What Due Diligence Actually Looks Like: A Polar Operator's LSA Checklist

Published by White Glacier Manufacturing Corp.

This post is the practical response to that problem.

What follows is not a marketing document. It is a working checklist — the questions a diligent polar vessel operator should be able to answer before their next polar voyage, and the documentation they should be able to produce if a flag state PSC officer, a P&I surveyor, or a court asks them to demonstrate that their LSA equipment was adequate for their operating area.

If you cannot answer these questions today, that is useful information. It tells you where your safety management system has a gap that needs to be closed.

Section 1: Know Your METR

The Polar Code requires that LSA equipment provide thermal protection for the Maximum Expected Time of Rescue — the METR — specific to the vessel's polar operating area. The METR is not a fixed number. It varies by operating area, season, and available SAR infrastructure. Before any polar voyage, a diligent operator should be able to answer the following:

☐ Have you formally documented the METR for each polar operating area your vessel enters?

☐ Is that METR assessment based on actual SAR response data for that specific area — not a generic assumption drawn from temperate operating experience?

☐ Does your METR assessment account for seasonal variation — the difference between summer operations with ice-free access and winter operations where SAR asset deployment may be significantly delayed?

☐ Has your METR assessment been reviewed and endorsed by your Recognized Organization or flag state authority?

☐ Is the METR documented in your vessel's Polar Water Operational Manual, as required by the Polar Code?

If you cannot produce a documented METR for each of your polar operating areas, you do not yet have the baseline from which to assess whether your LSA equipment is adequate.

Section 2: Assess Your LSA Equipment Against the METR

Once your METR is established, the next question is whether your immersion suits can actually deliver thermal protection for that duration under the conditions your crew will face. This is the core of the goal-based inquiry.

☐ What is the certified thermal protection duration of the immersion suits currently aboard your vessel?

☐ Under what test conditions was that certification issued — specifically, what water temperature, air temperature, and wind conditions were used during the certification test?

☐ Do those test conditions reflect the actual conditions your crew would face in an abandonment scenario in your polar operating area?

☐ Has the suit manufacturer provided independent test data — not marketing literature — demonstrating thermal performance under simultaneous polar immersion conditions: freezing water, sub-zero air temperature, and wind chill?

☐ Has the suit been tested with water ingress — reflecting the reality that seawater will enter the suit during a real abandonment — and has the manufacturer documented the thermal impact of that ingress?

☐ Can you demonstrate, with reference to independent test data, that the suits aboard your vessel provide thermal protection sufficient to cover your documented METR?

This last question is the one a PSC officer applying the Polar Code goal-based framework is entitled to ask. If the answer is that your suits carry an MSC.81(70) certificate but have not been independently validated under polar conditions, that is an answer — but it is not necessarily a sufficient one.

Section 3: Examine Your Supplier's Evidence

The quality of an LSA supplier's evidence matters. Marketing claims, brochure specifications, and unverified performance statements are not a substitute for independent test documentation. A diligent operator should examine the following:

☐ Has the supplier provided the full independent test report — not a summary, not a certificate, the actual report — from a recognised testing facility?

☐ Does that report document the specific test conditions, the methodology, and the results in sufficient detail to allow independent assessment?

☐ Was the test performed at a facility with recognised expertise in cold-weather immersion testing?

☐ Does the test data address performance under combined polar conditions — not water temperature alone, but water temperature, air temperature, and wind chill simultaneously?

☐ Does the test data address performance with water ingress — or was the suit tested only under dry interior conditions that do not reflect field reality?

☐ Is the test data current — or was it generated for an earlier product iteration that may differ from the suit currently supplied to your vessel?

A supplier who cannot provide a full independent test report addressing these points is a supplier whose polar performance claims cannot be verified. In the context of a liability inquiry following an abandonment event, unverifiable claims are not a defence.

Section 4: Audit Your Safety Management System

The Polar Code places an affirmative obligation on operators to maintain a safety management system that addresses the specific hazards of polar operations. LSA adequacy is a component of that system. A diligent operator should be able to demonstrate:

☐ That your SMS contains a documented LSA assessment specific to your polar operating areas — not a generic reference to certification standards.

☐ That your DPA has reviewed and signed off on that assessment within the past twelve months, or following any change in operating area.

☐ That your vessel's Polar Water Operational Manual addresses the thermal survivability requirements of the Polar Code and identifies the specific LSA equipment aboard as meeting those requirements.

☐ That your crew training program addresses the actual conditions of polar abandonment — including water ingress, extended immersion duration, and the limitations of conventional survival techniques in polar environments.

☐ That your P&I club has been informed of your polar operating areas and has confirmed that your LSA arrangements are consistent with your coverage terms.

This last point deserves particular attention. P&I clubs assess claims in the context of what a reasonable operator should have known and done. An operator whose SMS contains a documented, evidence-based LSA assessment — even if the conclusions are imperfect — is in a materially better position than an operator whose SMS contains nothing on the subject.

Section 5: Document Everything

Due diligence that is not documented did not happen — at least not in any form that will assist you in a regulatory inquiry, an insurance claim assessment, or litigation.

☐ Retain copies of all independent test reports for LSA equipment currently aboard your vessels.

☐ Retain documentation of your METR assessments, including the data sources and methodology used.

☐ Retain correspondence with your Recognized Organization and flag state authority relating to LSA adequacy.

☐ Retain records of DPA review and sign-off on polar LSA assessments.

☐ Retain records of crew training relating to polar abandonment procedures.

The standard of documentation required is the standard that would satisfy a reasonable investigator examining the circumstances of an abandonment event after the fact. Build your documentation with that investigator in mind.

Where This Checklist Leaves Most Operators

For most polar vessel operators, working through this checklist will identify at least one gap — and frequently several. The most common gap is Section 2: operators who can produce a certification certificate but cannot produce independent test data demonstrating polar performance under conditions relevant to their operating area.

That gap is closeable. It requires asking different questions of your LSA supplier, and if those questions cannot be answered satisfactorily, it requires examining whether your current supplier is the right one for your polar operations.

White Glacier Manufacturing Corp. can provide the full Ergopro independent test documentation for the Arctic 10+ and Arctic 25+ — including test conditions, methodology, results, and the Ergopro facility's assessment of extended survivability beyond the six-hour ethical test ceiling. That documentation is available to operators, DPAs, fleet managers, Recognized Organizations, and P&I surveyors upon request.

The checklist above identifies what due diligence requires. The documentation exists. The question is whether your current LSA supplier can provide it.

For independent test documentation, fleet specifications, and polar LSA assessment support, contact White Glacier Manufacturing Corp.: djacobson@whiteglacier.com