NOPSEMA – Fauna entanglement

  • Safety Flash
  • Published on 20 February 2025
  • Generated on 21 February 2025
  • IMCA SF 03/25
  • 3 minute read

The National Offshore Petroleum Safety and Environmental Management Authority of Australia, NOPSEMA, has published an environmental alert relating to aquatic animals getting tangled up in subsea equipment. 

What happened?

During a subsea survey, the operator of a remotely operated vehicle (ROV) noticed a shark caught in a pre-existing rope loop attached to an electrical flying lead (EFL). Fortunately, the shark was alive when found, and the rope was able to be cut using an ROV knife, allowing the shark to swim away. No additional harm was caused while releasing the shark. NOPSMEA notes that “it is common industry practice during installation of some subsea equipment (such as EFLs and concrete mattresses) to affix rope loops or other installation aids to equipment to enable ROVs to manoeuvre the equipment into position, minimise the risk of damage to the equipment, and/or assist with later removal”.

NOPSEMA is also aware that other adverse fauna-equipment interactions have occurred in the industry, including interactions directly with ROVs; and that these have been inconsistently reported or not reported to the regulator.

What could go wrong?

If installation aids are not removed, cut, or otherwise made safe (e.g. by design), they can present a risk of entanglement to marine fauna, including species that may be under regulatory protection in some countries. In addition to installation aids, other subsea equipment that uses lights, cables or thrusters has potential to attract attention from marine animals which may result in entanglement or other adverse interactions. While in this incident the shark was released safely, it is considered likely that a similar incident could result in serious injury (as an animal attempts to free itself) or death to the animal.

Lessons learned

Marine contractors and others involved in subsea construction should ensure that environmental impacts and risks are identified and reduced to a level that is as low as reasonably practicable (ALARP). Credible risks (such as fauna entanglement or interaction) should be evaluated when identified, and control measures should be implemented to reduce those risks to ALARP levels.

Control measures that should be considered may include:

  • Implementation and verification of requirements for the removal/recovery of installation aids or debris during installation, inspection/maintenance/repair (IMR) activities
  • Alternative design of installation aids, such as monkey fist knots, clamps or lifting pads, including those that can be made safe when not in use
  • Design of equipment or installation of protective guards that prevent interaction with thrusters and other mechanisms of potential injury.

Members may wish to refer to:

  • Australian regulations:

-          Offshore Petroleum and Greenhouse Gas Storage (Environment) Regulations 2023 Regulation 22

-          Environment Protection and Biodiversity Conservation Regulations 2000 Regulation 9

Latest Safety Flashes:

Crew transfer vessel (CTV) drifts onto turbine tower

A CTV drifted into and hit a nearby structure at 0.5 knots.

Read more
LTI: Fall from height during FRC maintenance

A worker fell 2.3 m to deck from a small boat in the davit, and broke a leg as a result. 

Read more
Near miss: narrowly avoided fall from height due to missing deck gratings

After a grating was removed, the Chief Engineer, on the way to inspect the work, nearly fell 4-5m.

Read more
MSF: A broken stretcher could have led to injury

The Marine Safety Forum (MSF) published Safety Alert 24-09 relating to a broken stretcher.

Read more
Positive story: Excellent galley hygiene and housekeeping

On a walk-around audit, a member highlights very high standards of housekeeping and hygiene in the galley on one of its vessels.

Read more

IMCA Safety Flashes summarise key safety matters and incidents, allowing lessons to be more easily learnt for the benefit of the entire offshore industry.

The effectiveness of the IMCA Safety Flash system depends on the industry sharing information and so avoiding repeat incidents. Incidents are classified according to IOGP's Life Saving Rules.

All information is anonymised or sanitised, as appropriate, and warnings for graphic content included where possible.

IMCA makes every effort to ensure both the accuracy and reliability of the information shared, but is not be liable for any guidance and/or recommendation and/or statement herein contained.

The information contained in this document does not fulfil or replace any individual's or Member's legal, regulatory or other duties or obligations in respect of their operations. Individuals and Members remain solely responsible for the safe, lawful and proper conduct of their operations.

Share your safety incidents with IMCA online. Sign-up to receive Safety Flashes straight to your email.