Navigational Risk Assessment for The New Zealand King Salmon ...

Navigational Risk Assessment
for
The New Zealand King Salmon Co. Ltd.
Prepared for: The New Zealand King Salmon Co. Ltd.
Author & Risk Analyst: Sandy Pont, Director, Enhanced Operating Systems Limited
Checked by: John Colebrook, Director, Enhanced Operating Systems Limited
EOS Ltd
PO Box 28749
Remuera 1541
Auckland
Phone: 09 579 6498
March 2012
© EOS Ltd. All rights reserved.
EOS Ltd has prepared this document for the sole use of the Client and for a specific purpose. No other party should rely on this document without the prior written consent of EOS Ltd. EOS Ltd undertakes no duty, nor
accepts any responsibility, to any third party who may rely upon or use this document. This document has been prepared based on the Client’s description of its requirements and EOS Ltd’s experience, having regards to
assumptions that EOS Ltd can reasonably be expected to make in accordance with sound professional principles. EOS Ltd may also have relied upon information provided by the Client and other third parties to prepare this
document, some of which may not have been verified.

1 Executive Summary.....................................................................................................................3
2 Background & Introduction ........................................................................................................5
3 Objectives....................................................................................................................................6
4 Reference Documents & Information.........................................................................................8
4.1 Navigation Report on New Zealand King Salmon’s Proposal for New Salmon Farms in the Marlborough
Sounds 29 September 2011 by David Walker ..............................................................................................................8
4.2 Marlborough Sounds Harbour Navigational Risk Assessment 2005 & Marlborough Sounds Harbour
Navigational Risk Assessment Review 2009.................................................................................................................8
4.3 Other Supporting Reports..............................................................................................................................9
4.4 NZ King Salmon Documents...........................................................................................................................9
5 Marlborough Sounds Port & Harbour Safety Management System ........................................10
6 Risk Assessment Key Steps........................................................................................................12
6.1 Risk familiarisation and information gathering:...........................................................................................12
6.2 Risk identification: .......................................................................................................................................13
6.3 Create a Risk Inventory ................................................................................................................................13
6.4 Risk analysis & evaluation:...........................................................................................................................15
6.5 Risk treatment: ............................................................................................................................................16
6.6 Monitor and review: ....................................................................................................................................17
6.7 Risk Tables & Formulae................................................................................................................................18
7 Controls.....................................................................................................................................22
8 Selected Risk for Detailed Analysis – Bowtie Analysis ..............................................................24
9 Risk Assessment Summary from MDC Risk Assessments .........................................................31
9.1 2005 Risk Assessment:.................................................................................................................................31
9.2 2009 Risk Assessment Review: ....................................................................................................................31
10 Conclusions & Recommendations ............................................................................................32
Annex A: Detailed List of Risks by Highest Rating.................................................................................34
Annex B: Detailed List of Risks by Category:.........................................................................................37
Annex C: List of Risks:............................................................................................................................40
Annex D: Risks within each Farm/Proposed Farm Risk Area: ..............................................................42
Annex E: Full List of Controls & Control Adequacy Rating & Priorities:................................................46
Annex F: MDC Risk Controls related to Salmon Farms ........................................................................54
Annex G: Risks Related to Salmon Farms Identified in MDC Risk Assessments ...................................56
Annex H: Consultation Summary – Navigation Consultation in the Marlborough Sounds ..................59
Annex I: Extracts from MNZ Guidelines & Codes.................................................................................61
NZ King Salmon Risk Assessment Rev: 1 Page 2 of 63

1 Executive Summary
This navigational risk assessment provides information for the Marlborough District Council (MDC)
Harbourmaster to add to and support the existing risk assessment for the Marlborough Sounds.
This risk assessment has been prepared in accordance with the New Zealand Port & Harbour Marine
Safety Code (the Code), and referencing the Final Guidelines for Port & Harbour Risk Assessment &
Safety Management Systems in New Zealand, the Guidelines for Aquaculture Management Areas
and Marine Farms.
All navigational risks 1 associated with New Zealand King Salmon’s (NZ King Salmon) salmon farms,
given the current controls and enhancements to controls arising from NZ King Salmon commitments,
fall within or below the widely recognised designation of As Low As Reasonably Practicable (ALARP).
Stakeholder interest in the risk of mooring system failure was given special consideration and
responded to by extended scrutiny, in the form of detailed analysis of the controls that effectively
reduce the likelihood and potential consequences of this risk.
MDC identified two risks directly related to salmon farms in both the Marlborough Sounds Harbour
Navigational Risk Assessment 2005 and the Marlborough Sounds Harbour Navigational Risk
Assessment Review 2009. Despite a farm breaking free from its moorings in 2006, the 2009 review
found the level of risk to be unchanged. This would appear to support a view by MDC that sufficient
mitigating action had been taken to prevent recurrence and increased risk ranking.
This report also provides information on the framework of NZ King Salmon’ safety management
system to support the Code’s aim to promote good practice in the conduct of safe marine
operations.
This risk assessment complements the Navigation Report by David Walker that assessed the effects
of the proposed marine farms on navigation in the Marlborough Sounds.
Risks were identified during a risk inventory workshop and with discussions with key stakeholders.
Some of these risks have also been assessed by the MDC Risk Navigational Risk Assessment and the
MDC Risk Navigational Risk Assessment review, however it was important to assess these risks in
relation to King Salmon operations and not marine farms in general.
No risks overall were identified as significant, 55% of risks rated low overall, with the remaining 45%
rating within As Low As Reasonably Practical (refer to Section 6.7.4 of this report). 8% of risks were
1 Risk is defined in ISO 31000:2009 as: “the effect of uncertainty on objectives”.
Given the MNZ and MDC focus on events as opposed to objectives, an event focussed definition of risk is: An
event with the ability to impact the mission, strategy, projects, routine operations, objectives, core processes,
key dependencies and/or the delivery of stakeholder expectations.
NZ King Salmon Risk Assessment Rev: 1 Page 3 of 63

identified as having significant individual consequence ratings and have been identified for further
scrutiny and attention of mitigations and controls associated with the risks.
It is also noted that Tory Channel is not the sole route that can be taken by commercial vessels to
reach Port Marlborough, an alternate route is available through Queen Charlotte Sound.
The application for new farms is built on design, operational and maintenance knowledge gained
from King Salmon’s existing farms.
Mooring system design will use existing proven technology, based on experience with the Te Pangu
and Clay Point farms and will draw on NZ King Salmon’s ongoing development and refinement work.
It is recommended:
1. A navigation risk improvement & management plan be developed by NZ King Salmon (refer
Section 6.6 of this report).
2. A sufficiently detailed basis of design is needed to substantiate the semi-qualitatively determined
consequences and risk ratings at Annexes A & B of this report.
NZ King Salmon Risk Assessment Rev: 1 Page 4 of 63

2 Background & Introduction
As part of an application for plan change and resource consents for new water space, NZ King
Salmon has commissioned Enhanced Operating Systems Limited (EOS Ltd) to undertake a
navigational risk assessment that meets the requirements of the Maritime New Zealand Final
Guidelines for Port & Harbour Risk Assessment and Safety Management Systems 2004 (the
Guidelines).
The recently published Board of Inquiry Minute number 2 dated 14 February 2012 sums up the
requirement for the Navigation Risk Assessment thus (direct quotes):
[11] King Salmon provided with the plan change requests a “Navigation Report” that
assesses the effects of the proposed salmon farm on navigation within the Marlborough
Sounds. Notwithstanding, the Marlborough District Council Harbour Master requested the
EPA to ask King Salmon for a specific Navigation Safety Risk Assessment.
[12] As we understand it, such a formal risk assessment would be produced by reference to
the New Zealand Port and Harbour Marine Safety Code, which the Council Harbour Master is
concerned has not been addressed in the Navigation Report as lodged with the plan change
requests.
…….
[15] The Marlborough District Council seeks the following:
A Navigation Safety Risk Assessment, adding to and supporting the existing Harbour Risk
Assessment for the Marlborough Sounds, prepared in accordance with the NZ Port and
Harbour Marine Safety Code and with specific reference to the “Guidelines for Aquaculture
Management Areas and Marine Farms” and the “Port and Harbour Risk Assessment and
Safety Management Systems in New Zealand”.
EOS Ltd has had extensive specialist experience with New Zealand Ports and Harbours and overseas
Ports and Harbours, in the development and review of Safety Management Systems, which include
Risk Assessments, over the past five years (soon after the Code and Guidelines were issued). These
assignments in New Zealand have been approved/endorsed by Maritime New Zealand. EOS Ltd has,
alongside this specialist experience, had experience in Port Company’s and Harbour Authority’s
operational management systems for the past twenty years.
EOS Ltd has had experience with various Port & Harbour authorities to achieve ISO 9001
Certification; assistance with preparation for ACC Tertiary Level Audits; provision of H&S training;
Safe Ship Management Company management, including safe ship management manual
preparation, review and audit; representation during SSM audits, Environmental audits, Aids to
Navigation audits, Vessel Class Surveys, ISPS audits, Section 54 audits; conducting contractor audits;
preparation of emergency plans; training programmes for pilots (approved by MNZ), pilot exempt
masters, tug crew, pilot vessel crew, linesgang, hammermen, survey vessel crew, harbour
controllers, harbourmasters, boating advisors, enforcement officers, straddle drivers, crane drivers,
lashers, shuttle drivers; preparation of pilot guidelines, exempt master guidelines, examinations,
peer reviews; job safety analyses; hazard register review and preparation; emergency drills and
exercises (development and participation); accident/incident investigation; task and job analyses;
development of pilot vessel design criteria; legislation review and drafting; providing an interface for
NZ King Salmon Risk Assessment Rev: 1 Page 5 of 63

Ports and Harbours with Department of Transport, water Police, maritime regulators, customs,
border security agencies.
“The guidelines, as also the Code itself, are not statements and good practice intended to stand for
all time. Rather, they are living documents to be revised in the light of the lessons drawn from
experience, advances in technical knowledge and capability, and the ongoing imperative of
continually improving safety management within our port and harbour system.” 2
“Any safety management system inherently needs an assessment of risk to inform it of safety
priorities and the performance of risk management systems managing those priorities.” 3 This risk
assessment is just one component of New Zealand King Salmon’s Safety Management System
Framework, as depicted in the diagram in Section 5.
3 Objectives
The objectives of the risk assessment are:
To satisfy the specific request of the Board of Inquiry Minute No. 2 dated 14 February 2012
referenced in Section 2 of this report Background & Introduction.
To satisfy the specific request of the MDC Harbourmaster in his letter to the Environmental
Protection Authority dated 6 September 2011: “ … a risk assessment of the navigation safety
aspects of the application should be undertaken to clarify any substantive issues not
immediately apparent. Any such assessment should follow not only the principles, but
should form an addition to the current harbour risk assessment. It is suggested that a risk
assessment is undertaken … to ensure that the appointed decision makers are fully informed
of the potential risks that may impact on navigation safety.”
To assess navigational risks to King Salmon and inform it of safety priorities and the
performance of risk management systems managing those priorities (Maritime New Zealand
Guidelines for Port & Harbour Risk Assessment and Safety Management Systems in New
Zealand).
To contribute to the risk management capability of NZ King Salmon as a means of assisting
better decision making and improved efficiency, thus providing greater stakeholder
assurance.
Efficient and effective management of hazards to NZ King Salmon property and to other
Sounds users from the proposed additional salmon farms.
Providing a safe working environment for NZ King Salmon staff.
Maintaining safe navigational access for other navigational users of Tory Channel and the
Pelorus Sound.
Reducing the chances of economic loss to NZ King Salmon to acceptable levels.
To support the objectives of the New Zealand Port & Harbour Marine Safety Code: “to:
o Provide for … a safe operating environment in the harbour;
2 Director of Maritime New Zealand’s Preface to The Guidelines
3 Introduction to The Guidelines
NZ King Salmon Risk Assessment Rev: 1 Page 6 of 63

o Identify all risks and establish safeguards to ensure that all identified risks are kept
as low as reasonably practicable; and
o Continuously improve safety management skills of all personnel, including
preparation for emergencies related to both safety and environmental protection.”
To satisfy NZ King Salmon’ obligations arising from relevant New Zealand legislation and the
New Zealand Salmon Farmer’s Environmental Code of Practice.
NZ King Salmon Risk Assessment Rev: 1 Page 7 of 63

4 Reference Documents & Information
4.1 Navigation Report on New Zealand King Salmon’s Proposal for New Salmon Farms in
the Marlborough Sounds 29 September 2011 by David Walker
Key information from David Walker’s report was reviewed during the risk assessment. In carrying
out his study to assess the effects of NZ King Salmon’s new marine farm sites on Navigation in the
Marlborough Sounds, it is noted that David Walker drew on:
His substantial experience and recognised (international) qualifications for
navigating/piloting and commanding a wide range of passenger and commercial vessels in
the Marlborough Sounds, including Master for passenger & freight ferries for InterIsland
Line and Strait Shipping.
His established dialogue relationships with other Masters, Pilots and Boating/Recreational
Organisations in the Marlborough Sounds.
Assessment of Marlborough District Council Harbourmaster monthly incident reports since
2005.
The requirements of current versions of Maritime New Zealand’s:
o New Zealand Port and Harbour Marine Safety Code
o Guidelines for Port and Harbour Risk Assessment and Safety Management Systems
o Guidelines for Aquaculture Management Areas and Marine Farms
The requirements of:
o The International Regulations for preventing Collisions at Sea, 1972
o Marlborough District Councils current Navigation By Laws
o Maritime Rules issued by the Minister of Transport
o Land Information nautical charts
o “The New Zealand Pilot”
o “The New Zealand Cruising Guide”
4.2 Marlborough Sounds Harbour Navigational Risk Assessment 2005 & Marlborough
Sounds Harbour Navigational Risk Assessment Review 2009
The existing Harbour Risk Assessment for the Marlborough Sounds comprises: “Marlborough Sounds
Harbour Navigational Risk Assessment”, April 2005, and “Marlborough Sounds Harbour Navigational
Risk Assessment Review”, December 2009.
The December 2009 Review appends a “Marlborough Sounds Harbour Desktop Due Diligence
Review”, October 2009, prepared for Marlborough District Council by R2A Risk & Reliability
Associates Pty Ltd;
R2A confirm “that the work [i.e. the April 2005 Marlborough Sounds Harbour Navigational Risk
Assessment and a June 2009 Draft of the Marlborough Sounds Harbour Navigational Risk
Assessment Review] is in line with the requirements of the Final Guidelines for Port & Harbour Risk
Assessment and Safety Management Systems in New Zealand as published by the Maritime Safety
Authority in 2004”.
NZ King Salmon Risk Assessment Rev: 1 Page 8 of 63

The Marlborough Sounds Navigational Risk Assessment Report notes that its findings are
underpinned by:
“Following the methodology and risk scoring criteria of Maritime New Zealand Final
Guidelines for Port & Harbour Risk Assessment and Safety Management Systems in New
Zealand”,
“Deploying methodology that is intentionally practical and uses experience drawn from port
and harbour risk assessment as well as the marine experience provided by representatives
from the harbour regulator and key harbour users”.
“Consideration of :
o Incident data and near miss reports,
o The views of relevant harbour stakeholders about navigational safety.
o The varying trade routes and commercial activities ongoing in the Sounds.
o The varying environmental considerations at specific locations in the Sounds.
o The organisational structure available to manage any identified risks of significance”
The Marlborough Sounds Harbour Navigational Risk Assessment 05NR109 Issue 1 April 2005 was
conducted in 2005 and then reviewed in 2009.
It is of particular note that the 2009 review concluded there were no changes to the two risks,
associated controls and consequence ratings that directly related to salmon farms. For details, refer
Annex G of this report.
4.3 Other Supporting Reports
The NZ King Salmon application provided detailed information for risk assessment purposes on farm
locations, weather and environment, tidal currents, wave climates, farm structures, engineering
design, farm operating practices, Sounds recreational usage and patterns, navigational focal points,
etc.
4.4 NZ King Salmon Documents
Sea cage manual (Selected sections):
o Oil spill plan
o Threats
o Contractors safety handbook
o Emergency procedures
o Sea cage maintenance
o Hazard ID register Picton seafarms
o Vessel operation policy
Vessel Safe Ship Management Manual
Environmental policy
Maintenance schedules & reports
OCEL construction drawings of existing farms
OCEL preliminary engineering & layout drawings related to proposed farms
Consultation reports
NZ King Salmon Risk Assessment Rev: 1 Page 9 of 63

5 Marlborough Sounds Port & Harbour Safety Management System
The New Zealand Port & Harbour Marine Safety Code identifies that in order for Marlborough
District Council to meet the objectives and standards set by the Code, Council needs to align with,
adopt, and be accountable for, the effective implementation of a number of risk assessment and
safety management principles, including 4 :
Marlborough District Council shall undertake a full harbour risk assessment of marine
operations, and implement a harbour safety management system. Implementation of the
harbour safety management system is the responsibility of the harbourmaster;
Marlborough District Council’s statutory powers, including those powers of Marlborough
District Council’s appointed harbourmasters, to regulate marine operations shall be
exercised in accordance with the harbour safety management system;
Every safety management system shall include a systematic approach to formally monitor
and review the effectiveness of the system;
Every safety management system shall deal with preparedness for emergencies.
Review of NZ King Salmon’s own Safety Management System, encompassing the same criteria and
focal points (main bones in line with topics identified by Maritime New Zealand when evaluating
compliance of Safety Management Systems with the Code), shows that that NZ King Salmon Safety
Management System is entirely supportive of the objectives and standards of the Code. Refer the
‘fishbone’ diagram below.
Accordingly, the established capability of the NZ King Salmon Safety Management System together
with the information the MDC Harbourmaster can uplift from the detailed risk assessment covered
by this report should contribute to Marlborough District Council’s achievement of compliance with
both the requirements and principles of the Code so as to ultimately underpin …”prevention of
human injury or loss of life, and avoidance of damage to the environment, in particular to the
marine environment and to property.”
4 Extracted from Clause 2.2.1 of The Code and Annex I of this report.
NZ King Salmon Risk Assessment Rev: 1 Page 10 of 63

NZ King Salmon Safety Management System Framework
Global Trust
certification audits
Audit & Review
Audit Schedule - based
on risk, status & importance
Process, objectives,
performance indicators
Accidents/ Incidents
Improvements, changes, issues
Internal Audits
& Inspections
Safe Ship Management Audits
Environmental Conditions
Data loggers
Farm
design
Splicing
standards
Approved
engineering
designs
Risk Awareness
Load testing
Implementation
Internal SSM reviews
Farm servicing
Vessel Surveys
Net management
Farm manning
& rostering
Knowledge
base
Manufacturing &
Installation
specialist
review
NZKS environmental
workplace inspections
HASNO certificates
Internal H&S reviews
WSMP Audits
Training Manuals
Organisation &
Individuals
NZ King Salmon Risk Assessment Rev: 1 Page 11 of 63
Training
Pre-requisites for training
Safety Focus
MDC consent
Training Records
monitoring Training Information
NZKS Induction
Contractor
Management
Aids to Navigation
Audits (HM)
Net audits
Approved Suppliers
Procurement
Maintenance
Routines
Mooring audits
Diver audits
5S programme
audits
Environmental policy
monitoring audits
Accountabilities &
Responsibilities
Sea Cage Manual
Organisational
Structure
Daily meetings
Reporting
Business Management
System
Safety objectives
Field Team Manual
Harvest Manual
Confined
Space
Netloft Manual
Farm/pen towing
agreements
Fire
Emergency
Training
Designated Person
Ashore (SSM)
Risk Assessment
Fish health
training
First aid
training
Key stakeholder
liaison
Review
Policy
Risk
Controls Identified
Hazard Identification & controls
Vessel operator
training
Policies
Health & Safety Manual
Diver training
NZQA affiliation SITO (Seafood Industry
Training Organisation)
Assessment
of stakeholder
needs
Controls
assessed
Refresher training
SSM policies
Vessel
operation
policy
NZKS H&S Policy
NZKS
Environmental
Management
Policy
Hazard
registers
Incident Procedures
Emergency Procedures
Communications
Systems
PPE
Permits
Maintenance
plan
Consents
Safety Plan
NZ Salmon Farmers Association Inc.
Finfish Aquaculture Environmental Code
of Practice
Delegations & Responsibilities
Emergency Exercises
Regular drills
Oil spill drills
Diver drills
Follow Up
Fire drills
Accident/Near Miss
Procedures
Accident/incident
investigation
Safe Salmon
Farms
Compliance with
NZ Port & Harbour Safety Code
Compliance with
Aquaculture Guidelines

6 Risk Assessment Key Steps
Risk assessment key steps comprise:
Risk familiarisation and information gathering
Risk identification
Create a risk inventory
Risk analysis & evaluation
Risk treatment
Monitor & review
Each step is detailed as follows.
6.1 Risk familiarisation and information gathering:
Study of key documents including:
NZ King Salmon plan change application
o Navigation Report (David Walker)
o Engineering Report (OCEL)
o The King Salmon Report
MDC Risk assessments
Review NZ King Salmon’ documents:
o Sea cage manual (Selected sections):
Oil spill plan
Threats
Contractors safety handbook
Emergency procedures
Sea cage maintenance
Hazard ID register Picton seafarms
Vessel operation policy
o Vessel Safe Ship Management Manual
o Environmental policy
o Maintenance schedules & reports
o OCEL construction drawings of existing farms
o OCEL Preliminary engineering & layout drawings of proposed farms
o Consultation reports
Seafarm familiarisation visits to:
Clay Point
Ruakaka
Proposed Tory Channel Seafarm sites:
o Ngamahau
o Ruaomoko
o Kaitapeha
NZ King Salmon Risk Assessment Rev: 1 Page 12 of 63

Interviews with NZ King Salmon staff and selected stakeholders.
Attend two typical management meetings:
Morning LEAN meeting
Seafarm shift handover meeting – Ruakaka Farm
6.2 Risk identification:
Identify the risks associated with salmon farms based on information from the risk inventory
workshop, NZ King Salmon meetings, site visits and subsequent discussions and meetings with key
stakeholders.
6.3 Create a Risk Inventory
The risk inventory is a vital component of risk management. Unless it is known exactly what is being
managed, it will not be possible to identify all the sources of risk.
A risk inventory workshop conducted with a cross section of King Salmon staff using a formal,
structured approach and EOS Ltd’s templates. Workshop participants were:
Mark Gillard – Operations and Contracts Manager
Mitch Rowe – Engineering and Facilities Manager
Damian Cotton – Seafarm Area Manager
Baz Henare – Harvest Manager (Ex-Field Team Manager)
Salvador Delgado – Seafarm Area Manager
Sandy Pont – Risk Analyst
John Colebrook – Director EOS Ltd
The workshop participants were taken through the risk assessment process and
introduced/refreshed on the MNZ Code & Guidelines.
This was followed by discussions and feedback from:
Charles Park – Seafarm Area Manager
Jason Watene – Aqua Field Team & Vessel Master
Grant Lovell – Outgoing Harvest Manager
Ian Robertson – Seafarm Operations Manager
Gail Learmonth – Aqua Net Loft
Andy Fairhall – Engineering Project Development Manager
Marjorie O’Doherty - Aquaculture Technician of the Fish Performance Trial Area
Bob Metcalf - Maintenance Supervisor
Dave Eastman - Mechanic
Chris Rossiter - Aquaculture Technician
Bill Woollcombe - Aquaculture Technician
Barry Van Velzen - Aquaculture Technician
Andrew Turnbull - Aquaculture Technician
Allen Hawke – Storeman/Driver
NZ King Salmon Risk Assessment Rev: 1 Page 13 of 63

6.3.1 Describe Risk Categories
The following categories were identified from the risk inventory, so risks could be appropriately
grouped:
Human Factors
Events related to a person arising from human factors/errors/decisions (including lack of training,
personal issues, medical conditions, lapse of concentration, commercial pressure, alcohol, drugs,
etc.).
Collision
An event that involves a vessel and either another vessel (including kayak, jetski, seaplane, etc.) or
object (sea pen, sea farm, etc.), which may or may not be moving.
Contact
The act of a vessel contacting a fixed object (salmon farm/pen/barge, etc.).
Environmental
Any event, meteorological, tidal or geological which may have an effect on operations, but which is
outside those experienced in normal daily operations (including wind gusts, restricted visibility,
tsunami, earthquake, predators, biosecurity issues, etc.), especially those events that may cause a
farm to be relocated, or causes increased traffic in the vicinity of a farm (e.g. seal watchers).
Also includes the physical presence of existing and proposed farms (consistent with views of
Relieving MDC Harbourmaster).
Interaction
An event relating to the effect of a stationary or moving object, without contact.
Equipment Failure
The failure of equipment or associated items required for the safe operation of farm activities
(railing, nets, etc.) or equipment failure related to overall operations (including aids to navigation
failure, communication equipment breakdown, etc.).
Fire/Explosion
A fire or explosion.
Grounding
The unintentional or inappropriate grounding of a vessel (including salmon farm/barge/pen).
NZ King Salmon Risk Assessment Rev: 1 Page 14 of 63

Personal Injury
An event that may result in significant harm 5 .
57 risks were identified during the risk inventory workshop. This inventory of risks encompasses
that could potentially cause the farm to be moved (e.g. algae bloom), thereby leading to a potential
navigational risk and some risks that are specific to NZ King Salmon operations only, and took into
account some of the business risks associated with the operation that may lead to a navigational
risk.
The Relieving MDC Harbourmaster drew focus to an additional risk (related to the physical presence
of the proposed farms), which was added to the risk assessment (split out to two risks to highlight
the proposed farms in the Tory Channel). The Relieving MDC Harbourmaster noted that some of
the risks were within the context of NZ King Salmon operations only and will reside within its own
safety management system. However, he acknowledged the merit of NZ King Salmon’ rounded
approach to risk assessment.
A number of risks identified by NZ King Salmon have also been assessed by the MDC Navigational
Risk Assessment and the MDC Risk Navigational Risk Assessment review (refer Annex G). However,
it was felt that it was important to assess the risks in relation specifically to NZ King Salmon
operations and not marine farms in general, therefore 5 related risks in 2005 and 6 in 2009 were
identified and subject to NZ King Salmon workshop analysis.
Risks were grouped by category - refer Annex C List of Risks.
Risk Areas were identified (each existing & proposed farm).
Risks applicable to each area were assigned to each area – refer Annex D Risks within each
Farm/Proposed Farm Risk Area.
6.4 Risk analysis & evaluation:
Select staff for risk analysis workshop and calibrate workshop participants on risk tables and criteria
within the boundaries of the Guidelines, the Ministry for the Environment Aquaculture Risk
Management Options balanced with NZ King Salmon’ desired risk profile.
Mark Gillard – Operations and Contracts Manager
Mitch Rowe – Engineering and Facilities Manager
Damian Cotton – Seafarm Area Manager
Baz Henare – Harvest Manager (Ex-Field Team Manager)
Sandy Pont – Risk Analyst
John Colebrook – Director EOS Ltd
5 As defined in the current version of the NZ Health & Safety in Employment Act 1992
NZ King Salmon Risk Assessment Rev: 1 Page 15 of 63

Determine the frequency of the mostly likely and worst credible consequences of each risk using
expert opinion (since the inception of salmon farms in the Marlborough Sounds) and referenced to
historical data and event statistics .
Assign risk ratings from the risk matrix to each risk for the 4 consequence categories and apply an
overall risk rating to each risk.
No risks overall were identified as significant (refer Section 10 for details) , five risks were identified
as having significant individual consequence ratings and have been identified as needing further
scrutiny and attention of mitigations associated with the risks.
Post workshop, one risk that was highlighted by a number of stakeholders, was given full scrutiny, in
the form of detailed analysis. This was not due to its high ranking, however, due to the level of key
stakeholder comment – Risk EF4 - Mooring System Fails. Refer to Section 8 of this document for
detailed analysis.
Input on the risks and the scores by the following key stakeholders was sought. Risks and scores
were then refined and updated
Selected workshop participants
MDC Relieving Harbourmaster
OCEL Design Engineer
NZ King Salmon Engineering and Support Services Manager
Strait Shipping (including Master)
Interislander (including Master)
Marlborough Sounds Maritime Pilots (including Pilot)
Port Marlborough New Zealand Limited (including Pilot)
McManaway Tug & Barge (including Tug Master)
Kenny Barging Limited (including Barge Master)
Selected NZ King Salmon staff (including Human Resources)
Other stakeholders comments were taken into account based on previous extensive
consultation as per Annex H
EOS Ltd Risk Analyst
6.5 Risk treatment:
Controls were discussed and identified during the risk inventory and analysis workshops, seafarm
visits and subsequent focal group meetings e.g. Engineering & Maintenance meetings.
Controls were assessed and evaluated for criticality and effectiveness resulting in assignment of
indicators for controls that merit improvement/implementation.
A full list of controls and ratings is detailed at Annex E.
NZ King Salmon Risk Assessment Rev: 1 Page 16 of 63

6.6 Monitor and review:
Ensures the risk management system and changes that may effect it are recognised. The NZ King
Salmon risk assessment should be subject to ongoing update, review, performance assessment,
validation of controls or necessary modifications to controls and will ensure the risk management
plan remains relevant by recognising changing factors that may affect the likelihood or consequence
of a risk, including integration of newly identified risks.
It is recommended this be most appropriately dealt to by the establishment of a Risk Improvement
& Management plan to be put in place prior to the initial placement of the first salmon farm
structures being installed.
It is anticipated that NZ King Salmon’ Risk Improvement & Management Plan will be subject to audit,
consistent with the control and compliance provisions of the Guidelines for Aquaculture
Management Areas and Marine Farms.
NZ King Salmon Risk Assessment Rev: 1 Page 17 of 63

6.7 Risk Tables & Formulae
Consistent with Para 2.2 6 the risk assessment has considered the needs of King Salmon in relation to
the Port & Harbour and has consequently modified some of the risk assessment criteria and
guidelines. King Salmon operations are neither Port nor Harbour (is in a harbour).
In deriving the most appropriate risk tables for the NZ King Salmon risk assessment, we have been
mindful of:
The customisation of the MNZ Guidelines for risk assessment by MDC.
Contemporary experience with other risk assessment reports submitted to and approved by
MNZ.
The recognition that NZ King Salmon is neither a port nor a harbour.
NZ King Salmon’ desired risk profile (less conservative than may be expected of a Port or
Harbour Regulating Authority).
The resulting detailed risk assessment spreadsheet data (at Annexes A & B) can be easily uplifted
and integrated into the MDC risk assessment database and will be duly conditioned into the MDC
risk profile by the HAZMAN software manipulation.
6.7.1 Frequency
Using the frequency table the risk assessment team was asked for what they considered was the
most frequent for the most likely consequences and the most frequent for worst credible
consequences based on historical recording, local knowledge, recent incidents and near misses.
Rating Frequency
5 Frequent 1 or more times per year
4 Likely 1 or more times per 5 years
3 Possible 1 or more times per 10 years
2 Unlikely 1 or more times per 100 years
1 Rare (may have occurred elsewhere) Less than once per 100 years
The frequencies were chosen after careful consideration of the frequency tables published in both
the Port & Harbour Risk Assessment Guidelines (a 5 scale table, with 1 the most frequent and 5 the
rarest at occurring less than once in 1000 operating years) and the Aquaculture Risk Management
Options (produced for the Ministry for the Environment) (with 5 the most the frequent and 1 the
rarest occurring less than once per 50 year), and the duration of the consent for the farms (35
years).
A conservative approach has been taken (a 5 scale table with 5 the most the frequent and 1 the
rarest occurring less than once per 100 years), which also allows an operational focus of
improvement of controls, given the rapid changes in this relatively young industry.
6 The Guidelines
NZ King Salmon Risk Assessment Rev: 1 Page 18 of 63

6.7.2 Consequence
The following table was based on the MNZ Port & Harbour Risk Assessment Guidelines to determine likely/actual (in the case of known events)
consequences for most likely and worst credible scenarios:
Consequence People NZ King Salmon
business &
Property
C1
(insignificant)
C2
(minor)
C3
(moderate)
C4
(major)
C5
(catastrophic)
Possibly very minor
injury (e.g. bruise)
Single slight injury $20 000 to
$100 000
multiple minor or
single major injury
multiple major injuries
or a single fatality
NZ King Salmon Risk Assessment Rev: 1 Page 19 of 63
Environment Stakeholders business
and property

6.7.3 Risk Matrix
Risks have been displayed using a two-dimensional map, (sometimes called a heat map, where
colour coding is used and red is the hottest or sometimes called a risk matrix or risk map). MNZ
Guidelines call this a derived risk matrix.
A standard 5 x 5 risk map (matrix) was utilised. Using the values assigned to consequence and
frequency, a risk factor was obtained with the factor scaled from 1 (low risk) to 10 (high risk) as per
the table below.
This table (slightly different to MNZ’s and MDC’s) supports an operational focus and places more
attention on those risks of high frequency, that may well have near miss (minor or low consequence)
history, but could potentially have high consequences. This also supports NZ King Salmon’ desired
risk profile.
Following Bird’s “Accident Pyramid” principles, NZ King Salmon feels it important to place emphasis
on frequent events that may occur as opposed to directing a major effort only at the relatively few
events resulting in significant consequences when there are so many opportunities that provide a
much larger basis for more effective control of risks.
This is also an approach that supports a focus on the recreational boating community, where
consequences may be much lower than damage to a ferry, for example, but merit attention,
considering the local environment and range of harbour traffic.
5 (2) 2 4 6 8 10
4 (1.75) 1.75 3.5 5.25 7 8.75
3 (1.5) 1.5 3 4.5 6 7.5
2 (1.25) 1.25 2.5 3.75 5 6.25
1 (1) 1 2 3 4 5
Factor 1 2 3 4 5
Consequence Frequency
The overall risk rating was calculated using the following formula:
The highest individual consequence ratings of most likely (people, property, environment,
stakeholder) + highest individual consequence rating of the worst credible (people, property,
environment, stakeholder) – then matched to a scale of 1 to 10 to ultimately determine the
risk significance.
It is anticipated that risks selected by the Harbourmaster for integration into the MDC Risk
Assessment, will be subject to the proprietary formula and rating system embedded in the HAZMAN
database.
It is further anticipated that the information contained in this document will form part of the MDC
Port & Harbour Safety Management System.
NZ King Salmon Risk Assessment Rev: 1 Page 20 of 63

6.7.4 Risk Rating Significance
As per colours on detailed spreadsheets at Annexes A & B:
Risk Rating Risk Definition Action
1, 2 & 3 low Risks managed by current controls and
procedures
4, 5 & 6 tolerable Risks within ALARP area, procedures and controls
to be reviewed
7 & 8 significant Risk not acceptable except in unusual
circumstances, procedures and controls to be
reviewed to reduce risk to ALARP area
9 & 10 high Immediate action required or activity to be
discontinued
The As Low As Reasonably Practicable (ALARP) principle is applied to reflect that there may be a
number of risks that should only be tolerated if risk control measures in place provide risk reduction
into the ALARP region. If risk ratings cannot be reduced into the ALARP region without excessive
cost or disruption, the risk requires urgent review and the operation may need to cease.
A band of 4 categories were used (as opposed to MNZ’s 6 and MDC’s 5), in order to facilitate a more
streamlined approach for management of the risks and clearly focus on those risks occurring above
the low and ALARP categories.
NZ King Salmon Risk Assessment Rev: 1 Page 21 of 63

7 Controls
Risk Controls were grouped into the following 7 control types:
Legislation, Codes, Best Practices, etc. (not subject to KS control)
KS SOPs, Policies
KS Exercises & Drills, Audits, Certificates
KS Training & Qualifications
Farm Design, Testing, Audits (Inspections)
Consents & Permits
KS Health & Safety & Emergencies
The controls were then further broken down, as detailed in Annex E.
Particular emphasis was placed on the assessment of Control 5, Farm Design, discussions were held
with King Salmon, OCEL, EOS and Navigatus representatives.
Each individual control was assessed for criticality against the following scale:
1 2 3 4 5 6 7 8 9 10
Not critical
Has little
contribution to
mitigation
Each individual control was assessed for effectiveness according to the following table:
Nothing is in
place,
Control not
implemented
Controls were assessed for review priority according to the following table:
Control requires
monitoring only
Supportive
Satisfies safety
policy and
regulation
Control requires
review in longer
term
Important
Necessary for
best practice
Control requires
attention to
improve
mitigation of
risks
Vital
Mitigation
relies on this
control
Control warrants
priority attention
to mitigate risk
NZ King Salmon Risk Assessment Rev: 1 Page 22 of 63
Critical
Absolutely essential
for mitigation
1 2 3 4 5 6 7 8 9 10
Very little is in
place
Improvements in
progress
Reasonable
measures are in
place, controls
not fully
implemented
Everything
practicable is in place
and fully
implemented
Normal Low Medium High Urgent
Control requires
urgent attention to
mitigate risk

The following controls with high criticality and low effectiveness ratings were identified for high
priority review for improvement/ completion/ implementation/action:
Controls Criticality Effectiveness
How
effectively
has KS
implemented
these
Legislation (not subject to KS control)
Aquaculture Risk Management Options – Ministry for the
Environment (Clause 4.6.4 – yet to complete analysis “for
potential of increased risk, particularly from tidal and
tsunami events”)
KS SOPs, Policies
Mooring manual – documentation under development
established practices in place
NZ King Salmon Risk Assessment Rev: 1 Page 23 of 63
controls
Status
10 6 High
6 1 High
KS Exercises & Drills, Audits, Certificates
Fire drills 8 6 High
Oil spill drills 8 6 High
Diver evacuation drills
KS Training & Qualifications
8 6 High
KS Seacage Training manual (incl. information)
8 4 High
Due for review & update
Confined space training 10 6 High
Fire training 10 6 High
First aid training
KS Health & Safety & Emergencies
10 6 High
Crisis management plans for events:
Catastrophic damage to structures that impact on fish
containment or affect the environment
6 1 High
Tsunami response plan – site specific plans to be done
Under development for Ruakaka & most sites
Farm Design, Maintenance, Testing & Audits
5 3 High
Inventory control – segregation of critical mooring items 10 6 High
Emergency plans 7 6 High
Tsunami response plan
Site specific plans to be developed, under way for
Ruakaka & most sites
5 3 High
Crisis management 6 1 High
The above findings, identifying a need to improve risk controls in a range of areas, is typical in the
experience of EOS Ltd for an organisation at this stage of development of risk control and safety
management systems and illustrates how a continual improvement approach works in practice. It is
anticipated that action on the controls above would readily be within NZ King Salmon’ capability.
Note: MDC control status as at 2009 related to salmon farm controls are extracted from the MDC
Risk Review and included at Annex F.

8 Selected Risk for Detailed Analysis – Bowtie Analysis
Based on comments by key Stakeholders, Risk EF4 (Mooring system fails), ranked no. 34 in the risk
assessment, was selected for detailed review and analysis. Although this ranks low in the overall risk
rating, there is a high focus on ensuring the farm does not break free and drift into the channel
causing a navigational hazard for ferries and other large commercial traffic.
Also of importance when assessing this risk, are the numbers and spread of controls associated with
preventing the risk from occurring, i.e. there is not just one control preventing this event from
happening.
The Bowtie method was selected to analyse the event of a farm breaking adrift.
Preventive
controls
Event
Recovery
preparedness
This method goes beyond the usual risk assessment snapshot and puts emphasis on the linkage
between risk controls and the management system. It can help to ensure that risks are truly
managed, rather than just analysed. It forces the undertaking of a comprehensive and structured
approach.
NZ King Salmon Risk Assessment Rev: 1 Page 24 of 63

Bowtie analysis showing Causes (Blue), Event (centre) & Impacts (Red)
Event – what is the risk?
Cause – what could cause the risk to happen?
Impact – how can the event develop? What are the worst outcomes?
NZ King Salmon Risk Assessment Rev: 1 Page 25 of 63

Bowtie analysis showing Preventive Controls (boxes on the left of the Event) & Preparedness Controls (boxes on the right)
Preventive controls – how is the event prevented from occurring? How is control kept?
Preparedness controls – how is recovery made once the event occurs? How is severity of the event limited?
NZ King Salmon Risk Assessment Rev: 1 Page 26 of 63

Bowtie analysis showing Preventive Escalation Controls & barriers (yellow boxes and boxes linked to yellow boxes) on left, Mitigating Escalation Controls & barriers (yellow boxes and boxes linked to yellow boxes) on right
Escalation Control – how might controls fail? How could their effectiveness be undermined? How do we make sure the controls do not fail?
NZ King Salmon Risk Assessment Rev: 1 Page 27 of 63

In summary, there are numerous controls that contribute to both prevention and mitigation of the
event, spread across a variety of control types:
Control Type Control Detail
Isolation Cross over separation of lines
Passage planning
Farm lighting
Designated farm consent areas
Selection of farm locations
Elimination Farm worker presence (sabotage)
HM authority to remove navigation hazard
Providing more
information
Decreasing the
consequences
Implementing standard
procedures
Knowledge base on engineering controls
Load cell information & analysis
Harbour charts
AIS transponder
Analysis of weather & tidal conditions
Dynamic farm behaviour
Tsunami modelling
Local knowledge
Changing load cell location
Weekly diving inspections
Daily visual inspections by farm workers
Improvement initiatives
NZCD tsunami warning system
NZCD tsunami preparedness plans
PHR communications
Navigation warnings
MDC HM emergency & contingency plans
Vessel emergency & contingency plans
NZ King Salmon emergency & contingency plans
Vessel master/crew experience
Splicing standards & competency
Farm communications
Inventory control
Procedures for mooring line release
Engineering controls Procurement specifications
Supplier selection
Mooring line anchor integrity
Torque analysis of anchor installation
Anchor installation standards
Training & preparedness Splicing standards & competency
Vessel radar & watchkeeping
Risk assessments
Accident/incident investigation
Master/crew experience
Resourcing & rostering
Maintenance controls Maintenance plan
Maintenance strategy & schedule
Selected line annual refurbishment
Net cleaning
Legislative controls Maritime Rules
MD Nav Bylaws
SOLAS requirements
NZ King Salmon Risk Assessment Rev: 1 Page 28 of 63

Two areas of control merit elaboration:
the role of engineering design, and
the experience and competency of commercial vessel/ferry masters and crew.
Both of these areas of control have been the subject of substantial discussion during the risk
analysis.
8.1.1 Engineering Design
Detailed discussions with the specialist structural and mooring system design engineer from
Offshore and Coastal Engineering Limited (OCEL), and NZ King Salmon engineering & maintenance
personnel, has highlighted a number of important matters related to the basis of design (the design
case) for the proposed new Salmon Farms, namely:
It is noted that a substantial OCEL and NZ King Salmon Body of Knowledge has accrued for
existing NZ King Salmon farms on design data, ‘as-built’ construction detailing, observations
of dynamic response of farm and linked barge structures, monitoring and adjustment of
mooring line loads, equipment specifications, maintenance and continuous improvement
practices.
We are advised by OCEL and NZ King Salmon that the design of the proposed new farms will
uplift and take full advantage of the accrued Body of Knowledge and significant operational
experience. From a risk management perspective it is a widely recognised concept that risks
are greater in circumstances of change. Utilising the present ‘successful’ design, and its
associated well established maintenance practices and operational familiarity, as a
foundation for the new farm design reduces the relative level of change and consequently
must be an acknowledged risk mitigation.
Additionally, comments on the integrity of the farm structure and its mooring system by a
range of stakeholders together with the requirements of Clause 7.1.3 “…proof of fit for
purpose [of the mooring design] should rest with the applicant.”..of Maritime New Zealand’s
Guidelines for Aquaculture Management Areas and Marine Farms leads to a focus on design
integrity and the need for design verification to be performed against a particularly sound
basis of design.
It is also to be noted that the Ministry for the Environment publication “Aquaculture Risk
Management Options”, Clause 4.6.4, Residual risk of adrift farm structures, makes the
comment “In future, more open sea environments may be used for finfish farms. These must
be analysed for the potential of increased risk, particularly from tidal and tsunami events”.
Whilst the author of this statement may well have had coastal rather than Marlborough
Sounds location in mind, the statement highlights that tsunami situations need to be
considered to the engineering basis for design.
The OCEL design engineer advises that there would be further refinement and definition of
the basis of design as the new farm design work transitions from the outline information
contained in his Engineering Feasibility Reports (forming part of the NZ King Salmon plan
change request) to a fully specified basis of design. However, an effective and robust
navigational risk assessment, as is required for this Report, relies on sufficient certainty of
design principles to substantiate the semi-qualitatively determined consequences and risk
NZ King Salmon Risk Assessment Rev: 1 Page 29 of 63

anking in Annexes A and B and to underpin the Bowtie analysis in this Section of Report. In
our view the preliminary engineering design reports taken together with the
recommendations below provide a suitable basis for this risk assessment.
After review of the current design parameters it is recommended that the following design
and maintenance requirements be incorporated into the basis of design for the finished
design verification to be provided to NZ King Salmon & Marlborough District Council (as
intended by the Maritime New Zealand Code, its supporting Guidelines and the Guidelines
for Aquaculture Management Areas and Marine Farms) and in resource consent conditions:
o The mooring system shall be designed and maintained such that the maximum
loading on any mooring is the lesser of 20% of the anchor pullout capacity (as
determined by a test pull out loading carried out on a representative screw anchor
at each farm) or 20% of the mooring line tension capacity after allowing for the
deleterious effects of splices and ties.
o The design, including the design loading, for the anchoring and mooring warp
system shall cater for the maximum wave loading, maximum and minimum spring
tidal levels and currents and for yet to be agreed tsunami conditions (maximum and
minimum currents and water levels) for events of a 250 year average recurrence
level. [It is acknowledged that as there does not appear to be any current Tsunami
modelling or comprehensive data established for the Marlborough Sounds and it
may be more realistic to address tsunami situations in an alternative manner than
the statement proposed.
o The tsunami loadings (currents and water levels at each site) for the design return
period are determined jointly by NZ King Salmon-OCEL-MDC, and potentially
Maritime New Zealand in their advisory role to MDC.
o The farm structure and mooring system shall be designed such that under all design
cases other than tsunami, the failure of a critical component under the design
loading case does not result in the progressive break-up of the structure or
progressive failure of the mooring system.
8.1.2 Experience and Competency of Commercial Vessel/Ferry Masters and Crew
Vessel masters and crew are well experienced in avoiding navigational hazards, including frequent
encounters of vessels unfamiliar with Collision Regulations, vessels breaking down, yacht races, and
other navigational hazards.
Vessel masters ferries and vessels >500GRT advise that in the worst case, should one of their vessel
contact a salmon farm, the farm would either be deflected or bend around the vessel without
breach of hull integrity or impact on vessel manoeuvrability. As such, the farm would sustain the
damage, the vessel would sustain limited damage and that accordingly there is no credible risk to
the vessel integrity or the availability to maintain passenger safety after such an incident.
The Navigation Report 7 has substantial discussion on the considerations, skills and competencies
that vessel masters apply in their regular passage planning that would avoid contact with a salmon
7 Navigation Report by David Walker
NZ King Salmon Risk Assessment Rev: 1 Page 30 of 63

farm. “There is no suggestion from the large vessel community that existing salmon farms are a
hindrance to shipping in the Marlborough Sounds”. During discussions with Masters and Pilots, the
same would apply to the proposed farms. The viewpoint of David Walker was reinforced “It is useful
to consider that these proposed farms are no different to a ship at anchor”.
9 Risk Assessment Summary from MDC Risk Assessments
9.1 2005 Risk Assessment:
2 risks directly associated with marine farms were identified, with a further 19 risks indirectly
associated.
MDC Title MDC Rating KS Title KS Rating
Small vessel or craft in contact ALARP Recreational vessel/pwc/yacht Low
with marine farm
contacts salmon farm
Vessel over 500GRT in contact with
marine farm
ALARP Ferry contacts salmon farm Low
Of the 19 indirect risks, 15 relate to King Salmon’s own vessels and potential incidents with those, 4
relate to vessels that may service the farms.
9.2 2009 Risk Assessment Review:
2 risks directly associated with marine farms were identified, with a further 21 risks indirectly
associated.
MDC Title MDC Rating KS Title KS Rating
Small vessel or craft in contact ALARP Recreational vessel/pwc/yacht Low
with marine farm
contacts salmon farm
Vessel over 500GRT in contact with
marine farm
ALARP Ferry contacts salmon farm Low
Of the 21 indirect risks, 16 relate to King Salmon’s own vessels and potential incidents with those, 4
relate to vessels that may service the farms, one related to a barge hitting a marine farm.
The NZ King Salmon risk assessment focuses on salmon farms (as opposed to all marine farms) and
known events since salmon farming has been an activity in the Marlborough Sounds.
NZ King Salmon Risk Assessment Rev: 1 Page 31 of 63

10 Conclusions & Recommendations
A total of 59 risks were identified. The full list sorted by highest rating is detailed in Annex A, with risks by category at Annex B.
The risk assessment resulted in no risks being identified with overall ratings above ALARP level and five risks with individual ratings above ALARP level,
which were all in Worst Credible scenarios.
These five risks with individual worst credible consequences (and their associated controls) above the ALARP level are identified for NZ King Salmon review:
Incident
Category
Area
PI2 Personal injury All existing & proposed
farm areas
EV7 Environmental Clay Pt, Te Pangu,
Ruakaka Bay,
Ngamahau, Kaitapeha,
Ruaomoko
EV12 Environmental All existing & proposed
farm areas
EV13 Environmental All existing & proposed
farm areas
HF2 Human factors All existing & proposed
farm areas
Incident Detail
Person falls off farm/pontoon/into
water during transfer from tender
NZ King Salmon Risk Assessment Rev: 1 Page 32 of 63
Worst Credible Scenario
People Property Environment Stakeholder
Con Rating Con Rating Con Rating Con Rating
4 7 1 4 1 4 3 6
Strong tidal flows 1 4 4 7 1 4 4 7
Lightning 4 7 2 5 1 4 2 5
Restricted visibility/fog/heavy rain/
night conditions
Sabotage/ Security breach/
vandalism/theft
4 7 2 5 2 5 2 5
1 4 4 7 1 4 4 7
Given NZ King Salmon size, history and stage of development, it has a number of practices and resources that mitigate risk. This report recommends that
NZ King Salmon build on and refine those practices and resources by developing a navigation risk & improvement management plan, including the
improvement and verification of controls. The requirement to have such a plan, as well as to review it both periodically and after any event that impacts
the basis of the risk assessment should be a condition of the consents granted to NZ King Salmon, and will form a basis for an improved level of risk
maturity.

Aside from NZ King Salmon’ fundamental desire to keep its staff farms and the farms secure at all
times, key stakeholders expressed interest in the risk of mooring system failure. This risk of mooring
system failure was given special consideration and responded to by extended scrutiny, in the form of
detailed analysis of the controls that effectively reduce the likelihood and potential consequences of
this risk.
This navigation risk assessment relies on sufficient certainty of design principles for each farm
structure and mooring system. The basis of design is capable of being included in conditions of
consent. A description of those conditions can be found in paragraph 8.1.1 of this report.
NZ King Salmon Risk Assessment Rev: 1 Page 33 of 63

Annex A: Detailed List of Risks by Highest Rating:
NZ King Salmon Risk Assessment Rev: 1 Page 34 of 63

NZ King Salmon Risk Assessment Rev: 1 Page 35 of 63

NZ King Salmon Risk Assessment Rev: 1 Page 36 of 63

Annex B: Detailed List of Risks by Category:
NZ King Salmon Risk Assessment Rev: 1 Page 37 of 63

NZ King Salmon Risk Assessment Rev: 1 Page 38 of 63

NZ King Salmon Risk Assessment Rev: 1 Page 39 of 63

Annex C: List of Risks:
CL1 Collision Vessel collides with salmon farm/pen during tow
CN1 Contact Ferry contacts salmon farm
CN2 Contact
Ferry contacts salmon farm - Ngamahau, Kaitepeha,
Ruaomoko
CN3 Contact Recreational vessel/pwc/yacht contacts salmon farm
CN4 Contact
CN5 Contact
Recreational vessel contacts mooring system (wc causing
mooring line break)
Commercial vessel contacts salmon farm (fishing vessels,
etc.)
CN6 Contact Cruise/naval vessel contacts farm
CN7 Contact Kayak/non-powered vessel contacts farm
CN8 Contact Aircraft/seaplane contacts farm
CN9 Contact Servicing barge contacts farm
CN10 Contact KS Water taxi contacts farm
CN11 Contact Vessel contacts other vessel moored alongside farm
CN12 Contact Knuckle crane contacts farm
GR1 Grounding Seapen/farm grounds during tow
GR2 Grounding Contracted tug grounds during tow of farm/seapen
GR3 Grounding KS accomodation/feedstorage farm barge sinks
GR4 Grounding Contracted dumb barge sinks
GR5 Grounding Mortality storage bin sinks
GR6 Grounding Seapen sinks
FR1 Fire KS accomodation/feedstorage barge catches fire
FR2 Fire Fuel storage locker catches fire
EX1 Explosion LPG gas leak
PI1 Personal injury Diving injuries/entanglement in net/ropes
PI2 Personal injury
Person falls off farm/pontoon/into water during transfer
from tender
EV1 Environmental Oil/petrol/diesel/chemical spill
EV2 Environmental Accidental blackwater discharge
EV3 Environmental Seal interaction
EV4 Environmental Bird interaction
EV5 Environmental Jellyfish
EV6 Environmental Other predators
EV7 Environmental Strong tidal flows
EV8 Environmental Biosecurity event
EV9 Environmental Algae bloom
EV10 Environmental Inclement weather/high winds/wind gusts/swell/surge
EV11 Environmental Tsunami (12hr warning)
EV12 Environmental Lightning
EV13 Environmental Restricted visibility/fog/heavy rain/ night conditions
NZ King Salmon Risk Assessment Rev: 1 Page 40 of 63

EV14 Environmental Weeds/seaweed
EV15 Environmental Volcanic eruption
EV16 Environmental Earthquake
EV17 Environmental Existing salmon farm structures
EV18 Environmental Proposed salmon farm structures
EF1 Equipment failure Towline failure during salmon farm/pen tow
EF2 Equipment failure Railing fails & net collapses
EF3 Equipment failure Mooring line fails
EF4 Equipment failure Mooring system fails
EF5 Equipment failure Hydraulic line failure
EF6 Equipment failure Farm supplies/equipment falls into sea
EF7 Equipment failure Servicing barge ramp fails
EF8 Equipment failure Aid to Navigation fails - lighting
EF9 Equipment failure Aid to Navigation fails - AIS transponder
EF10 Equipment failure Communication (VHF/cellphone reception) breakdown
EF11 Equipment failure Vessel mooring line failure (when moored alongside farm)
IN1 Interaction Vessel wake/wave (wc causes damage or mooring breakout)
IN2 Interaction Vessel wake/wave causes vessel alongside mooring failure
HF1 Human factors
KS Procedures, policies/legislation/Bylaws/Maritime Rules
infringed
HF2 Human factors Sabotage/ Security breach/ vandalism/theft
HF3 Human factors Failure to report accidents/near misses etc.
HF4 Human factors Commercial pressure/budgetary contraints - lack of
resources (shifts/contractors/barge operators/ divers,
maintenance, etc.)
NZ King Salmon Risk Assessment Rev: 1 Page 41 of 63

Annex D: Risks within each Farm/Proposed Farm Risk Area:
Code Risk Type Risk Detail
CL1 Collision Vessel collides with salmon farm/pen during tow X X X X X X X X X X X X X X X X X X
CN1 Contact Ferry contacts salmon farm X X X
CN2 Contact
Ferry contacts salmon farm - Ngamahau, Kaitepeha,
Ruaomoko
NZ King Salmon Risk Assessment Rev: 1 Page 42 of 63
Crail Bay 1
Crail Bay 2
Waihinau
Forsyth
Otanerau
Clay Point
Te pangu
Ruakaka
Kaitapeha
Ruaomoko
Ngamahau
X X X
CN3 Contact Recreational vessel/pwc/yacht contacts salmon farm X X X X X X X X X X X X X X X X X X
CN4 Contact Recreational vessel contacts mooring system X X X X X X X X X X X X X X X X X X
CN5 Contact
Commercial vessel contacts salmon farm (fishing
vessels, etc.)
X X X X X X X X X X X X X X X X X X
CN6 Contact Cruise/naval vessel contacts farm X X X X X X X X X X X X X X X X X X
CN7 Contact Kayak/non-powered vessel contacts farm X X X X X X X X X X X X X X X X X X
CN8 Contact Aircraft/seaplane contacts farm X X X X X X X X X X X X X X X X X X
CN9 Contact Servicing barge contacts farm X X X X X X X X X X X X X X X X X X
CN10 Contact KS Water taxi contacts farm X X X X X X X X X X X X X X X X X X
CN11 Contact Vessel contacts other vessel moored alongside farm X X X X X X X X X X X X X X X X X X
CN12 Contact Knuckle crane contacts farm X X X X X X X X X X X X X X X X X X
GR1 Grounding Seapen/farm grounds during tow X X X X X X X X X X X X X X X X X X
GR2 Grounding Contracted tug grounds during tow of farm/seapen X X X X X X X X X X X X X X X X X X
GR3 Grounding KS accomodation/feedstorage farm barge sinks X X X X X X X X X X X X X X X X X X
GR4 Grounding Contracted dumb barge sinks X X X X X X X X X X X X X X X X X X
GR5 Grounding Mortality storage bin sinks X X X X X X X X X X X X X X X X X X
GR6 Grounding Seapen sinks X X X X X X X X X X X X X X X X X X
FR1 Fire KS accomodation/feedstorage barge catches fire X X X X X X X X X X X X X X X X X X
Kaitira
Tapipi
Richmond
Waitata
White
Papatua
Melville

Code Risk Type Risk Detail
FR2 Fire Fuel storage locker catches fire X X X X X X X X X X X X X X X X X X
EX1 Explosion LPG gas leak X X X X X X X X X X X X X X X X X X
PI1 Personal injury Diving injuries/entanglement in net/ropes X X X X X X X X X X X X X X X X X X
PI2 Personal injury
Person falls off farm/pontoon/into water during
transfer from tender
NZ King Salmon Risk Assessment Rev: 1 Page 43 of 63
Crail Bay 1
Crail Bay 2
Waihinau
Forsyth
Otanerau
Clay Point
Te pangu
Ruakaka
Kaitapeha
X X X X X X X X X X X X X X X X X X
EV1 Environmental Oil/petrol/diesel/chemical spill X X X X X X X X X X X X X X X X X X
EV2 Environmental Accidental blackwater discharge X X X X X X X X X X X X X X X X X X
EV3 Environmental Seal interaction X X X X X X X X X X X X X X X X X X
EV4 Environmental Bird interaction X X X X X X X X X X X X X X X X X X
EV5 Environmental Jellyfish X X X X X X X X X X X X X X X X X X
EV6 Environmental Other predators X X X X X X X X X X X X X X X X X X
EV7 Environmental Strong tidal flows X X X X X X
EV8 Environmental Biosecurity event X X X X X X X X X X X X X X X X X X
EV9 Environmental Algae bloom X X X X X X X X X X X X X X X X X X
EV10 Environmental
Inclement weather/high winds/wind
gusts/swell/surge
X X X X X X X X X X X X X X X X X X
EV11 Environmental Tsunami (12hr warning) X X X X X X X X X X X X X X X X X X
EV12 Environmental Lightning X X X X X X X X X X X X X X X X X X
EV13 Environmental Restricted visibility/fog/heavy rain/ night conditions X X X X X X X X X X X X X X X X X X
EV14 Environmental Weeds/seaweed X X X X X X X X X X X X X X X X X X
EV15 Environmental Volcanic eruption X X X X X X X X X X X X X X X X X X
EV16 Environmental Earthquake X X X X X X X X X X X X X X X X X X
EV17 Environmental Existing salmon farm areas X X X X X X X X
EV18 Environmental Proposed salmon farm areas X X X X X X X X X X
Ruaomoko
Ngamahau
Kaitira
Tapipi
Richmond
Waitata
White
Papatua
Melville

Code Risk Type Risk Detail
EF1
EF2
EF3
EF4
EF5
EF6
EF7
EF8
EF9
EF10
EF11
Equipment
failure Towline failure during salmon farm/pen tow
Equipment
failure Railing fails & net collapses
Equipment
failure Mooring line fails
Equipment
failure Mooring system fails
Equipment
failure Hydraulic line failure
Equipment
failure Farm supplies/equipment falls into sea
Equipment
failure Servicing barge ramp fails
Equipment
failure Aid to Navigation fails - lighting
Equipment
failure Aid to Navigation fails - AIS transponder
Equipment
failure
Equipment
failure
Communication (VHF/cellphone reception)
breakdown
Vessel mooring line failure (when moored alongside
farm)
NZ King Salmon Risk Assessment Rev: 1 Page 44 of 63
Crail Bay 1
Crail Bay 2
Waihinau
Forsyth
Otanerau
Clay Point
Te pangu
Ruakaka
Kaitapeha
X X X X X X X X X X X X X X X X X X
X X X X X X X X X X X X X X X X X X
X X X X X X X X X X X X X X X X X X
X X X X X X X X X X X X X X X X X X
X X X X X X X X X X X X X X X X X X
X X X X X X X X X X X X X X X X X X
X X X X X X X X X X X X X X X X X X
X X X X X X X X X X X X X X X X X X
X
X X X X X X X X X X X X X X X X X X
X X X X X X X X X X X X X X X X X X
IN1 Interaction Vessel wake/wave X X X X X X X X X X X X X X X X X X
IN2 Interaction
Vessel wake/wave causes vessel alongside mooring
failure
X X X X X X X X X X X X X X X X X X
Ruaomoko
Ngamahau
Kaitira
Tapipi
Richmond
Waitata
White
Papatua
Melville

Code Risk Type Risk Detail
HF1 Human factors
KS Procedures, policies/legislation/Bylaws/Maritime
Rules infringed
NZ King Salmon Risk Assessment Rev: 1 Page 45 of 63
Crail Bay 1
Crail Bay 2
Waihinau
Forsyth
Otanerau
Clay Point
Te pangu
Ruakaka
Kaitapeha
X X X X X X X X X X X X X X X X X X
HF2 Human factors Sabotage/ Security breach/ vandalism/theft X X X X X X X X X X X X X X X X X X
HF3 Human factors Failure to report accidents/near misses etc. X X X X X X X X X X X X X X X X X X
HF4 Human factors
Commercial pressure/budgetary constraints - lack of
resources
X X X X X X X X X X X X X X X X X X
Ruaomoko
Ngamahau
Kaitira
Tapipi
Richmond
Waitata
White
Papatua
Melville

Annex E: Full List of Controls & Control Adequacy Rating & Priorities:
Controls
Legislation & Publications (not subject to KS control)
Criticality Effectiveness
(How
effectively has
KS
implemented
these controls)
Status Control Detail/ Notes
NZ Salmon Farmers Association Inc. Finfish Aquaculture
Environmental Code of Practice
10 10 Normal Recent audit
Resource Management Act 1991 10 10 Normal
Agricultural Compounds and Veterinary Medicines Act 1997 10 10 Normal
HASNO Act 1996 10 10 Normal
Fisheries Act 1996 10 10 Normal
Biosecurity Act 1993 10 10 Normal
Marine Mammals Protection Act 1978 10 10 Normal
Aquaculture Reform (Repeals and Transitional Provisions) 10 10 Normal
Act 2004
Animal Welfare Act 1999 10 10 Normal
Maritime Transport Act 1994 10 10 Normal
Local Government Act 2002 10 10 Normal
Department of Labour Code of Practice for Diving 10 10 Normal
Australian Diver Accreditation Scheme (AIDAS) 10 10 Normal
Health Safety in Employment Act 1992 and Amendment 10 7 Medium Hazard registers for sea farms in place
2002
Crimes Act 1961 10 10 Normal
Employment Relations Act 2000 10 10 Normal
Electrical Act 1992 and Amendments 10 10 Normal
Conservation Act 1987 10 10 Normal
MAF approval for transfer between farms: 10 10 Normal
NZ King Salmon Risk Assessment Rev: 1 Page 46 of 63

Controls Criticality Effectiveness
(How
effectively has
KS
implemented
NZ King Salmon Risk Assessment Rev: 1 Page 47 of 63
these controls)
Status Control Detail/ Notes
Fresh water fish farming regulations 1983
Harbour Charts 10 10 Normal Updated under SSM system
Notice to Mariners 10 10 Normal
MDC Navigation Bylaw 2009 16 August 2010 10 10 Normal
MDC Navigation (Vessel Speed) Bylaws 2009 1 July 2010 10 10 Normal
MDC Harbourmaster Directions
10 10 Normal
2011/1 and 2010/02
MNZ Guidelines for Risk Assessment 10 10 Normal
MNZ Guidelines for Aquaculture and Marine Farming 10 7 Medium Safety management system definition
is under development
MNZ Safe Ship Management System 10 10 Normal
MNZ Rules 10 10 Normal
MNZ Rule 22 Collision Regulations 10 10 Normal
Aquaculture Risk Management Options – Ministry for the
Environment
SOLAS Convention 10 10 Normal
KS SOPs, Policies
KS Health & Safety Manual
H&S Policy
Environmental management policy
Contractor H&S Handbook
hazard registers
accident reporting
fatigue management
10 6 High Clause 4.6.4 – yet to complete analysis
“for potential of increased risk,
particularly from tidal and tsunami
events”
8 7 Medium

Controls Criticality Effectiveness
(How
effectively has
KS
implemented
KS Seacage Manual – incl.
oil spill
environmental monitoring
threats (mammals, seals, jellyfish, algae)
diving
OSH policy
Emergency procedures
Vessel operations (part of SSM)
NZ King Salmon Risk Assessment Rev: 1 Page 48 of 63
8
these controls)
7 Medium
Status Control Detail/ Notes
Mooring manual 6 1 High Documentation under development –
well established practices are in place
Harvest manual 6 7 Low under update 90% complete
Field Team Manual 8 9 Normal
Netloft Manual – under development 6 6 Medium Final draft
Letter of agreement on salmon farm/pen tows 6 7 Low King Salmon/Interislander
KS Exercises & Drills, Audits, Certificates
Fire drills 8 6 High
Oil spill drills 8 6 High
Diver evacuation drills 8 6 High
Global Trust Certification Body audits 8 9 Normal
KS Environmental workplace inspection audit 7 7 Medium Annual by Ops & Contracts Mgr
HASNO stationary tank certificates 10 10 Normal 5 yearly audits
HASNO location test certificates 10 10 Normal Annual audits
ACC WSMP Tertiary Level Programme – see Lisa Stevenson 6 10 Normal Tertiary level 4 years last audit Nov 11
5S programme and audits 5 7 Low
Weekly water sampling 6 10 Normal

Controls Criticality Effectiveness
(How
effectively has
KS
implemented
NZ King Salmon Risk Assessment Rev: 1 Page 49 of 63
these controls)
Status Control Detail/ Notes
Diving equipment servicing 10 10 Normal
Purchasing test certificates (shackles, ropes etc.) 10 10 Normal
SMS drills & SMS Co. audits, MNZ audits 10 10 Normal
Forklift, hiab CoFs
KS Training & Qualifications
4 10 Normal
KS Seacage Training manual (incl. information) 8 4 High Due for review & update
KS Induction 9 9 Normal
Workshops & On-the-job training 10 9 Normal
Salmon Unit Standards (Seafood Industry Training
8 10 Normal
Organisation)
Confined space training 10 6 High
Fire training 10 6 High
Fish health training 6 10 Normal
First aid training 10 6 High
Aquaculture Code of Practice for Diving 10 10 Normal
NZQA affiliation for various courses 10 10 Normal
Oxygen provider 10 10 Normal
Vessel qualifications 10 10 Normal
Drug & alcohol identification training 6 6 Medium Transitioning to new policy
Site HASNO approved handler 10 10 Normal
KS Internal Vessel refresher training 6 6 Medium
KS Internal Diver audits & refresher training 6 8 Low
Stress & mental health training for managers 4 9 Normal Via Mental Health Trust
Farm Design, Maintenance, Testing & Audits
Design of mooring systems 10 9 Normal
AIS transponders 1 4 Normal At Clay Pt Only

Controls Criticality Effectiveness
(How
effectively has
KS
implemented
these controls)
Status Control Detail/ Notes
Tension measuring devices, load cells fitted to selected 10 10 Normal
mooring lines
Other weekly farm audits – as per board 4 9 Normal
Daily visual checks
Weekly diving inspections
10 10 Normal
Weekly mooring line audit (visual from surface) 7 9 Normal
Navigation light audits – in accordance with Marine 10 10 Normal
Farming Association requirements – 3 monthly
Weekly mooring data logger downloads & analysis 10 10 Normal
Annual/bi-annual mooring line audit (divers field team) 10 7 Medium
Predator nets audits (divers field team) monthly 6 7 Low
Farm divers checks post incident (e.g. seal entry) 6 9 Normal
Farm divers checks – annual anodes 6 9 Normal
Knowledge base arising from mooring line development
> 6 years
10 9 Normal
OCEL Design review verification & validation practices 10 8 Medium The design case for new farms is
subject to full definition post consent
Specialist design, manufacturing, maintenance &
installation input
10 10 Normal
Recognised stress analysis software OCEL 10 10 Normal
Procurement specifications derived from OCEL drawings & 10 9 Normal
sea cage maintenance procedures
Supplier selection & performance monitoring 10 8 Medium
Inventory control – segregation of critical mooring items 10 6 High Currently adopting strategy for
stocking a streamlined inventory to
reduce complexity and reduce chance
NZ King Salmon Risk Assessment Rev: 1 Page 50 of 63

Controls Criticality Effectiveness
(How
effectively has
KS
implemented
these controls)
Status Control Detail/ Notes
of mis-picks (selecting an incorrect
component)
Analysis of weather & tidal conditions 10 9 Normal Certified agency used
Selection of farm location 10 9 Normal Specialist reports & analyses used
Understanding of dynamic farm behaviour 10 9 Normal OCEL experience & case studies >6 yrs
World-wide experience & review of
Tsunami modelling
Not yet modelled in Marlborough Sounds
Not selected by Civil Defence as a focal area for tsunami
consideration MDC risk assessment rates as low overall risk
NZ King Salmon Risk Assessment Rev: 1 Page 51 of 63
other farms
? ? ? Role in design case is yet to be
determined
NZ King Salmon Splicing standard 10 9 Normal Established method & established
competency – formal standard to be
documented
Maintenance planning, scheduling & routines 10 8 Medium OCEL/NZ King Salmon practice – forms
part of Sea Cage Maintenance Manual
Anchor installation standards 10 10 Normal Specialist installer
Tuning of mooring line layout 10 10 Normal NZ King Salmon/OCEL practice
Annual mooring line refurbishment 10 10 Normal
Net cleaning
Consents & Permits
10 9 Normal Done by specialist contractor
Seal permit from DOC 10 10 Normal
Discharges from net cleaning – resource consent 10 10 Normal
Annual environmental monitoring report – Cawthorn
Scientists
10 10 Normal
Resource Consents for farms 10 9 Normal Note: Reflective tape - need to check

Controls Criticality Effectiveness
(How
effectively has
KS
implemented
these controls)
Farming permit 10 10 Normal
Copper levels monitored and reported on annually 10 10 Normal
Black water discharge to barge 10 10 Normal
Hotwork permits 10 10 Normal
Anti-fouling paint permit
10 10 Normal
Anti-fouling inspections
NZ King Salmon Risk Assessment Rev: 1 Page 52 of 63
Status Control Detail/ Notes
if sea pens are marked as per consent
requirements
KS Health & Safety & Emergencies, Risk
Permit to work system 10 9 Normal
Health & Safety Meetings 6 7 Low Review timely follow up of actions
KS hazard registers for farms 8 7 Low Some hazards yet to be added to
Vessel SSM
Maintenance plans
Vessel Hazard registers
8 8 Low
registers
Contractor Safety Handbook 3 4 Medium
Selected contractor audits 6 6 Medium
General annual health checks 2 10 Normal
Trained first aider on farms at all times 7 10 Normal
First aid kit 7 10 Normal
Emergency plans 7 6 High
Tsunami response plan 5 3 High Site specific plans to be developed,
under way for Ruakaka & most sites
Crisis management 6 1 High
Tow plan for fish & pen transfer to other sites 9 9 Normal

Controls Criticality Effectiveness
(How
effectively has
KS
implemented
these controls)
Status Control Detail/ Notes
Security – staff on farms 24/7 4 7 Low Deters theft & sabotage
Aids to navigation (navigational lighting) – MTA 1994 –
hours of sunset to sunrise – approved by HM – daily visuals,
weekly audits conducted, 3 monthly audits faxed to HM
10 9 Normal
MDC HM navigation light check (frequency not known) 6 10 Normal
Communications – cell phone + VHF on farms
VHF on KS vessels
Staff personal cell phones
E-mail
5 10 Normal
KS Investigation system 4 6 Low
Risk assessments 10 10 Normal
NZ King Salmon Risk Assessment Rev: 1 Page 53 of 63
(note: not all farms are manned 24/7)

Annex F: MDC Risk Controls related to Salmon Farms
MDC Risk Control Measure intent Risk Control Measure Description 2009 Status Control
Adequacy
No. 1 Audit of moorings and marine farm
installations
No. 15
Reduction of collision and grounding risk in
the approaches to Havelock.
Primarily for marine farm vessels with may
not be able to comply with maximum
speed of 5 knots through design or through
instability to maintain steerage at this
speed in a strong tidal stream and
Increase of maximum proper speed in
Havelock Approaches to between 6 and 10
knots.
Establish Cullen Point as a radio reporting
point for commercial vessels, by way of an
‘All Ships’ VHF call.
Increase number of starboard hand
NZ King Salmon Risk Assessment Rev: 1 Page 54 of 63
Occurring and resource available.
Auditing of marine farms put in
abeyance for lighting plans to be
implemented. Auditing then to
recommence.
Mooring failure reports are increasing
and new hazard created. Mooring issues
are presently passed on to Council
compliance Team. Would be addressed
by organisational recommendations
made in the 2009 review.
Consultation with operators and need to
find common ground.
Recommended for further consultation.
Assessment
6
Decision Making
Recommendations
Process in place
recommended to
progress
Mooring failure
3
issues are
recognised and
hard data is
informative.
Solution being
progressed.
Recommended to
continue.
3 Take forward 8
8 Has now been amended to 8 knots
http://www.marlborough.govt.nz/Environment/Harbours/~/media/Files/MDC/Home/Environment/Harbours/Notices/2011/NTM%20No%2011%20of%202011.ashx

influence of river discharge into the
channel
No. 25
Marine Farm Monitoring and Service
Vessels.
Mandatory Traffic reporting may be
necessary for the approaches to Havelock,
in particular for commercial vessels
rounding Cullen Point, which is blind (ship
to ship). A number of operators already
have this in place.
channel markers in vicinity of Cullen Point
to improve definition of channel and water
available for manoeuvres to avoid risk of
collision.
Improve signage informing users of
requirement to keep to the Starboard side
of the channel and observe the speed limit.
Monitoring (e.g. Camera)
Develop a register of marine farm vessels
operating in the Sounds. Monitor marine
farm position; provide Notices to Mariners;
local information for recreational users and
supply information for LINZ charts.
NZ King Salmon Risk Assessment Rev: 1 Page 55 of 63
A rough register is now available, which
needs to be revised and updated.
3-4 Recommended to
take forward

Annex G: Risks Related to Salmon Farms Identified in MDC Risk Assessments
Risks from MDC Risk Assessment 2005:
Risks related directly to marine farms
Rank Hazard ref title Overall risk Remarks Notes
9 73 Small vessel or craft in contact with marine ALARP Has also been
farm
assessed by KS
20 74 Vessel over 500GRT in contact with marine ALARP Has also been
farm
assessed by KS
Risks related indirectly to marine farms
Rank Hazard ref title Overall risk Remarks Notes
15 9 Vessels in collision situation in Picton Harbour ALARP e.g. service vessels to farm MDC risk
22 13 Small commercial vessel grounds in Tory
Channel
ALARP e.g. service vessels to farms MDC risk
29 37 Ferry in conflict with small craft ALARP KS’ own vessels MDC risk
38 2 Tug and tow grounding in narrow tidal ALARP Has also been
channel
assessed by KS
40 78 Small commercial vessel grounding Low KS’ own vessels MDC risk
41 51 Fishing and small commercial vessel in conflict Low KS’ own vessels MDC risk
42 56 Tug and tow in conflict with leisure vessel Low Has also been
assessed by KS
44 8 Commercial and leisure craft in conflict in
narrows
Low KS’ own vessels MDC risk
45 44 Small vessel fire/explosion Low KS’ own vessels MDC risk
48 61 Serious earthquake in region (tsunami) Low MDC risk
Risk also
assessed by KS
53 36 Small vessel suffers contact during navigation Low KS’ own vessels MDC risk
56 7 Ferry and commercial vessel in conflict Low KS’ own vessels MDC risk
62 53 Small commercial vessel conflict Low KS’ own vessels MDC risk
64 20 Commercial vessel and leisure craft in conflict Low KS’ own vessels MDC risk
NZ King Salmon Risk Assessment Rev: 1 Page 56 of 63

69 31 Contact by small commercial vessel Low KS’ own vessels MDC risk
75 17 Small commercial vessel and vessel over
500GT
Negligble KS’ own vessels MDC risk
76 19 Ferry and small commercial vessel in conflict Negligble KS’ own vessels MDC risk
78 55 Kayak in conflict with small commercial vessel Negligble KS’ own vessels MDC risk
83 28 Commercial vessel in contact during berthing Negligble KS’ own vessels MDC risk
Risks from MDC Risk Assessment 2009 Review:
Risks related directly to marine farms
Rank Hazard title Overall Remarks Notes
ref
risk
9 73 Small vessel or craft in contact with marine ALARP Lighting on marine farms is reported to now be Has also been
farm
improving. Marine Farms have now got approved
lighting plans and resources consents in place.
Monitoring of compliance with new lighting plans. Six
incidents reported in four years, including a marine
farm mooring failure and closure of Tory Channel. WC
event has occurred. Risk scoring remains.
assessed by KS
20 74 Vessel over 500GRT in contact with marine ALARP One incident of marine farm mooring failure resulting Has also been
farm
in the closure of Tory Channel recorded. WC event
has thus occurred after after as predeicted by original
risk assessment. Scoring remains unchanged.
assessed by KS
Risks related indirectly to marine farms
Rank Hazard title Overall Remarks Notes
ref
risk
7 9 Vessels in collision situation in Picton Harbour ALARP e.g. service vessels to farm MDC risk
15 20 Commercial vessel and leisure craft in conflict ALARP KS’ own vessels MDC risk
18 37 Ferry in conflict with small craft ALARP KS’ own vessels MDC risk
21 44 Small vessel fire/explosion ALARP KS’ own vessels MDC risk
26 13 Small commercial vessel grounds in Tory
Channel
ALARP e.g. service vessels to farms MDC risk
NZ King Salmon Risk Assessment Rev: 1 Page 57 of 63

34 63 Mooring failure of anchored barge ALARP Worst credible comment: barge drags into marine
farm
NZ King Salmon Risk Assessment Rev: 1 Page 58 of 63
Has also been
assessed by KS
(not found in
2005 RA)
41 31 Contact by small commercial vessel ALARP KS’ own vessels MDC risk
42 2 Tug and tow grounding in narrow tidal Low Has also been
channel
assessed by KS
42 56 Tug and tow in conflict with leisure vessel Low Has also been
assessed by KS
44 78 Small commercial vessel grounding Low KS’ own vessels MDC risk
46 51 Fishing and small commercial vessel in conflict Low KS’ own vessels MDC risk
47 53 Small commercial vessel conflict Low KS’ own vessels MDC risk
47 78 Small commercial vessel grounding Low KS’ own vessels MDC risk
(ref 78
appears twice)
48 8 Commercial and leisure craft in conflict in
narrows
Low KS’ own vessels MDC risk
53 61 Serious earthquake in region (tsunami) Low MDC risk
Risk also
assessed by KS
57 36 Small vessel suffers contact during navigation Low KS’ own vessels MDC risk
61 7 Ferry and commercial vessel in conflict Low KS’ own vessels MDC risk
63 19 Ferry and small commercial vessel in conflict Low KS’ own vessels MDC risk
79 17 Small commercial vessel and vessel over
500GT
Negligble KS’ own vessels MDC risk
80 55 Kayak in conflict with small commercial vessel Negligble KS’ own vessels MDC risk
83 28 Commercial vessel in contact during berthing Negligble KS’ own vessels MDC risk

Annex H: Consultation Summary – Navigation Consultation in the Marlborough Sounds
The King Salmon report outlines the level of consultation regarding the proposed salmon farms. The following table summaries any comments raised by
consulted parties in relation to navigational aspects:
Consultation Contact name Date Comments
Picton Professional
Fishers Association
Dick Hall 25 August 2011 Commercial fishing reduced significantly over the years within the Marlborough Sounds
Port Marlborough Ian McNabb 25 November Would like to work with NZ King Salmon to help them achieve their expansion aims
(CEO)
2011
Pelorus Mail Boat Jim & Amanda
Baillie
13 February 2012 Environmental concerns mainly, no concerns with altering course for new sites
Marlborough Travel Chris Godsiff Many meetings Marlborough Travel who operates mussel tours in Pelorus is long term supporters of the
new farms.
No navigation issues.
Marlborough
Betty McNabb 4 March 2011 Prefer Salmon farms to mussel as they take up less space.
Recreational Fishers Tony Orman
Prefer salmon farms 200 metres off shore and away from reefs
Association
Eric Bowers
Marlborough
Shane Boese 14 November No navigation issues, would like opportunity to come along side farm to view feeding
Recreational Fishers
Association(MRFA)
(chair)
2011
Sounds Advisory Group Combination of 8 November 2010 Environmental issues raised, no navigation
Sounds Residents
formed by
Marlborough
District Council
7 November 2011
Waikawa Boating Club Nicky Jenkins 1 November 2011 Concern around the Ruaomoko site only for navigation,
(Commodore)
Would like to work with NZ King Salmon to deal with any specific issues they have and
Steve Anderson
welcome further meeting
Support the economic development opportunity for Marlborough
NZ King Salmon Risk Assessment Rev: 1 Page 59 of 63

Will not be opposing the applications
Mana Cruising Club Commodore various No response
Yachting New Zealand CEO and Board 2 December 2012 Safe navigation especially good lighting required
Access to sheltered bays for anchoring
Structures to be removed if farms fall into disrepair
Prefer consultation with local boating clubs, especially Waikawa
Pelorus Boating Club Commodore and 9 December 2011 Main issue, effect of the scallop beds from the Tapipi farm.
Board
Navigation not a major issue but will get back to us.
Royal Port Nicolson Yacht CEO and Board 22 November They have 800 members and will distribute maps
Club (RPNYC)
2011
Personally have no objection to new sites, appropriate lighting
Tasman Cruising Club Dr Phil Silva 22 November Fully supports application. Economic benefit far out way any loss of water space.
Commodore
Interislander Thomas Davis
(GM)
Ivor Minnis
(Marine
Manager)
Maritime NZ- Wellington John Whitely
(RMA)
Strait Shipping Sheryl Ellison
(MD)
2011
17 November
2011
30 November
2011
30 November
2011
300 members cruising Sounds
NZ King Salmon Risk Assessment Rev: 1 Page 60 of 63
No navigation issues, ensure good maintenance on anchoring systems-
Emergency response plan and work with Interislander
Support application
16 vessels movements a day
Unavailable the day we visited. Did not contact us.
No issues with navigation through Tory Channel
Ensure that there is emergency procedure in the event of a farm breakaway
Letter received supporting NZ King Salmon
8 vessel movements a day
Maritime NZ-Picton Colin Perkins 1 December Secure farms with good R&M programmes
Correct lighting
Emergency plans if breakaway
Harbour Master Alex van
Wijngaarden
Moving farms-check tidal and wind
12 July 2011 Like to see AIS units trial on Tory channel farms-trial commenced
Concerned about Tory channel site-Ngamahau
Main concern-farm security-evidence of bomb proof security required.

Annex I: Extracts from MNZ Guidelines & Codes
New Zealand Port and Harbour Marine Safety Code.
Introduction
The Code aims to promote good practice in the conduct of safe marine operations in ports and
harbours. It represents the national standard against which the policies, procedures and
performance of regional councils, port companies, the Maritime Safety Authority [now Maritime
New Zealand] and other relevant parties may be measured.
The Code serves as a framework for the preparation of safety management systems by regional
councils. That safety management system will be informed and based upon a formal risk assessment.
The aim is to establish a system covering all marine operations in ports and harbours which ensures
that risks are both tolerable and as low as reasonably practical.
The Code aims to help those who have duties in respect of safe marine operations to understand
and discharge them, and to be seen to achieve and maintain nationally agreed benchmarks for safe
marine operations in their waters. The best practice guidelines set a standard to which in future they
will hold themselves accountable publicly. While compliance is not mandatory, prudent participants
in the system will be able to use compliance with the Code to demonstrate they have taken all
reasonable steps to ensure safe marine operations in ports and harbours.
2.2 Risk Assessment & Safety Management
2.2.1 The Code applies the well developed principles of formal risk assessment and safety
management systems to the provision of harbours and port facilities, including marine services by
port companies. This chapter outlines the approach which regional councils, in conjunction with port
companies, should take, with regard to following these general principles:
Regional Councils shall undertake a full harbour risk assessment of marine operations, and
implement a harbour safety management system. Implementation of the harbour safety
management system is the responsibility of the harbourmaster;
A port company shall develop a formal safety management system for port related marine
operations, developed after a formal port risk assessment. The port company shall communicate the
assessment and the safety management system to the harbourmaster for incorporation into the
harbour risk assessment and harbour safety management system;
The harbour safety management system shall be made available to the Maritime Safety Authority
[now Maritime New Zealand] setting out the regional council’s and each port company’s policies and
procedures;
Every regional council’s statutory powers, including those powers of regional council appointed
harbourmasters, to regulate marine operations shall be exercised in accordance with the harbour
safety management system;
Every safety management system shall include a systematic approach to formally monitor and
review the effectiveness of the system;
Every safety management system shall deal with preparedness for emergencies.
2.2 Risk Assessment & Safety Management
2.2.1. Risk assessments shall employ principles and methodology equivalent to “Guidelines of
Good Practice for Risk Assessments in Ports and Harbours.”
NZ King Salmon Risk Assessment Rev: 1 Page 61 of 63

Guidelines for Aquaculture Management Areas and Marine Farms, Maritime New Zealand,
December 2005
Purpose of Document
This document sets out the guidelines of Maritime New Zealand in relation to AMAs [Aquaculture
Management Areas] and marine farms. The information contained herein is intended to support the
appropriate authorities while they develop their AMAs, and to give guidance to marine-farm
applicants on areas of concern for maritime New Zealand with respect to navigational safety. The
guidelines identify relevant navigational issues and describe the criteria that regional councils and
marine farm applicants should be aware of during the process of the creation of AMA’s, and the
establishment and management of marine farms
[EOS comment: The guidelines have a number of Risk statements; extracted as follows]
5.0 Location.
Risk: The incorrect positioning of marine farms can increase their potential as a navigational hazard,
both through their geographical positioning with regard to user of marine areas, and their physical
positioning and size with respect to currents and sea states.
6.0 Marking and Lighting
Risk: Incorrect, inaccurate or unreliable marking and lighting poses a serious navigational hazard to
other marine users. The risk applies to both the initial positioning and quality of the mark and lights
used, and the continued efficiency of the equipment thereafter.
7.0 Safety Management
Poorly designed, constructed and maintained farms are more likely to pose a hazard of navigational
safety
8.0 Control and Compliance
Risk: Marine Farms not correctly maintained and monitored have increased potential to become a
navigational hazard
Guidelines for Port & Harbour Risk Assessment and Safety Management Systems, Maritime Safety
Authority, 2004
Introduction
This document provides guidance to those responsible for navigational safety within designated
harbour areas. It is designed to provide important assistance to Regional Councils and Port
Companies when undertaking a risk assessment of navigational activities and installing a safety
management system in accordance with the requirements of the New Zealand Port & Harbour
Marine Safety Code (the Code). The focus of these guidelines is on risk assessment and safety
management to improve safety of vessel or craft movement and navigation within a harbour area as
defined by the Code.
………
Any safety management system inherently needs an assessment of risk to inform it of safety
priorities and the performance of risk management systems managing those priorities.
NZ King Salmon Risk Assessment Rev: 1 Page 62 of 63

………
There is a New Zealand/Australian standard for risk management which provides base information
to set a common standard for assessments undertaken. These guidelines [ie the Guidelines for Port &
Harbour Risk Assessment and Safety Management Systems] are founded on the New
Zealand/Australian standard but goes much further to provide a common set of risk criteria as a
reference for the introduction of port and harbour risk assessment in New Zealand.
NZ King Salmon Risk Assessment Rev: 1 Page 63 of 63