year

One or more times in 1 year

F2

Unlikely

An event occurring in the range once a year to once in 5 years

One or more times in 5 years

F1

Remote

Considered to occur less than once in 10 years

Less than once in 10 years

Consequence was assessed considering three navigationally significant categories (Table 8-4):

• People – Including personal injury and fatalities;

• Property – including cosmetic damage, unavailability and loss of vessel; and

• Reputation – Including public concern and publicity.




Table 8-4: Consequence Descriptors.

Cat People Property Reputation

1

No injuries Cosmetic damage to property – activity can continue

No adverse publicity

2

Minor bruising, cuts and abrasion requiring first aid

Damage to property resulting in minor repairs and temporary unavailability

Local public awareness but no discernible concern No media coverage

3

Major bruising, cuts / abrasion, or fracture requiring treatment

Damage to property resulting in repairs and prolonged unavailability

Local public concern, local media coverage

4

Multiple injuries / single fatality

Damage to property resulting in major repairs and extended unavailability

Regional public concern, Local stakeholder concern Extensive adverse attention in local media

5

Multiple fatalities

Complete loss requiring replacement

National public concern Impacts on regional and national stakeholder relationships

Each risk assessment is scored twice considering both the most likely and worst credible outcomes

and then combined using a weighted average to produce a single numeric value representing the final

risk score between 0 (Negligible) and 10 (High) for each hazard (Table 8-5).

At the low end of the scale, frequency is extremely remote, consequence insignificant and risk can be

said to be negligible (or broadly acceptable). At the high end, where hazards are defined as frequent

and the consequence catastrophic, then risk is termed intolerable. Between the two is an area defined

As Low As Reasonably Practicable (ALARP).

Figure 8-1: Frequency/Consequence Chart.




ALARP can be defined as a level of risk which is tolerable or acceptable because the reduction of the

risk is impracticable, or the cost of such reduction would disproportionate to the improvement gained.

If, however, mitigation measures can be identified which would significantly reduce the risk posed by

hazards within the ALARP band and those mitigations are reasonable given the development and

implementation costs; efforts should be made to ensure their implementation.

Table 8-5: Risk Matrix.

Matrix Outcome

Risk Definition Action Taken

0 & 1 Negligible Risk A level where operational safety is unaffected.

2 & 3 Low risk A level where operational safety is assumed.

4 ,5 and 6

As Low As Reasonably Practicable (ALARP)

A level defined by study at which risk control in place is reviewed. Tolerable if reduction of the risk is impracticable.

7 & 8

Significant Risk

A level where existing risk control is automatically reviewed, and suggestions made where additional risk control could be applied if appropriate. New risk controls identified should be introduced in a timescale of two years.

9 & 10 High Risk A level requiring immediate mitigation.




9 NAVIGATION RISK ASSESSMENT RESULTS

9.1 BASELINE ASSESSMENT RESULTS

The hazards identified in Table 8-2 were assessed in-line with the methodology detailed in Sections

8.1 and 8.2. The baseline assessment assumes the implementation of all embedded risk control

measures identified within Table 7-1. A ranked summary of the risk assessment results is given in Table

9-1. Full hazard logs are detailed in Annex A.

All hazards assessed within the baseline assessment were assessed to be ALARP or lower, with 6

individual hazards scored as ALARP, with the highest scoring hazard assessed to be: Small Recreational

Vessel Contacts Trestle: 5.24.

Table 9-1: Ranked Baseline Hazard Log.

ID

Category

Hazard Title

Score

1 Contact Small recreational vessel contacts trestle 5.24

2 Contact Small sailing vessel contacts trestle 4.93

3 Contact Small powered craft contacts trestle 4.93

6 Contact Small sailing vessel contacts pole and line structure 4.26

7 Contact Small powered craft contacts pole and line structure 4.26

14 Collision Collision - recreational ICW commercial 4.07

18 Sinking / Capsize Sinking / capsize - recreational craft 3.95

11 Contact Small powered craft contacts buoy 3.82

10 Contact Small sailing vessel contacts buoy 3.59

13 Collision Collision recreational ICW recreational 3.51

5 Contact Small recreational vessel contacts pole and line structure 3.49

9 Contact Small recreational vessel contacts buoy 3.00

15 Collision Collision - commercial ICW commercial 2.64

4 Contact Small commercial craft contacts trestle 2.39

8 Contact Small commercial craft contacts pole and line structure 2.39

16 Grounding Grounding - recreational craft 1.88

17 Grounding Grounding commercial vessel 0.92

12 Contact Small commercial craft contacts buoy 0.74




9.2 POSSIBLE ADDITIONAL RISK CONTROL MEASURES

A number of possible additional risk control measures have been identified aimed at further reducing

the residual risk informed by stakeholder consultation and the baseline risk assessment.

Table 9-2 provides a description of each of the proposed possible additional mitigation measures. The

individual hazards to which each measure applies is indicated within Annex A. While all hazards have

been assessed to be ALARP or lower, it is recommended that consideration is given to their

implementation with a view to further reducing risk.

It is noted that the majority of measures recommended within the 2017 NRA were not adopted (or

maintained) (Table 7-2). A review of their efficacy given the 2019 WOFC oyster bed footprint and

activities was undertaken and any continued recommendations for their implementation have been

made in Table 9-2.

It is important to note that some of the risk control measures recommended may require a marine

licence. Further, recommendations are made from a navigation risk perspective only and do not take

into account broader considerations that may need to be applied by the MMO in the event a marine

licence is required. Advice about marine licence requirements should be sought from the MMO.




Table 9-2: Recommended Possible Additional Risk Control Measures ID Risk Control Control Description Risk Control effect

Adapted from 2017 NRA Recommendations

1

Review of Marking and Lighting

Special marker buoys to mark trestles and poles (hazard) only, as opposed to the full site.

To increase visibility and reduce the likelihood of contact with farm infrastructure by recreational craft. To increase water space reducing the likelihood of collisions and increasing the sailing area for WYC.

Seaward end of trestles marked with permanent beacon rather than withies.

Changes to the layout and subsequently buoyed area should be carried out following consultation with Trinity House and other appropriate stakeholders.

To ensure the marking and lighting continues to be fit for purpose and in-line with appropriate regulations. To ensure stakeholders remain informed of any changes to reduce risk of contact.

Review removal of 8 knot speed limit buoys in consultation with Trinity House.

2 Chart Area

Mark site and buoyage on navigational chart. Inform UKHO of any changes to layout.

To ensure marine users remain aware of the oyster farm location and layout to reduce risk of contact and collision.

3 Promulgation

Inform all local users of changes to the site footprint, trestle locations, buoyage and new activities.

To ensure marine users remain aware of the oyster farm location and layout to reduce risk of contact and collision. Ensure signs and notices relating to the site

are properly maintained and updated.

Additional 2019 NRA Recommendation

4 Remove Pole and Line Activity

Remove new pole and line activity to the north of the site.

To reduce risk of contact caused by the presence of differing cultivation methods. The pole and line structures reduce the available under keel clearance to a greater extent than the trestles.

5 Incident Reporting

Introduce a process for formal incident reporting and logging.

To ensure proper records are kept to determine any change in incident profile.

6 Restrict Further Expansions to the north-east

Restrict further expansions to the north-east of the site.

To not impede on the sailing area and access to public slipways to the east.

7 Emergency Response Plan

Emergency Response Plan drafted in consultation with the RNLI.

To ensure that search and rescue capabilities are maintained.




9.3 RESIDUAL ASSESSMENT RESULTS

The baseline assessment has been reassessed assuming the implementation of all proposed possible

additional risk control measures identified within Table 9-2 to establish the residual risk profile.

A ranked summary of the risk assessment results is given in Table 9-3. Full hazard logs are detailed in

Annex B.

Two hazards remain in the ALARP category in the residual assessment with the highest scoring

individual hazard assessed to be: Small Recreational Vessel Contacts Trestle: 4.16, with this hazard

showing a reduction in risk score of 1.08.

The greatest reduction in risk score is noted for pole and line contact hazards, where the removal of

the structure has eliminated the risk.

Table 9-3: Ranked Residual Hazard Log.

ID

Category

Hazard Title

Risk Score


3 Contact Small sailing vessel contacts trestle 4.16

1 Contact Small powered craft contacts trestle 3.91


14 Contact Small powered craft contacts buoy 3.78

10 Collision Collision - Recreational with Commercial 3.59

17 Contact Small sailing vessel contacts buoy 3.48

9 Sinking / Capsize Sinking / Capsize - Recreational Craft 3.00

15 Contact Small recreational vessel contacts buoy 2.64

13 Collision Collision - Commercial with Commercial 2.62

4 Collision Collision Recreational with Recreational 2.28

15 Contact Small commercial craft contacts trestle 1.88

12 Grounding Grounding - Recreational Craft 0.74

16 Contact Small commercial craft contacts buoy 0.74

6 Grounding Grounding Commercial vessel 0.00

7 Contact Small sailing vessel contacts pole and line structure 0.00

5 Contact Small powered craft contacts pole and line structure 0.00

8 Contact Small recreational vessel contacts pole and line structure 0.00




10 CONCLUSIONS AND RECOMMENDATIONS

Since 2015, and since the previous 2017 NRA was undertaken WOFC has increased the quantity of

trestles on the foreshore to approximately 1,500 trestles and introduced a new pole and line

cultivation method. The 2017 NRA recommendations were largely unadopted or not maintained

(Table 7-2). For example, WOFC installed signs on groynes and put up public notice boards (Figure 4-

5), however, these signs are either out of date and therefore; not fit for purpose, or have since been

removed.

Concern was raised from the local stakeholder groups (Table 6-1) that the Oyster farm poses both an

obstruction and a danger to leisure water users. Primary concerns centred around passage being

impeded or prevented by the farms existence (obstruction) and the risk of entrapment, injury or

damage (danger to navigation) should a vessel be set-on to the farm.

10.1.1 Obstruction

In the absence of formal legislation regarding the enforcement of ‘exclusion zones’, public right of

access is maintained unless local authority byelaws state that an exclusion zone is in enforcement. As

such, at tidal states that allow for navigation to continue, it is up to an individual mariner’s judgement

to determine whether to proceed. In this case, measures should be taken by WOFC to ensure that the

hazard is properly marked (see Table 9-2, Item 1) and that users are well informed of the potential

risk (Table 9-2, Item 2 and Item 3).

10.1.2 Danger to Navigation

While it is recognised that the oyster farm does represent a hazard to navigation, the NRA has

identified that the risk posed by the presence of the oyster farm remains ALARP or lower (broadly

acceptable). Full implementation of additional practicable mitigation measures has been

demonstrated to reduce risk still further and efforts should therefore be made for their adoption, if

possible.

Available data reveals that historic incident rates are low with up to 20 navigationally significant

incidents noted within the provided incident data between 2016 and 2019, of which the majority

resulted in minor injuries and minor repairs / temporary vessel unavailability. It is noted that due to

lack of detailed incident data and multiple data sources, there is also potential for duplications and

omissions. Incidents identified within Table 6-2, therefore, serve as an indication of the types and




frequency of incidents rather than an absolute representation of the incident profile. It is

recommended that procedures are implemented for more effective incident reporting to ensure

accurate records are maintained going forwards (Table 9-2, Item 5). It was reported by the RNLI in the

2017 NRA that there was no history no callouts to the oyster farm. However, it is recommended that

an Emergency Response Plan is drafted in consultation with the RNLI to ensure search and rescue

capabilities is maintained in the event of an incident within the trestle area (Table 9-2, Item 7).

It is considered that the removal of the new pole and line activity (Table 9-2, Item 4) would contribute

the most significant reduction to navigation risk, without preventing the WOFC’s ability to operate.

Additionally, restrictions on further expansions to the north-east will help mitigate against an

increased danger to navigation for recreational vessels resulting from the restriction of the existing

sailing area and access to slipways (Table 9-2, Item 6).

Additional comments were noted during the consultation process relating to non-navigational

activities, such as health and safety (swimming) and environmental impacts. These are outside of the

scope of this NRA. Further assessment should be undertaken to assess these hazards if required



Marine Management Organisation A-1

Annex A Baseline Navigation Risk Assessment – Hazard

Log




ID

Category

Hazard Title

Hazard Detail

Possible Causes

Most Likely Outcome

Worst Credible Outcome

Most Likely Consequence

Worst Credible Consequence

R

isk

Sco

re

Possible Additional Risk Controls

Peo

ple

Pro

per

ty

Bu

sin

ess

Freq

uen

cy

Peo

ple

Pro

per

ty

Bu

sin

ess

Freq

uen

cy

1

Co

nta

ct

Small recreational vessel contacts trestle

SUP, Kayak, inflatable dinghy, sailboarder/ kite surfer makes contact with partially submerged / submerged trestle.

Severe weather; inattention; poor local knowledge; no warning of trestle placement; trestles poorly marked; change of trestle position; equipment failure.

First-aid; Minor repairs and temporary unavailability; Local public awareness, no media coverage.

Multiple injuries or fatality; Prolonged unavailability; National publicity.

2

2

2

5.0

4

3

5

1.0

5.24

1 : Review Marking and Lighting 3 : Promulgation 5 : Incident Reporting 6 : Restrict Further Expansions to the North- East 7 : Emergency Response Plan

2

Co

nta

ct

Small sailing vessel contacts trestle

Small yacht makes contact with partially submerged / submerged trestle

Severe weather; inattention; poor local knowledge; no warning of trestle placement; trestles poorly marked; change of trestle position; machinery failure; equipment failure; poor event management

Minor injury requiring treatment; Minor repairs and temporary unavailability; Local public awareness, no media coverage.

Multiple injuries or fatality; Extended unavailability; National publicity.

3

2

2

4.0

4

4

5

1.0

4.93

1 : Review Marking and Lighting 2 : Chart Area 3 : Promulgation 5 : Incident Reporting 6 : Restrict Further Expansions to the North- East 7 : Emergency Response Plan

3

Co

nta

ct

Small powered craft contacts trestle

Small rib, leisure user, Jet ski, RNLI, makes contact with partially submerged / submerged trestle


First-aid; Minor repairs and temporary unavailability; Local publicity.


2

2

3

4.0

4

4

5

1.0

4.93


4

Co

nta

ct

Small commercial craft

contacts trestle

Small commercial vessel makes contact with partially submerged / submerged trestle

Severe weather; inattention; poor local knowledge; no warning of trestle placement; trestles poorly marked; change of trestle position; machinery failure; equipment failure;

No injuries; Cosmetic damage; Local media coverage.

Minor injury requiring treatment; Prolonged unavailability; Local media coverage.

1

1

3

1.0

3

3

3

1.0

2.39

1 : Review Marking and Lighting 2 : Chart Area 3 : Promulgation 5 : Incident Reporting 7 : Emergency Response Plan

5

Co

nta

ct

Small recreational vessel

contacts pole and line structure


Severe weather; inattention; poor local knowledge; no warning of placement or structure/ new activity; structure not marked; machinery failure; equipment failure;



2

2

2

3.0

4

3

5

1.0

3.49

4 : Remove pole and line activity




ID

Category

Hazard Title

Hazard Detail

Possible Causes

Most Likely Outcome




R

isk

Sco

re


Peo

ple

Pro

per

ty

Bu

sin

ess

Freq

uen

cy

Peo

ple

Pro

per

ty

Bu

sin

ess

Freq

uen

cy

6

Co

nta

ct

Small sailing vessel contacts

pole and line structure

Small yacht makes contact with pole and line structure.




3

2

2

3.0

4

4

5

1.0

4.26


7

Co

nta

ct

Small powered craft contacts pole and line

structure

Small rib, leisure user, Jet ski, RNLI, makes contact with pole and line structure.




2

2

3

3.0

4

4

5

1.0

4.26


8

Co

nta

ct

Small commercial craft contacts pole and line

structure

Small commercial pilot / workboat makes contact with pole and line structure.


No injuries; Cosmetic damage; Local publicity.


1

1

3

1.0

3

3

3

1.0

2.39


9

Co

nta

ct

Small recreational vessel

contacts buoy

SUP, Kayak, inflatable dinghy, sailboarder/ kite surfer makes contact with buoy.

Severe weather; inattention; poor local knowledge; change of buoy position; change of trestle position; machinery failure; equipment failure; buoy placed close to sailing area.

No injuries; Cosmetic damage; Local public awareness, no media coverage.

Minor injury requiring treatment; Prolonged unavailability; Regional media coverage.

1

1

2

4.0

3

3

4

1.0

3.00

1 : Review Marking and Lighting 3 : Promulgation 5 : Incident Reporting 6 : Restrict Further Expansions to the North- East

10

Co

nta

ct

Small sailing vessel contacts

buoy

Small yacht makes contact with buoy.




2

2

2

4.0

3

3

4

1.0

3.59

1 : Review Marking and Lighting 2 : Chart Area 3 : Promulgation 5 : Incident Reporting 6 : Restrict Further Expansions to the North- East

11

Co

nta

ct

Small powered craft contacts buoy

Small rib, leisure user, Jet ski, RNLI, makes contact with buoy.

Severe weather; inattention; poor local knowledge; change of buoy position; change of trestle position; machinery failure; equipment failure.


Multiple injuries or fatality; Prolonged unavailability; Regional media coverage.

2

2

3

3.0

4

3

4

1.0

3.82





ID

Category

Hazard Title

Hazard Detail

Possible Causes

Most Likely Outcome




R

isk

Sco

re


Peo

ple

Pro

per

ty

Bu

sin

ess

Freq

uen

cy

Peo

ple

Pro

per

ty

Bu

sin

ess

Freq

uen

cy

12

Co

nta

ct

Small commercial craft

contacts buoy

Small commercial pilot / workboat makes contact with buoy.


No injuries; Cosmetic damage; No adverse publicity.


1

1

1

1.0

2

2

2

1.0

0.74

1 : Review Marking and Lighting 2 : Chart Area 3 : Promulgation 5 : Incident Reporting

13

Co

llisi

on

Collision Recreational with Recreational

Recreational vessel collides with another recreational vessel as a result of navigating around trestles.

Avoidance of other recreational vessel; inattention; failure to follow ColRegs; machinery failure; equipment failure; poor communication; severe weather.

First-aid; Cosmetic damage; Local public awareness, no media coverage.

Minor injury requiring treatment; Prolonged unavailability; Local public awareness, no media coverage.

2

1

2

4.0

3

3

2

3.0

3.51


14

Co

llisi

on

Collision - Recreational with

Commercial

Recreational vessel collides with a commercial vessel as a result of navigating around the trestles.

Avoidance of other recreational vessel; inattention; failure to follow ColRegs; machinery failure; equipment failure; poor communication; severe weather.

First-aid; Prolonged unavailability; Local publicity.

Multiple injuries or fatality; Complete Loss; National publicity.

2

3

3

2.0

4

5

5

1.0

4.07


15

Co

llisi

on

Collision - Commercial with Commercial

Commercial vessel collides with a commercial vessel as a result of navigating around the trestles.

Avoidance of other commercial vessel; inattention; failure to follow ColRegs; machinery failure; equipment failure; poor communication; severe weather.



2

2

3

1.0

3

3

3

1.0

2.64


15

Gro

un

din

g

Grounding - Recreational Craft

A recreational craft grounds.




1

1

1

4.0

3

2

2

3.0

1.88


16

Gro

un

din

g

Grounding Commercial vessel

A commercial vessel grounds.

Severe weather; inattention; poor local knowledge; no warning of trestle placement; trestles poorly marked; change of trestle position; equipment failure;



1

1

1

3.0

2

2

2

2.0

0.92





ID

Category

Hazard Title

Hazard Detail

Possible Causes

Most Likely Outcome




R

isk

Sco

re


Peo

ple

Pro

per

ty

Bu

sin

ess

Freq

uen

cy

Peo

ple

Pro

per

ty

Bu

sin

ess

Freq

uen

cy

17

Sin

kin

g /

Cap

size

Sinking / Capsize - Recreational Craft

A recreational craft sinks or capsizes as a result of avoidance action.

Severe weather; inattention; poor local knowledge; no warning of trestle placement; trestles poorly marked; change of trestle position; equipment failure; vessel drifts on to trestles.

First-aid; Cosmetic damage; No adverse publicity.


2

1

1

4.0

4

4

5

2.0

3.95




Marine Management Organisation B-1

Annex B Residual Navigation Risk Assessment – Hazard

Log




ID

Category

Hazard Title

Hazard Detail

Possible Causes

Most Likely Outcome


Most Likely Consequence Worst Credible Consequence

Ris

k Sc

ore

Peo

ple

Pro

per

ty

B

usi

ne

ss

Fr

equ

ency

P

eop

le

P

rop

erty

B

usi

ne

ss

Fr

equ

ency

1

C

on

tact

Small recreational vessel contacts trestle





2

2

2

4.0

4

2

5

1.0

3.91

2

C

on

tact

Small sailing vessel contacts trestle

Small yacht makes contact with partially submerged / submerged trestle




3

2

2

3.0

4

3

5

1.0

4.16

3

C

on

tact

Small powered craft contacts trestle

Small rib, leisure user, Jet ski, RNLI, makes contact with partially submerged / submerged trestle




2

2

3

3.0

4

3

5

1.0

4.16

4

C

on

tact

Small commercial craft contacts

trestle

Small commercial vessel makes contact with partially submerged / submerged trestle

Severe weather; inattention; poor local knowledge; no warning of trestle placement; trestles poorly marked; change of trestle position; machinery failure; equipment failure;

No injuries; Cosmetic damage; Local media coverage.


1

1

3

1.0

3

2

3

1.0

2.28

5

C

on

tact

Small recreational vessel contacts pole and line structure





1

1

1

1.0

1

1

1

1.0

0.00

6

C

on

tact

Small sailing vessel contacts pole

and line structure

Small yacht makes contact with pole and line structure




1

1

1

1.0

1

1

1

1.0

0.00




ID

Category

Hazard Title

Hazard Detail

Possible Causes

Most Likely Outcome



Ris

k Sc

ore

Peo

ple

Pro

per

ty

B

usi

ne

ss

Fr

equ

ency

P

eop

le

P

rop

erty

B

usi

ne

ss

Fr

equ

ency

7

C

on

tact

Small powered craft contacts pole

and line structure

Small rib, leisure user, Jet ski, RNLI, makes contact with pole and line structure




1

1

1

1.0

1

1

1

1.0

0.00

8

C

on

tact


pole and line structure

Small commercial pilot / workboat makes contact with pole and line structure


No injuries; Cosmetic damage; Local publicity.


1

1

1

1.0

1

1

1

1.0

0.00

9

C

on

tact

Small recreational vessel contacts

buoy

SUP, Kayak, inflatable dinghy, sailboarder/ kite surfer makes contact with buoy


No injuries; Cosmetic damage; Local public awareness, no media coverage.


1

1

2

4.0

3

3

4

1.0

3.00

10

C

on

tact

Small sailing vessel contacts buoy

Small yacht makes contact with buoy




2

2

2

4.0

3

3

4

1.0

3.59

11

C

on

tact

Small powered craft contacts

buoy

Small rib, leisure user, Jet ski, RNLI, makes contact with buoy



Multiple injuries or fatality; Prolonged unavailability; Regional media coverage.

2

2

3

3.0

4

3

4

1.0

3.82

12

C

on

tact


buoy

Small commercial pilot / workboat makes contact with buoy




1

1

1

1.0

2

2

2

1.0

0.74




ID

Category

Hazard Title

Hazard Detail

Possible Causes

Most Likely Outcome



Ris

k Sc

ore

Peo

ple

Pro

per

ty

B

usi

ne

ss

Fr

equ

ency

P

eop

le

P

rop

erty

B

usi

ne

ss

Fr

equ

ency

13

C

olli

sio

n

Collision Recreational with Recreational

Recreational vessel collides with another recreational vessel as a result of navigating around trestles

Avoidance of other recreational vessel; inattention; failure to follow ColRegs; machinery failure; equipment failure; poor communication; severe weather;

First-aid; Cosmetic damage; Local public awareness, no media coverage.

Minor injury requiring treatment; Prolonged unavailability; Local public awareness, no media coverage.

2

1

2

3.0

3

3

2

2.0

2.62

14

C

olli

sio

n

Collision - Recreational with Commercial

Recreational vessel collides with a commercial vessel as a result of navigating around the trestles

Avoidance of other recreational vessel; inattention; failure to follow ColRegs; machinery failure; equipment failure; poor communication; severe weather;

First-aid; Prolonged unavailability; Local publicity.

Multiple injuries or fatality; Complete Loss; National publicity.

2

3

3

1.0

4

5

5

1.0

3.78

15

C

olli

sio

n

Collision - Commercial with

Commercial

Commercial vessel collides with a commercial vessel as a result of navigating around the trestles

Avoidance of other commercial vessel; inattention; failure to follow ColRegs; machinery failure; equipment failure; poor communication; severe weather.



2

2

3

1.0

3

3

3

1.0

2.64

15

G

rou

nd

ing

Grounding - Recreational Craft

A recreational craft grounds

Severe weather; inattention; poor local knowledge; no warning of trestle placement; no markation of trestles; change of trestle position; equipment failure;



1

1

1

4.0

3

2

2

3.0

1.88

16

G

rou

nd

ing

Grounding Commercial vessel

A commercial vessel grounds

Severe weather; inattention; poor local knowledge; no warning of trestle placement; no markation of trestles; change of trestle position; equipment failure;



1

1

1

3.0

2

2

2

1.0

0.74

17

Si

nki

ng

/ C

apsi

ze

Sinking / Capsize - Recreational

Craft

A recreational craft sinks or capsizes as a result of avoidance action.

Severe weather; inattention; poor local knowledge; no warning of trestle placement; no markation of trestles; change of trestle position; equipment failure;vessel drifts on to trestles.

First-aid; Cosmetic damage; No adverse publicity.


2

1

1

3.0

4

3

5

2.0

3.48



Marine Management Organisation C-1

Annex C Stakeholder Consultation Minutes




Minutes of Meeting held on 09th October 2019 – Whitstable Yacht Club

Client: MMO

Project: Whitstable NRA Update

Venue: The Marine Hotel, Whitstable

Date of Meeting: 09 October 2019

Present:

Marico Marine (MM)

Marico Marine (MM)

Whitstable Yacht Club (WYC)

Whitstable Yacht Club(WYC)

Item Notes for the record Actions

1 Introductions, Topic of Discussion

• and introduced Marico Marine and the scope of work Marico has been contracted to provide.

• and introduced the Marico NRA process.

2 Existing shipping

• and asked the stakeholders to provide an account of marine activities that occur in or near the site of the oyster farm.

o WYC has dinghy’s, sailboarders, paddle boarders, Kayaks, swimmers, jet skis, and yachts all operating in the vicinity of the oyster farm.

• and informed that they have club members of all abilities from novice to experienced operating all of the above-mentioned craft.

• and also mentioned that as well as regular club members they also hold events during which a large population of additional water users can take part. These water users do not know the area as well as the club members.

• KT and MG also noted that their club holds training sessions and delivers RYA courses.

3 Hazards

and informed of several potential hazards:

• Craft unable to manoeuvre properly being set onto the oyster farm trestles.

• Sailboarders and others now (due to the expansion of the oyster farm) have go a long way off shore (round to the off-shore side of the oyster farm) to practise their activities. This causes two issues; One it forces them to operate in rougher sea conditions and also if they need to get back to shore in an emergency, they cannot take a straight line back to the beach because the oyster farm is in the way. They now have to sail around the oyster farm which can be almost a mile.

• All of these different activities are now forced to operate closer to each other then they would like to due to the available space during some




states of the tide which can run in and east west direction at a rate up to two knots.

• At LW there is a risk that the craft involved in club activities could get set onto the trestles damaging craft and potentially injuring persons. Persons could also get trapped under the trestles.

• Some yellow buoys indicating a 8 knot speed (council by law) limit have been removed and not replaced.

4 Incidents

As per the incident log forwarded to Marico separately from the meeting.

5 Other

• WYC is not aware of any public consultation having taken place

regarding the expansion of the oyster farm. They have also not been made aware of the UKHO having been informed.

6 Supplementary information pertaining to race areas: email dated 27th January 2020:

[The attached] shows the area (hatched orange) where the majority of the racing took place. The pink line indicates the limit of the seabed originally leased to the club for moorings, as the trestles are located immediately to the west, this is the limit of the area left for sailing. The club has been forced, in the summer, to move its sailing area out to sea beyond the trestles and run the racing from a committee boat.




Minutes of Meeting held on 09th October 2019 – Canterbury City Council

Client: MMO




Present:

Marico Marine (MM)

Marico Marine (MM)

Councillor for Seasalter Ward, Canterbury City Council (CC)




and introduced the Marico NRA process

2 Existing shipping

and asked the stakeholders to provide an account of marine activities that occur in or near the site of the oyster farm.

replied he has seen dinghy’s, sailboarders, paddle boarders, Kayaks, swimmers, jet skis, and yachts all operating in the vicinity of the oyster farm.

3 Hazards

informed of several potential hazards:

Craft unable to manoeuvre properly being set onto the oyster farm trestles.

Sailboarders and others have go a long way off shore (round to the off-shore side of the oyster farm) to practise their activities. This causes two issues; One it forces them to operate in rougher sea conditions and also if they need to get back to shore in an emergency, they cannot take a straight line back to the beach because the oyster farm is in the way. They now have to sail around the oyster farm which can be almost a mile.

All of these different activities are now forced to operate closer to each other then they would like to due to the available space during some states of the tide which can run in and east west direction at a rate up to two knots.

At LW there is a risk that the craft could get set onto the trestles damaging craft and potentially injuring persons. Persons could also get trapped under the trestles.

Some yellow buoys indicating an 8 knot speed (council buy law) limit have been removed and not replaced.




Spike on top of the trestles have been bent over which could cause an entrapment issue.

4 Incidents

is aware of a sailboarder being hurt

5 Other

informed that prior to 2009 the farm was a small experimental site which has grown over the past few years and now covers an area of about three quarters of a mile by a third of a mile. At HW it sits in about 15 feet of water. The trestles stand about 5 feet clear of the sea bed leaving about 10 feet of clearance. AT LW the trestles are exposed but between HW and LW you cannot see the trestles and there isn’t enough water to safely pass over head.

The whole area is a SSSI area.




Minutes of Meeting held on 09th October 2019 –Whitstable Harbour

Client: MMO




Present:

Marico Marine (MM)

Marico Marine (MM)

Harbour Master Whitstable Harbour (WH)





2 Existing shipping


replied he has seen dinghy’s, sailboarders, paddle boarders, Kayaks, swimmers, jet skis and yachts all operating in the vicinity of the oyster farm.

3 Hazards

informed from his view the potential hazards are:


Sailboarders and others have go a long way off shore to practise their activities.

Water users are now forced to operate closer to each other than they would like to due to the available space during some states of the tide which can run in and east west direction at a rate up to two knots.

At LW there is a risk that the craft could get set onto the trestles damaging craft and injuring persons. Persons could also get trapped under the trestles.

Some yellow buoys indicating an 8 knot speed (council by law) limit have been removed and not replaced.

Spike on top of the trestles have been bent over which could cause an entrapment issue.

4 Incidents

is aware of a sailboarder being hurt




5 Other

informed that prior to 2009 the farm was a small experimental site which has grown over the past few years and now covers an area of about three quarters of a mile by a third of a mile. At HW it sits in about 15 feet of water. The trestles stand about 5 feet clear of the sea bed leaving about 10 feet of clearance. AT LW the trestles are exposed but between HW and LW you cannot see the trestles and there isn’t enough water to safely pass over head.

The whole area is a SSSI area.




Minutes of Meeting held on 09th October 2019 – Canterbury City Council

Client: MMO




Present:

Marico Marine (MM)

Marico Marine (MM)

Council Foreshore Manager, Canterbury City Council (CC)





2 Existing shipping

and asked to provide an account of marine activities that occur in or near the site of the oyster farm.

replied he has seen dinghy’s, sailboarders, paddle boarders, Kayaks, swimmers, jet skis, and yachts all operating in the vicinity of the oyster farm.

3 Hazards


3 Incidents

No official incident reports.

4 Other

The council has not sighted any recent risk assessments for the operation.

Privately owned land below MLWL.

Bye Laws allow some management part of the area above MLWL

In the past the Oyster company had worked with the council to manage the area but that had seemed to stop recently.

The Oyster company used to employee a public relations officer although that post had also gone recently and not been replaced.




Minutes of Meeting held on 09th October 2019 – Marine Environment Group

Client: MMO




Present:

Marico Marine (MM)

Marico Marine (MM)

Attendees requested to remain anonymous





2 Existing shipping


They replied mostly leisure users such as. dinghy’s, sailboarders, paddle boarders, Kayaks, swimmers, jet skies, and yachts all operating in the vicinity of the oyster farm.

3 Hazards

The trestles have spikes on them some of which have been bent over.

The Withies used to mark the trestles cannot be seen at HW.

4 Incidents

As per forwarded incident log. Mostly Kayaks, swimmers, walkers (at LW) colliding with the trestles.

5 Other

The Marine Environment Group is a volunteer organisation which is run from a Facebook page. They run beach clean-up sessions on the last Sunday of each month between 1230 and 1630. The area they clean is between Whitstable Harbour and the Neptune pub. Over the last three years the organisation has worked with 1600 volunteers.




Minutes of Meeting held on 09th October 2019 – Whitstable Beach Campaign

Client: MMO




Present:

Marico Marine

Marico Marine

Councillor – Labour Party response

Whitstable Beach Campaign

Independent Marine Witness

Whitstable Beach Campaign

Kent Law Clinique – Legal Advisor

Item Notes for the record

1/2 Introductions, Topic of Discussion

• and introduced Marico staff and informed of the scope of work that Marico has been contracted to provide.

• and introduced the Marico NRA process and set the topic and boundaries for the meeting discussion.

3 Existing shipping

• and asked the stakeholders to provide an account of marine activities that occur in or near the site of the oyster farm.

• Users are predominantly recreational, such as; dinghies, windsurfers, paddle boarders, Kayaks, swimmers, jet skies, and yachts all operating in the vicinity of the oyster farm.

4 Hazards

WBC considers that the risk posed by the site is now much given recent expansions.

• WBC noted that the steel upstands had been bent over as opposed to removed.

• A new design of oyster production has been implemented by WOFC.

• No life-saving equipment on the beach.

• Signs warning of the dangers of the oyster farm are limited and unclear.

• 8 Knot speed limit buoys removed.

• Withies do not show at all states of the tide.

• Leisure users now have to operate closer to each other due to available sea room.

• WBC consider that the trestles increase risk of entrapment issues.

• If craft were to experience mechanical issues they could drift into the farm site.

• WBC considers that the oyster trestle development would present a hazard to beach replenishment operations.




5 Incidents

• As detailed in log forwarded to Marico.

6 Other

• No public consultation was held on the expansion plans or new trestle design.

• No updates received from the UKHO about the oyster farm site and no NtM had been published.




Minutes of Meeting held on 09th October 2019 – Whitstable Oyster Fishery

Company, Furley Page Legal Services

Client: MMO




Present:

Marico Marine (MM)

Marico Marine (MM)

Whitstable Oyster Fishery Company (WOFC)

Furley Page Legal Services (FP)





2 Existing shipping

and asked to provide an account of marine activities that occur in or near the site of the oyster farm.

replied mostly leisure users such as. dinghy’s, sailboarders, paddle boarders, Kayaks, swimmers, jet skis, and yachts all operating in the vicinity of the oyster farm.

3 Hazards

replied any identified hazards the Oyster company had taken into account. They had conducted a risk assessment of the operations. They had buoyed the area, put Withies up, consulted the local population including local yacht clubs, sea scout groups and RNLI. He had gained the correct licences from the MMO to conduct the operation and had notified the UKHO who had charted the Oyster farm and trinity house who advised of the buoyage required.

did advise that he had removed the 8 knot speed limit buoys as that line ran through the middle of the farm and he considered they might attract water users to the sight. However, he would replace these if required.

4 Incidents

As detailed in log forwarded to Marico.

5 Other




Further risk mitigation methods were discussed during the meeting all of which was open to.

1 during a water user event could provide some funding towards a safety boat to ensure water craft users remain clear of the site.

2 Consider replacing the signage warning about the oyster farm site,

3 Produce a free information leaflet which informs water users what the meaning of a yellow marker buoy is and also information about the site.

4 Replace the 8 knot speed limit buoys.




Minutes of Meeting held on 09th October 2019

Client: MMO




Present:

Marico Marine (MM)

Marico Marine (MM)

Water Safety Committee (WSC)

Item Notes for the record

1/2 Introductions, Topic of Discussion

• and introduced Marico staff and informed of the scope of work Marico has been contracted to provide.

• and introduced the Marico NRA process and set the topic and boundaries for the meeting discussion.

3 Existing shipping

• and asked NA to provide an account of marine activities that occur in or near the site of the oyster farm.

• There are a number of sailing and water activities clubs nearby, mostly leisure users such as; dinghy’s, windsurfers, paddle boarders, Kayaks, swimmers, jet skis, and yachts all operating in the vicinity of the oyster farm.

4 Hazards

considered the following hazards could result from the presence of the oyster farm:

• Entrapment issue under trestles

• Craft can become disabled and drift into farm site.

5 Incidents

• was aware of one incident in which the RNLI were unable to get into the oyster farm with their craft to perform a rescue.

6 Other

• had not seen any notification from the UKHO about the oyster farm site or a NtM published.




Minutes of Meeting held on 09th January 2020 – Maritime and Coastguard

Agency

Client: MMO

Project: Whitstable NRA

Venue: Teleconference

Date of Meeting: 09 January 2020

Present:



Marico Marine (MM)


1 Introduction

• MM introduced the project including the site layout, cultivation methods and marking.

• Navigation profile was introduced (informed by local consultation)

• MCA queried whether recreational beach users – such as dinghies, kayaks and swimmers were also being considered?

o MM explained that the NRA will consider risk to navigation only and that health and safety and environmental impacts are not to be considered within the NRA.

2 Site Layout

• MCA feels that the site has grown significantly (perhaps four-fold) since the previous NRA, including a further extension offshore.

• MCA raised concerns that if the parameters of what was originally

assessed had changed (in terms of footprint, cultivation method or

equipment) it would likely have concerns regarding the safety of

navigation and need the opportunity to reassess the risk.

• Changes to the site layout since the 2017 NRA were noted including:

o The increased footprint of the trestle area (including expansion to the east)

o The presence of pole and line cultivation method to the north

o The removal of council speed limit buoys

o That the vertical steel rods used to retain the mesh bags in-situ have been bent at the top

3 Navigation Profile

• Primary vessel types utilising the area were discussed (primarily recreational vessels).

• MCA believes that windsurfing activity takes place to the north and west of the site and noted that the local yacht club runs dinghy races and

MM




utilises nearby areas for training. MCA suggested that race areas should be confirmed with WYC.

4 Incidents

• MM explained that incident data was received from Whitstable Beach Campaign and the Water Safety Committee.

• MCA had heard reports of windsurfing incidents occurring at or in the vicinity of the oyster farm.

• MM requested that any relevant incident data held by MCA be forwarded on for review.

MCA

5 Marking and Lighting

• MCA questioned how the withies are being used to mark the site, noting that the 2017 NRA advised that each trestle row should be marked with Withies. MM to confirm.

• Feedback from local stakeholders that the withies bend and subsequently can be submerged at high-tide was discussed and it was suggested that an alternative method for marking should be assessed in discussion with Trinity House.

MM

MM

6 Pole and Line Activity

• MCA questioned the height of the structures and the material that the poles are made of. RW explained that the poles are 1.5m in height and the material was not known. MM to confirm.

• MCA questioned the impact of the pole and line structure on navigation at high tide. It was established that at high-tide small unpowered craft would be able to navigate over the structure, however, UKC would not be sufficient to ensure safety of larger powered vessels.

MM

7 Hazard Review

• The MCA considers that the site does represent a danger to navigation increasing the potential for incidents to occur, particularly in-light of expansion.

• Concerns are largely the same as 2017. The following concerns were identified:

o Access to slipways in event of an emergency for recreational users, as raised by local stakeholders.

o The potential for continued expansions into the future.

o The possible failure to implement the recommended risk control measures identified within the 2017 NRA.

o The presence of multiple cultivation methods and the risk posed by the new pole and line structure.

o Maintaining SAR access to the site.

o The risk of propellers fouling on the new poles and lines.

• MCA requested that the final hazard list for assessment is sent to them for review.

MM




8 Possible Additional Mitigation Measures

• The following possible additional mitigation measures were suggested:

o Consultation should be required prior to any expansion or layout change and prior to the implementation of new technology or growing methods.

o Improvement of the marking of the site overall, including a review of the appropriateness of withies. Ensuring that AtoNs are monitored to ensure they are maintained and fit-for-purpose.

o Making the activity licensable going forward would ensure that appropriate stakeholder consultation occurs prior to any layout or activity changes and that appropriate marking and lighting is put in place.

o Implementation of restriction on future expansions to the north- east so not to further impede the recreational use/ sailing area.

o MCA questioned whether an Emergency Response Plan, agreed with the RNLI, has been put in place and suggested that it could be considered for the future if not.

o UKHO notified of any layout changes so that charts and publications can be updated.

9 Other

• Have the local Coastguard and RNLI been consulted?

• MCA questioned whether plots showing the layout could be sent for review?

• MCA questioned whether the Whitstable Society had been consulted?

MM

MM

MM



Marine Management Organisation D-1

Annex D Incident Data

Marine Management Organisation E-1


Annex E 2017 NRA Assessed Layout

Marine Management Organisation E-2


NAVIGATION RISK ASSESSMENT - WHITSTABLE OYSTER FARM

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Transcript of NAVIGATION RISK ASSESSMENT - WHITSTABLE OYSTER FARM