Brendan Eccles

Law Firm 
65-068 Zielona Góra, 3 Pod Filarami street
Attorney at Law Lech Cieślak 

__________________________________________________________________________________ 
 March 1, 2022 

Regarding: regulation 28 

Derek Winter DL 

Senior Coroner for the City of Sunderland 

Acting on behalf and with the authority of the President of the Management Board of POM-EKO, a 
limited liability company with its registered office in Szczecinek (Poland) further to the request in the 
letter  of  Mr.  Derek  Winter  -  Senior  Coroner  for  the  city  of  Sunderland  of  January  10,  2022  in  the 
matter of actions taken to prevent accidents while using the modular steel pontoons made by POM-
EKO limited liability company in Szczecinek, I explain the following: 

1. The  production  modular  steel  pontoons  in  POM-EKO  was  launched  in  2010  in  cooperation  with
companies operating in the European Union, which have been professionally used and rented by
companies  for  many  years.  Therefore,  these  companies  have  extensive  experience  in  their
construction process, technology and use. Until now, our company has made 1,600 pontoons that
have been sold in the European Union.

2. When  orders  were  carried  out,  the  pontoons  were  always  delivered  with  factory-made  binding
elements,  such  as  forks  and  half  rings.  Although  the  clients  of  our  pontoons  are  proof-of-the-art
companies in this industry, familiar with the regulations and procedures as far as handling of these
products is concerned, the principles of safe use were discussed at each trade meeting: such as the
use  of  factory  clamping  elements,  the  use  of  original  protective  barriers  that  are  twisted  to  the
flanges  on  the  rim  of  the  pontoon  as  well  as  not  making  any  unauthorized  modifications,  in
particular welding and cutting off non-original parts. As a result, on our part, we did not allow to
any design changes to the product  to be made on their (the clients) own.

3. Despite  the  fact  that,  as  we  mentioned,  our  clients  are  professional  companies  in  the  pontoon
industry,  we  decided  to  remind  them  in  writing  about  the  special  safety  rules  while  working  on
pontoons,  in  particular  about  the  prohibition  of  using  non-original  fasteners  for  coupling,  any
modifications, avoiding hot works,  and in case of their necessity about procedural obligations in
European countries, including the territory of Great Britain, and included in the provisions of the
Health  and  Safety.  We  have  also  decided  to  provide  an  extract  from  the  Health  and  Safety
Executive's  leaflet  for  safety  in  welding,  gas  cutting  and  similar  processes  and  for  hot  work  on
small tanks and drums with every pontoon we sell for the UK market.

 
 
 4.  In hermetically sealed tanks, such as steel pontoons, which are used in the sea water environment 
and at different ambient temperatures, water condensation is released outside, which causes rapid 
corrosion,  therefore  their  inside  must  be  protected  with  an  effective  anti-corrosion  coating.  The 
above  requirement  is  discussed  by  clients  when  placing  orders.  As  a  result,  their  inside  may 
contain traces of volatile organic compounds (VOCs) derived from the anti-corrosion coating. As 
well as under the conditions of high humidity, even the residual organic substances inside closed 
tanks can generate substances such as methane. Hence the need to always comply with the safety 
procedures described in the HSE, if it is necessary to conduct hot work. In such cases, the pontoon 
should be aired through the holes for screw plugs on its sides, e.g. with steam or inert gases, e.g. 
carbon dioxide CO2 or nitrogen N2. Such procedure is aimed at displacing even trace amounts of 
volatile  organic  compounds  from  the  inside  of  the  pontoon  from  the  anti-corrosion  coating  or 
organic  residues.  However,  it  is  safest  to  avoid  hot  work,  and  if  necessary,  outsource  it  to  a 
professional  company  that  will  do  it  safely  in  compliance  with  the  applicable  procedures.  It  is 
known that pontoons should be tight, therefore in the final production process they are tested for 
tightness. For this purpose, air is forced inside at a pressure higher than atmospheric pressure and 
after  several  minutes  it  is  let  in  through  the  holes  for  screw  plugs,  which  additionally  blows  the 
inside  of  the  pontoon.  Moreover,  in  the  process  of  manufacturing  pontoons  in  our  company,  in 
order  to  remove  even  trace  amounts  of  volatile  organic  compounds  (VOC),  we  extended  the 
interval  between  the  anti-corrosion  coating  inside  the  pontoon  and  its  closure  with  a  primer  to 
several days, which ensures virtually complete removal of volatile compounds. 

5.  At  the  same  time,  we  would  like  to  point  out  that  the  provisions  of  the  HSE  impose  specific 
obligations on employers, who are legally obliged to assess risks in the workplace and to take all 
reasonable  precautions  to  ensure  the  safety  of  employees  and  other  individuals  who  may  be 
exposed to risks while performing works. Any hot work should be supervised by an experienced 
manager or supervisor who has knowledge of how to perform it, the related risks and precautions 
that should be taken before starting the work. 

6.   The actions taken by our company to increase the safety while using our products and the absolute 
compliance of users with health and safety regulations will prevent similar accidents in the future. 

[illegible signature] 

Attorney at Law Lech Cieślak 

Attached:  Power of Attorney