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A Product of the Coast Guard - AWO Safety Partnership CEMS GETTING STARTED, MAKING IT WORK CREW ENDURANCE MANAGEMENT

CEMS CREW ENDURANCE MANAGEMENT ETTING S , … · CREW ENDURANCE MANAGEMENT. ... Kirby Corporation CEMS is a practical answer to addressing maritime safety issues, overall mariner

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A Product of the Coast Guard - AWO Safety Partnership

CEMSGETTING STARTED, MAKING IT WORK

CREW ENDURANCEMANAGEMENT

What is CEMS?The Crew Endurance Management System, or CEMS,is a process to manage risk factors that contribute todecreased physical stamina and mental alertness amongmariners. These risk factors, which have beenidentified through sleep science research, increase therisk of human error and degrade performance. Through25 years of research and use by U.S. Army SpecialForces and the U.S. Coast Guard Research andDevelopment Center, CEMS has proven an effectiveway to manage these risk factors.

CEMS has been implemented in a variety of maritimeoperations, including, over the last five years, inland,coastal, and harbor towing vessels. CEMS is gainingmomentum as a process that improves crew endurance byhelping crews deal with endurance-related risk factors.

To be effective, CEMS requires a comprehensive,step-by-step approach to addressing such issues asawareness and education; lifestyle issues like diet andexercise; the physical environment on board vessels,including light exposure management; companypolicies and procedures; and watch schedules. CEMSis not a one-shot-and-you’re-done process; it’s a cycleof continuous improvement in which you analyzerisks, establish a plan to deal with those risks,implement the plan, evaluate the results, and modifythe plan as necessary.

CEMS is not a one-size-fits-all system. It can betailored to meet your company’s and crews’ needs,whether you operate line-haul boats on the MississippiRiver, fleet boats in St. Louis Harbor, ocean-going tugson the Atlantic or Pacific coasts, or harbor tugs inBaltimore, New Orleans, or San Francisco.

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Marty WyattRelief CaptainM/V Doug Barker

Under CEMS, the crew hasteamed up to improve their qualityof life on the boats and at home.Working as a group has made iteasier to exercise, eat healthierand get better quality sleep.

In Your Own Words:

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Why implement CEMS in my company’soperations?Each company will have its own reasons toimplement CEMS, but here are some that areapplicable to all companies:

to further my success in achieving the goal of zero accidents.

to reduce crewmembers’ stress level, which mayhelp to reduce crew turnover.

to improve crewmembers’ decision-making, whichis linked to reducing accident rates.

to improve crewmembers’ quality of life, reducemedical costs, and improve my company’sbottom line.

How does CEMS work with my safetymanagement system?Like a safety management system, CEMS is a process;it’s an ongoing effort to improve mariners’ work andrest environments that will lead to improved quality oflife and improved productivity.

Just like implementing a safety management system,CEMS implementation will require cultural changes,which can be slow to evolve. Many companymanagers and vessel crewmembers who were onceskeptics of both safety management systems and CEMScan’t imagine operating without either system now.

As with safety management system implementation,implementing CEMS will require personnel from allareas of your company to be involved and supportthe process.

How much time will CEMS take?CEMS is about doing things differently, not doingsomething “extra” or time-consuming. While it does takesome time up front to attend CEMS training, establish awork group, conduct a risk assessment, and develop acrew endurance plan, over the long haul CEMS doesn’tmean adding new steps to your crewmembers’ busyschedules. It means finding ways to keep them refreshed,productive, and safe as they go about their work.

John BakerCorporate Quality ManagerKirby Corporation

CEMS is a practical answer toaddressing maritime safety issues,overall mariner health, andpotential fatigue issues. Whetheryou are a one-boat operator or amultiple boat operator, CEMS canand will help you achieve yourgoals of decreased safety incidentsand improved quality of life for youand your employees.

In Your Own Words:

Q: I have lunch-bucket boatswithout live-aboard crews. Whatcan I do to implement CEMS?

A: Dayboat crews have the samephysiological needs as live-aboardcrews. Everyone needs adequaterest, good nutrition, and the abilityto take advantage of lightmanagement. All crewmembers,including dayboat and harborservice crews, should be educatedabout the benefits of a healthylifestyle, factors that affect qualityrest, and how to manage their timeoff for optimum performance.Some companies using CEMShave adjusted the watch schedulefor their dayboats by changingcrews at 0400 and 1600 to allowcrews to get to bed before the sunrises, which promotes moreeffective sleep.

A&Q

How much will CEMS cost me?Getting started with CEMS requires little upfront cost.

There will be some training costs to send someonefrom your company to Coaches Training, a 2-daycourse offered by a variety of providers around thecountry. You can also expect some additional costsfor awareness and training as your roll CEMS outthroughout your fleet.

Instruments like light and sound level meters maybe needed to help assess environmental risk factorsonboard your vessels.

In the long term, your risk assessment couldidentify onboard environmental issues that shouldbe addressed to reduce the risks. It’s up to you todecide which risk factors to address and how muchto spend. Experience has shown many veryeffective changes cost little or nothing.

O.k. - so how do I get started?Starting a CEMS program is a classic case of thechicken and the egg -- which comes first? You cansend someone to CEMS coaches training or createawareness within your company about the benefits ofCEMS. Both methods have worked well for othercompanies, and you have the flexibility to choosewhat’s right for you. You might send someone tocoaches training first, so that your newly trained coachcan come back and conduct awareness training forothers in the company; or you might start by creatingbroad awareness, which then prompts the decision tosend someone to coaches training.

If you decide to begin by creating awareness but do nothave someone in your company who is familiar withCEMS, you might consider having a knowledgeablecoach or expert from another company help you getstarted. A list of experts and practicing companies isavailable from the Coast Guard.

Q: Why should I start a CEMSprogram now?

A: Why wait? You’ve just readabout the benefits of CEMS, foryour company, your crewmembers,and your bottom line. Themaritime industry operates 24hours, 7 days a week, andendurance risk factors are presentin any 24-hour industry. Congressand the public expect 24-7industries to recognize these risksand take steps to prevent fatigue-induced incidents. Why wait for anaccident - or a new law orregulation - when you can startnow to realize the benefits thatCEMS has to offer?

A&Q

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Here are a few ideas to get you started. Start at thepoint that best fits your level of understanding about CEMS:

Check out the Coast Guard’s CEMS website athttp://www.uscg.mil/hq/g-m/cems/index.htm.

Review the CEMS: The System pamphlet availableon the website.

Review the CEMS Executive Level Presentationavailable on the website.

Talk to a CEMS Expert. For a list of CEMSexperts in your area, call the Coast Guard at (202) 267-2997.

Go to Coaches Training. Check each issue of theAWO Letter for a current list of scheduled CEMStraining opportunities.

Once you’re ready to sendsomeone to coaches training,choosing the right person tosend is important. Here aresome things to keep in mind asyou decide:A coach should be a respectedindividual who cancommunicate effectively with alllevels in your company, from theCEO to the deckhands. Theindividual’s job title is lessimportant than his or her levelof respect in the company andability to communicate withothers. The person you select forcoaches training should be open-minded, inquisitive,and unafraid of change.

You may already have people in your company who’veexpressed an interest in endurance issues. By all means,encourage these individuals to go to coaches training andbecome CEMS champions.

CEMS Tip!The Ship Operations CooperativeProgram (SOCP), a government-industry cooperative sponsored bythe Maritime Administration, hasdeveloped an interactive CD-ROMprogram that provides an overviewof CEMS principles forcrewmembers. The CD can beused by crews during safetymeetings to familiarize themselveswith CEMS principles. The CoastGuard will distribute copies of theCD to all AWO members in the fallof 2005.

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What will my newly trained coach do when he orshe returns from training?Your coach will be ready to spread the word aboutCEMS to other individuals within your company, andestablish a Crew Endurance Working Group(CEWG) to formally start your CEMS program (moreabout the CEWG below). In some companies, thecoach has found it useful to conduct awareness trainingabout CEMS and its benefits at captains meetings andbriefings to company leaders. Spreading informationabout CEMS helps to generate interest in trying it atyour company.

Vertical and horizontal alignment are keys to a successful CEMS program. What does that mean?Management commitment is critical to the success ofany new process. This is especially true of anendurance management program. Without visiblesupport from the top of the organization andcommitment from all layers of management, CEMSwill be difficult to implement successfully. Becauseimplementation affects the lifestyle of the crew, CEMSalso requires support and commitment at the deck-platelevels of the organization. In the language of CEMS,this commitment is called vertical and horizontalalignment. Vertical alignment refers to all the tiers ofthe organization being committed to the success ofthe program. This doesn’t just mean verbal support,but a true understanding of the program so that anymanager or worker can discuss the components of theprogram knowledgeably.

Horizontal alignment is getting everyone involved atall levels of the operational organization - what youmight call going “deep and wide.” What you’re reallydoing is creating the infrastructure for success. Whenmore people in your management structure understandand believe in CEMS, you’ll have greater likelihood ofimplementing it successfully. Smaller companieshave an advantage in this area since they have fewerlayers of management to “align.”

Chuck KingVice PresidentBuffalo Marine Service, Inc.

We were using crew endurancetechniques at Buffalo and we didn’teven know it. We have alwayshad a program of healthier eating,exercise, and no smoking, all ofwhich are a part of the CEMSprocess. Buffalo has modified allof its vessels with additional doorsand insulation to minimize thenoise level in the crew sleepingquarters. Modifications have alsobeen made to provide light controlin the quarters, galley/lounge andthe wheelhouse. We have alsoestablished company policies of“quietness” while crewmembersare sleeping and/or napping. Wehave continued encouraging ouremployees through education toeat healthier, exercise more and toquit smoking. We have created anincentive program to reduce thenumbers of crewmembers thatsmoke by providing them withadditional pay when the whole boatis smoke-free. We have availedourselves of the services of aCEMS Expert, trained twocoaches, and will train two more inthe near term. After this trainingwe will form a company CEMSWorking Group and formalize ourprocess in accordance with thepublished CEMS Guide and theExpert and Coaches trainingprograms. We believe in CEMSand its benefits and will be “in theprocess” very soon.

In Your Own Words:

The Process Step-by-StepThe person you send to coaches training will comeback prepared to help shepherd your company throughthe CEMS process. As shown in the figure below, theprocess involves five steps:

I. Set up a Crew Endurance Working Group.

II. Analyze the current situation.

III. Develop a Crew Endurance Plan.

IV. Implement the Crew Endurance Plan.

V. Evaluate the results.

Crew Endurance ManagementThe Crew Endurance Management System (CEMS) was developed to manage the endurance-related risk factors that can degrade human performance and lead to human error. The CEMSprocess has five steps, four of which are repeated in a cycle of continuous improvement:

I. Set up Crew Endurance Work Group (CEWG) consisting of personnel from all levels ofthe organization. Their job is to keep the company’s CEMS efforts on course.

II. Analyze current situation.Use the Crew Endurance RiskFactor Survey / DecisionSupport System to determinehow and why the endurancelevels of crewmembers areaffected by your business andoperations.

V. Evaluate Results.Crew Endurance Plans shouldbe evaluated periodically tosee if risk factors havedecreased. Distribute the CrewEndurance Risk Factor Surveyor use the Decision SupportSystem to gauge yourprogress. Repeat the cycle forthose areas that need attention.

III. Develop a CrewEndurance Plan (CEP).Based on the risk assessmentresults, the CEWG recom-mends ways to improve condi-tions. DON’T try to changeeverything at once -- theCEMS process is cyclic. Focuson low-cost, high-return itemsfirst and make a good faitheffort to address each risk fac-tor as much as possible. CEMplans should address all CEMScomponents (see center box),and be deployed in the orderas listed.

IV. Implement CrewEndurance Plan.This is where the systemmodifications recommend inStep III are completed. Thesemight include physicalchanges to crew quarters, newonboard policies, and changesin watch schedules. This isalso where coaches are calledupon to help with the processand overcome obstacles.

CEMS Components1. Education2. Environmental changes3. Light management4. Trained coaches5. Schedule changes

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I. Set Up a Crew Endurance Working GroupThe Crew Endurance Working Group (CEWG) isresponsible for all aspects of implementing CEMS ina company, in a fleet, or on a vessel. The scope of thegroup’s work is up to you -- some companies havefound it helpful to establish a company-wide CEWG,while others have started with a single vessel or asubset of the fleet. The CEWG is responsible foridentifying endurance risk factors, creating acollaborative network to facilitate CEMSimplementation, and developing and implementing theCrew Endurance Plan.

To be effective, a CEWG must include or representeveryone that could be affected by theimplementation of CEMS. For example, a workinggroup might include one or two company executives,personnel from the operations, maintenance, and safetydepartments, and vessel personnel. The group shouldbe led by a trained coach who understands the scienceand practice of CEMS and can help educate otherworking group members.

II. Analyze the Current SituationThe working group’s first task is to analyze thecurrent situation by identifying the individual andenvironmental risk factors that may affect crewendurance in a particular operation.

There are 15 individual risk factors that can affectcrew endurance. These risk factors consider sleep,scheduling, physical stresses, environmental stresses,and personal stresses. The number of environmentalrisk factors that are relevant to a given operation willdepend on the vessel, the type of operation, and thelocation where the vessel operates. Environmental riskfactors are closely related to individual risk factors anddeal with the effects of the work or rest environment oncrew endurance.

The presence of endurance risk factors should not beviewed as a negative indicator of the safety of a vesselor the state of a company’s safety program. Such riskfactors are present in any 24-hour, 7-day-a-week

CEMS Tip!Companies have found that allmembers of the CEWG benefitfrom CEMS coaches training.

Don’t confuse thepresence of risk factorswith risky or unsafeoperations.

Trip Hazards to Avoid:

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operation. In fact, by identifying the most prominentrisk factors in your operation, you have actually takenthe first step to improving safety, simply by increasingawareness. Such action should be seen as evidence of anadvancing safety culture.

Identifying the presence of a risk factor does notnecessarily mean that you must address that factorto be considered “practicing CEMS.” Simplybecoming aware of a risk factor is, in many cases, asignificant improvement in the overall safety culture.There are times when addressing a particular risk factoris beyond a company’s reach or inconsistent with thenature of its operations. A challenge for any companyimplementing CEMS is to select and prioritize whichrisk factors to address so as to achieve the greatestoverall reduction in risk in the most efficient way.Prioritizing risk factors and determining the bestmitigation strategies are involved in the next step in theCEMS process.

The process you use to perform the endurance riskassessment is up to you. However, there are severaltools available to assist your Crew EnduranceWorking Group in this assessment. Decision SupportSoftware can be provided to trained CEMS coaches toassist in the gathering of individual risk factors, eitherthrough surveys or interviews. Environmental riskfactors are best gathered through vessel visits by aperson trained in CEMS. Checklists and computerspreadsheets are available to assist in data collection.

Once you’ve identified the risk factors that exist in youroperations, and understood why they’re there, the CrewEndurance Working Group brainstorms possible ways tomitigate those risk factors, using the five CEMS tools:education, environmental changes, lightmanagement, trained coaches, and schedule changes.

III. Develop a Crew Endurance PlanOnce the working group has brainstormed the range ofpossibilities for addressing the identified risk factors,it’s ready to develop a Crew Endurance Plan (CEP).There is no set format for the CEP. Your companyshould use the format that is most appropriate for yourparticular operation and management style.

Houston MoneyLead TankermanBarge Everglades

Since having been involved in theCEMS program, I have personallygained a great deal of insightconcerning sleep patterns. I havebeen able to make someadjustments to my daily habits thathave greatly improved my mentaland physical health. I practice thelighting and diet rules at home aswell as on the boat. Thanks forthe training.

In Your Own Words:

Q: I can’t tell my crewmemberswhen to sleep and I can’t tellthem what to do on their timeoff, so how can CEMS make adifference?

A: Implementing CEMS is achallenge and requires a seachange in thinking for bothmanagement and crews. Asuccessful CEMS programemphasizes the benefits of a gooddiet, exercise, and an awarenessof the factors that affect qualityrest. This knowledge can helpcrewmembers manage their timeoff, both on the boat and at home,for optimum performance.

A&Q

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Some companies have found it useful to have anoverall company-wide plan for implementing CEMS,but in any case, there should also be a plan to addressthe specific risk factors for each vessel. This cantake the form of a single plan that covers all vessels inthe fleet, or individual plans for each of yourcompany’s vessels. Regardless of format, the CEPshould contain specific recommendations to addressthe most critical risk factors identified by theCEWG. These recommendations will generally fallinto two major categories:

1. Operational Recommendations include changes topolicies, practices, or procedures related to vesseloperation and may include:

Time management (e.g., shower and meal times)

Light management

Watch changes (e.g., schedule changes, napping)

2. Environmental Recommendations include changesto the work and rest environment and may include:

On-board policies (e.g., courtesy to off-watchsleepers, avoiding excessive use of throttle, etc.)

Physical changes (e.g., making sleeping areasdarker, quieter, and more comfortable; increasinglighting in certain areas of the vessel, etc.)

In developing the plan, keep two things in mind:

1. The CEMS process is a cyclic effort to bring aboutlong-term culture change. You can’t “doeverything” -- that is, eliminate all your risk factors-- at once, and you shouldn’t try. Picking the low-hanging fruit first -- low-cost, high-impact changesyou can make in the short term -- will help tojump-start your CEMS implementation effort andbuild enthusiasm for further improvements downthe road.

2. The five CEMS tools should be deployed in theorder listed. For example, don’t even think aboutchanging crew watch schedules without a solidfoundation of education first!

One AWO member company saysthat its biggest mistake inimplementing CEMS was moving toofast. Based on itsexperience, thiscompany recommendsstarting with small stepslike environmentalimprovements that arerelatively easy to implement. Thisbegins the CEMS process in a waythat demonstrates to crewmembersthat the company cares about theirquality of life and paves the way formore dramatic changes later.

Trip Hazards to Avoid:

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IV. Implement the Crew Endurance PlanJust do it! Implement the changes called for in yourCrew Endurance Plan. To do that, you’ll need to findan effective way to provide onboard support for yourCEMS implementation effort. After all, it’s whathappens on the boats, day in and day out, that willdetermine whether your plan achieves its goals.

Here’s where a coach (or team of coaches) can help. Acoach can:

Model good endurance management practicesthrough his or her own behavior, actively encouragecrewmembers to follow these practices themselves,and monitor/reinforce adherence to the CEMS plan.

Provide information to crewmembers on thescience of CEMS, including diet, exercise, caffeineuse, environmental stressors, physiologicalrequirements, and sleep and body clockmanagement.

Help crewmembers learn how to maximize thebenefits of rest opportunities.

Good company-wide communication regarding thecompany’s crew endurance implementation plan is alsoimportant, and it’s essential that the communication andfeedback loop include crewmembers. Crew buy-in iscritical to the success of the CEMS!

V. Evaluate ResultsCrew Endurance Plans should be evaluatedperiodically to see whether identified risk factors havedecreased. Evaluate the plan using the same tools - theCrew Endurance Risk Factor Survey or the DecisionSupport System - that you used to identify risk factorsat the outset. Most companies implementing CEMShave found it helpful to conduct an initial evaluation ofthe CEP within 60 days, and then semi-annual reviewsthereafter. Since endurance risk factors have beenscientifically linked to accident risk, a reducedincidence of risk factors is a measure of CEMSsuccess. Long-term indicators of success such asreduced turnover, injury rates, or near misses may notbe measurable in the near term, but reducing risk

Joann SalyersSafety Supervisor and CEMS ExpertBlessey Marine Services, Inc.

One excessive coffee drinker wasin the habit of loading his manycups of coffee throughout the daywith a large amount of sugar.Through the implementation ofCEMS, he was encouraged toreduce his coffee intake and drinkmore water. He says this changehas made him feel better, a factsubstantiated by his crew whoreport him to be much morerelaxed and easier to live with.

In Your Own Words:

CEMS Tip!For best results, the CEWGshould maintain an activeeducation program forcrewmembers and ensure thatcrew endurance evaluations occurat least twice a year.

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factors is evidence that your CEMS implementationeffort is on the right track.

How about a real-world example?

This example comes from a vessel participating in aCoast Guard-AWO CEMS demonstration project:

Step 1: A Crew Endurance Working Group wasassembled, consisting of the company safety manager,company operations manager, and the entire vesselcrew. Before beginning its work, the CEWG wastrained in the science of crew endurance and theprocess of crew endurance management.

Step 2: Once trained, the working group analyzed thecurrent situation by studying the vessel’s operationalsystem and its major components. The CEWGidentified the relationships between these majorcomponents and isolated specific factors within eachcomponent that were affecting crew endurance.

OperationalComponent Factors Affecting Crew Endurance

Diet

Crewmembers were eating large mealsimmediately after watch before going to bed.

Crewmembers were also consuming largequantities of caffeine.

IndividualChoices

Crewmembers were being kept awake by noisesassociated with crews handling rigging near thevessel; slamming doors or banging manholecovers; and using TVs, radios, handheld VHFradios, etc. at high-volume levels.

Towing VesselEnvironment

Crewmembers were being awakened bysudden movements of the vessel.

Crewmembers were also being kept awake bylight coming into crew quarters throughwindow ports and air vents in the doors.

CompanyPolicies

Crewmembers were delayed in getting tosleep by having to take showers after watchand meals, and having to wait to be relievedfor meals.

Don’t expect everything to happen allat once. CEMS implementation is aprocess of continuous improvement.

Don’t becomesidetracked by CEMSskeptics whodiscourage you fromlearning more when they don’tunderstand CEMS and its benefitsthemselves.

Don’t just put the CEM Guide onthe boats and expect to start “doing CEMS!”

Avoid focusing on changing thewatch schedule initially. It is notrecommended during the earlyphases of CEMS implementation.

Trip Hazards to Avoid:

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Step 3: On the basis of its analysis, the CEWGdeveloped a list of specific recommendations. Theseincluded the following operational policies andenvironmental changes:

Early showers will be allowed. However,crewmembers will be expected to discuss any workto be completed before taking early showers. Anearly shower does not relieve anyone of any dutiesto be performed on watch.

Early meals will be allowed, provided they do notinterfere with the cook.

Crewmembers coming on watch will be givenpriority seating at meal times.

Pilothouse personnel will actively avoid rapidchanges in throttle settings whenever practicable.

Deck crew will actively minimize noise associatedwith the performance of their duties. This willinclude handling rigging with care near the vessel.

Crewmembers will avoid slamming doors orbanging manhole covers.

Crewmembers will keep TVs, radios, handheldVHF radios, etc. to mutually acceptable volumelevels.

Baffles will be installed on stateroom doors to allowairflow while restricting noise and light.

Slide panels will be installed over exteriorstateroom windows to restrict light.

Step 4: Once the CEWG’s recommendations wereapproved, the Crew Endurance Plan was deployed.Crew Endurance Management Coaches Training wasprovided, as well as information on diet and stressmanagement. The vessel’s own onboard coaches thencarried out additional crewmember training duringnormal operations.

Dan RogersCaptainM/V Big Al

We are presently working the 8-4schedule. It seems to be workingwell for us. We did hear a littlegrumbling from the pilots from timeto time because of the longerworking period at night, but wehave addressed this by backing upthe watch even further so they nowget off watch at 0400 and thensleep hard from 0400 to 1200. Wehave also cut back on the loudprojects such as chipping andgrinding until the afternoon so as toallow the back watch a quietersleep period. This also breaks upthe projects so no one tankermanhas to do all the outside work. At0200 we dim the lights down for theback watch crew so they don’t gethit with too much light prior to bed.I have also increased our bottledwater purchases, which havehelped to cut down on our soda andcaffeine consumption and havehelped us achieve better rest.

In Your Own Words:

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Capt. Don HinsonSouthern Fleet Manager andCEMS ExpertPenn Maritime, Inc.

Having started in this industry backin 1970, I have seen what can beaccomplished through small stepsusing CEMS. We all came from 6-on/6-off and now we are breakingthe surface on a 4-on/8-offschedule. Crews feel better. Theyare more rested. We are makingour vessels quieter through smallchanges in the environment.Crewmembers drink more waterand they eat better. Get on boardwith this: CEMS will work. Give ita chance.

In Your Own Words: Crewmembers were invited to make suggestions toimprove the Crew Endurance Plan and ensured that allof the system modifications recommended in the finalCEP were made. Vessel coaches served as models forcrew emulation and monitored adherence to the newpolicies and procedures.

Step 5: At various times during the implementationphase, the program was assessed using the CrewEndurance Risk Factor Survey/Decision SupportSystem. This assessment showed significantly reducedrisk factors scores. In addition, crewmembers reportedfeeling much less fatigued by the end of their 30-daytour, showed indications of well-adapted body clocks,and experienced minimal lapses in alertness. However,the CEWG also found that the crew had reporteddisrupted sleep due to broken-down mattresses andnoisy machinery vibration. Based on a recommendationby the CEWG, the company decided to replace themattresses as soon as possible, but decided that noise-dampening measures for the machinery would have towait until the next major maintenance period.

The American Waterways Operators801 North Quincy Street, Suite 200

Arlington, VA 22203Phone: (703) 841-9300

www.americanwaterways.com

United States Coast GuardHuman Element and Ship Design Division (G-MSE-1)

2100 Second Street, SWWashington, D.C.

Phone: (202) 267-2997www.uscg.mil/hq/g-m/cems/index.htm