Proceedings - United States Coast Guard

ProceedingsProceedingsVol. 67, Number 4Winter 2010-11

Commercial Fishing Vessel SafetyCommercial Fishing Vessel Safety

6 Fishing Vessel Safetyby CAPT Eric Christensen and Mr. Jack Kemerer12 The Coast Guard Authorization Act of 2010

14 Commercial Fishing Vessel Safety Program Information Onlineby ENS Amy Downton

16 Saving Lives at Sea Through Advocacyby Mr. Jonathan Wendland

18 Fishery-Specific Risk FactorsbyMr. Devin Lucas and CDR Jennifer Lincoln, Ph.D.

21 The Coast Guard and Third-Party Organizationsby Mr. David Belliveau

23 USCG Auxiliary Commercial Fishing Vessel Examinersby Mr. Matthew Hooper

24 Health and Safety at Seaby LCDRMichele Bouziane

26 The Alternate Compliance and Safety Agreementby Mr. Troy Rentz28 Relative Comparison of Load Line and ACSARequirementsby Mr. Tom Jordan

31 The North Pacific Fishing Vessel Owner’s Association Vessel SafetyProgramby Ms. Leslie J. Hughes

Mitigating RiskMitigating Risk

36 Fish Safe!by Ms. Gina Johansen

39 Operation Safe Crabby Mr. Daniel Hardin and Mr. Kenneth Lawrenson

44 Alternate Safety Compliance Programsby Ms. Leslie J. Hughes and CDR Chris Woodley

Mitigating

RISK

S A F E T Y

FISHING VESSELCommercial

4 Assistant Commandant’sPerspectiveby RADM Paul Zukunft

5 Champion’s Point of Viewby RADMKevin Cook

35 Upcoming in Proceedings

Training & OutreachTraining & Outreach

47 Better Safe Than Sunkby Dr. Madeleine Hall-Arber and Dr. Karina Lorenz Mrakovcich

51 AMSEA’s Port-Based Safety Trainingby Mr. Jerry Dzugan54 The Coast Guard and the AlaskaMarine Safety Education Associationby Mr. David Belliveau

55 Survival Through Educationby PA3 Colin White

57 Interventions in the Interest of Safetyby Ms. Ann S.N. Backus

Collaborative EffortsCollaborative Efforts

61 The United States Marine Safety Associationby Mr. Ed McCauley, Mr. Richard Hiscock, Ms. Kari Guddal, and Mr. TomThompson

63 Critical Communicationby Dr. Jeffrey L. Levin, Ms. Karen Gilmore, Ms. Ann Carruth, Ms. AmandaWickman, Ms. Sara Shepherd, Mr. Gilbert Gallardo, and Dr. MatthewNonnenmann

66 Integrated Safetyby Mr. Alan Dujenski

68 Breaking the Chainby Mr. Jerry Dzugan

73 Great Lakes Commercial Fishingby LCDRWm. Erik Pickering

Lessons LearnedLessons Learned

76 Lost at Seaby Ms. Daisy R. Khalifa

On DeckOn Deck

&TRAINING

OUTREACH

CollaborativeEFFORTS

fromCasualtyInvestigations

Lessons LearnedLessons Learned

75 Chemical of the QuarterUnderstanding AnhydrousAmmoniaby Ms. Sara Ju

Nautical Queries84 Engineering85 Deck

AssistantAssistantCommandant’sCommandant’sPerspectivePerspective

4 Proceedings Winter 2010-11

ADM Robert J. Papp Jr.Commandant

U.S. Coast Guard

The Marine Safety& Security Council

of theUnited States Coast Guard

RDML Frederick J. KenneyJudge Advocate General

Chairman

RADM Paul ZukunftAssistant Commandantfor Marine Safety, Security

and StewardshipMember

Mr. Jeff LantzDirector of Commercial

Regulations and StandardsMember

RADM Kevin CookDirector of Prevention Policy

Member

Mr. Dana A. GowardDirector of Marine Transportation

Systems ManagementMember

CDR Sandra SelmanExecutive Secretary

Ms. Kathryn SinnigerLegal Advisor

View Proceedings online atwww.uscg.mil/proceedings

By RADM PAUL ZUKUNFTU.S. Coast Guard Assistant Commandant for Marine Safety, Security and Stewardship

Recent reality television shows have raised awareness among the general public of the dan-gers associated with commercial fishing. For those of us in the maritime community, how-ever, commercial fishing safety has been a long-known concern. While the trend in themaritime and national workforces over the last century has been toward increased safetyand reduced casualties as working conditions improve and safety requirements have beenimplemented, the commercial fishing industry continues to lag behind.

The Commercial Fishing Industry Vessel Safety Act of 1988 was the first legislation to addressfishing vessel safety. Since its inception, the number of vessel losses and fatalities occurringeach year has been cut by over half, demonstrating the merit of prevention. Despite thisprogress, a recent preliminary Department of Labor finding indicates that the fatal injuryrate for fishers and fishing-related workers, at 200 per 100,000, is the highest of any occupa-tion.1 That number stands in sharp contrast to the fatal injury rate for all workers at 3.3 per100,000, and necessitates a call for action. The Coast Guard 2010 Authorization Act providesone additional vehicle to improve fishing vessel safety.

The contributors to this issue are many and varied, demonstrating the whole of governmentand NGO approach to improving fishing vessel safety. An article by the National Institutefor Occupational Safety and Health provides a scientific perspective on safety issues in thefishing industry. Experts in fishing vessel training from the North Pacific Fishing Vessel Own-ers’ Association, Alaska Marine Safety Education Association, and Fish Safe Program inBritish Columbia provide insight on fisherman safety education. Other contributors includemembers of our Commercial Fishing Vessel Safety Division at Coast Guard headquarters,Fishing Vessel Safety Coordinators and leaders from Districts 13 and 17, and numerous otherfishing industry stakeholders.

This issue also includes a summary of the fishing vessel safety provisions in the Authoriza-tion Act, which notes their impact on the industry and outlines tentative plans for imple-mentation. Although many of the articles in this issue were written before the Coast GuardAuthorization Act was signed, and some may contain information that will change in minorways as a result of the act, the information is still timely, relevant, and vital to addressing fish-ing vessel safety issues.

Enjoy this issue of Proceedings! Let’s make it our goal in the next commercial fishing safetyedition to celebrate a significant decrease in commercial fishermen injured or lost in theirprofession.Endnote:1. Bureau of Labor Statistics, U.S. Department of Labor (2010). National Census of Fatal Occupational Injuries in 2009 (Prelimi-

nary Results).

Champion’sChampion’sPoint ofPoint of

ViewView

5Proceedings Winter 2010-11

Editorial Team

Barbara ChiariziaExecutive Editor

Diana ForbesManaging Editor

Ann AikenArt Director

Ilene MuravnikDocumentation Specialist

Proceedings is published quarterly bythe Coast Guard’s Prevention Direc-torate, in the interest of safety at seaunder the auspices of the MarineSafety & Security Council. Special per-mission for republication, either inwhole or in part, except for copy-righted material, is not required, pro-vided credit is given to Proceedings.

The articles contained in Proceedingsare submitted by diverse public and pri-vate interests in the maritime commu-nity as a means to promote maritimesafety and security. The views ex-pressed by the authors do not neces-sarily represent those of the U.S. CoastGuard or the Department of HomelandSecurity or represent official policy.

Editorial Contact

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By RADM KEVIN S. COOKU.S. Coast Guard Director of Prevention Policy

This is an exciting and busy time in the prevention community. The Coast Guard AuthorizationAct of 2010 was four years in the making and contains provisions that will require an estimated40 rulemaking projects for the Coast Guard. As Director of Prevention Policy, perhaps the areaof greatest interest for me is the expansion of the Coast Guard’s authority and involvement withcommercial fishing vessels.

Among its provisions, the Coast Guard Authorization Act requires fishing vessels operatingmore than three nautical miles beyond the baseline to be examined at least once every two years.There are currently about 12,000 vessels subject to Coast Guard inspection. Compare that to thenumber of fishing industry vessels that will have to be examined. Based on numbers providedby each Coast Guard district, there are an estimated 35,000 fishing industry vessels operating be-yond three nautical miles of the baseline. It is clear that these new requirements will require amulti-pronged approach to mandatory safety examinations.

I believe that these examinations working in conjunction with the other provisions of the CoastGuard Authorization Act provide a framework for an enhanced safety effort that can bridge thegap between commercial fishing and other maritime industries. Up until now, the Coast Guard’sFishing Vessel Safety Program has relied on voluntary dockside exams to identify deficienciesand at-sea boardings to enforce the safety regulations. Much of our effort involved conductingoutreach and convincing fishing vessel owners to accept a safety exam, with only a fraction offishing vessels actually completing an exam each year. But with implementation of the Author-ization Act, the dynamics of the program will change. Mandatory dockside safety exams forfishing vessels operating more than three nautical miles from shore means compliance withsafety regulations will be a prerequisite to operation of these vessels. Fishing vessel owners nowwill have to seek out examiners, where it might have been the other way around in the past.

Our aim is to reduce the number of fishing vessel casualties and fatalities. We know that abouthalf of all fatalities occur as a result of a vessel loss. We want to prevent the casualty, not have toreact to it. We will have to draw on the lessons of the past, capitalize on research, team with in-dustry to provide realistic solutions, and ensure that our personnel have the knowledge andability to carry out our policies. As you read this issue, consider your role in fishing vessel safetyand what we can do to make this program as successful as possible. It will take effective team-work, creativity, and resolve from all involved in this effort to make safety in the fishing indus-try what it ought to be.

We do not want the commercial fishing industry to continue to be the most hazardous occupa-tion in the country, and it would be nice to see a new name for the “Deadliest Catch” reflectinga safer industry. Join me in making prevention of casualties on commercial fishing vessels a pri-ority and a reality. “FishSafe!”

6 www.uscg.mil/proceedings

It has been more than 20 years since the CommercialFishing Industry Vessel Safety Act of 1988 was passed,and almost that long since the 1991 Requirements forCommercial Fishing Industry Vessels were promul-gated in regulation under 46 CFR Part 28. The act andimplementing regulations were designed to give fish-ermen safety equipment, emergency systems, and aminimum level of instruction to help them survive avessel casualty at sea until help could arrive.

After the Safety Act and RegulationsOver the years since the 1988 act and 1991 regulations,the Coast Guard has made many attempts to improve

safety in the commercial fishing industry—some yield-ing success, and some not. Subsequent to the require-ments and standards becoming effective, data shows asignificant reduction in the number of vessels and fish-ermen’s lives lost each year.1,2

To put this in perspective, during the 10-year periodprior to the act and regulations, an average of well over200 vessels and more than 100 fishermen were lost an-nually. For the 10-year period after the safety regula-tions were implemented, the average number of vessellosses decreased to approximately 140 per year, whilethe annual fatality average dropped to approximately

70. In the past 10 years, the annual vesselloss average has dropped to under 90, andthe fatality average has declined to approx-imately 45 per year.

The Coast Guard submitted a report andrecommendations in 1992 for both the li-censing of operators on commercial fishingvessels and a plan to require the inspectionof fishing vessels. Neither the licensing plannor the inspection plan received congres-sional action. Follow-on rulemaking proj-ects after the 1991 regulations were initiatedin 1992, 1995, and 1998 regarding immer-sion suits and stability requirements; how-ever, they were later withdrawn.

To carry out the Commercial Fishing VesselSafety (CFVS) Program, the Coast Guard es-tablished 61 positions assigned to head-

Fishing VesselSafety

Where we’ve been,where we’re headed.

by CAPT ERIC CHRISTENSENChief, U.S. Coast Guard Office of Vessel Activities

MR. JACK KEMERERChief, U.S. Coast Guard Fishing Vessel Safety Division

Over the past several years, fishermen have topped the list of “most dangerousoccupations” in the United States. Source: U.S. Bureau of Labor Statistics, U.S.Department of Labor, 2010.

S A F E T Y


Proceedings Winter 2010-11

7Proceedings Winter 2010-11www.uscg.mil/proceedings

quarters, district offices,and marine safety offices(now sectors) in the mid-1990s. With the absenceof authority to regulatecommercial fishing in-dustry vessels as in-spected vessels, theCoast Guard embarkedon an outreach and edu-cation campaign.

Voluntary dockside safety examinations remain thehallmark of the campaign. During a voluntary exami-nation, a Coast Guard examiner works with owners,operators, and crew to explain requirements, checkcompliance with federal regulations, and assist thecrew in correcting deficiencies, when possible. Dis-crepancies are brought to the attention of the vessel op-erator, but no penalty action is initiated. If the vessel isfound to be in compliance with all requirements, asafety decal is issued to the vessel that may be valid forup to two years.

ATask Force on CasualtiesIn the first few years of implementing the CFVS Pro-gram, less than 10 percent of fishing vessels were com-pleting voluntary dockside safety examinations. Soonafter, a series of incidents spurred new interest in safetyand intervention. During a three-week period betweenthe end of December 1998 and the middle of January1999, four vessels were lost and 11 fishermen died offthe East Coast.

The Coast Guard responded by chartering a FishingVessel Casualty Task Force comprised of representa-tives from various Coast Guard offices, the NationalTransportation Safety Board, the National Oceanic andAtmospheric Administration, the National MarineFisheries Service, the Occupational Safety and HealthAdministration, and several advisors from the fishingindustry. The task force evaluated the casualties andrecommended measures to reduce the loss of life andvessels. Its report “Living to Fish, Dying to Fish” wasreleased in April 1999 with 59 recommendations to im-prove safety, including:

· coordinating fishery management with safety,· establishing operator and crew standards,· ensuring vessels comply with standards,· establishing safety and stability standards,· improving [CFVS] program management,

· conducting researchand development,

· informing fishermenon safety issues.

Subsequent to the taskforce report and recom-mendations, the Com-mercial Fishing IndustryVessel Safety AdvisoryCommittee and districtCFVS coordinators met

to review the report and develop a long-term actionplan for the CFVS Program. Because several items inthe developed action plan were not well-supported inthe past, the Coast Guard held regional listening ses-sions to receive public comments on the action itemsidentified in the plan. Surveys were also distributed toobtain feedback and information from fishermen on ac-tions to enhance safety.

To further promote safety and improve outreach in theindustry, and following a recommendation of the taskforce, the Coast Guard established more than 40 addi-tional positions in the CFVS program. These new as-signments at field units added personnel who couldconduct vessel safety examinations, assist in trainingfishing crews, and train boarding officers, who couldcheck for vessel compliance.

At about this same time, CFVS coordinators and ex-aminers began focusing on identifying fishing vesselsthat could be considered high-risk based upon theircondition, area of operation, or the fishery in whichthey were involved. Examiners increased outreach tothese targets to gain access and conduct dockside safetyexaminations. To further focus on high-risk fisheries,such as the Alaska/Bering Sea crab fishery, the CoastGuard began deploying personnel to key port areasprior to a season opening to conduct safety compliancechecks. These checks did not constitute a full safety ex-amination; they focused on safety and survival equip-ment being in serviceable condition, stabilityconditions, and other conditions of the vessel that couldlead to downflooding. These pulse operations wereadopted for vessels in other areas of the country withhigh-risk fisheries and operating environments withpositive, casualty-reducing results.

Training PromotedNumerous organizations such as the North PacificFishing Vessel Owners Association, the Alaska MarineSafety Education Association, and state sea grant pro-

U.S. Coast Guard photo.

grams have been providing safety and awareness train-ing programs for over 25 years. To provide training andencourage fishermen’s participation in the CFVS Pro-gram, the Coast Guard staged damage control trainingtrailers, damage stability trainers, intact stability train-ers, and emergency position-indicating radio beacon(EPIRB) test kits around the country in the 1990s. TheCoast Guard also offered safety and awareness train-ing programs in various port areas, in fishing commu-nities, and to industry groups. Many other programsexist that train fishermen and individuals to serve asdrill conductors on fishing vessels.

There have been various recommendations on enhanc-ing safety for and competencies of fishermen throughtraining. In a 1987 study, “Uninspected CommercialFishing Vessel Safety,” and marine accident reports, theNational Transportation Safety Board recommendedthat minimum safety training standards be establishedfor fishermen. In 1991, the National Research Councilreport “Fishing Vessel Safety, Blueprint for a NationalProgram” recommended requiring education andtraining with certification. And in 1997, the National In-stitute for Occupational Safety and Health recom-

mended that basic fishing safety training be completedby fishermen. Also, the 1999 casualty task force recom-mended required refresher training for drill conductorsand crew competency requirements be instituted.

Many safety recommendations having to do with train-ing resulted from commercial fishing industry vessel

casualty investigations over the years. Commonthemes in the investigation reports include enhancingand expanding safety orientations, emergency instruc-tions, and survival training requirements. Additionaltraining topics and areas recommended for fishermeninclude:

· fire prevention and firefighting,· damage control,· stability,· navigation safety,· survival awareness.

Increased awareness and greater emphasis on safetyafter the casualty task force report coupled with con-tinued vessel losses and crew fatalities off New Eng-land sparked fishing industry groups, localcommunities, and government agencies to partner indeveloping and conducting safety and survival train-ing workshops and programs. This was first imple-mented in New Bedford in October 2005. It was so wellreceived that the training program was expanded andhas become a model for programs in other parts of thecountry. Still, it was not mandatory.

New Authorities Sought—and GainedIn response to numerous safety studies and re-ports and a renewed awareness and interest intraining for crews and safety of vessels, the CoastGuard began requesting additional regulatoryauthority in 2005 through legislative change pro-posals. Specifically, we proposed a pilot projectfor mandatory safety examinations in areas of thecountry where casualty rates were the highest.We also began seeking requirements for crewtraining and new or upgraded types of safetyequipment.

Re-enforced by a number of casualties with mul-tiple fatalities in 2006 and 2007, there developeda new congressional interest in fishing vesselsafety. As a result, the House passed H.R. 2830 in2008. The bill would have made some significantchanges in requirements for the industry and au-thorities for the Coast Guard, including:

· treating documented and state-registered vesselsthe same for requirements;

· establishing three nautical miles (NM) from thebaseline as the operating boundary for equipment;

· making dockside safety examinations mandatory(vessels operating beyond 3NM of the baseline);

· adding new equipment and training requirements;

8 Proceedings Winter 2010-11 www.uscg.mil/proceedings


continued on page 10


Galaxy

Lady Luck

Lady of Grace

Recent Fishing Vessel CasualtiesEven with a re-invigorated interest in and action on fishing vessel safety, serious casualties have continued.

In April 2001, the Arctic Rose, a 92-foot steel-hulled trawler/processor, was lost off St. Paul, Alaska with 15crewmembers dead or missing. In October 2002, the Galaxy, a 171-foot steel-hulled long-liner/processor,suffered a fire and explosion in the Bering Sea, leaving three crewmembers dead or missing. Then in 2003, theAtlanta capsized and sank off Chatham, Mass., leaving three crewmembers dead, and the Candy B II sank offNantucket, leaving four dead.

Every year since then, at least one significant vessel casualty occurred leaving multiple crewmembers deador missing, including:1

· 2004 – Northern Edge capsizes and sinks off Nantucket, five fatalities;· 2005 – Big Valley sinks in the Bering Sea, five fatalities;· 2006 – Ocean Challenger,Catherine M, and Ash capsize and sink off Alaska and the Oregon coast; three,

three, and four fatalities, respectively;· 2007 – Lady Luck and Lady of Grace sink off New England, two and four fatalities;· 2008 – Katmai and Alaska Ranger sink in the Bering Sea, seven and five fatalities;· 2009 – Patriot and Lady Mary sink off Mass. and N.J., two and six fatalities;· 2010 – Majestic Blue sinks in the central Pacific, two fatalities.Endnote:1. Marine Information for Safety and Law Enforcement database.

Ocean Challenger

Lady Mary

Recent Fishing Vessel Casualties

Majestic Blue

U.S. Coast Guard photos.

· expanding stability, classification, and load line re-quirements for fishing vessels;

· establishing grant programs for training and research;· reauthorizing and expanding the advisory com-

mittee.

In 2009, the same provisions were included in H.R.2652, but again the bill did not become law. However,in September 2010, H.R. 3619 was passed by Congressand the president signed the Coast Guard Authoriza-tion Act of 2010 on 15 October 2010. The provisionsnoted above are key portions of the act that will impactsafety on commercial fishing vessels and give the CoastGuard additional authorities. When implemented, wefully expect these new requirements will help reducevessel losses and crew fatalities, so that commercialfishing is no longer the most hazardous occupation inthe United States.

Others Embrace Safety RequirementsThe National Oceanic and Atmospheric Administra-tion’s National Marine Fisheries Service (NMFS) re-quires fishery observers aboard vessels fishing undercertain permits. In an effort to monitor by-catch and en-sure these vessels were safe for carriage of the observers,NMFS proposed a rule in 2006 clarifying the requirementfor a Coast Guard safety examination that had alreadybeen in effect since 1998. This rule became final in 2007,so now any vessel subject to observer carriage must suc-cessfully complete a Coast Guard dockside safety ex-amination and be issued a safety decal. The observersalso complete a vessel safety checksheet to ensure all crit-ical safety and survival equipment has been checked andtested in accordance with the regulations. Further, theycomplete a safety orientation, review safety instructions,or participate in a drill on the vessel.

Regional fishery management councils develop fisherymanagement plans. Under the Magnuson-Stevens Fish-eries and Conservation Management Act, the councilsare required to ensure that their conservation and man-agement measures also promote the safety of human life

at sea. The Coast Guard is a non-voting member oneach of eight regional councils. Our representativesaid fisheries managers in addressing various man-agement alternatives by providing them with ex-pert advice on the operational realities of at-sea lawenforcement, as well as vessel and crew safety. Wewill continue to champion safety in fisheries man-agement regimes and provide information and rec-ommendations from our Commercial FishingIndustry Vessel Safety Advisory Committee.

Additionally, several states are partnering with theCoast Guard to promote fishing industry safety. Ini-tiatives such as requiring crew training and safetychecks on vessels with state permits are examples ofprograms that are already in effect or being consid-ered. Tribal nations on the Great Lakes have insti-tuted fishery management and enforcementprograms. The Coast Guard has memorandums ofagreement with several tribes to provide enforce-ment officer and examiner support and training andto promote safety programs for tribal fishermen.

TheWay ForwardWhile the Coast Guard and industry have made sig-nificant strides in improving safety and survival offishing vessels and crews, the Department of Labor’sBureau of Labor Statistics has listed “fishers and re-lated fishing workers” as the occupation with thehighest fatality rate for the past five years in a row.The latest report on fatal occupational injuries indi-cates that the fatality rate in the fishing industry ismuch higher than the average rate for all workers(see chart on first page of article).

With all the efforts to improve safety in the com-mercial fishing industry, there remains much thatcan still be accomplished to reduce the loss of lifeand vessels, even with the additional authority andnew requirements in the 2010 Authorization Act.As long as commercial fishing is the most hazardousoccupation in the country, the goal of the FishingVessel Safety Program will be to increase the level ofsafety so that it is no more dangerous than any othersegment of the maritime community. We can go along way in effecting this by:

· Increasing the rate of safety compliance withexisting standards and requirements throughadditional education and outreach programs.Promoting, supporting, and helping facilitateexisting safety awareness and crew compe-tency training programs will raise the knowl-


Vessel losses have been the leading cause of fatalities over the years.

Falls overboard account for the second-highest cause of fatalities in theindustry. Between 2000 and 2009, falls overboard led to 155 deaths.1

Significant in this statistic: Not one of the dead was wearinga personal flotation device.

Endnote:1. “Commercial Fishing Deaths-United States, 2000-2009,” Morbidity and Mortality Weekly Report

(MMWR), July 16, 2010.

Safety Statistics

edge and skills of all fishers. We need to encouragenew and expanded programs, whether community-based or offered by industry organizations.

· Expanding and developing better lines of communi-cation with the industry. Established websites suchas the Coast Guard’s www.fishsafe.info andhttp://homeport.uscg.mil and numerous industrysites can be made more visibleand marketed to fishermen tomake them more aware of avail-able resources.

· Expanding awareness and dis-tribution of safety informationfliers, alerts, and references tofishermen during docksidecontacts and promoting theiravailability on the above web-sites and in trade publications.

· Expanding the dockside exam-ination program to the fullestextent resources permit. Asmentioned previously, lessthan 10 percent of fishing ves-sels were completing voluntarydockside safety examinationsshortly after the CFVS Programbegan, and unfortunately, thisis still the case today. Increasingthe number of qualified exam-iners in the Coast Guard Re-serve and Auxiliary ranks willprovide additional capacityand capability. Over the pastfive years we have been averaging more than 7,000dockside exams and we will strive to increase thatlevel by 10 percent per year until the mandatoryexam requirement can be implemented. Mandatoryexams are estimated to be applicable on about halfthe fleet, or approximately 35,000 vessels. We willalso seek to increase compliance on vessels not re-quired to complete an exam.

· Increasing compliance with and enforcement ofsafety regulations through risk-based “safe catch”-type operations and targeting high-risk/high-casualty fisheries. Vessels found with especiallyhazardous conditions should be required to correctdeficiencies before getting underway, or their voy-ages terminated if at sea. Compliance boardings atsea have been averaging over 7,000 per year. Again,we should seek to increase this number as resourcesand operational tempos allow.

· Improving industry risk management practices andpromoting a heightened safety culture with fisher-men. Outreach and education programs will help fa-cilitate this effort.

· Partnering with fisheries resource managers to reducerisk by embracing safety considerations in all fisherymanagement plans and policies. Increasing our visi-

bility and participation at regional management coun-cil meetings are an integral part of this effort.

Authors’ note:Discussions on several of the topics in this article were not extensive, as thereare other articles in this edition that provide more detail.

About the authors:CAPT Christensen’s earliest exposure to commercial fishing vessel safetywas as the first Commercial Fishing Vessel Safety Coordinator at MarineSafety Office Portland, Ore., from 1992 to 1994. A 1987 graduate of theCalifornia Maritime Academy, he has spent his career dedicated to ma-rine safety, culminating in his assignment as Office of Vessel ActivitiesChief at Coast Guard headquarters.

Mr. Kemerer served as the 1996-1997 Fishing Vessel Safety programman-ager prior to retiring from active duty with the U.S. Coast Guard. Afteremployment in the private sector, he returned to the Coast Guard as aCommercial Vessel Safety Specialist in the Office of Vessel Activities, Fish-ing Vessel Safety Division at Coast Guard headquarters, and later wasappointed as the division chief.Endnotes:1. “Living to Fish, Dying to Fish,” Fishing Vessel Casualty Task Force Report,

March 1999.2. “Analysis of Fishing Vessel Casualties,” U.S. Coast Guard, October 2008.


After the rulemaking projects regarding immersion suits and stability requirements were initiatedand then withdrawn in the 1990s, a new regulatory project began in 2003. Work progressedslowly and it became evident that the Coast Guard needed additional information and feed-back from the industry and public on requirements that might be considered in the rulemakingproject, based on recent studies and safety recommendations.

An advanced notice of proposed rulemaking (ANPRM) was published on March 31, 2008 andthe comment period closed on July 29, 2008, but was reopened on August 13, 2008 until De-cember 15, 2008. Two public hearings were held in Seattle, Wash., on November 21 and 22, 2008.

The ANPRM discussed the history of Coast Guard rulemaking under the Commercial Fishing In-dustry Vessel Safety Act of 1988 and the need for further rulemaking. Thirty questions were posedfor public comment that could be grouped into the following general topic areas:· stability and watertight integrity,· causes of vessel loss other than stability and watertight integrity,· risk awareness,· training and drills,· safety and survival equipment,· regulatory costs and benefits.

Comments received in response to the ANPRM and the public hearings, information from recentstudies and reports, and safety recommendations from fishing vessel casualties are all being con-sidered as we move forward with the rulemaking project. At the time of this writing, and in re-sponse to the passage of the Coast Guard Authorization Act of 2010, the rulemaking is beinginternally reviewed and may be revised before administrative review.

New Requirements Considered

Parity for All VesselsUniform safety standards are established for all vessels, particularlythose vessels operating beyond three nautical miles of the baselineof the territorial sea and coastline of the Great Lakes. In Title 46 U.S.C.§4502(b)(1) “documented” is deleted, so there will no longer be dif-ferent standards for federally documented and state-registered ves-sels operating on the same waters. Additionally, 46 CFR part 28,subpart C must be amended to reflect the change.

Replacing Boundary Line with Three Nautical MilesTitle 46 U.S.C. §4502(b)(1)(A) is amended by replacing“Boundary Line”with“three nautical miles from the baseline from which the territorialsea of the United States is measured or three nautical miles from thecoastline of the Great Lakes.” Various sections of 46 CFR part 28 mustbe amended to reflect this change. The boundary line location wasconfusing, whereas the three-mile line is a well-known demarcationshown on most charts.

Survival CraftAll fishing industry vessels operating beyond three nauticalmiles are re-quired to carry survival craft that will meet a newperformance standardfor primary lifesaving equipment. Title 46 U.S.C. §4502(b)(2)(B) isamended by replacing “lifeboats or liferafts” with “a survival craft thatensures that no part of an individual is immersed in water.” This meansthat life floats and buoyant apparatus will no longer be accepted as sur-vival craft on any commercial fishing vessel operating beyond three nau-tical miles; 46 CFR part 28 must be amended to reflect this change andthere could be a phase-in period for this requirement.

RecordsA new provision requires that the individual in charge of a vessel oper-ating beyond three nautical miles maintain a safety logbook—a recordof equipment maintenance and required instruction and drills. Title 46U.S.C. §4502(f) is amended to add this requirement; 46 CFR part 28 mustbe amended.

Examinations and Certificates of ComplianceDockside safety examinations at least once every two years are nowmandatory for vessels operating beyond three nautical miles. A cer-tificate of compliance will be issued to a vessel successfully complet-ing the exam; 46 U.S.C. §4502(f) is amended to add this requirement,and 46 CFR part 28 must be amended to implement it. Voluntaryexams will continue to be promoted for vessels operating inside threenautical miles.

Related to this, individuals authorized to enforce Title 46 may removea certificate from a vessel operating in a condition that does not com-ply with the provisions of the certificate. And, if the vessel does nothave the required certificate on board, or if the vessel is being oper-ated in an unsafe condition, it may be ordered to return to a mooringand remain there until the certificate is issued/reissued or the condi-tion is corrected. Title 46 U.S.C. §2117 is amended to change this re-quirement, and 46 CFR part 28 must be amended to implement it forfishing vessels.

Training for OperatorsA new provision applicable to vessels operating beyond three nauti-cal miles requires individuals in charge of the vessel to pass a training


The Coas t Guard Author i za t ion Ac t o f 2010 *

New requirements for commercial fishing industry vessels.


For more INFORMATION

www.fishsafe.infoFor more in-depth information and full text, go to


*(P.L.111-281)

program covering certain competencies. This is covered in a new 46U.S.C. §4502(g) and 46 CFR part 28 must be amended. The trainingmust include, among other things, seamanship, navigation, stability,fire fighting, damage control, safety and survival, and emergencydrills. Credit can be considered for recent experience on fishing ves-sels. Refresher training is required every five years. A publicly acces-sible database listing individuals who completed the training will beestablished.

Construction Standards for Smaller VesselsVessels built after January 1, 2010 and less than 50 feet overall in lengthmust be constructed in a manner that provides a level of safety equiv-alent to the standards for recreational vessels established under 46U.S.C. §4302. This provision is set forth in a new 46 U.S.C. §4502(h).Implementing regulations must be developed. Note: “overall inlength” means the horizontal distance of the hull between the fore-most part of the stem and the aftermost part of the stern excluding fit-tings and attachments. This is different from“registered length.”

LoadlinesThe act amends 46U.S.C. §5102(b)making assignment of a loadline a re-quirement on fishing vessels 79 feet or greater in length that are builtafter July 1, 2012.

Further, in 46 U.S.C. §5103, a new paragraph (c) is added that requiresfishing vessels built on or before July 1, 2012 that undergo a substantialchange to thedimensionof or typeof vessel completed after July 1, 2012,or a later date set by the Coast Guard, to comply with an alternate load-line compliance program developed in cooperationwith the industry. Itis anticipated that the Commercial Fishing Safety Advisory Committeewill be engaged in helping to develop alternate compliance programshere, and related to vessel classing below. Regulations must be devel-oped to implement these programs.

Classing of VesselsThe act amends 46 U.S.C. §4503 to make it applicable to fishing andfish tender vessels in addition to fish processing vessels. A new para-graph (c) is added that requires survey and classification of a fishing

vessel that is at least 50 feet in overall length, built after July 1, 2012,and operates beyond three nautical miles. It also requires the vesselto remain "in class" and have the appropriate certificates on board.

A new paragraph (d) is added to 46 U.S.C. §4503 that requires:(1) development of an alternate safety compliance program by Janu-ary 1, 2020 for vessels over 50 feet in length, built before July 1,2012, and 25 years of age or older;

(2) an alternate safety compliance program for vessels built beforeJuly 1, 2012 that undergo a substantial change after the later ofJuly 1, 2012, or a date to be determined by the Coast Guard; and

(3) owner(s) of 30 or more vessels subject to (1) who enter into acompliance agreement with the Coast Guard can delay meetingthe requirement of (1) until January 1, 2030.

The alternative safety compliance programs are to be developed incooperation with the industry, and may be developed for specific re-gions and fisheries. Further, in this new paragraph, vessels classed be-fore July 1, 2012 are required to remain in classification and have acurrent certificate on board.

A new paragraph (e) is added to 46 U.S.C. §4503 that requires the CoastGuard to prescribe the alternate safety compliance program for oldervessels by January 1, 2017.

Other ProvisionsTitle 46 U.S.C. §4502 is amended by also adding requirements for theCoast Guard to establish a Fishing Safety Training Grants Program anda Fishing Safety Research Grant Program. The grants will be awardedon a competitive basis. The federal share of the activities costs cannotexceed 75 percent.

Title 46 U.S.C. §4508 is amended by renaming the Commercial Fish-ing Safety Advisory Committee and reauthorizing it until September30, 2020. The committee is also expanded to 18members and will con-tinue to represent groups with expertise, knowledge, and experienceregarding the commercial fishing industry.


Homeport is a secure Internet portal that provides crit-ical information and service delivery to the public, mar-itime industry, and United States Coast Guard. Itenables partnerships across the entire maritime com-

munity by providing secure collaboration environ-ments over the Internet.

The official United States Coast Guard Fishing VesselSafety Division homepage is unrestricted and open to the

public, offering current andhistorical commercial fish-ing vessel-related informa-tion. Links enable the userto access a wide range of re-lated information, Naviga-tion and Vessel InspectionCirculars, safety notices,and alerts. The archive sec-tion offers valuable insightinto the program’s forma-tion and direction.

The main objective is to in-crease awareness of andcompliance with fishingvessel safety requirements.1

Helpful HintsHere are some useful tipsfor navigating around theUnited States Coast GuardHomeport portal.

Commercial FishingVessel Safety ProgramInformation Online

Information sharingand outreach.

by ENS AMY DOWNTONU.S. Coast Guard Reserve

U.S. Coast Guard Office of Vessel ActivitiesCommercial Fishing Vessel Division

The Homeport quick reference card can be found at http://asvts.com/home/news/news_docs/qrchome.pdf.

S A F E T Y



formation. Recent updates to Homeport include a fea-ture enhancement allowing users to customize contentthat will personalize the display content to includemultiple ports, increasing the dissemination of area-specific information by port or interest. Users may alsosign up for USCG text message alerts.

About the author:ENSAmyDownton is assigned to the Office of Vessel Activities, Com-mercial Fishing Vessel Division. Previous experience includes marinesafety, investigation, inspection, maritime law enforcement, and search

and rescue operations. Prior tobecoming an officer, she enteredthe Coast Guard in 2005 as a ma-rine science tech.

Endnote:1. Title 46 Code of Federal Regula-

tions, Part 28—Requirements forCommercial Fishing Industry Ves-sels.

The tabs on Homeport currently available to guestusers are:

· Missions—information about the U.S. CoastGuard’s efforts in marine safety, marine security,and environmental protection.

· Port Directory—public information directory foreach U.S. Coast Guard port area.

· Library—U.S. Coast Guard marine safety, marinesecurity, and environmental protection regulations,policy, forms,and publica-tions.

Creating a personaluser account onHomeport will in-crease available in-

www.fishsafe.info

A large segment of the commercial fishing industrycommunity uses www.fishsafe.info to link directly intospecific Homeport topic areas.

In addition, the website provides the fishing communitya forum for interaction and access to training and educationalresources, instructor listings, contact information, andindustry connections.

Fishsafe.info also provides a medium for communicationwith Coast Guard headquarters personnel.

2. Read the list of requirements, then click “ok.”

3. If you meet the requirements, complete the Home-port registry form. Required fields are indicated withan asterisk.

4. If you wish to receive USCG alerts by SMS/textmessaging, check the box.

5. Select “primary Captain of the Port zone” from thedrop-down menu.

HOW TO REGISTER FOR A HOMEPORT ACCOUNT

6. To add one or more COTP zones, check the box or see“adding other COTP zones to the registration form.”

7. If applicable, select a value under “committees.” For theSafety Advisory Committee, enter your title, role, andassociated subcommittee.

1. From the Homeport homepage (http://homeport.uscg.mil) click the “register” link in the upper-right corner ofthe screen.


The U.S. fishing industry, which dates back to our ear-liest settlers, was recently estimated to contribute $38.5billion to the U.S. gross domestic product.1 It is also ar-guably the most dangerous profession in the country.Mindful of the social and economic impact of this in-dustry, the Coast Guard’s Commercial Fishing IndustryVessel Safety Advisory Committee* (CFIVSAC) pro-vides insight and advice to the Coast Guard on mattersrelating to safe operations, regulatory requirements,and policies affecting fishermen’s lives at sea.

These recommendations include information regardingsafety equipment, procedures, marine insurance, train-

ing, personal qualifications, navigation safety, vessel de-sign, vessel construction, and vessel maintenance. TheCFIVSAC may review regulatory proposals and makeavailable to Congress any information, advice, and rec-ommendations it is authorized to give the Coast Guard.

CFIVSACThe Commercial Fishing Industry Vessel Safety Advi-sory Committee consists of 17 members who are ap-pointed by the Secretary of the Department ofHomeland Security from recommendations made bythe Commandant of the Coast Guard. The membership

Saving Livesat Sea

Through AdvocacyThe Commercial Fishing

Industry Vessel SafetyAdvisory Committee.

by MR. JONATHAN WENDLANDU.S. Coast Guard Office of Vessel Activities

The Commercial Fishing Industry Vessel Safety AdvisoryCommittee came into being largely as a result of a 1985vessel incident.

On August 20, 1985, the body of crewmember Peter Barryfrom the F/V Western Sea was found in the frigid watersnear Kodiak, Alaska. Prior to this discovery, there was noindication that the vessel was in peril.1 The son of Mr.Robert Barry, U.S. Ambassador to Bulgaria, Peter was on asummer break from college working in Alaska.

Twenty-one days after Peter’s body was recovered, twomore crewmembers were recovered—floating lifeless.Sadly, all were wearing Coast Guard-approved life jackets.

At that time, however, survival craft, immersion suits, andemergency position-indicating radio beacons were not re-quired safety items for fishing vessels.

The ambassador immediately sought more informationand answers to questions regarding his son’s tragedy.When he learned that fishing vessels weren’t mandated tocarry that safety equipment, he began aggressively lobby-ing for fishing vessel safety regulations. On September 9,1988, the Commercial Fishing Industry Vessel Safety Act,which contained the legal authority for the CFIVSAC, be-came law.

Endnote:1. USCG F/V Western Sea investigation March 31, 1986.

SPURRED BY GRIEF

S A F E T Y



is organized as fol-lows:

· 10 members rep-resent the com-mercial fishingindustry;

· 3 members arefrom the generalpublic;

· 1 is a naval archi-tect or marinesurveyor;

· 1 is an equipmentmanufacturer;

· 1 is an education or training professional related tofish processor, fish tender, or fishing vessel safety;

· 1 is a vessel insuranceunderwriter.

A committee member isappointed to a three-yearterm, and can serve morethan one term. The chiefof the U.S. Coast GuardOffice of Vessel Activitiesmanages the committeeand, in addition to otherresponsibilities, approvesor calls its meetings andapproves agendas.

USCG, CFIVSAC, and NMFSTo better understand the interagency relationshipsamong the National Oceanic Atmospheric Administra-tion (NOAA)’s National Marine Fisheries Service, theCommercial Fishing Industry Vessel Safety AdvisoryCommittee, and the Coast Guard, it may help to knowsome fishery management history.

Fishery management in America commenced inearnest in the mid-1970s when the Fishery Conserva-tion and Management Act of 1976 established today’sfishery management councils. These councils have theauthority to mandate fisheries management plans thatsupport sustainable fisheries.

The Coast Guard is involved in fisheries managementplanning and enforcement, but does not have any vot-ing authority on any fishery management council. Ad-ditionally, the CFIVSAC is not part of the fisherymanagement councils, and so relies on its Coast Guard-designated representative to present CFIVSAC views

and recommenda-tions to the councils.

CFIVSAC EffortsThe CFIVSAC hasmade hundreds ofrecommendationsto the Coast Guardsince its inauguralmeeting in 1989. Forexample, recent datashowed that in vir-tually all man-over-board fatalities overthe last 10 years,

none of the individuals was wearing a flotation device.As a result, the committee passed a recommendation

to require fishing vesselcrewmembers to wear aflotation device whenworking on deck out-side the rails or whensetting or hauling gear.The Coast Guard cur-rently has a rulemakingproject in progress toaddress this recommen-dation.

Get in TouchIf you have anythoughts on improving

fishing vessel safety, the Coast Guard encourages youto contact the Commercial Fishing Industry VesselSafety Advisory Committee or the USCG Fishing Ves-sel Safety Division.

About the author:Mr. Jonathan Wendland works at USCG headquarters in the FishingVessel Safety Division in the Office of Vessel Activities. Prior to his cur-rent position, he served as a NOAA Corps Officer, splitting time be-tween Ocean Atmospheric Research (OAR) and the National MarineFisheries Service. His background is in ocean engineering.

Champion’s Note:*The 2010 Coast Guard Authorization Act re-namesthe committee the “Commercial Fishing Safety Advi-sory Committee,” adds an 18th member representingfishing communities and families, and extends thecommittee to 2020.Endnote:1. NOAA Current Fishery Statistics No. 2009.

Bibliography:46 U.S.C.16 U.S.C.

For more information on theUSCG Fishing Vessel Safety Division

and CFIVSAC go to http://www.fishsafe.info.

CFIVSAC recommendations andmeeting minutes can be found at:

https://homeport.uscg.mil/CFIVSACHistoricalRecommendations

https://homeport.uscg.mil/CFIVSACmeetingminutes

NEW DEADLIEST CATCH

The CFIVSAC held its 30th meeting in May 2010 in Oakland, Calif.During this meeting, the National Institute for Occupational Safetyand Health (NIOSH) presented new data associated with fatalityrates. The data presented by Dr. Jennifer Lincoln conveyed that theinherently dangerous fishing industry had a new (but perhaps notmeant for television) “deadliest catch.”

NIOSH data (2000–2009) shows that the Alaska Crab fishery wassupplanted by the New England multi-species ground fishery asAmerica’s new“most deadly catch.”See related article in this edition.

For more INFORMATION:


Although progress has been made to improve safety oncommercial fishing vessels, commercial fishing contin-ues to be the most dangerous occupation in the country.In 2008, commercial fishermen had a fatality rate nearly36 times higher than the rate for all U.S. workers.1Broadinterventions on a national level have had some suc-cess in reducing fatalities, but greater improvementswill come from tailored programs targeted at specifichazards of various fleets.

The Public Health ApproachA proven and frequently used method for reducing in-juries and illnesses in a variety of settings and circum-stances is the “public health approach.” The NationalInstitute for Occupational Safety and Health (NIOSH)has also referred to this approach as “the AlaskaModel” when describing safety improvements amonghigh-risk workers in Alaska. This approach seeks tobenefit the largest number of people through a sys-tematic, four-step process. Applied to the problem offatal injuries in the fishing industry, the steps of thepublic health approach are:

· Define the problem through surveillance. Collectdata about the magnitude, scope, characteristics,and consequences of fatal injuries. It is especiallyimportant in the fishing industry to gather dataabout a specific fishery, gear, and type of vessel.

· Establish why fatalities occur. Use scientific re-search and industry input to determine the causesand risk factors.

· With input from industry, design tailored inter-ventions for specific fisheries and evaluate their ef-fectiveness.

· Implement the interventions found to be most ef-fective.

The value and importance of this approach wasdemonstrated in the Bering Sea and Aleutian Islands(BSAI) crab fishery.2

The Approach in PracticeScientists at NIOSH conducted injury surveillance inthe Alaska fishing industry during the 1990s. They dis-covered that the BSAI crab fishery had the highest fa-tality rate in the state, and that capsizing due tooverloading was the leading cause of fatalities.

In 1999, the identification of this major safety problemprompted the local USCG office to work with industryto develop an intervention—the USCG PreseasonDockside Enforcement Program. This program focuseson the immediate hazard of vessel overloading anddoes not allow vessels to be overloaded with crab potswhen they leave port.2

NIOSH evaluated the effectiveness of this program andfound that since implementation, the average annualfatality rate for the BSAI crab fleet has decreased by 60percent—from a high of 768 deaths per 100,000 fisher-men during 1990-1999 to 305 deaths per 100,000 fisher-men during 2000-2006.3 This success can be replicatedin other fisheries across the country.

Fishery-SpecificRisk Factors

Using the public healthapproach to improvefishing vessel safety.

by MR. DEVIN LUCAS, MSStatistician

National Institute for Occupational Safety and HealthAlaska Pacific Regional Office

CDR JENNIFER LINCOLN, PH.D., CSPU.S. Public Health Service

Injury EpidemiologistNational Institute for Occupational Safety and Health

S A F E T Y



Step 1: Data collectionHistorically, part of the difficulty in improving safetyin the U.S. fishing industry has been with implement-ing this first step. There was a lack of data needed toproperly identify hazards by region, fishery, and type ofevent. In 2007, NIOSH developed the Commercial Fish-ing Incident Database (CFID) to collect and analyzedata on fatalities in the U.S. commercial fishing indus-

try to identify high-risk fisheries (defined by speciestargeted, location of fishing grounds, time of year, andgear type) and to discover the patterns of risk factorsthat contribute to fatal events.

Every occupational fatality in the U.S. fishing industryis entered into the CFID each year. Currently, the data-base has detailed information about all commercial fish-

According to the NIOSH Commercial Fishing Incident Data-base, during 2000-2009, 504 commercial fishing fatalities oc-curred in the U.S., averaging 50 per year.

Most deaths (261, or 52 percent) occurred following a vesseldisaster (including sinking, capsizing, fire) in which the crewwas forced to abandon ship. Falls overboard accounted for155 fatalities (31 percent). The remaining deaths were due toonboard injuries (51, or 10 percent), diving injuries (19, or 4percent), and on-shore injuries (18, or 3 percent).

VVeesssseell DDiissaasstteerrThe 261 fatalities that resulted from vessel disasters occurredin 148 separate vessel disaster incidents, and were generallythe result of a sequence of events. The most frequent initiat-ing events were flooding (37, or 28 percent), vessel instability(24, or 18 percent), and vessels struck by a large wave (23, or18 percent). Severe weather conditions contributed to 61percent of fatal vessel disasters.

FFaallllss OOvveerrbbooaarrddAmong the 155 victims who died from falling overboard,none wore a personal flotation device, and 53 percent of fallswere not witnessed. The main causes of falls overboard weretrips/slips (43, or 33 percent), losing balance (34, or 26 per-cent), and gear entanglement (21, or 16 percent).

GGeeooggrraapphhiicc DDaattaaThe fisheries and events that led to the highest number of fa-talities included:

·· falls overboard in the Gulf of Mexico shrimp fishery (29,or 6 percent of total U.S. fatalities),

·· vessel disasters in the Northeast scallop fishery (27, or 5percent),

·· vessel disasters in the West Coast Dungeness crab fishery(21, or 4 percent),

·· vessel disasters in the Northeast multi-species ground-fish fishery (19, or 4 percent).

The 29 fatal falls overboard in the Gulf of Mexico shrimp fish-ery were largely caused by trips/slips (48 percent) and losingbalance (24 percent). About half (48 percent) of these fallsoverboard were not witnessed.

IInniittiiaattiinngg EEvveennttssThe main initiating events for the nine vessel disasters (lead-ing to 27 fatalities) in the Northeast scallop fishery were ves-sel instability (25 percent), collisions (25 percent), andsnagging gear on the ocean floor (25 percent).

In the West Coast Dungeness crab fishery, the main initiatingevents for the 10 vessel disasters (leading to 21 fatalities) werecrossing a river bar (40 percent), vessel instability (30 percent),and vessels struck by a large wave (20 percent). Severeweather was associated with all vessel disaster incidents inthis fishery.

Finally, in the Northeast multi-species groundfish fishery, themain initiating events for the 12 vessel disasters (19 fatalities)were instability (50 percent) and flooding (40 percent).

U.S. fishing fatalities by year and incident type, 2000-2009 (504 total), “Commercial Fishing Deaths–United States, 2000-2009.” MMWR 2010; Vol. 59, No. 27.

THE STATISTICS


ing fatalities in the country during 2000-2009. The in-formation comes from multiple sources includingUSCG investigation reports, local law enforcement re-ports, news media, and death certificates. The CFID in-cludes information regarding the vessel characteristics,environmental factors, and victim demographic data foreach incident.

Step 2: Identify risk factorsWith 10 years of robust fatality data available for the coun-try, NIOSH recently moved forward to the second step ofthe public health approach—data analysis to identify thecauses and risk factors for fatalities in hazardous fisheries.The results can be used to design tailored interventionsthat address the primary risk factors in specific fisheries.

Steps 3 and 4: Develop, evaluate, and implement tailored interventionsTo be most effective, interventions should focus on thefisheries and incident types accounting for the highestnumber of fatalities.

For example, shrimp fishermen falling overboard in theGulf of Mexico led to the highest number of fishery-spe-cific fatalities in the country during 2000-2009 (see side-bar). Since none of these fishermen wore a personalfloatation device (PFD), identifying and understandingthe barriers to PFD usage is necessary. In addition, manyof these events were caused by trips/slips and losing bal-ance, and almost half were not witnessed. Fishermenneed to be able to alert others when they fall overboardor be able to stop the engine and re-enter the vessel if theyare fishing alone.

In the Northeast scallop fleet, preventing the hazardsleading to vessel instability, collisions, and snagginggear on the ocean floor is necessary. A previous studyon the scallop fleet in Maine reported a distinct patternof serious injuries and capsizings in the mid-1990swhile towing fishing apparatus across the sea bed orwhile lifting laden fishing apparatus from the water torecover the catch.4 USCG personnel then engaged thefishermen in town hall meetings to discuss the hazardsand potential solutions. This type of an approach couldbe repeated for the entire Northeast scallop fleet, andan evaluation could be done for its effectiveness.

The causes of vessel disasters in the West Coast Dunge-ness crab fishery are different from those in the North-east scallop fishery, and so require interventions tailoredto the problem. In 2008 NIOSH published a report out-lining the hazards in the West Coast Dungeness crabfishery and recommended continuing the preseason

safety inspections in place for this fleet, as well as im-proved weather reporting, addressing the hazards ofriver bars, marine safety training, and encouraging fish-ermen to wear PFDs.

Since the report was published, the USCG has imple-mented stricter guidelines for all vessels crossing haz-ardous bars, legislatures have sought betterinfrastructure for marine forecasting, and the OregonDungeness Crab Commission has encouraged fleet par-ticipation in safety training programs by offering incen-tives for members to attend. The commission has alsosponsored a rebate program to help fishermen purchasePFDs. These types of targeted efforts and others shouldcontinue and should be evaluated for their effectiveness.

ConclusionEvery fishery has unique risk factors, and interventionsmust be tailored to each fishery to be effective. Inter-ventions should be evaluated to measure their effec-tiveness. Once a safety intervention has been pilottested and found to be effective, it should be expandedto cover other vessels that experience similar risk fac-tors and become a permanent safety improvement.

More work is needed to develop and implement inter-ventions in fisheries across the country. NIOSH willcontinue to collect and analyze data in the CFID andprovide detailed information on fishery-specific haz-ards. Organizations, agencies, and other groups locatednear the fishery can use the information to create prac-tical, industry-supported solutions.

About the authors:Mr. Devin Lucas is a statistician with NIOSH at the Alaska Pacific Re-gional Office. He conducts research on occupational safety in the fish-ing industry across the U.S. The results of his research have appearedin scientific journals and industry publications.

CDR Jennifer Lincoln, Ph.D., CSP, is an injury epidemiologist and leadsthe NIOSH Commercial Fishing Safety Research and Design Program.Dr. Lincoln is a strong advocate of providing science to improve safetyin the workplace and specializes in commercial fishing safety research.

Endnotes:1. U.S. Department of Labor, Bureau of Labor Statistics, Injuries, Illnesses and Fatali-

ties: Census of Fatal Occupational Injuries (CFOI)—current and revised data. Wash-ington, DC: U.S. Department of Labor, Bureau of Labor Statistics; 2010. Available athttp://www.bls.gov/iif/oshcfoi1.htm.

2. C.J. Woodley, J.M. Lincoln, and C.J. Medlicott, “Improving Commercial Fishing Ves-sel Safety through Collaboration,” Proceedings of the Marine Safety and Security Coun-cil, the Coast Guard Journal of Safety and Security at Sea, Spring 2009, p. 38-44.

3. Centers for Disease Control and Prevention (CDC), Commercial Fishing Fatalities—California, Oregon, and Washington, 2000-2006. MMWR 2008; 57:425-429.

4. J. Ciampa, V. Wilczynski, T.J. Smith, and A.S. Backus, “An Innovative Investigationof the Relationship between Fisheries Equipment Design and Marine and Occupa-tional Accidents in the Inshore Scallop Fishery of the Northeastern United States.”In: Proceedings of the International Fishing Industry Safety and Health Conference.Woods Hold, MA: October 23-25, 2000. Cincinnati, OH: U.S. Department of Healthand Human Services, CDC, National Institute for Occupational Safety and Health.NIOSH publication no. 2003-102.


The Commercial Fishing Industry Vessel Safety Act of1988 and the subsequent requirements for commercialfishing industry vessels in 46 CFR Part 28 were in-tended to reduce commercial fishing vessel losses andfatalities.

To help fishermen understand the regulations and re-quirements for their vessels, the Coast Guard instituteda dockside safety examination program in 1991. Safetyexaminations are generally conducted by Coast Guardactive duty, reserve, auxiliary, or civilian personnel atno cost to the fishermen. These examinations are vol-untary and “no-fault.” This means that if during thecourse of an examination a discrepancy is found—saya couple of missing fire extinguishers—there will be noviolation written for the discrepancy. The discrepancywill be noted on the commercial fishing vessel safetyexamination form, no safety decal will be issued, andthe owner/operator/master will be informed that untilthe discrepancies are corrected no decal will be issued.

The voluntary dockside safety exam is not considereda law enforcement boarding, per se. If an extremely haz-ardous condition is found that would put the lives ofthe crew or the safety of the vessel at risk, then the fish-ing vessel examiner may bring that condition to the at-tention of the cognizant captain of the port (COTP). The

COTP can then decide if enforcement action needs totake place, e.g. detaining a vessel in port. Upon suc-cessful completion of a dockside examination, a vesselis issued an examination decal.

Low ParticipationSince the program’s inception, the Coast Guard hasconducted an average of 7,000 dockside safety exami-nations and issued approximately 3,000 decals per year.Unfortunately, that represents less than 10 percent ofcommercial fishing vessels.

In an effort to increase outreach and make safety ex-aminations more readily available to the commercialfishing industry, these examinations may also be con-ducted by approved members of a “third-party” or-ganization.1 However, there will normally be a costincurred when the examination is conducted by a third-party examiner.

Third-Party Examination ProgramThe Coast Guard’s third-party examination programutilizes the established corps of surveying profession-als in the maritime industry as a supplement to theCoast Guard’s own uninspected fishing industry vesselboarding and examination program. Owners of com-mercial fishing industry vessels can benefit by having

The Coast Guard and Third-Party OrganizationsIndustry professionals working together to improve fishing vessel safety.

by MR. DAVID BELLIVEAUU.S. Coast Guard Fishing Vessel Safety Division

S A F E T Y



experienced, professional surveyors assisting them incomplying with the regulations. This, in turn, helps im-prove fishing vessel safety by increasing the total num-ber of vessels examined annually.

An organization desiring to be designated as an ac-cepted organization or similarly qualified organizationmust request such designation in writing from the U.S.Coast Guard Fishing Vessel Safety Division. Naviga-tion and Vessel Inspection Circular 13-91 providesguidance.

About the author:Mr. Belliveau currently works at USCG headquarters in the Office ofVessel Activities, Commercial Fishing Vessel Safety Division. He is agraduate of Massachusetts Maritime Academy, has sailed as a licensedmerchant marine officer, and served in the Coast Guard on active dutyfor over 20 years.

Endnote:1. Precedent for use of third-party examiners can be found in 46 CFR 28.700.

46 CFR 28.700 stipulates that each fish processing vessel that is not subjectto inspection must be examined biennially. Examinations are to be per-formed by the American Bureau of Shipping, a “similarly qualified organ-ization,” or a surveyor of an “accepted organization.” These vessels, whenexamined and found to be in compliance with 46 CFR Chapter I, are issueda certification of compliance in accordance with 46 CFR 28.710(c). Addi-tionally, the third-party examiner may issue any fishing vessel the CFVSexamination decal.

For more INFORMATION:For more information on third-party examiners

or on how to qualify as a similarly qualified or accepted organization,

visit the USCG commercial fishing vessel site atwww.fishsafe.info.

Navigation and Vessel Inspection Circular 13-91http://www.uscg.mil/hq/cg5/nvic/pdf/1991/n13-91.pdf


Working in the highest-risk industry for fatalities andserious injury, fishermen rely on their vessels andequipment to allow them to provide a living for them-selves and their families. By helping to ensure fisher-men operate seaworthy vessels, have the properlifesaving equipment on board, and are familiar withhow to use it, the Coast Guard can help save lives inthis dangerous industry.

However, with nearly 80,000 commercial fishing vesselsnationwide, it becomes very difficult for the Coast Guardto conduct vessel safety exams and life-saving training.This is where the U.S. Coast Guard Auxiliary comes in.

Commercial Fishing Vessel Safety Exams The Coast Guard Auxiliary was established by Congressin 1939 and today is comprised of nearly 30,000 mem-bers. These men and women volunteer more than twomillion hours annually, performing a vast array of mis-sions including vessel safety checks, harbor patrols,search and rescue, marine environmental protection, andcommercial fishing vessel safety exams. Working along-side civilian, active duty, and reserve personnel, auxilar-ists perform hundreds of commercial fishing vessel safetyexams annually. Nationwide, approximately 25 percentof all exams are performed by auxiliary examiners.

Prospective examiners may attend a week-long train-ing course, must complete a “personal qualificationstandard,” and pass an oral and practical examination

to demonstrate the appropriate knowledge. Once qual-ified, auxiliary commercial fishing vessel examinersjoin the ranks of those who work diligently to improvefishing vessel safety.

About the author:Mr. Hooper is currently a marine safety transportation specialist in theU.S. Coast Guard Office of Vessel Activities Fishing Vessel Safety Di-vision. Prior to this position, he worked as a USCG marine sciencetechnician in Miami, Fla. For the last two years he has worked underthe D7 CFVS coordinator as well as the Sector Miami Chief of Unin-spected Vessels, conducting over 150 commercial fishing vessel examsand acting as a training liaison for the USCG Auxiliary.

For more INFORMATION:For more information on the Coast Guard’s Commercial Fishing Vessel Safety Program

or on becoming a member of the Coast Guard Auxiliary visit

www.FishSafe.info and www.cgaux.org.

WWHHAATT’’SS IINN IITT FFOORR MMEE??Aside from the peace of mind provided by earning aUSCG commercial fishing vessel safety decal, show-ing compliance with vessel requirements, it benefitsthe fisherman by reducing the time involved in an at-sea Coast Guard fisheries enforcement boarding. Itmay also decrease premium rates on vessel insur-ance, saving the operator both time and money.

USCG Auxiliary Commercial Fishing Vessel ExaminersAmerica’s volunteer guardians aid prevention efforts. by MR. MATTHEW HOOPERMarine Safety Transportation SpecialistU.S. Coast Guard Office of Vessel Activities, Fishing Vessel Safety Division

S A F E T Y



The Occupational Safety and Health Administration(OSHA) has rules that apply to commercial vessels, in-cluding uninspected fishing industry vessels. Its au-thority to regulate workplace safety on uninspectedvessels was upheld and effected by a United StatesSupreme Court decision,1 and the most current infor-mation with respect to OSHA authority over personsworking on vessels on U.S. navigable waters can befound in OSHA’s Compliance Directive, CPL 02-01-047.2

The directive provides information concerning OSHA’sauthority over persons working on vessels (inspectedvessels, uninspected vessels, and commercial unin-spected fishing industry vessels) and facilities on or ad-jacent to U.S. navigable waters and the outercontinental shelf intended for OSHA national, regional,and area offices; industry parties; OSHA state pro-grams; and federal agencies.

JurisdictionThe authority of OSHA is limited to employment per-formed within the geographical limits covered by theOccupational Safety and Health Act of 1970.3 The actapplies to employment performed in a state of theUnited States, the District of Columbia, Puerto Rico, theVirgin Islands, American Samoa, Guam, the NorthernMariana Islands, Wake Island, Johnston Island, andouter continental shelf lands. “State” includes all U.S.navigable waters within the state.

For coastal states, the state territorial seas extend threenautical miles seaward from the general coastline, ex-

cept for the Gulf Coast of Florida, Texas, and PuertoRico, where the state territorial seas extend for ninenautical miles.

Authority Over Commercial Uninspected Fishing Industry Vessels Commercial uninspected fishing industry vessels arefish processors 5,000 gross tons and less, fish tenders500 gross tons and less, and all fishing vessels (see def-initions sidebar). Authority over working conditions oncommercial uninspected fishing industry vessels isshared by the U.S. Coast Guard and OSHA, with theU.S. Coast Guard as the lead agency.4

These vessels are also subject to the general regulationsfor uninspected vessels in 46 CFR Parts 24, 25, and 26.5Uninspected vessels are vessels that are not requiredby law to be inspected (vessels subject to inspection arelisted in 46 U.S.C. 3301) and are not recreational ves-sels.6 Encompassed within the category of uninspectedvessels are all commercial fishing vessels, towing ves-sels,7 and six-passenger vessels.

OSHA will continue to exercise its authority and issuecitations to the owners, charterers, managing operators,or agents in charge of commercial uninspected fishingindustry vessels for working conditions that are notspecifically covered by U.S. Coast Guard regulationswithin the jurisdictional limits, for the protection of allemployees, including seamen.8

Health and Safety at Sea

OSHA’s authority over commercial fishing

industry vessels.

by LCDR MICHELE BOUZIANEAttorney, U.S. Coast Guard Office of General Law

S A F E T Y



Factory production operations (fish processing) and as-sociated equipment operations, including cleaning,maintenance, and repair, are exclusively covered by 29CFR Part 1910 general industry standards. Repairs andmaintenance to structural components of the vessel andmechanical, electrical, and other systems that are notdirectly associated with the factory production opera-tions are covered by 29 CFR Part 1915 shipyard em-ployment standards. Such repairs and maintenancecovered by 29 CFR Part 1915 would include repairs andmaintenance of bulkheads, decks, and overheads of thefactory area; and any systems in the factory area thatare not related to the factory production operations andnot covered by U.S. Coast Guard regulations.

For uninspected vessels and commercial uninspectedfishing industry vessels, OSHA standards are applica-ble to the working conditions of all workers, includingcrewmembers, as detailed in the instruction.9

About the author:LCDR Michele Bouziane is an attorney currently working in the CoastGuard Office of General Law. She spent the previous two years in theCoast Guard Office of Legislation. A polyglot (speaking French, Span-ish, and Portuguese), she was the Coast Guard’s Foreign Language pro-gram manager from 2005-2008.

Endnotes:1. Chao v. Mallard Bay Drilling, Inc., 534 U.S. 235 (2002). 2. CPL 02-01-047, which became effective on February 22, 2010, can be viewed

or downloaded in its entirety at www.osha.gov. 3. 29 U.S.C. 653(a).4. OSHA is precluded under section 4(b)(1) of the OSH Act from enforcing re-

quirements pertaining to working conditions regulated by another federalagency. Applicable U.S. Coast Guard regulations in force that preemptOSHA for commercial uninspected fishing industry vessels are set forth in46 CFR Part 28, and are summarized in Appendix B of the instruction.

5. See also Appendix C, Applicable U.S. Coast Guard Regulations for Unin-spected Vessels.

6. 46 U.S.C. 2101(43).7. Effective August 9, 2004, towing vessels were added to the list of vessels in

46 U.S.C. 3301 subject to inspection (i.e., inspected vessels). Thus, the U.S.Coast Guard has the authority to prescribe and enforce regulations for alltowing vessels. However, until the U.S. Coast Guard has inspected vesselsafety and health regulations in place for towing vessels in general, towingvessels continue to be classified as uninspected vessels; except for steampowered towing vessels and tugboats, and seagoing towing vessels andtugboats that are 300 gross tons or more, which are classified as inspectedvessels. Thus OSHA will continue to provide safety and health coverage ofemployees on uninspected towing vessels until the U.S. Coast Guard issuesinspected vessel regulations for these vessels.

8. A list of the most common enforceable OSHA requirements for commercial unin-spected fishing industry vessels is provided in the instruction’s Appendix A.When OSHA has safety and health coverage over working conditions of em-ployees on vessels and facilities on or adjacent to U.S. navigable waters andthe OCS, the following OSHA standards apply: 29 CFR Part 1910 for generalworking conditions not otherwise regulated, such as the working conditionson uninspected vessels that are not addressed by U.S. Coast Guard regula-tions; and Section 5(a)(1), the general duty clause of the Occupational Safetyand Health Act (OSH Act), for recognized hazardous situations that arecausing or are likely to cause death or serious physical harm to the em-ployees of the employer to be cited, for which there are no specific OSHAstandards or U.S. Coast Guard regulations.

9. CPL 02-01-047. Also see Appendix A and Appendix C to the instruction.

DEFIN

ITIONS

Commercial Fishing Industry Vessel: Afishing vessel, fish tender vessel, or a fish pro-cessing vessel per 46 CFR 28.50.

Fish: Finfish, mollusks, crustaceans, and allother forms of marine animal and plant lifeexcept marine mammals and birds per 46U.S.C. 2101(11).

Fish Processing Vessel: A vessel that com-mercially prepares fish or fish products otherthan by gutting, decapitating, gilling, skinning,shucking, icing, freezing, or brine chilling per46 U.S.C. 2101(11b).

Fish Processing: As defined by OSHA, fishprocessing is a production function that in-volves any preparation of a fish or fish productby a worker including: gutting, decapitating,gilling, skinning, shucking, icing, freezing, orbrine chilling. It is important to recognize thatthe definition of fish processing used by OSHA,based on North American Industry Classifica-tion System Code 31171 (Seafood Product

Preparation and Packaging), is predicated onworker function, and therefore may occur onvessels other than a U.S. Coast Guard-classi-

fied fish processing vessel (such as a fish tendervessel or fishing vessel).

Fish Tender Vessel: A vessel that commer-cially supplies, stores, refrigerates, or transportsfish, fish products, or materials directly relatedto fishing or the preparation of fish to or froma fishing vessel, fish tender vessel, fish pro-cessing vessel, or a fish processing facility per46 U.S.C. 2101(11c).

Fishing Vessel: A U.S. Coast Guard classifi-cation for a vessel that commercially engagesin the catching, taking, or harvesting of fish oran activity that can reasonably be expectedto result in the catching, taking, or harvestingof fish per 46 U.S.C. 2101(11a).

U.S. Navigable Waters: Includes territorialseas of the U.S. and U.S. internal waters (i.e.,all rivers, tributaries, lakes, bays, and soundsshoreward of the territorial sea baseline) that:1) are subject to tidal influence; or 2) are, havebeen, or are susceptible for use, by them-selves or in connection with other waters, forsubstantial interstate or foreign commerceper 33 CFR Part 2.

Seaman:An individual engaged or employedin any capacity aboard a vessel in navigation,and who has a substantial connection with avessel or fleet of vessels, and who contributesto the function of the vessel or to the accom-plishment of its mission.1

Uninspected Vessel: A vessel not subject toinspection under 46 U.S.C. 3301 and not arecreational vessel per 46 U.S.C. 2101(43). Avessel classified as an uninspected vessel by theU.S. Coast Guard is subject to limited U.S. CoastGuard inspection of the following areas: basicfirefighting equipment, approved life jacketsand lifesaving equipment, ventilation of enginebilges and fuel tank compartments, and back-fire traps/flame arresters on inboard enginecarburetors using gasoline as a fuel. Commer-cial uninspected fishing industry vessels mustcomply with U.S. Coast Guard regulations inthese areas, as well as a number of others.2

Endnotes:1. A vessel in navigation is one which is on a voyage or which is

at anchor, berthed, or dockside, but not one which is under-going a major overhaul or renovation. The connection to thevessel or vessels must be substantial in terms of both its du-ration (30 percent or more of the seaman’s time) and its na-ture. [See the U.S. Supreme Court decision in Chandris, Inc.v. Latsis, 515 U.S. 347 (1995).]

2. 46 U.S.C. 4502.


The Bering Sea/Aleutian Island and Gulf of Alaskafreezer longliner and freezer trawler fleet, referred toas the “head and gut” (H&G) fleet, occupies a uniqueniche in the North Pacific fishing industry. Unlike othercatcher vessels that deliver fish to shore plants, H&Gvessels catch, sort, head, eviscerate, clean, and preparefish into various fish products aboard the vessel. Theseproducts are then frozen, packaged, and stored on thevessel until they are offloaded.

Before 2006, vessels in the H&G fleet were regulated asfishing vessels as opposed to “fish processing vessels.”Following several marine casualties within this fleet,1marine casualty investigations determined that H&Gvessels should be classified as fish processing vesselsand be subject to the requirements of that classification.

The Alternate Compliance and Safety Agreement Due to age restrictions imposed by classification soci-eties, however, nearly 70 percent of the H&G fleet

The Alternate Compliance and Safety Agreement

A model program with the ability to evolve.

by MR. TROY RENTZACSA Coordinator

U.S. Coast Guard Thirteenth District

The ACSA 2010 stakeholders meeting. USCG photo by Mr. Dan Hardin.

S A F E T Y



would not be accepted for classification.2 The AlternateCompliance and Safety Agreement (ACSA) program,which allows exemptions to class and load line re-quirements, was developed as an alternative.

To enroll in the program, operators agree to complywith appropriate safety standards to improve water-tight integrity, vessel stability, fire prevention, machin-ery maintenance, lifesaving equipment, andcrewmember training. Safety standards for theprogram are developed by the Coast Guard col-laboratively with vessel owners, operators, andvessel associations.

Safety MeasuresACSA takes a regional approach to adoptingsafety measures, evaluating strategies to preventfatalities and vessel losses based on specific riskswithin the head and gut fleet and the remote coldwater environment in which they operate. Ex-amples of ACSA safety measures:

· dry-dock examinations to verify the condi-tion of the hull, watertight closures, criticalsystems, and internal structure;

· watertight integrity plans containing specificinstructions for all watertight closures, high-water alarms, and vents;

· at-sea watches must verify the status water-tight closures;

· additional trained drill conductors;· additional training for fire teams; · safety videos and training programs in the lan-

guage of the crew;· life rafts3 must be capable of being launched by a

single person;

· embarkation ladders for sur-vival craft;

· immersion suit lights must bestrobe type;

· engine room fire detectionsystems are required;

· communications must beavailable between the wheel-house and CO2 discharge sta-tion.

Currently there are more than 50vessels enrolled in the AlternateCompliance and Safety Agreementprogram. All vessels enrolled in theprogram complete examinations forcompliance with ACSA safety stan-

dards each year and complete dry-dock examinationstwice in each five-year period. In the past year, 439safety discrepancies were identified and corrected.

Lessons learned from shortfalls in initial implementa-tion of the program have called for re-examination ofthe program to ensure risks are identified and ad-dressed. A major advantage of the ACSA program is

the ability to evolve, taking into account lessonslearned. The Coast Guard will continue to exercise anaggressive leadership role in this program while con-

Vessel hull thickness is evaluated during an Alternate Compliance andSafety Agreement dry-dock examination. The examinations are conductedtwice in every five-year period. USCG photo by Mr. Mike Rudolph.

The internal structure, including the tanks and void spaces of an AlternateCompliance and Safety Agreement vessel, is examined by a USCG exam-iner. USCG photo by Mr. Mike Rudolph.

sulting with the H&G fleet stakeholders to honor theirsignificant commitment to date.

The Alternate Compliance and Safety Agreement hasbeen recognized by lawmakers as a model alternatecompliance program. Similar programs tailored to re-gional fisheries and their specific risks have been re-cently authorized.

About the author:Mr. Troy Rentz is a Coast Guard veteran with a diverse background invessel inspections and marine casualty investigations. He serves as theCoast Guard Thirteenth District ACSA coordinator.

Endnotes:1. “Crisis in the Bering Sea. The fire and explosion aboard a fish processor.”Proceedings of the Marine Safety & Security Council, Summer 2006, p. 45. “NoSurvivors. A fishing vessel meets a mysterious end in the Bering Sea.” Pro-ceedings of the Marine Safety & Security Council, Summer 2010, p. 81.

2. The regulations in 46 CFR 28.720 do not provide an alternative for the op-erator of a fish processing vessel that cannot be classed; however, under 46CFR 28.60, such a vessel may request an exemption letter.

3. All life rafts must meet SOLAS standards, USCG Approval 160.151, whichinclude improved design, construction, testing, and features such as largerballast bags and boarding ramps. The date for full implementation is Jan-uary 1, 2011.


For more information go to www.fishsafe.info.

Recovering an individual from the water during adrill. USCG photo by Mr. Mike Rudolph.

RELATIVE COMPARISON OF LOAD LINE AND ACSA REQUIREMENTS

by MR. TOM JORDAN

U.S. Coast Guard Office of Designand Engineering StandardsNaval Architecture Division

The purpose of load line assignment is to ensurethe seaworthiness of an intact (undamaged) ves-sel. This is accomplished by:

·· Ensuring a robust hull that can with-stand severe sea conditions (i.e. structuraldesign, construction, and maintenance)

·· Ensuring weathertight and watertightintegrity (i.e. coamings; exposed doors,hatches, hull valves, etc., are in good workingcondition)

·· Ensuring that the vessel has reservebuoyancy and is not overloaded (by limit-ing the maximum loaded draft)

·· Ensuring that the vessel has adequatestability for all loading and operatingconditions (by approved stability documen-tation and instructions)

·· Ensuring rapid drainage of boardingseas (by adequate arrangement of freeingports in bulwarks)

·· Ensuring safety of crew while workingon deck (by increased freeboard to reduceboarding seas, guardrails)

·· Ensuring that modifications to vessel donot compromise seaworthiness (modifi-cations must be approved by LL assigning au-thority)

·· Periodic third-party inspections (afloatand drydocked) to verify that the abovemeasures are properly maintained (byauthorized class society)

Each of these seaworthiness elements are com-pared with the equivalent ACSA requirement.

RELATIVE COMPARISON OF LOAD LINE AND ACSA REQUIREMENTS



·· Designed and constructed in accordancewith ABS rules for ocean service

·· Maintained in accordance with ABS struc-tural requirements and corrosion limits

·· Drydocked every five years for inspection

·· Audiogauging of hull (plating and stiffen-ers) as required by ABS. Extent of gaugingsincreases as vessel ages (especially after 15years).

·· Critical vents, air pipes, doorways pro-tected by coamings (6” to 24” high, de-pending on location)

·· Documented list of closures·· Inspected annually

·· Documented list of penetrations·· Inspected during drydockings (i.e., every

five years)

·· Draft limit determined by freeboard as-signment or stability calculations(whichever is more severe)

·· Limiting draft marked on hull with mid-ship load line marks

·· Must meet appropriate stability criteria·· Easy-to-use stability and loading instruc-

tions must be provided for master·· Must have valid stability documentation

·· Stability is reassessed only if modificationsresult in significant weight changes

Strength of hull

Weathertight integrity(coamings, exposed doors,hatches, vent covers, etc.)

Watertight integrity ofhull penetrations(valves and associatedpiping systems)

Reserve buoyancy andprevention of overloading

Stability

·· Many ACSA vessels were not originallybuilt to ABS standards. However, the ro-bustness of their hull construction hasbeen demonstrated by years of service.The objective, therefore, is to preservetheir inherent robustness.

·· Must undergo hull and structural gaugingas part of ACSA enrollment. Excessivelycorroded members (i.e., more than 25%loss) must be replaced unless calculationsshow that remaining thickness exceedsABS minimum standards.

·· Similar to ABS standards

·· Drydocked twice in five years (not morethan three years between drydockings)

·· Similar to ABS standards

·· 24-inch coamings required on main deckdoors located in aft 1/3 of vessel; other ex-isting comings may have to be increased

·· Documented list of closures·· Inspected annually

·· Documented list of penetrations·· Inspected every other drydocking (i.e.,

every five years)

·· Draft limited by stability calculation

·· Maximum draft marked on hull with special midship marks

·· Must meet appropriate stability criteria·· Easy-to-use stability and loading instruc-

tions must be provided for master·· Must have valid stability documentation·· Must have been inclined within previous

five years of ACSA enrollment·· Stability must be reassessed every five

years (must be re-inclined unless a dead-weight survey confirms that no weightchanges have occurred)

Seaworthiness Element Load Line Requirements ACSA Requirements


Rapid drainage ofboarding seas

Protection of crew whileworking on deck(increased freeboard,guardrails)

Control

Periodic inspections

·· Bulwarks must have adequate arrange-ment of freeing ports (specific require-ments regarding location, size)

·· Manned vessels assigned more free-board than unmanned vessels

·· Guardrails required around periphery ofall decks and other critical walkways(must meet specific design and con-struction requirements)

·· Modifications that affect seaworthinessor freeboard assignment must be re-viewed and approved by the load lineassigning authority

·· Annual inspections:·· Protection of openings (weather-

tight closures)·· Guardrails·· Freeing ports·· Means of access to crew quarters·· Verification that no modifications

have been made that invalidate loadline assignment

·· Drydock inspections:·· Hull and deck plating (gauged as re-

quired)·· Internal structure (gauged as re-

quired)·· Hull penetrations (valves, sea

chests, discharges, etc.)·· Inspections conducted by surveyors of

load line-assigning authority

·· Existing freeing ports might have tobe upsized (must be sufficient toallow rapid clearing of water in allprobable conditions of list and trim)

·· Existing guardrail arrangements mayhave to be improved

·· Modifications that affect stability,closures, hull penetrations, and fac-tory sump pumping system must beapproved by naval architect andbrought to attention of USCG in-spector

·· Copies of stability instructions andinclining/deadweight surveys are tobe submitted to local USCG

·· Annual inspections:Same as load line inspections

·· Drydock inspections:Same as load line inspections

·· Annual and drydock inspectionsconducted by USCG inspectors/ex-aminers

Seaworthiness Element Load Line Requirements ACSA Requirements


By the mid-1980s the commercial fishing industry waswidely recognized for its high casualty rate. Faced withthe prospect of controls designed by those outside thefishing industry, as well as concerns about the cost andavailability of insurance, the North Pacific Fishing Ves-sel Owners’ Association (NPFVOA) developed a vol-untary safety training program.

Recognizing the importance of vessel safety standardsand crew safety awareness and training, but lacking theauthority to regulate the commercial fishing industry,the U.S. Coast Guard was also beginning to develop aunique voluntary safety program in 1984. When theCoast Guard learned that the NPFVOA had alreadyembarked upon a safety program for its fishermen, itjoined those efforts in 1985. This union produced a setof comprehensive voluntary standards aimed at vesselsafety, personnel safety, operational safety awareness,and education.

Now celebrating its 25th anniversary, the NPFVOA ves-sel safety program is a model safety training programthat offers hands-on safety training and addressesCoast Guard regulations as well as a multitude of othersafety concerns for the fishing industry.

The Vessel Safety ProgramThe North Pacific Fishing Vessel Owners’ Associationvessel safety program is unique in that it is entirely self-

The North Pacific Fishing Vessel Owners’ Association Vessel Safety Program

Twenty-five years of improving safety through training.

by MS. LESLIE J. HUGHESDirector of Government and Industry AffairsNorth Pacific Fishing Vessel Owners’ Association Vessel Safety Program

During NPFVOA vessel safety training, students work as a team tocontrol flooding in damage control classes. All photos courtesy ofNPFVOA.

S A F E T Y



supporting through member dues,course tuition, and the sale of educa-tional materials. It is governed by aboard of directors, and an executivedirector and staff plan and manageday-to-day operations.

Vital to NPFVOA’s success is itsmembership base, which spans therange of industry from single-opera-tor fishing boats to the largest pro-cessing ships with crews of 150 ormore, and includes support busi-nesses and individuals. This diversemembership base facilitates earlyidentification of safety issues andconcerns and allows broad and rapiddissemination of safety information.

Vessel Safety ManualThe vessel safety manual, originallyprepared in conjunction with the U.S.Coast Guard, was first published in1986. NPFVOA has updated it fivetimes since then, with significant re-visions following the Fishing VesselSafety Act of 1988, subsequent regu-lations, and Coast Guard interpreta-tions. The most recent edition waspublished in 2004.

The manual provides useful andpractical measures that address awide range of situations gleanedfrom those who have fished in theBering Sea and North Pacific Ocean.It is not a set of legal documents, noris it intended to be a rigid set of stan-dards. Each vessel owner and captainshould adopt his own safety practicesbased upon the specific characteris-tics of his vessel and gear type, theseason and area of operation, andcrew experience.

Crew Safety Training ProgramSince 1985, the North Pacific FishingVessel Owners’ Association has pro-vided Coast Guard-approved safetytraining classes to nearly 40,000mariners. Using hands-on practice todramatize and enliven the informa-Intense fires in a vessel simulator provide students hands-on practice in firefighting.


tion, the crew safety training program offers both ship-board and classroom exercises.

Instructors who are experts in their respective fieldsprovide training including:

· Standards of Training, Certification and Watch-keeping (STCW) basic safety training, includingpersonal survival techniques (12 hours), personalsafety and social responsibilities (4 hours), fire-fighting (16 hours), and first aid/CPR (8 hours);

· STCW basic safety training refresher course (24hours);

· STCW medical care provider (32 hours);· STCW medical person in charge (40 hours);· emergency drill instructor workshop (8 hours);· drill instructor for small boat operators (8 hours);· onboard drill safety orientation (8 hours);· proficiency in survival craft (limited) (16 hours);· HAZWOPER (24 hours and 8-hour refresher); · shipboard damage control (8 hours);· shipboard watertight door and hatch maintenance

(4.5 hours);· OSHA compliance workshop (8 hours).

The classes emphasize teamwork and hands-on prac-tice managing emergencies. The instruction often pro-vides fishermen their first in-the-water experienceswearing immersion suits, as well as deploying, board-ing, and righting life rafts. Many owners and captains

require training for new hires and refresher training forreturning crew.

“Safety and Survival at Sea” SeriesThe “Safety and Survival at Sea” videotapes/DVDs aredesigned to complement hands-on training classes for:

· medical emergencies at sea,· safety equipment and survival procedures,· fire prevention and control,· fishing vessel stability.

All but the stability DVD are also available in Spanish.

Crews practice cold water survival techniques using lifesaving equipment.

Situated in Fishermen’s Terminal in Seattle, the North Pacific FishingVessel Owners’ Association is easily accessible to the fishing vessel fleet

that provides about half of the nation’s seafood harvest.

For more information, contact the North Pacific Fishing Vessel Owners’ Association at:

North Pacific Fishing Vessel Owners’ Association1900 West Emerson, Suite 101

Seattle, WA 98119 206-285-3383

Fax: 206-286-9332 [email protected]


Future Direction NPFVOA plans to build upon the suc-cesses of the last 25 years and continue toexpand course offerings and educationaltools so the industry can continue to im-prove safety practices.

About the author:Ms. Hughes was theexecutive director ofthe NPFVOA vesselsafety program until2008, when she be-came the director ofindustry and govern-ment affairs. She hasbeen actively involvedwith the commercialfishing industry formore than 35 yearsand currently serveson the Coast Guard’sCommercial FishingIndustry VesselSafety AdvisoryCommittee. She hasreceived two CoastGuard meritoriouspublic service awardsfor promoting safetyfor commercial fisher-men.


Students learn to give each other injections in STCWmedical care provider classes.

Students practice helping an injured crewmember into a life raft inthe STCW personal survival techniques class.

Students set off distress signals in the drill instructor workshop class.

Waterways Management

The MarineTransportation System

Waterways Management

The MarineTransportation System

Spring 2011

Summer 2011

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In 1975 during the herring season in British Columbia(BC), Canada, 14 vessels capsized and 12 men were lost.Since then, regulatory agencies have scrambled to de-velop curricu-lums aroundfishing vesselsafety, and thefederal govern-ment createdregulatory re-quirements forstability on fish-ing vessels andvessel mastertraining. TheProvincial Com-pensation Board( Wo r k S a f e B C )created regula-tions for safepractices aboardthe vessels.

Still, capsizingsand other fishingvessel casualtiescontinued. In2002, a seiner cap-sized near Van-couver and became the 152nd capsizing in BC since1975. Members of the British Columbia fishing industryrecognized they needed to take a more strategic role in

improving safety and hired a fishing industry safety co-ordinator to look at ways the fishing industry could de-velop its own programs to reduce injuries and fatalities.

WorkSafeBC acknowledged the importance of indus-try sectors developing their own safety programs andworked to facilitate the “Fish Safe” program that en-

Fish Safe!Inspiring

safety through collaboration.

by MS. GINA JOHANSENProgram Manager

Fish Safe BC

Captain Tim Joys aboard the Sena II takes his crew through an abandon ship drill. All pho-tos courtesy of Fish Safe.

Mitigating

RISK


courages fishermen to take ownership of safety in col-laboration with regulations.

It’s All in the PresentationMany fishermen live in small fishing communities. Theyand their neighbors are often fourth-generation fisher-men. These fishermen consider themselves unique, andrightly so—you have to be a little “unique” to take to sea.

We recently hosted a strategic planning session on fish-ing safety and hired a professional facilitator. The firstquestion from the audience to the facilitator, whoseonly job was to make sure we got through the agenda,was: “What do you know about fishing?”

If you have an inspection system that is prescriptiveand does not allow fishermen to use their knowledge ofthe vessel or have input into what procedures theyshould have in place, you will undermine their abilityto take ownership of a safety program. As a result, youcould end up with a “compliance only” program thathas them just following a formula for the sake of get-ting cleared to go fishing.

So how do we inspire fishermen to incorporate safetyaboard? They have to be involved in the developmentand delivery of education and training programs, andthey must be convinced that incorporating safety intotheir fishing operations will benefit them.

Fish SafeThe Fish Safe program uses real fishermen in all aspectsof program development and delivery. For example,the Fish Safe advisory committee brings together

everyone involved in fishing safety, from federaland provincial regulatory agencies to individualfishermen, educational institutions, and marinesafety suppliers.

By providing a forum to discuss safety concernsand work on solutions, regulators are better in-formed on the realities of fishing, and fishermenprovide insight on how to make regulations rel-evant and effective. Marine safety suppliers hearwhat needs to be done to make their products ef-fective in a fishing environment, and all kinds ofrelationships are built. This forum has also cre-ated the needed support for Fish Safe to accessfunding from provincial and federal agencies.

It’s WorkingOver the last three years, Fish Safe has provideda four-day stability education program to more

than 800 fishermen in 26 different communities inBritish Columbia. The Applied Research EvaluationServices of the University of BC evaluated the programand noted:

“Participants ranked the course, instructors, and in-struction very highly, with particular emphasis on thepractical application of course content and the relaxedand interactive course delivery. Not only did 96.8 per-cent gain knowledge from the course, 60.1 percentmade substantive changes on their vessels to increasestability and safety. As evidence of how worthwhilethey thought the course was, 94.4 percent recom-mended the course to others.”1

The author, Gina Johansen, is a third-generation fishermanout of Prince Rupert, BC.

Fishermen participate in the stability education program.

In 2009 we had no fishing fatalities and nocapsizings.2 Although this is a very positiveindicator, we don’t plan to hang our hat on this statis-tic. We still have at least the same amount of fishermento reach and have now started cycling the first 800through a one-day stability refresher course focusingon human factors.

Safest CatchThe good work and the good news continue. We re-cently launched the “Safest Catch” program, whichtrains fishermen as safety advisors. These advisors pro-vide one- or two-day onboard workshops to theirpeers, providing tools and direction to the master andcrew on how to develop their own safety procedures,emergency drills, and safety equipment orientation.

Within the first six months of the program, we have en-gaged more than 120 vessels with amazing results. Im-mersion suits are being dusted off and tested, life rings

that have never been taken off their holder are beingused in a life ring toss, and the mystery is taken out oftesting an emergency position-indicating radio beacon.Most importantly, Fish Safe advisors strive to impartthe information needed for fishermen to incorporatesafety into their regular operations and not just whatthey do when an inspector is around.

The benefits of regular drills and procedures come tolight quite quickly. Many “A-ha!” moments make be-lievers of the fishermen receiving the information aswell as the fishermen delivering it.

About the author:Gina Johansen, Fish Safe Program Manager, has owned and fished sev-eral seine vessels in the herring and salmon fisheries. She has an exten-sive background in project management and marketing, and hasprovided marketing and quality programs for the BC seafood industrysince 1992. Her experience as a third-generation commercial fishermanand the unfortunate loss of her father and uncle in the capsizing of afishing vessel has given her the motivation and insight to develop com-mon-sense safety programs for her peers in the commercial fishery.

Endnotes:1. Applied Research Evaluation Services of the University of BC, Executive

Summary, Fish Safe Stability Education Program, May 2009.2. WorkSafeBC, 2009 statistics.


Fish Safe uses real fishermen in safety ads.

For more information, go to www.fishsafebc.com.



The ProblemIn 2008 the National Institute for Occupational Safetyand Health (NIOSH) released a study that dubbed theDungeness crab fishery off the Oregon and Washing-ton coast the most dangerous fishery on the WestCoast.1

Why is this? While the Dungeness crab season lastsfrom early December to August, consumer demand ishighest during the Christmas holiday season. This,along with other economic factors, can create an annual“race to fish.” Additionally:

· Oregon and Washington ports are located at riverentrances with hazardous bars.

· Winter presents the worst weather of the year offthe Pacific Coast.

· Although the crab season is open Decemberthrough August, 75-80 percent of all Dungenesscrab is landed during the first two months of theseason.

· Pots are typically fished in relatively shallow water,where surf conditions are at their worst.

· Crabbers operate with gear over the side, at slowspeed, abeam to the seas and swell.

· Stacks of loaded pots on deck raises a vessel’s cen-ter of gravity, lowers freeboard, and reduces intactstability.

A worse set of operating conditions is difficult to imagine.

Objective: Improve Safety in This FisheryDistrict 13 and 17 staffers were aware of the hazards inthis fishery and had been keeping statistics regardingCoast Guard dockside safety examinations since 2003.With this new NIOSH “distinction,” they determinedthat conducting safety examinations specifically fo-cused on improving vessel stability and verifying thatprimary lifesaving equipment was on board, in goodcondition, and ready for use would greatly reduce thecurrent fatality rate.

And so they launched “Operation Safe Crab,” a port-by-port, just-in-time pulse operation consisting of ves-sel safety compliance checks.2 Coast Guard personnelfocused their initial efforts on ports with the greatestconcentrations of crab vessels and scheduled the examsclose to the start date of the season. This provided thebest chance of interaction with the fishermen (no pointvisiting empty docks) and gave the vessel operators

Operation Safe CrabA port-by-port, just-in-time pulse operation of targeted vessel safety compliance checks.

by MR. DANIEL HARDINCommercial Fishing Vessel Safety CoordinatorU.S. Coast Guard 13thDistrict

Mitigating

RISK

MR. KENNETH LAWRENSONCommercial Fishing Vessel Safety Coordinator U.S. Coast Guard 17thDistrict


time to address any safety concerns before the officialseason start.

With the goal of keeping the safety compliance checksto 15 minutes or less, Coast Guard examiners workedthrough a checklist that included items such as:

· Immersion suits in serviceable condition with per-sonal marker lights, in a readily accessible location.

· Survival craft checked to ensure they have beenserviced, of sufficient capacity for all aboard, andstowed in a readily accessible or float-free location.

· If used, survival craft hydrostatic release properlyinstalled and not expired.

· Emergency position-indicating radio beacons self-tested by the operator, batteries not expired, lo-cated in a float-free location if required, hydrostaticrelease units not expired, and properly registeredwith NOAA.

· Freeing ports adequately sized and kept clear.· Watertight envelope of vessel maintained.· Minimum freeboard midship not less than six

inches.· Downflooding points above 35 degrees.· Evaluate stability of vessel with roll period test, if

warranted (see sidebar).

Vessels with discrepancies were issued a captain of theport order holding the vessel to the dock. The decisioncriteria for the order: If the vessel had been discoveredat sea during a boarding with the same condition,would the voyage be terminated?

Compliance*Commercial fishing industry vessels are classified asuninspected vessels and are not required to undergoCoast Guard inspection. Regardless, these vessels mustcomply with the requirements of 46 Code of FederalRegulations Part 28, and are traditionally examined forcompliance during fisheries and law enforcementboardings at sea.

So can the Coast Guard compel mandatory compliancewith safety compliance checks prior to vessels gettingunderway? After studying various sources of legal au-thority, planners determined that this effort fell into abit of a “gray area”3 and decided the dockside safetychecks would be consensual. Given the vital importanceof examining as many of these high-risk crab vessels aspossible, however, district commanders encouraged ex-aminers to communicate that we would prefer to dothese checks at the dock, where it is much safer for both

We analyzed the data on the fishery andthe Coast Guard’s efforts, with the goalof answering three questions:

·· Is there a statistical correlation be-tween having a safety compliancecheck (SCC) and not having a fatalcasualty?

·· How efficient has the Coast Guardbeen at performing safety compli-ance checks, as described by thepercentage of SCCs done on vesselsin the target population—did theSCC hit the right target?

·· How effective has the Coast Guardbeen at reaching the target fleetwith an SCC, as measured by thepercentage of target vessels that ac-tually had an SCC performed?

The DataCrab landing data was compiled fromthe Pacific States Marine Fisheries Com-mission’s PACFIN database. Althoughthere are between 1,400 and 1,600 ves-sels participating in the fishery, the num-ber of vessels landing the vast majorityof the product is considerably smaller.

To account for the considerable diversityin total landing weight per season, weused a cutoff of 20,000 lbs. of Dungenesscrab delivered per season. This reflects atruer picture of those vessels crabbing ina commercially viable manner, and thusexpected to be at the greatest risk, as op-posed to the much larger number of ves-sels that were crabbing incidentally orwere making a minimum landing peryear to maintain a “fishing history” (toprotect their interests should this fisheryever go to a quota-based scheme).

Does a Safety ComplianceCheck Make a Difference?



Figure 3.

Table 1.

Table 2.

Table 4.

Table 5.

Lastly, vessels that suffered a fatal casualtythat were below the 20,000-pound cutofffor that season were added to the total, toaccount for their presence in the popula-tion. Results are shown in table 1.

Table 2 shows that we are reaching be-tween 69 to 83 percent of the targetedhigh-volume vessels. The chance that a par-ticular vessel in the target fleet actually hadan SCC is dramatically lower: between 24percent and 42 percent (Figure 3).

We attempted to recreate their previousmethodology for establishing statistical sig-nificance by testing a two-by-two columntable using Fisher’s exact two-tailed test.1

It was soon evident that there were toomany small and zero values to produce anymeaningful results for each season. Wethen decided to aggregate all the data fromthe six seasons into one table. The data isshown in table 4, and the resulting two-by-two table is shown in table 5.

This table was tested for odds-ratio andconfidence interval.2 The resulting oddsratio is 1.2 to 1, with a confidence intervalof 0.30 to 4.7. This odds ratio is too low, andthe confidence interval too wide (overlap-ping 1.00) to suggest any statistical signifi-cance of the hypothesis that having an SCCis related to no fatalities. Despite the ag-gregation of six years of data into one table,the left column remains too small to showstatistical support of the efforts of thesepulse operations. We believe that a higherpercentage of the target population withan SCC in the future will result in a higherodds ratio.

Endnotes:1. http://en.wikipedia.org/wiki/Fisher's_exact_test2. D.J.R. Hutchon, 2001. Online Statistical Calculator,

www.hutchon.net/ConfidOR.htm.

the fishermen and our personnel, but it is our intentionto check all vessels participating in this fishery.

The message: Participate in the dockside safety com-pliance check or risk being boarded at sea and sent backto port for safety violations.

Does the Program Work?While the current statistical analysis does not prove anabsolute statistical connection between safety compli-ance checks (SCCs) and fatalities, the result may havemore to do with the size of the sample than the over-all effectiveness of the program (see sidebar). Addi-tionally, it’s not possible to prove a “negative.” Wecan’t say conclusively that a specific vessel would haveexperienced a casualty if it hadn’t undergone a safetycompliance check.


The most importantand most difficult as-

pects of the safety compli-ance checks were issues

related to stability. Few of these vessels are required to havestability books, yet loss of stability was the leading factor infatalities.

In an effort to establish reasonable stability criteria for dock-side examiners, limiting measures were employed:

·· a minimum six inches of freeboard midship, ·· no downflooding points at a heel angle less than 35 de-

grees.

Vessels that failed either of these were subjected to a simple“roll period” test to calculate a minimum metacentric height.1

Since the angle of deck edge immersion essentially drives theroll period calculation, vessels with insufficient freeboardwere unlikely to pass the roll test.

It is important to note that these criteria were never designedto be a standard for safe loading of a crab vessel, but ratherprovided a means of identifying stability problems that wereclearly especially hazardous.

Endnote:1. In a roll test, the vessel is rolled through a small angle of heel several times in still

water so that an average time is obtained for a complete roll cycle (from port to star-board and back to port). A value of GM (the metacentric height of the ship) can thenbe estimated using the vessel's beam. The value of GM determines the slope of therighting curve at small angles of heel, and the resulting area under the curve from zeroto the angle of deck edge immersion represents the vessel's righting energy and canbe compared to a minimum standard.

STABILITY What can we say? Operation Safe Crab has generallydone a good job of targeting the “right” vessels—that is,those vessels identified as at the greatest risk. However,the program has not reached its goal of reaching nearlyall commercial Dungeness crab vessels.

So, while we believe we’re on the right track and thatthis program has value, we will continue efforts to im-prove and refine it. We will work to increase the num-ber of safety compliance checks.

Additionally, the list of target vessels can also be used tobetter prioritize at-sea boardings. Future analysisshould include the numbers of at-sea boardings in ad-dition to safety compliance checks, as a more completepicture of overall Coast Guard interaction with the fleet.

About the authors:Mr. Daniel Hardin is the 13thDistrict Commercial Fishing Vessel Safetycoordinator. He is a retired Coast Guard officer with 25 years of serviceand has been a civilian employee working with the commercial fishingindustry vessel safety program since 1998. While on active duty Danserved as an aviation survivalman and aircrewman, then later served asa Coast Guard marine inspector. Dan has a master of science degreefrom Boise State University in human performance technology.Mr. Kenneth Lawrenson is currently the 17thDistrict Commercial Fish-ing Vessel Safety coordinator, and has been involved in commercial fish-ing safety since 1992. A 1984 graduate of the Coast Guard Academywith an MSE degree in naval architecture from the University of Michi-gan, he has researched vessel stability, risk mitigation, and fatigue andhuman factors in marine operations extensively and participated in nu-merous major marine casualty investigations.

Champion’s Note:*The 2010 Coast Guard Authorization Act now givesthe Coast Guard the authority to conduct, and re-quires vessels to complete, a dockside safety exami-nation at least once every two years. For moreinformation, see “The Coast Guard Authorization Actof 2010,” pages 12-13.Endnotes:1. CDC. Commercial fishing fatalities—California, Oregon, and Washington,

2000-2006. MMWR 2008; 57:425-9.2. The approach was modeled after a similar successful pulse operation de-

veloped by Coast Guard Marine Safety Office Anchorage to reduce fatali-ties in the Bering Sea Red King, Opilio, and Tanner crab fisheries. C.Medlicott, 2002, “Using Dockside Enforcement to Compel Compliance andImprove Safety,” Proceedings of the International Fishing Industry Safetyand Health Conference, Woods Hole, MA, NIOSH.

3. 14 U.S. Code 89 grants the Coast Guard authority to board any vessel inU.S. waters without a warrant. 33 CFR 160 provides the COTP authority to compel a vessel to operate in amanner directed by the COTP, but does not allow Coast Guard personnelto gain access to those vessels.33 CFR 6 authorities for Coast Guard boardings provided by the MagnusonAct were enacted to fight terrorism, and could not be used to gain access toa vessel for safety enforcement.


The Coast Guard Authorization Act of 2010 providesfor the development of regional and fishery-specificsafety programs, known as “alternate safety compli-ance programs” (ASCP). Such programs provide an al-

ternative safety standard to existing vessels that cannotmeet future requirements of vessel classification andloadline.

In fact, the 13th and 17th Coast Guard Districts have hadmuch success with this kind of regional approach. Ad-ditionally, the recent Alternate Compliance and SafetyAgreement (see related article) has resulted in a com-prehensive vessel inspection and training program formore than 50 catcher-processor vessels operating in theBering Sea/Aleutian Island region.

Measuring Risk in the Fishing IndustrySince 1990, the National Institute for OccupationalSafety and Health (NIOSH) Alaska Pacific Regional Of-fice has monitored the safety performance of fishingfleets throughout Alaska by measuring individual fleetfatality rates. Fatality rates are measured by comparingthe ratio of the number of fatalities to an occupationalrisk exposure.

This operational risk exposure measurement is basedupon several variables including: · the number of vessels operating, · the number of days the vessel is at sea, · the number of crewmembers exposed to the occu-

pational risk.

Alternate Safety Compliance Programs

USCG and affected industry parties strategize to target

safety performance variability.

CDR CHRIS WOODLEYChief of Prevention

U.S. Coast Guard Sector Puget Sound

Mitigating

RISK

A U.S. Coast Guard marine inspector examines watertight integrityon a fish processing vessel. USCG photo.

by MS. LESLIE J. HUGHESDirector of Government and Industry Affairs

North Pacific Fishing Vessel Owners’ Association Vessel Safety Program


Review of this data clearly demonstrates that fatalityrates and causal factors are highly differentiated amongvessel types, fishery gear, species being fished, and ge-ographic region.

Risk is RegionalFor example, a recent safety study found that in thewaters of the state of Alaska there were nearly 60 dif-ferent vessel/gear/species combinations, with eachfishery having significantly different fatality rates andcasual factors.

Some of these fisheries had high rates of falls overboardrelated to gear-specific operational practices, some hadproblems with vessel stability, and other fisheries hada large number of capsizing events due to poor weatherand local geographic features. Other fisheries had vir-tually none of these problems.

Alternate Safety Compliance ProgramsOnce a fishery has been determined to be high-risk andconsidered for an alternate safety compliance program,the Coast Guard and affected industry parties considerwhich strategies could prevent fatalities or vessellosses. Specifically, mitigation strategies should focuson achievable improvements, with some of the follow-ing considerations in mind.

Training. Are the risks associated with a particular fish-ery such that crewmembers would be better preparedto deal with the most common emergencies if they hadmore extensive training and/or if additional crewmem-bers received training? Is there a need for customizedtraining to address the particular hazards a gear typeencounters? Do crews actually conduct drills on a reg-ular basis? Is there a need for increased compliance?

Structural considerations. Are vessel losses due to poorhull condition, downflooding, overloading, or a com-bination of these? Are vessels seaworthy and able towithstand the sea conditions encountered? Do crewsmaintain watertight and weathertight closures? Do ves-sels have adequate stability for typically encounteredloading conditions? Are captains adhering to vesselloading limits?

Operational factors. Does a vessel need to cross a haz-ardous bar to get to the fishing grounds? Does the ves-sel operate in remote areas, far from Coast Guardsearch and rescue? How many people are aboard thevessel? Is processing conducted on board? Is fatigue anissue? Do crews adhere to watchkeeping standards?

Equipment issues. Does the onboard safety equipmentaddress the most common types of fatalities within thefleet? Is there better or more appropriate lifesaving

A U.S. Coast Guard marine inspector checks that immersion suits are donned properly during a emergency drillcompliance check. USCG photo.


equipment? If man overboard fatalities are a problem,do crewmembers wear flotation when working ondeck? Do crewmembers wear strobe lights on their im-mersion suits?

Compliance. Are fatalities occurring within a fleet de-spite high levels of participation with the Coast GuardDockside Exam Program? What is the level and qualityof interactions with the Coast Guard? Could fatalitiesbe reduced with increased compliance with existingfishing vessel safety regulations? Does the vessel carryrequired lifesaving appliances? Is lifesaving equipmentwell maintained and serviceable?

Implementing an ACSPFor an alternate safety compliance program to be suc-cessful, the Coast Guard must have a solid under-standing of actual industry practices, and risk to thefleet. Industry needs to acknowledge risks and be will-ing to move forward in order to mitigate them.

True collaboration with industry is vital. As such, eachside must sublimate its own agenda to the overall goalof effectively reducing risk. Some guidelines include:· All parties should understand that quantifying the

safety improvements may take years. This shouldnot be viewed as a deterrent to establishing incre-mental safety improvements.

· All entities must be realistic about what will be re-quired to implement an alternate safety compli-ance program and adequate resources must bededicated to conduct the program.

· Both Coast Guard and industry must be flexible re-garding how risks can be mitigated as well as howa safety regime can be upgraded. As the alternatesafety compliance program for a particular fleetevolves, additional concerns may be discoveredand changes to the requirements may result.

· The Coast Guard must assume the lead for com-pliance with ACSP provisions by providing clearprogram guidance.

· The Coast Guard must exercise continuous evalu-ation of industry’s progress and assess the effec-tiveness of the ACSP.

About the authors: Ms. Hughes was the executive director of the NPFVOA vessel safetyprogram until 2008, when she became the director of industry and gov-ernment affairs. She has been actively involved with the commercialfishing industry for more than 35 years and currently serves on theCoast Guard’s Commercial Fishing Industry Vessel Safety AdvisoryCommittee. She has received two Coast Guard meritorious public serv-ice awards for promoting safety for commercial fishermen.

CDR Chris Woodley is currently chief of the Prevention Department atSector Puget Sound. As a 20-year career marine safety officer, he has en-joyed the unique fate of being able to collaboratively work with the NorthPacific fishing industry in multiple tours and capacities as a senior ma-rine inspector, an investigating officer, an oil spill responder, and as afishing vessel safety/fishery management policy analyst. CDR Woodleygraduated from the University of Oregon and also has a Master of Ma-rine Affairs degree from the University of Washington.

An effective alternate safety compliance pro-gram can provide advantages that allow for:

·· government and industry “buy-in” forsafety improvements;

·· an approach that is tailored to a specificfleet, operating environment, and crewsize;

·· program requirements that respond tothe magnitude of the identified risk.

Benefits for High-Risk Fisheries



When the New Bedford, Mass.-based commercial fish-ing vessel Northern Edge sank on December 20, 2004,only one of the six-person crew survived. Reports ex-plained he was the only one of the six to have partici-pated in fishing vessel safety training required forfishing in his native Portugal.

Soon after the accident, New Bedford’s mayor FredKalisz visited William Hogarth, the head of NOAAFisheries in Washington, D.C., to discuss improvingsafety. Subsequently Mr. Hogarth committed to pro-viding $100,000 toward safety training in New Bedford.A diverse advisory panel including professional safetytrainers, a local fisherman, Coast Guard personnel, ad-visors, and academics was assembled to begin imple-mentation of a safety training program.

A Sea Change Ultimately more than 1,200 fishermen attended basichands-on safety training in Massachusetts between2005 and 2010. Of these, 895 were trained in a programsponsored by the city of New Bedford. Another 307participated in training offered by the MassachusettsFishermen’s Partnership (MFP) with funding from theCooperative Research Partners Program of NationalMarine Fisheries Service Northeast Regional Office,Fisherman’s Fund, and various insurance companies.

In an effort to learn what led to this unprecedented levelof participation, officials conducted several surveys. Apreliminary survey interviewed 30 fishermen during aNew Bedford training session. Though this was notideal, since the participants were interviewed in briefperiods between training stations, four interviewerswere able to interview almost half the participants.

And the Surveys Said …In contrast to expectations, those responding to the pre-liminary survey did not cite the loss of life on the North-ern Edge as a motivating factor in their attendance.

· More than half of the respondents noted their cap-tain and/or owner had made attendance eithermandatory or strongly recommended.

· Twelve of the 30 interviewed mentioned that theywere “curious,” “interested,” “couldn’t hurt,”and/or “been meaning to learn more about safety.”

· At least two noted that their vessel had newcrewmembers and that the workshops were also agood idea as refreshers for those already familiarwith safety training.

Ten randomly selected participants in New Bedfordtraining sessions were later interviewed on the phone.When offered a list of reasons from which to select, ofthe 10 interviewed who took the New Bedford training:

Better Safe Than Sunk

Massachusetts fishermen find value in hands-on safety training.

by DR. MADELEINE HALL-ARBERCenter for Marine Social SciencesMIT Sea Grant College Program

DR. KARINA LORENZ MRAKOVCICHDepartment of ScienceU.S. Coast Guard Academy

&TRAINING

OUTREACH


· Six confirmed that the F/V Northern Edge’s fate didattract them to the training.

· Most (eight of the 10) also noted that either they asowner or captain, or their owner or captain, en-couraged participation.

· Five said they had been “meaning to learn moreabout safety,” one because a boat of his had sunkand another because of horror stories he had heard.

· Two mentioned they came because training wasfree.

· Seven mentioned they had experienced an emer-gency on board their vessel, though most of theevents were not life-threatening.

Telephone interviews of 17 participants in the sessionssponsored by Massachusetts Fishermen’s Partnership

provided interesting data. In fact, there were almost asmany reasons offered for taking the training as therewere participants.

· Only one of the 17 interviewed mentioned mediaattention to accidents.

· Five noted they “had been meaning to take train-ing.”

· Five mentioned they took the course because it wasfree.

· One noted he fishes alone and believes in “beingsafety-minded, keeping up with the latest tech-niques.”

· Another said he had been run down offshore, sohe’s very safety conscious.

· Two owner/captains stressed the importance oftheir crew being familiar with safety procedures.

Next StepsAll of the sessions were judged useful and clearly pre-sented. The main suggestions were for slightly longersessions to allow even more hands-on training, partic-ularly for first aid and fire extinguishing.

Two respondents suggested using a more realistic set-ting for the firefighting simulation; one suggested avessel and the other an enclosed space. Respondentsalso recommended that CPR training be added to thefirst aid module.

Basic stability demonstrations using boat models havebeen added to the training offered by MFP. As morefishermen are introduced to the primary concepts andsee how they might easily be applied to their own ves-sels, agreement with proposals to require stability as-sessment might increase.

Unfortunately, icing conditions are believed to havecost the lives of four fishermen and the loss of F/V Ladyof Grace out of New Bedford in February 2007. Just oneweek after that, another two fishermen were lost alongwith the F/V Lady Luck out of Newburyport. Floodingwas determined to be a possible cause. (See article“Lost at Sea” in this edition.)

The Take-AwaysThe tipping point for the fishermen of Massachusettsmay have been the loss of the F/V Northern Edge, fol-lowed quickly by an offer of free training. Communityleaders also played a central role in attracting partici-pation in both New Bedford and the small ports whereMFP organized training.

The safety project managers found that direct commu-nication with vessel owners and captains by someonethey respect is crucial. Crewmember participation wasfrequently dependent on the captain’s and/or owner’sencouraging or requiring attendance. Timing is alsovery important, since it is challenging to attract atten-dance during active fishing periods, but should beavailable when safety is still on fishermen’s minds.

The workshops also seemed to develop “risk knowl-edge” among participants so that they began to seesafety preparation and training as potentially life-sav-ing rather than simply another bureaucratic require-

Table 1: Results of surveys about reasons why commercial fish-ermen in Massachusetts have attended safety training.

Capt/owner suggested 16 6 1Northern Edge 0 6 1Meaning to/interested 12 5 5Horror stories 0 1 0Past experience 1 1 0Hands-on 0 0 1Free 0 2 5Facilities/proximity 0 2 2Well-respected 1 2 2Media 0 0 1Safety 0 0 4Regulations 0 0 1

Refresher 0 0 2

New Bedford on site (30)

New Bedfordfollow-upphone interviews (10)

MassachusettsFishermen’sPartnershiptraining participants(17)NUMBERS INTERVIEWED



This half-day course consists of an in-troduction with a short video of vesselssinking and comments from the U.S.Coast Guard safety program officer.

Immersion Suit ModuleIn this module, participants don im-mersion suits, jump in the water,swim/float to a raft, and climb in. Oneinterviewee suggested that the experi-

ence of climbing into the raft could beused by designers to redesign the raft,saying “The first one in the raft helpedpull in the next guy, but the fourth guy,who ended on top of the third guy, wasoverweight. We thought we wouldhave to do CPR!”

Life Raft Module In this module a trainer displays thecontents of a raft, explaining each itemand its utility. Araft deploymentdemonstrationusing a volun-teer participantclearly illustratesthe length of ropeincorporated intothe raft’s housingand the force ofthe deployment.

Flares and Firefighting ModulesDuring the flares module participantshave the opportunity to shoot off a va-riety of flares and sample the rationskept in the raft. The firefighting mod-

ule includes practicing a mayday calland extinguishing fires after an expla-nation of the different types of fires andextinguishers.

Damage Control ModuleThe damage control module providedby the Coast Guard offers fishermen achance to attemptto stem the suddenoutpouring ofwater mimickingactual flooding con-ditions. A traineralso demonstratesstability issuesusing vessel mod-els.

One participant mentioned he used theinformation gained to deal with a prob-lem on his vessel, explaining “After theworkshop, I used flood kit pack to plugwater coming through hull.”

First Aid ModuleThe Massachusetts Fishermen’s Part-nership training sessions include a firstaid module that addresses basic issuessuch as how to handle trauma and

bleeding. The mod-ule also provides in-formation onoccupational healthissues such as avoid-ing breathing fumesand particulate mat-ter in enclosedspaces (for example,when sanding lob-ster buoys).

Most of the trainingsessions also in-cluded an at-sea res-cue demonstrationby a Coast Guardhelicopter team andan opportunity to

look at the helicopter and speak to theteam.

Two fishermen participate in the firefight-ing module.

Workshop trainer Ted Williams explains life raft use.

Instructor Tom Toolis and Dana Collier(not pictured) lead an immersion suitdemonstration while U.S. Coast Guardmembers serve as lifeguards. All pho-tos by Dr. Madeleine Hall-Arber.

A fishing vessel stabil-ity demonstration.

A U.S. Coast Guard at-sea rescuedemonstration.

Safety Training Modules


ment. The significant level of participation inthe safety training by the Northeast fishing in-dustry suggests increasing optimism amongfishermen about their ability to survive acci-dents at sea. Author’s note:This article is largely drawn from Hall-Arber and Mrakovcich’s“Reducing Risk to Life and Limb: Safety Training Steps TowardsResilience in Massachusetts’ Commercial Fishing Industry,” pub-lished in Human Ecology Review 15:2 (2008). We thank the edi-tors for permission to reprint portions of the article.

About the authors:Dr. Madeleine Hall-Arber is an anthropologist who hasworked with the commercial fishing industry for over 25 years.She is a marine advisor for the MIT Sea Grant Program inCambridge, Mass. Among other accomplishments, she workswith the New England Fishery Management Council’s staff toidentify social impacts of regulatory change on fishing com-munities.

Dr. Karina Lorenz Mrakovcich is a professor and marine sci-ence section chief at the U.S. Coast Guard Academy. She holdsa Ph.D. in fisheries science from Oregon State University. Sheteaches fisheries biology, fisheries management, and atmos-pheric and marine sciences.

Handling Immersion Suits

When the safety training courses began, approximately 30percent of the immersion suits brought to the courses bythe fishermen who owned them failed.

Failures included:

·· malfunctioning zippers (the fishermen could not en-tirely close the suit);

·· dried-up neoprene that cracked when unfolded; ·· extraneous lights or whistles that were improperly tied

to the suit, resulting in tears or holes; ·· suits too large or too small for their owners;·· suits so old that the seams ripped when tried on.

One measure of the extended benefit of these trainingcourses is that the trainers are seeing a much lower per-centage of failures in the suits among the more recent par-ticipants.

Those who had never attended formal traininglearned that:

·· The suit was harder to get on than they thoughtit would be.

·· Getting into the raft with the suit on can be challenging.

·· Having your own suit is important.

Handling Immersion Suits


The emerald-green island of Kodiak rises out of the Gulfof Alaska about 25 miles from its mainland, about 200miles from Anchorage. Commercial fishing has been amainstay for all of the communities on the island.

Unfortunately, plane fare to Anchorage to take fishingvessel safety training would cost almost $600. Fortu-

nately fishermen on Kodiak do not have to travel totake safety training: It has been brought to them foryears.

HistoryIt wasn’t always this way. In the not-so-distant past,Alaska suffered the highest rate of fishing fatalities in

the nation. There were no resources, fishingvessel safety training programs, or budgetfor them for Alaska.

So, with few training resources and greatneed, individuals from the University ofAlaska Sea Grant/Marine Advisory Pro-gram and Coast Guard air stations inAlaska pulled together resources from theirown agencies. They flew out to remote fish-ing ports to teach marine safety workshops.In 1983 the University of Alaska produceda four-part “Fishermen’s Survival” videoseries to help in this effort. In addition, anumber of safety workshops were given.

Since most of the remote fishing portsstrung along thousands of miles of Alaskacoastline are not connected by roads, it be-came obvious that a more permanent train-ing and outreach effort was needed to make

safety training available to these far-flungports.

AMSEA’s Port-Based Safety Training

by MR. JERRY DZUGANExecutive DirectorAlaska Marine Safety Education Association

&TRAINING

OUTREACH

AMSEA instructor Steven Campbell explains to commercial fish-ermen how to form a human raft in pool exercise. USCG photo.


The Alaska Marine SafetyEducation AssociationBy the mid-1980s, a group ofpeople from these and otheragencies formed a non-profitgroup, the Alaska MarineSafety Education Association(AMSEA), to address thehigh fatality rates in boatingactivities. Core principles ofAMSEA’s safety trainingprogram:

· The training had to bemeaningful, relevant,and hands-on.

· It had to be delivered totheir homeports whenfishermen were not fish-ing.

· Additionally, the training needed to be low- or no-cost to effectively include even small fishing portsthat did not have a steady cash economy.

Program BasicsInitial efforts focused on four areas.

First, much of the information on cold water survival atthat time was outdated or not appropriate to cold cli-mates such as Alaska, so new information needed to be

incorporated into a cold weather-relevant marine safetymanual.

Second, marine safety instructors needed to be trainedso remote fishing ports could have their own localtraining resources. These instructors would know thelocal fishery and would mostly be credible fishermenthemselves.

Third, an inventory of marine safety training gear suchas immersion suits, life rafts, wearable lifejackets, etc.,

had to be established so this gearcould be procured, maintained,and sent to instructors in theseports. Many port-based instruc-tors would only teach a few timesa year, but needed expensive gearfor training. They would be able toobtain this gear through AMSEAin a revolving loan program.

Finally, these instructors wouldneed support staff to help acquirefunding, promote safety work-

As part of an AMSEA drill conduc-tor course, Floyd Tomkins (fore-ground) splits wedges wrapped incloth to fix one of several floodingproblems (similar to a crack in ahull) in AMSEA’s flooding controltrailer, which was designed basedon the USCG’s flooding controltrailers stationed around the U.S.Photo by Mr. Jerry Dzugan.

AMSEA trainer Mary Chambers trains Sitka teens like Ellen Chenowith, picturedleft, in outboard motor safety. Photo by Mr. Jerry Dzugan courtesy of the AlaskaMarine Safety Education Association.


shops, maintain training gear, coordinate classes, andperform other duties.

AccomplishmentsThe first Marine Safety Instruc-tor Training (MSIT) course washeld in Sitka, Alaska in 1986.Since that time, more than 1,000instructors have been trained.These instructors train commer-cial fishermen from AmericanSamoa to Maine and fromFlorida to Northwestern Alaska.Almost 10,000 fishing emer-gency drill conductors havebeen trained in more than 1,000workshops since 1990. In addi-tion, over 180,000 fishermen andother mariners have also beenprovided with hands-on safetytraining in custom courses ondifferent topics.

Agencies such as the NationalMarine Fisheries Service Ob-server Training Program havealso used the MSIT training asthe basic qualifications for theirinstructors; thus, all fisheries ob-servers receive this training.

“AMSEA training” has become synonymouswith marine safety training in many parts ofthe country.

ResultsAMSEA has documented mariners whohave been helped in an emergency by thetraining they received through this commu-nity-based instructor network. Research bythe National Institute of Occupational Safetyand Health has documented that a mariner isone and a half times more likely to survivean emergency at sea if he has taken safetytraining.1

Additionally, the majority of instructors teach-ing marine safety to commercial fishermen in the U.S.have now been trained in AMSEA’s Coast Guard-ac-

Robert Ngugen teaches MAYDAYs to Vietnamese fishermen in Galveston, Texas. Photo byJerry Dzugan.

Get the Kids On Board

In Alaska, many children work on their family’s fishingvessels. They learn to clean fish and other fishing skillsat a young age. When a boat is at risk, so are the children, so the survival skills they learn are critical.

Training school children in marine safety is also seenas critical, since the attitudes and behaviors of children are typically easier to influence than those ofadults. Since 1986 the AMSEA network has trainedteachers in half the school systems in Alaska as wellas schools in Maine and other states.

Some school systems start training their children inimmersion suit use and marine safety through AMSEAas early as third grade. Some of these former thirdgraders are now taking over their parents’ fishing operations and are asking for refresher training.

Get the Kids On Board


For books, curriculum, brochures, DVDs,current information on marine safety,

and a quarterly newsletter, go towww.amsea.org.


cepted MSIT course. This network would not be possi-ble without the collaboration of a network that includesthe Coast Guard, Sea Grant agents, marine equipmentsuppliers, private trainers, and many others. Thesepartners provide survival gear, expertise, funding, pro-motion, and facilitate training in many ways.

Due in part to these efforts, in the last 20 years the av-erage number of fishing fatalities in Alaska fell from 38per year to an average of 11.2

About the author: Mr. Jerry Dzugan is the Executive Director of the Alaska Marine SafetyEducation Association. He is also currently serving as the chairman ofthe Coast Guard’s Commercial Fishing Industry Vessel Safety Advi-sory Committee. He has been a lifelong educator and has commerciallyfished Alaskan salmon and halibut.

Endnotes:1. Lincoln, J. (2006). Fresh Seafood at a Price: Factors Associated with Surviv-

ing Fishing Vessel Sinkings in Alaska, 1992-2004. Unpublished doctoral dis-sertation, Johns Hopkins University, Baltimore, Maryland.

2. AMSEA analysis.

· fishing vessel crew survivability,· fishing vessel stability awareness, · fishing vessel examiners,· fishing vessel inspection techniques.

Training is not limited to commercial fisherman andtheir local communities; it is also offered to people suchas state and federal employees who work closely along-side the fishing community and industry. Additionally,training locations have expanded to include ports inHawaii and on the West, East, and Gulf Coasts.

To date AMSEA has trained approximately 9,500 fish-ing vessel drill conductors, over 1,000 vessel marinesafety instructor trainers, 114,300 school children, and55,000 members of the general public.

With fishing vessel casualties rising in the 1980s and1990s, the Coast Guard concluded that, in conjunctionwith writing and implementing new regulations, im-plementing an aggressive fishing vessel safety trainingprogram would help reduce fatalities.

The Coast Guard sought assistance from other organi-zations to provide products and services to enhance thetraining infrastructure for commercial fishermen inAlaska and throughout the U.S., and in 2001 it awardeda contract to the Alaska Marine Safety Education Asso-ciation (AMSEA).

AMSEA focused its training on practical informationdelivered in a hands-on format. The initial training fo-cused on cold water safety and survivability and waspresented to school children, commercial fishermen,and the general boating public in remote areas ofAlaska.

Its courses have expanded and now include training for:

· fishing vessel drill conductors,· fishing vessel marine safety instructors,

The Coast Guard and the Alaska Marine Safety Education AssociationPartners in fishing vessel safety. by MR. DAVID BELLIVEAUU.S. Coast Guard Fishing Vessel Safety Division

For information on training opportunities, visit

www.fishsafe.info.


“If you rescue a man at sea, yougive him his life that day. Teach aman how to save himself, and yousave him for a lifetime.”


Survival Through EducationNational Marine Fisheries Service observer safety training.

by PETTY OFFICER 3RD CLASS COLIN WHITEPublic Affairs SpecialistU.S. Coast Guard Thirteenth District

&TRAINING

OUTREACH

National Oceanographic and Atmospheric Adminis-tration (NOAA) National Marine Fisheries Service(NMFS) observers are an important link in the chain ofthose who assist in the stewardship of the nation’s liv-ing marine resources and associated habitats.

NMFS observers in general are recent college gradu-ates with a background in biology or marine science.They work to collect at-sea scientific data required forthe conservation and management of marine resourceswithin the United States’ exclusive economic zone.

The U.S. Coast Guard and NOAA share a mutual in-terest in fishing vessel safety and National Marine Fish-eries Service observer safety. As part of the NMFSobserver program, it is mandatory that all observedfishing vessels pass a Coast Guard commercial fishingvessel safety examination and that all observers partic-ipate in marine safety training demonstrating compe-tency in emergency response skills.

“The Coast Guard has been working with the NMFS,providing survival training to the observers since1998,” according to Dan Hardin, Commercial FishingVessel Safety Coordinator for the U.S. Coast GuardThirteenth District in Seattle. “NMFS wanted to makesure the Coast Guard was involved to provide training

to observers on what the regulations are for commercialfishing vessels and what kind of safety equipmentshould be on board and routinely inspected,” he said.

The TrainingObservers are trained over a three-week period. Fortwo weeks they learn how to collect catch and by-catchdata from U.S. commercial fishing and processing ves-sels. In the final week, they are introduced to requiredvessel safety equipment, the use of personal survivalequipment, and survival techniques in the water.

“During the training we teach the observers how to de-termine what the vessel is required to have, in additionto teaching them to use a vessel safety checklist,” saidHardin. “The checklist describes each piece of equip-ment, where each should be located on the vessel, andhow each is used.”

The last day of survival training combines all knowl-edge and skills the observers-in-training have beentaught into a practical in-water exercise. Observersmust don their immersion survival suits in under 60seconds, demonstrate the proper water entry method,inflate and enter a life raft from the water, display theheat escape lessening posture, initiate methods ofarrangement to better signal possible rescuers, andenter a mock Coast Guard helicopter rescue basket.


“The training was excellent,” said Jonathan Fusaro, arecent NMFS observer program graduate. “It was greatto have the Coast Guard instructors in the water withus during the practical exercises. I’m more informed ofrescue techniques and what to anticipate when rescuersarrive.”

About the author:Public Affairs Specialist 3rd Class Colin White is stationed at the U.S.Coast Guard Thirteenth District Public Affairs Office in Seattle. PA3White was previously stationed with Aids to Navigation Team Mobile,Ala. His awards include two Commandant’s Letter of CommendationRibbons, a Coast Guard Unit Commendation, two Meritorious TeamCommendations, a Coast Guard Good Conduct Medal, and two SpecialOperations Service Ribbons. He recently returned to the Gulf Coast insupport of the Deepwater Horizon response.

The Alaska Ranger flooded andsank 180 miles west of Dutch Har-bor, Alaska, on March 23, 2008. Thecrew and NMFS observers aban-doned ship at night into frigid wa-ters, facing 15-foot seas and30-knot winds.

The incident marked one of thelargest cold-water rescue opera-tions in Coast Guard history. Heli-copter rescue crews from Saint

Paul Island, Alaska, attached to theCoast Guard Cutter Munro wereable to rescue 20 people, while 22others were rescued by the AlaskaRanger’s sister ship, the AlaskaWarrior. Sadly, five perished in thiscasualty.

It could have been much worse.Fortunately, an NMFS observeraboard, Jayson Vallee, activated apersonal locator beacon, providing

the Coast Guard critical search andrescue information.

He attributed his success and ulti-mate survival to his training. “Thetraining through NMFS and theCoast Guard made all of the safetyand survival equipment familiar,”explained Vallee. “It became sec-ond nature, having the ‘musclememory’ to put on the immersionsuit.”

Putting the Training into Practice

Aboard the Alaska Ranger

U.S. Coast Guard photos.


Interventions in the Interest of SafetyTraining, research, and outreach in Maine’s commercial fishing industry.

by MS. ANN S.N. BACKUS, M.S.Occupational Safety InstructorHarvard School of Public Health

&TRAINING

OUTREACH

Maine’s Commercial Fishing IndustryAccording to preliminary figures from the Maine De-partment of Marine Resources (DMR) and the NationalOceanic and Atmospheric Administration, of the morethan 233 million live pounds of fish landed in 2008 byMaine commercial fishermen, the American lobster ac-counted for 30 percent of the catch, the Atlantic herringfor 28 percent, and the cultured Atlantic salmon fornine percent.

In terms of dollar value, however, the American lobstercatch accounted for 68 percent of the $362 million in-dustry in Maine in 2008, cultured Atlantic salmon ac-counted for 17 percent, and the value of the Atlanticherring catch was only two percent of the total catch.1

High Dollar, High RiskClearly the lobster industry plays a major economicrole in Maine. On the other hand, its economic viabilityand sustainability are of concern. The average price perpound for lobster was at an all-time high of $4.43 in2007 and has dropped each of the succeeding years inspite of (or perhaps because of) major increases in land-ings in 2008 and 2009.2

Fatality rates in the lobster fishery are also of great con-cern. In terms of casualty data, from 1993 to 2010, ac-cording to U.S. Coast Guard First District statistics:

· 29 percent of the deaths were in the trawler indus-try,

· 24 percent were in the lobster fishery,· 6.7 percent were divers.

If we look at deaths by fishery in thelast three years (Table 1) we see that:

· 37 percent were trawler industrydeaths, · 11 percent were lobster fishery deaths, · 19 percent were diver deaths.

Table 1: Fatalities by fishing industry. Data for 2010 as of 2/1/2010.U.S. Coast Guard First District data.

Fishery Extended period: Recent period:1993-2010 data 2007-2010 data

Trawler deaths 29% (49 of 167) 37%(10 of 27)

Lobster deaths 24% (40 of 167) 11% (3 of 27)

Diver deaths 6% (10 of 167) 19% (5 of 27)


Mandated TrainingIn 1995 the Maine DMR supported the apprentice li-cense requirement and apprentice program that be-came effective in 1996. In November 2006, the MaineCommercial Fishing Safety Council recommended thatfishing vessel drill conductor training be part of the ap-prentice program. Under this program, full-time stu-dents and those wishing to become lobstermen (themale is used to describe all in this industry) must com-plete an apprenticeship that requires 1,000 hours of lob-stering over 200 days and successfully complete anaccepted Coast Guard fishing vessel drill conductorcourse and a first aid course.

To date almost 900 apprentices have completed the pro-gram.3 Consequently, those entering the lobster fisheryhave a substantive and practical knowledge of fishingsafety. According to the statistics in table 1, deaths inthe lobster fishery (USCG First District) have been cutfrom 24 percent to 11 percent.

In a parallel effort to es-tablish a more safety-savvy cadre of divetenders for the hand-harvest industry(urchins, scallops, lob-ster), the DMR collabo-rated with the MaineCommercial FishingSafety Council in 2009 tocreate a dive tender ruleand a DMR online div-ing safety course for ten-ders. Under the rule,those seeking a dive ten-der license must pass a test and present current first aidand CPR certifications. As of mid-June 2010, 40 peoplehad been issued dive tender licenses through thisprocess.4

In the most recent three years, there was a 19 percent in-cidence rate of diver deaths recorded in the USCG FirstDistrict. With dive tenders now presumably alert to un-safe diving situations and able to recognize divers indistress, we hope to see a reduction in Maine’s contri-bution to this rate.

Research and OutreachThe Harvard Education and Resource Center (ERC) forOccupational Safety and Health is currently one of thehubs for research and outreach activities that engage

Maine’s fishing industry. In 1999 the Harvard ERClaunched a lobsterman entanglement study along theMaine coast in collaboration with the Centers for Dis-ease Control/National Institute of Occupational Safetyand Health Alaska Field Station in Anchorage, Alaska.After learning that more than 70 percent of Maine lob-stermen interviewed had been caught in trap rope,pinned to the deck, or pulled overboard, we initiatedan outreach effort to reach lobstermen through mail-ings, posters, and presentations.

A second Harvard ERC study focused on indoor airquality in lobstermen’s workshops. It showed they areexposed to respirable particulates, volatile organic com-pounds (VOCs), and polycyclic aromatic hydrocarbons(PAHs) when they scrape, sand, brand, and paint theirstyrofoam lobster buoys, and to endotoxins when theywork with algae-covered rope. These exposures are se-rious risks for the respiratory, cardiovascular, and nerv-ous systems, and the PAHs from branding styrofoambuoys carry a risk of cancer.

Outreachefforts as-sociatedwith thisw o r k -s h o p -based airq u a l i t ystudy in-cluded an u m b e rof articlesin indus-try publi-

cations and discussions at the Harvard School of PublicHealth, a vendor table at fishermen’s forums, and otherindustry events. During these discussions, fishermenreported anecdotally that they are using more latex andlow-VOC paint, wearing respirators more frequently,and working outdoors to reduce their exposure.

In a third major research project, Mary Davis, Ph.D., ofthe Tufts University Department of Urban and Envi-ronmental Policy and Planning, and Ann Backus, M.S.,of Harvard collaborated on a study titled “Safety andCompliance in the Maine Commercial Fishing Indus-try” that was funded by NOAA and the Maine SeaGrant. This study investigated the current level ofsafety preparedness in the industry from the equipmentand training perspectives.

Table 2. Safety training among 259 captains in Maine. Safety ComplianceStudy, Davis and Backus, investigators.

Safety Training <5 Years Ago >5 Years Ago Never

First Aid 24% 42% 34%

CPR 24% 50% 26%

Survival Suit 19% 22% 59%

Life Raft 17% 17% 66%

Drill Conductor 13% 9% 78%

Cold Water 13% 11% 76%

Preliminary statistics show that in generalthe commercial fishing vessels are well out-fitted with safety equipment. However, theseasoned captains had significant trainingdeficiencies. As table 2 shows, only 13 to 24percent of the fishermen interviewed hadcompleted a particular safety course lessthan five years ago. Fifty-nine percent hadnever had survival suit training, and a stag-gering 66 percent had never had life rafttraining.

AdvocacyThe linkages among key players function tomove advocacy and outreach efforts wherethey each need to go—to the law makersand to the fishermen. Throughout 2009 and2010, the Maine Commercial Fishing SafetyCouncil actively followed the progress ofthe Coast Guard Authorization Act in theU.S. House and Senate. The council votedto support H.R. 3619 and the inclusion ofSection 804 from the House Bill in the Sen-ate version of H.R. 3619.

Letters signed by council Chairman ElliotThomas were sent to the Maine and Massa-chusetts House and Senate delegations urg-ing passage of H.R. 3619, including thefishing safety provisions in Section 804.*The council also advocates for parity acrossthe state registered and federally docu-mented vessels so that vessels fishing side–by-side will have the same safetyequipment requirements. Finally, of course,the council fully supports additional train-ing for fishermen.

Future DirectionFishing safety is—and has to be—a joint effort of gov-ernment, industry, and private players. I would like toacknowledge those mentioned here and all others whoare participating in building an infrastructure that willdrive and support a culture of safety in Maine.

About the author: Ms. Ann Backus, M.S., is an instructor in occupational safety at theHarvard School of Public Health and a member of the Maine Commer-


cial Fishing Safety Council. She engages in fishing safety research proj-ects and authors the columns “FISH SAFE” for Commercial Fish-eries News as well as “The Voice of Safety” for The Fishermen’sVoice.

Champion’s Note:*The act that included these provisions was passedand signed into law in October 2010.Endnotes:1. Http://www.maine.gov/dmr/commercialfishing/recentlandings.htm, ac-

cessed June 23, 2010. 2. See www.nmfs.noaa.gov.3. Maine Marine Patrol data.4. Maine Marine Patrol data.

John McMillan and Coast Guard commercial fishing safety examiner PaulSmith-Valley teach escape techniques using an egress trainer at the 2010Fishermen’s Forum, Rockport, Maine. Photo courtesy of Ms. Ann Backus.

SAFETY TRAINING

John McMillan, a long-standing in-structor of fishing safety in Maine andelsewhere, provides safety training inMaine, including the fishing vesseldrill conductor course and first aidtraining.

He reports he has trained 957 ap-prentices and fishermen throughoutcoastal Maine since 2007. McMillannoted, “Many of the students areteenagers, which is a great way to de-velop the safety culture needed inthis industry.”

uals dedicated to protecting life and property at sea,eventually becoming the United States Marine SafetyAssociation (USMSA).

The association has grown from only a handful of peo-ple to 130 members. It represents all segments of the


The United States Marine Safety AssociationFishing vessel safety advocates for more than 25 years.

by MR. ED MCCAULEYPresidentUnited States Marine Safety Association

MR. RICHARD HISCOCKFormer MemberCommercial Fishing Industry Vessel Advisory Committee

In 1983, the U.S. Lifesaving Manufacturers’ Associationwas formed to promote performance, manufacturing,maintenance, service, and training standards for life-saving and emergency rescue equipment. Originallyconceived as a manufacturers’ association, it expandedto include a broader group of companies and individ-

MS. KARI GUDDALPresidentGuddal Enterprises, LLC

MR. TOM THOMPSONExecutive DirectorUnited States Marine Safety Association


During WWII the need for pro-tection from hypothermia be-came apparent as Allied forceswere shot down over the EnglishChannel and torpedoed in thecold North Atlantic. Borrowingon work already begun by theBritish, U.S. and Canadian ex-perts developed lightweight “ex-posure” suits. Production ceased,however, when the war emer-gency was over.

In the late 1960s Gunnar G. Gud-dal, founder of Imperial Interna-tional, a USMSA membercompany, invented the modern-day neoprene immersion suitwith a water-tight zipper.

In the 1970s, two major maritimeaccidents1 and an increase inrecreational boating deaths due tocold water exposure focused newattention on cold water survival.

Today, professional mariners arewell aware of the importance ofthe immersion suit.

Endnote:1. When the F/V Crystal S sank in August of1974 in the Bering Sea, the life raft surfacedupside-down and the crew struggled to re-main on top of it to wait for rescue. Immer-sion suits were credited with keeping theentire crew alive throughout the ordeal de-spite frigid waters and inclement weather.

The second and more unfortunate of the ac-cidents occurred on November 10, 1975, asthe S/S Edmund Fitzgeraldwent down in theGreat Lakes. All 29 crewmembers lost theirlives.

USMSA and the Immersion Suit


At that time, however, there wasno official standard for training.There were also many ports withno access to trained instructors.USMSA partnered with the NewJersey Marine Sciences Consor-tium and the Alaska MarineSafety Education Association todevelop the curriculum and infra-structure required for this train-ing. This effort resulted in acomprehensive document con-taining guidelines, lesson plansfor safety and survival training,and onboard drill scenarios.

With a comprehensive curriculumin place, the next step was to de-velop a network of qualified in-structors and support them withequipment necessary to train drillconductors. Multi-day instructortraining courses were held acrossthe Unites States. AMSEA tookthe lead on instruction. USMSAmembers provided the equip-

ment, personnel, and facilities necessary to conduct thehands-on training. Each course includes life raft infla-tions, pool and open water exercises, in-water immer-sion suit donning, distress flare demonstrations, andextended open water life raft exercises.

About the authors:Mr. Ed McCauley is president of the United States Marine Safety As-sociation. Mr. Richard Hiscock is a long-time safety advocate. He is a former mem-ber of the Commercial Fishing Industry Vessel Advisory Committee andadvisor of the USCG Fishing Vessel Casualty Task Force. He was alsoa member of the senior professional staff on the U.S. House subcom-mittee on Coast Guard and Maritime Transportation.Ms. Kari Guddal is president of Guddal Enterprises, LLC.

Mr. Tom Thompson is executive director of the United States MarineSafety Association.

marine safety industry, including companies involvedwith safety training; the manufacture, maintenance,and promotion of lifesaving and emergency rescue

e q u i p m e n t ;and classifica-tion societiesand individu-als involved inmarine safety.

USMSA andTrainingThe UnitedStates Marine

Safety Association has long been active in facilitatingsafety training for the commercial fishing industry. Theregulations resulting from the Commercial Fishing Ves-sel Safety Act of 1988 required that drills be conductedmonthly aboard fishing vessels by a trained individual.

A history of support for marine safety.

In 1985 the USMSA supported the Coast Guard with a proposal related to the del-egation of its responsibilities regarding factory inspections of life boats and otherlifesaving equipment. USMSA is pleased to note that equipment and marine safetyinspection remains under the purview of the U.S. Coast Guard.

In 1986 the USMSA urged its members to express their support for pending fish-ing vessel safety bills. Vigorous support from members would eventually helppass the Commercial Fishing Industry Vessel Safety Act of 1988.

In 2005, the association organized an international life and fire safety systemsand equipment summit that brought together industry leaders from around theworld. One issue brought to the forefront of this summit was the importance ofdeveloping uniform standards for extended service interval life rafts. The explo-ration of this topic at the summit galvanized the USMSA membership to play anactive role as standards evolved. After many years of hard work, the InternationalMaritime Organization published guidance that helped to fill a gap in the Inter-national Convention for the Safety of Life at Sea (SOLAS), 1974 regulations, whichpreviously lacked any substantial guidance on life raft design and maintenance.

The United States Marine Safety Association


The United States Marine Safety Association5050 Industrial Road Farmingdale, NJ 07727

(732) 751-0102 fax: (732) 751-0508www.usmsa.org


Critical CommunicationUnderstanding cultural factors enhances design and delivery of workplace safety training interventions.

by JEFFREY L. LEVIN, M.D., M.S.P.HUniversity of Texas Health Science Center

KAREN GILMORE, M.P.H.University of Texas Health Science Center

ANN CARRUTH, D.N.S., R.N.Southeastern Louisiana University

The ProblemAccording to U.S. Coast Guard statistics, the USCGEighth District, which encompasses the Gulf Coastfrom Texas to the panhandle of Florida, has the second-

highest level of vessel losses and crew fatalities amongcommercial fishermen.

How Do You Fix That? First, work to understand these fishermen. The makeup

of the commercial fishing population alongthe United States Gulf Coast is diverse, withmany Asian (primarily Vietnamese)shrimpers.

Cultural barriers can get in the way of criticalcommunication and interfere with receptiv-ity to necessary safety training. For example,during early community interactions withVietnamese shrimp fishermen, it came to lightthat many lack basic navigation and commu-nication skills despite many years of experi-ence in the commercial fishing trades. This iscompounded by a language barrier, whichcreates a reluctance to communicate, particu-larly by radio. All of these challenges can leadto hazardous situations on the waterways.

AMANDA WICKMAN, B.S.University of Texas Health Science Center

SARA SHEPHERD, M.A.M.S.University of Texas Health Science Center

GILBERT GALLARDO, A.A.U.S. Coast Guard Eighth DistrictCommercial Fishing Vessel Safety

MATTHEW NONNENMANN, PH.D., C.I.H.University of Texas Health Science Center


A trainer presentsnavigation scenariosin the classroom inVietnamese. All pho-tos courtesy of theSouthwest Center forAgricultural Health,Injury Prevention, andEducation.


To successfully communicate with this seg-ment, one must understand and embraceits cultural norms. Compared to othergroups, the immigration pattern to the U.S.among Vietnamese is more recent, resultingin stronger cultural ties to their heritage.Furthermore, older Vietnamese refugeeshave more problems with language accul-turation than their younger counterparts.Research indicates this group responds bestwhen training is conducted in their nativelanguage by trusted and respected author-ity figures.

How Does This Work?Recognizing these issues early on, theSouthwest Center for Agricultural Health,Injury Prevention, and Education (SW AgCenter), in collaboration with USCG Ma-rine Safety Unit Texas City, added a mod-ule for safety training for Vietnameseshrimp fishermen.

Instructors in the SW Ag Center effort developed typi-cal onboard scenarios that a skilled mariner used to in-struct a small group of fishermen in Vietnamese on avessel bridge. The trainees then practiced the variousskills.

Key skills included signaling with the horn and exe-cuting a “mayday” call. For this skill training, the stu-dents use a model that replicates a vessel’s steeringwheel, speed control, horn, and radio to simulate thebridge of a fishing vessel. While video footage of ap-proaching freighters is projected on a screen, the vessel

captains are instructed by an ex-perienced mariner in Vietnameseregarding how to listen to and sig-nal approaching vessels with thehorn.

Trainees are given a tip card withEnglish and Vietnamese instruc-tions for conducting a radio may-day call. They practice making thecall in English, with emphasis onthe essential elements.

Future DirectionFeedback has been highly favor-able. The project has demonstratedthe importance of considering cul-

tural factors, including language, in the design and de-livery of workplace safety training interventions. It hasincreased acceptance of the USCG as partners in safety,and recognition by individual fisherman of their re-sponsibility to be safe at work. Ongoing meetings withmultiple USCG stakeholders will focus on further pro-gram development.

Mariners practice signaling and communication skills on the bridge of a shrimp vessel.

An experienced Vietnamese freighter captain instructs a fishermanduring the navigation simulation.


About the authors: Jeffrey L. Levin, M.D., M.S.P.H., is professor/chair of OccupationalHealth Sciences at the University of Texas Health Science Center atTyler, and director of the National Institute for Occupational Safety andHealth (NIOSH) Southwest Center for Agricultural Health, InjuryPrevention, and Education.

Karen Gilmore, M.P.H., is a program director for the NIOSH SouthwestCenter for Agricultural Health, Injury Prevention, and Education, lo-cated at the University of Texas Health Science Center at Tyler.

Ann K. Carruth, D.N.S., R.N., is a professor of Nursing and HealthSciences at Southeastern Louisiana University in Hammond, La.

Amanda Wickman, B.S., is the education and outreach coordinator forthe NIOSH Southwest Center for Agricultural Health, Injury Preven-tion, and Education located at the University of Texas Health ScienceCenter at Tyler.

Sara Shepherd, M.A.M.S., is the database coordinator for the Occupa-tional Health Sciences Department at the University of Texas HealthScience Center at Tyler.

Gilbert D. Gallardo, A.A., is Chief Commercial Fishing Industry Ves-sel Safety Examiner for the Prevention Department of U.S. Coast GuardMarine Safety Unit Texas City, Texas.

Matthew Nonnenmann, Ph.D., C.I.H., is an assistant professor of Oc-cupational Health Sciences at the University of Texas Health ScienceCenter at Tyler. He is also deputy director of the NIOSH SouthwestCenter for Agricultural Health,Injury Prevention, and Educa-tion.

Bibliography:A.K. Carruth, J. Levin, K. Gilmore, T.Bui, G. Gallardo, W. Evert, and L.Sealey. “Cultural influences onsafety and health education amongVietnamese fishermen.” Journal ofAgromedicine, 2010; 15:375-385.D.H. Dickey and Q.P. Ellis. “Analy-sis of fishing vessel casualties: a re-view of lost fishing vessels and crewfatalities, 1994-2004.” A report of theUnited States Coast Guard. Wash-ington, D.C.: USCG, Office of Inves-tigation and Analysis, ComplianceAnalysis Division; 2006:1-42.J.L. Levin, K. Gilmore, S. Shepherd,A. Wickman, A. Carruth, J.T. Nal-bone, G. Gallardo, and M. Nonnen-mann. “Factors influencing safetyamong a group of commercial fish-ermen along the Texas Gulf Coast.”Journal of Agromedicine, 2010; 15:363-374.Tran TV. “Language acculturationamong older Vietnamese refugeeadults.” Gerontologist. 1990; 30:94-99.

The laminated “mayday” tip card serves as a tool to help the fish-erman communicate the call over the radio in English.

In an onboard training session presented in Vietnamese, the shrimp fishermen listen respectfullyto an experienced mariner.


I have been helping clients develop safety programssince the early 1990s. Some of my clients had extensiveprograms in place, but many had just bare bones. Ei-ther way, losses continued despite their efforts. Ratherthan starting from scratch, I sought to develop a pro-gram that could be integrated with whatever safetyprogram the client had in place and coined the term“integrated safety.”

The Integrated Safety ProcessThe concept is simple: An effective safety program mustinvolve all levels of management and personnel in acombined effort to identify potential problem areas andresolve them before an incident occurs.

Sounds simple, right? Stating the goal and end result iseasy. Getting there is another matter.

The ABCs of AccidentsBefore we get into the integrated safety concept, weneed to understand the basic elements of an accident.Statistics have shown that accidents are rarely the re-sult of a single event. Take fires, for example. You needthree things to start a fire: an ignition source, fuel, andoxygen.

To put out the fire (or to keep one from breaking out inthe first place) all you need to do is remove one of theseelements. Most other accidents also generally havemultiple elements. If you remove one or more of theseelements, you minimize or eliminate the possibility ofthat accident occurring.

Additionally, accidents usually don’t happen withoutsome forewarning. Casualty and accident data over theyears bears this point out. For most major accidents,there are about 10 minor accidents that preceded it. Ifyou see these early indications and you take timely cor-rective action, you can hopefully prevent the accident.This is the cornerstone of the integrated safety concept.

As an example, let’s say a crewmember walks out ondeck and trips on a machinery part lashed out on deckand he breaks his leg. About 20 other people havetripped over this same obstruction, but without majorinjury. Had the problem been identified in the 20 prioroccurrences and corrective action taken, the 21st

crewmember would not have broken his leg.

The Integrated Safety Action PlanAn integrated safety program is developed with inputfrom management and employees. To be successful thisprogram must have top management, front-line man-agement, and employees buying into and supportingthe plan.

Integrated Safety

A risk reduction program.

by MR. ALAN DUJENSKIAlan R. Dujenski & Associates, Inc.


What Is Safety?

Safety is defined as the state or condition of freedom fromdanger, risk, or injury. A misconception held by many in themaritime industry is that installing safety equipment makesan environment safe. Safety is not equipment—rather, it isa state. Although equipment such as emergency position-indicating radio beacons (EPIRBs) and life rafts are impor-tant, they do nothing to reduce the original problem thatwould require their use.

True safety centers around risk reduction. To be able to re-duce risk, you first need to be able to detect a problem.For this, you need to know what is a problem or a potentialproblem, and then be vigilant for that condition. It is there-fore necessary for all personnel to be alert at all times.


First, the collaborators must identify problems or haz-ards. All the hazards or problems in that particular areaare listed and a systematic approach is then taken to dealwith one area at a time. As an example, we will use a firein the machinery space as our initial “hazard.” After thehazards are identified, collaborators work to identifyways to eliminate or mitigate the hazard. Failing that,they create a contingency plan.

Hazard: Fire in the machinery space.Eliminate the hazard. In some cases the problem can be re-moved. Eliminate oily bilges, remove flammables fromthe space, repair leaking fuel lines.

Mitigate the hazard. Some design changes can mitigate thehazard. Say you have noted that your gauges for the fueltanks are made of plastic tubing. These can easily rup-ture, or if there was a small fire, they could melt, addingfuel to the fire. These could be replaced with gauges con-structed with fire-resistant glass and equipped with flowcheck valves that stop fuel flow should the gauge glassbreak.

Develop a contingency plan. You have identified a hazardthat can’t be removed and can’t be designed out. Theonly other alternative is to have a plan to deal with thepotential problem. An example might be an engine thathas developed excessive oil leakage. You are finishing upthe season and need to schedule an overhaul when youget back. In the meantime, you schedule more frequentchecks on the space and bring a portable fire foam unitaboard for the trip.

Finally, the program needs to be dynamic and amenableto modification when warranted. A program that existsonly in a binder, or that is so constricting as to makechanges difficult, will soon become obsolete and beburied on the shelf with other manuals.

Designing the ProgramOnce you make the decision to pursue integrated safety,you need to design it in stages, starting at the top. Runthrough an exercise of hazard identification and decidewhat to do with the issues. Then do the same thing withfront-line managers (supervisors, masters, chief engi-neers), then the rest of the workforce. For these initialmeetings it is usually best to use an outside facilitator.

In each case, the group is taught to identify the safety is-sues or risks. They are then asked to help decide what todo about them. In subsequent sessions, be sure to involveall levels of management. This creates a team paradigmand facilitates full company buy-in.

These sessions will help you identify practices applicable toyour company that can limit the risks. Your final goalshould be a written program that is straightforward andeasy to use. In many cases, using a checklist will suffice.

You may need to call in a consultant to ensure you meet reg-ulatory requirements. You will have an excellent foundationfor the consultant to assist you in building a final plan that isusable and designed to fit your company.

An Ongoing ProcessOnce you have your final, written integrated safety program,you’d think your work is done, right? Not quite! You’re justbeginning. You must continually evaluate the safety pro-gram, work environment, and employee training needs.

The steps should look something like this:· Ensure all personnel receive training on the integrated

safety program.· Create an “action team” to monitor the program and im-

plement updates and any corrective actions. Ideally theaction team should consist of a master, engineer, deck-hand, port engineer or port captain, and representativesfrom different company vessels.

· Tap an “audit board” made up of a port captain, portengineer, and operations manager to review the actionteam’s efforts and provide the CEO an annual review ofthe past year’s injuries, mishaps, accidents, items ofconcern, and any recommendations for improvement.

About the author:Mr. Alan R. Dujenski is the president of Alan R. Dujenski & Associates, Inc.He graduated from the Coast Guard Academy in 1971, and his Coast Guardmarine safety duties included shipboard engineering, technical plan review, ves-sel inspections, and port operations. Subsequent to his Coast Guard career, heprovided maritime regulatory and safety advice to a major insurance broker andserved as marine superintendent for an offshore oil drilling company.

Why Safety Programs FailManagement is not fully committed. If a safety program does notget full backing from all levels of management, it will never achieveits full potential and is doomed to fail. The insincere attitude makesits way down to the workers.

The program is not a product of all levels of management andcrew. Programs where one of the management staff members or asafety manager or outside third party writes up a safety plan andgives it to the workers usually die an anguishing death. These plansgenerally do not incorporate the practical applications the workersencounter, or they are written in such great detail that they are im-practical to refer to on a regular basis.

Training programs don’t address applicable risk.At times com-panies send their personnel to courses required by a regulatoryagency without analyzing the requirement or researching the course.Such a haphazard approach is like pouring money down the drain.


Commercial fishing vessels in the U.S. are arguably themost complicated vessels of their size. A 45-foot fish-ing vessel can have sophisticated navigation electron-ics; engines; generators; hydraulic systems; freezersystems; storage systems for products; living, eating,

and sleepingquarters for acrew; and, ofcourse, as muchfishing gear aspossible.

In addition, mostvessels leave portwith securedcargo in water-tight compart-ments that are notopened until theyreach the nextport. This is not sowith commercialfishing vessels,which have theunique distinctionof opening theirwatertight spacesto take on “cargo”while out on theocean—the high-est-risk environ-

ment in which to conduct such an activity. It is notsurprising, then, that commercial fishing is listed as oneof the highest-risk occupations in the United States.


Mark and Kelly Klinger troll for salmon in Salisbury Sound, SE Alaska. Many salmon boats arefamily-run fisheries, so children learn to fish and act safely on a vessel from a very youngage. Photo by Ms. Deborah Mercy.


Breaking the Chain

Using risk assessment scores to prevent

fishing vessel casualties.

by MR. JERRY DZUGANExecutive Director

Alaska Marine Safety Education Association


Complete the assessment, assigningeach element a numerical value of 1-5

with 5 being the highest risk. Use this assess-ment to identify high-risk elements and considermethods to reduce risk in those or other elements.

The following situations override the risk assessment, so the vessel SHOULD NOT LEAVE.·· storm forecast·· hull integrity problems·· expired and/or damaged or missing safety/sur-

vival equipment·· power plant(s) and machinery not fully operational·· bait, food, fuel, ice, fishing gear not sufficient for trip

TRAINING Level of safety training of crewClassroom vs. hands-on trainingPrior training from other sourcesMonthly, thorough drills conducted

CREW EXPERIENCE Amount of experience among individual crewDoes crew have substantial fishing/boat expe-rience and skills? Age of crew and level of physical fitnessCG License? Stability training? Drill conductor certified?

OPERATOR EXPERIENCE Does the captain/operator have a backgroundand experience in this type of fishery and thistype of vessel?

LOCATION How remote are the fishing grounds? How far is help if needed from Coast Guardand other resources? What risks are presented by the locations (cur-rents, “blow holes,” distance from shelter incase of rough weather)?

WEATHER How dangerous is the predicted weather orweather typical for this time of year? For this trip? How will this impact bar crossings?

EQUIPMENT Do vessel and crew have proper safety equip-ment such as life raft, immersion suits, EPIRB,personal PFDs for deck work, bilge/fire alarms,etc. and redundancy? Gear within certification? Extra non-required gear such as dewateringpumps? Dockside exam sticker within last year?

COMPLEXITY What is the overall complexity of the fishingoperation? Length of trip, crew fatigue, crew size, complicating variables, size of operational area,economic limitations, competitiveness of fishery?

HULL/GEAR Hull integrity, recent survey/classification, gen-eral condition of hull, gear and machineryRecent changes/weight affecting stability?

ELEMENT ASSESSMENT CRITERIA RISK VALUE

A total score of 8-15 is low-risk. A score of 16-24 requires caution, and 25-40 is high-risk. Use similar score breakdownsif certain elements are given greater weight than others. Identify elements or areas that require special emphasis. To loweroverall risk due to a high-risk category you do not have control over, look for ways to lower risks in another category youdo have control over.

This score sheet was adapted by the Alaska Marine Safety Education Association and refined by the Coast Guard’sCommercial Fishing Industry Vessel Safety Advisory Committee for fishing vessels.

Risk Assessm

ent Score

sheet

FISHIN

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Risk ManagementCommercial fishingvessel casualty reportsoften list one or tworeasons for a vessel’sloss. However, a prob-lem such as “flooding”or “capsizing” doesnot give a completepicture of the chain ofevents that led to theloss. Vessel casualtiesusually occur as a re-sult of widely varyingfactors that may in-clude crew fatigue,vessel maintenance and upgrade history, and fisheriesmanagement regime, along with many other issues.

Additionally, this industry includes hundreds of dif-ferent types of fisheries and vessels. Some fishing ves-sels may fish only in the summer in southern coastalwaters or in the winter in the Bering Sea. They may besingle-handed operations or have a crew of well over

100 people. Therefore a “one-size-fits-all” risk manage-ment program will not be very effective.

To assess risks more systematically and apply methodsto lower risks more precisely, the unique characteristicsof individual fisheries and casualties must be exam-ined. The Alaska Marine Safety Education Association

The spring herring roe fishery in Sitka, Alaska, lasts only a few hours, with about 50fishing vessels participating. It is one of the last large commercial fisheries for herringin Alaska. Photo by Mr. Jerry Dzugan.

Salmon seining usually takes place in areas closeto where salmon are returning to their homestreams. The vessel’s seine skiff pulls the netclosed. Photos by Mr. Jerry Dzugan.

(AMSEA) has identified eight areas that should be ex-amined for every fishery.

Casualty DataAs a first step, it is important to determine in what typeof fisheries the fatalities, injuries, and vessel losses areoccurring. The amount of effort and resources placedin managing risk in fisheries should be proportional tothe risk, as demonstrated by the statistics.

Type of Fishery A description of a fishery should include the typicalnumber of crewmembers, length of trips, and descrip-tion of gear types. It should also address how the prod-uct is stored and processed.

It would also be useful to know the permitting systemsthe fisheries work under. For example, are they open-access permits? Is each vessel held to a catch limit? Ifthere are a limited number of permits, how many exist?Are the permits locally owned?

It is also important to determine under what type offisheries management program the fishery operates.Some management programs encourage a “race tofish” in any weather. Some limit crew size, which canlead to fatigue or cause other unintended consequencesthat increase risk. Fisheries that are either over- orunder-capitalized can also have inherent risks.

Vessel Types and HazardsVessel size, age, layout, and how the gear is operatedcan indicate risks. If the vessel participates in other fish-eries and changes fishing gear, there are implicationsfor stability and other hazards. One can expect certainfisheries that use power blocks and winches will havemore crushing injuries, while hook-and-line fisherieswill have more cut and punctures-type injuries.

Environmental HazardsThe geographic location of a fishery, the season of theyear, the distance offshore, remoteness from rescue re-sources, water temperature, seasonal storm patterns,and predictability all affect risk.

The assessment should also take into considerationnavigational challenges including crossing hazardousbars or transits involving complex navigation, currents,natural hazards, and other traffic.

Subjective HazardsIssues such as operator and crew experience, fatigue,over- or under-capitalization, traditions, attitude, eco-nomics, culture, crew communication, and drugand/or alcohol use all affect risk and should be ex-amined.

Salmon trolling often occurs in the Alaskansummer by solo fishermen or family membersin small vessels. Photos by Mr. Jerry Dzugan.

Safety Requirements and Level of EnforcementBecause safety regulations differ depending on the sizeof the boat and the number of crewmembers, whetherthe vessel is documented or state numbered, tempera-ture of the water, and other factors, the level of safetyrequirements on a vessel will have an effect on risk.

Generally, the larger the vessel and the farther offshoreit works, the greater the safety requirements.

StabilityCasualty reports and statistics should demonstratewhich fisheries are known to have more stability issuesand determine the cause of sta-bility problems in a fishery. Gearhang-ups, icing, downflooding,improper loading, heavyweather, and other factors maybe problems in some fisheries,but not in others. Vessel size andstability requirements and en-forcement will also be factors inassessing risk in a fishery.

ImplementationIt is important to recognize that the risk factors in anindividual fishery can change quickly. Fishing can be

restricted suddenly to protect a resource, the price offuel can soar, the value of product can drop, or a seasonof particularly bad weather can occur.

Vessel owners can take a proactive approach in man-aging the ever-changing world of risk in their fisheries.In most cases, these operators will be the first ones tonotice the changes.

A basic risk assessment score sheet (see sidebar) filledout at the beginning of every season or trip can remindthe operator of changing risk. One of the most usefulaspects of this risk score sheet is that it makes the op-

erator think about everyaspect of the operation ina systemic way. In addi-tion, it allows the opera-tor to decrease overallrisk by making changesin controllable areas.

About the author: Jerry Dzugan is the ExecutiveDirector of the Alaska MarineSafety Education Association.

He is currently the chairman of the Coast Guard’s Commercial FishingIndustry Vessel Safety Advisory Committee. He has been a lifelong ed-ucator and commercially fished Alaskan salmon and halibut.


Contact AMSEA at Alaska Marine Safety Education Association

2924 Halibut Point RoadSitka, Alaska 99835907-747-3287

Fax: 907-747-3259 www.amsea.org



Great Lakes Commercial Fishing

Success through partnerships.

by LCDR WM. ERIK PICKERINGAssistant ChiefU.S. Coast Guard District NineInspections and Investigations Branch

When most people think of commercial fishing, theythink of ocean-going vessels; almost no one thinks ofthe hundreds of commercial fishermen that ply the wa-ters of the Great Lakes. The general public is also prob-ably unaware that many of these fishermen aremembers of the many tribal nations that share the wa-ters with various states bordering the Great Lakes.

In 2001, a group of Great Lakes tribal nations (the BayMills Indian Community, the Sault Ste. Marie Tribe ofChippewa Indians, the Grand Traverse Band of Ottawaand Chippewa Indians, the Little River Band of OttawaIndians, and the Little Traverse Bay Bands of OdawaIndians) formed the Chippewa Ottawa Resource Au-thority (CORA).

Coast Guard InvolvementTo oversee the fisheries management and enforcementof their tribal vessels, the Coast Guard signed memo-randums of agreement (MOA) with the CORA tribesfor the enforcement of federal commercial fishing ves-sel regulations. These MOAs also established guide-lines for cooperation among CORA members and theUSCG concerning the enforcement of laws relating tocommercial fishing vessel safety on waters within theconcurrent jurisdiction of the CORA member tribes andU.S. navigable waters. In addition, two other non-CORA tribes, the Red Cliff Band of the Lake Superior

Chippewa Indians and the Keweenaw Bay IndianCommunity, have also signed MOAs with the CoastGuard.

The MOAs state that the Coast Guard will providetraining to tribal law enforcement officers or other per-sons designated by the tribes and certify them as dock-side examiners. This training is generally in conjunctionwith the commercial fishing vessel examiner courseheld at Training Center Yorktown alongside USCG ac-tive, reserve, civilian, and auxiliary members. Thisraises awareness of tribal issues and how they relate tocommercial fishing vessel safety. Coast Guard SectorSault Ste. Marie is working to implement a localizedversion of the course to train additional tribal law en-forcement personnel, saving travel and per diem costsand overcoming limited class quotas at Yorktown.

The other unique aspect of the MOA is that when aCoast Guard boarding officer observes a violation oftribal commercial fishing vessel regulations, the case isreferred to the tribal court for processing. Should thetribal court not wish to process the case, the CoastGuard retains the right to do so.

CORA exercises many of the same provisions under theMOA as the Coast Guard. If a violation is observed bytribal law enforcement, the case can be turned over to



Coordinated EffortsThe MOA also covers law enforce-ment patrols. Recognizing theunique talents of the Coast Guardand tribal law enforcement, provi-sions are made to not only conductpatrols on their respective water-ways, but also conduct coordinatedpatrols. This approach extends tomarine safety education and out-reach. The Coast Guard will furnishinformation regarding dockside ex-aminations to the tribes, who willhelp to distribute it.

The ResultDistrict Nine sectors and local unitshave been able to leverage theseagreements to expand their abilityto ensure the safety of the commer-cial fisherman. Their efforts seek toprevent personnel and vessel casu-alties through enforcement of fed-eral regulations and outreach andeducation to ensure vessels arecompliant with federal and tribalregulations.

About the author: LCDR Wm. Erik Pickering has served in theU.S. Coast Guard for nearly 20 years. He has

more than 18 years of experience in the marine safety field, primarily inmarine inspections and foreign vessel examinations. LCDR Pickeringholds an MBA from National University, La Jolla, Calif.

Tribal treaty waters and locations of CORA tribes courtesy of theChippewa Ottawa Resource Authority and used with their permission.

the Coast Guard for processing. In addition, they willprovide the Coast Guard with copies of their boardingsand examinations for Coast Guard records and inclu-sion into the MISLE database.


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Health concerns.Anhydrous ammonia is extremely irritating and corrosive.It is classified by the Department of Transportation as apoisonous, non-flammable compressed gas and defined bythe Coast Guard as a “toxic cargo” (46 CFR 154.7).

As a gas, it is an inhalation hazard and can cause breathingdifficulty, coughing, lung injury, and a burning sensationand pain in the eyes and respiration system. As a liquid, itcan cause burns and frostbite if in contact with tissue. If aperson inhales ammonia vapor or has skin or eye contactwith ammonia, call a physician immediately and follow thefirst aid procedures.

For short-term exposure, a 2,500 ppm (0.25%) concentrationof ammonia in air may be fatal within 30 minutes. Ammo-nia has an Occupational Safety and Health Administrationpermissible exposure limit-time weighted average of about50 to 60 ppm, which is the maximum average concentrationof ammonia in air that a worker may be exposed to over thecourse of an eight-hour work shift. It also has a thresholdlimit value-time weight average of 25 ppm set by the Amer-ican Conference of Governmental Industrial Hygienists.This is the time-averaged concentration for a conventionaleight-hour work day and a 40-hour work week, to which itis believed that a worker may be repeatedly exposed for awork life without adverse effect.

Fire or explosion concerns.Ammonia is a fire hazard when in high concentrationsand at high temperature. Presence of oil or other com-bustible vapors increase the fire hazard. In case of fire,water spray can be used to blanket the fire and cool tanks.

What is the Coast Guard doing about it?Ships carrying liquefied compressed ammonia are regu-lated by the Coast Guard in 46 CFR part 154—Safety Stan-dards for Self-Propelled Vessels Carrying Bulk LiquefiedGases. Barges carrying liquefied compressed ammonia areregulated by 46 CFR part 151—Barges Carrying Bulk Liq-uid Hazardous Material Cargoes.

These regulations contain requirements for vessel inspec-tion, test, and certification; vessel and cargo tank designand construction; equipment and materials; operations;and special requirements for specific cargoes.

About the author: Ms. Sara S. Ju is a senior chemical engineer with the Hazardous Mate-rials Standards Division at U.S. Coast Guard headquarters. She is re-sponsible for the Marine Vapor Control Systems Program, includingdeveloping regulations, policies, and guidelines.

What is it?Ammonia (NH3), or anhydrous ammonia, is one of themost commonly produced industrial chemicals in theUnited States. About 80 percent of the ammonia producedby industry is used in agriculture as fertilizer. The rest isused in household and industrial-strength cleaning prod-ucts, as a refrigerant gas, for water purification, and in themanufacture of plastics, explosives, textiles, pesticides,dyes, and other chemicals. It is a colorless gas at ambientconditions. It is poisonous, extremely irritating, corrosive,and pungent. It can also easily dissolve in water to formammonium hydroxide, a caustic solution.

How is it shipped?Bulk anhydrous ammonia is typically shipped as a liquefiedcompressed gas. This state is maintained by applying pres-sure, reducing temperature, or a combination of both. In theU.S., ammonia is transported in pipelines, pressure tankcars, pressure tank trucks, pressure tanks, and refrigeratedbarges. For long-distance marine shipping, ammonia is usu-ally carried in mid-size liquefied petroleum gas (LPG) ships.

Why should I care? Shipping concerns.Liquefied ammonia is usually shipped at a low tempera-ture. LPG ships or barges carrying ammonia are eitherfully refrigerated (FR) or semi-refrigerated (SR). The FRLPG ships have a large cooling capacity and keep the am-monia fully refrigerated at -27oF and a vapor pressurebelow the atmospheric pressure.

SR LPG ships have a less powerful cooling capacity and cankeep the ammonia at the liquefied condition with a tem-perature of -15oF to 5oF and a vapor pressure of 4 to 5 at-mosphere pressure. Because ammonia is poisonous, it isvery important to prevent it from leaking out of its cargotanks. Ships and barges carrying ammonia must have a hullstructure and cargo tank type that can withstand the lowtemperature, high pressure, or both. Additionally, materialfor construction and equipment should be non-corrosivewhen exposed to the liquid and vapor phase of ammonia.

To protect crew from ammonia vapor, cargo tanks shouldbe vented vertically upward at a point; at least 10 feet forbarges, or one-third of breadth or 19.7 feet (whichever isgreater) for ships; above the weather deck or the top of thecargo tank or house located above the weather deck. En-closed spaces containing ammonia cargo tanks must bewell ventilated to prevent accumulation of ammoniavapor. Canister masks or respirators approved for ammo-nia must be carried for each person aboard.

by MS. SARA S. JU , Senior Chemical Engineer, U.S. Coast Guard Hazardous Materials Standards Division

Understanding Anhydrous Ammonia


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In this ongoing feature, we take a close look at recent marine casualties. We explore how these incidents occurred, including any environmental, vessel design, or human

error factors that contributed to each event.

We outline the U.S. Coast Guard marine casualty investigations that followed, describe in detail the lessons learned through them, and indicate any changes in maritime regulations

that occurred as a result of those investigations.

Unless otherwise noted, all information, statistics, graphics, and quotes come from the in-vestigative report. All conclusions are based on information taken from the report.

A regular feature in Proceedings: “Lessons Learned From USCG Casualty Investigations.”


Lessons Learned Lessons Learned


When a ship sinks far from shore and into the obscuredepths of the sea in such a way that it cannot be sal-vaged, nor is there any trace of its ill-fated crew, the taskof unraveling what might have happened to the vesselis all the more daunting and painful. Such was the casein the Gulf of Maine when the F/V Lady Luck, a 52-footsingle diesel stern trawler set out on a cold Januarynight in 2007 for a ground fishing trip. Two young menmanned the vessel, which had departed from Portland,Maine, and was scheduled to arrive two days later in itshome port in Newburyport, Mass.

The 24-year-old master, soon to be married, owned thevessel and had been upgrading it for nearly three years.His 21-year-old deckhand had been in the fishing busi-ness for about a year and a half, and was the father of anewborn baby.1 Both crewmembers separately calledtheir fathers the evening of Wednesday, Jan. 31, 2007, totell them that the weather was rough, but that they wouldbe arriving home Friday. Sadly, however, the master anddeckhand were never heard from again. Shortly before11:00 p.m. that night, the vessel vanished beneath thepounding seas about 12 miles off Cape Elizabeth, Maine.

The CasualtyThe Coast Guard investigation, including an extensiveMarine Safety Center (MSC) analysis into the sinkingof the vessel, was inconclusive. According to the inves-tigation, the Coast Guard believed the most likely causeof the casualty was capsizing due to water on deck orflooding. Following the investigation, the Coast Guardalso believed that the sinking was a very rapid eventthat did not allow the crew time to respond or accesslifesaving gear.

Because the vessel could not be recovered and therewere no eyewitnesses, it was impossible for investiga-tors to determine exactly what may have occurred onthe ship when it sank. Both crewmembers’ bodies werealso never recovered, and the men were presumeddead. The vessel’s last known vessel monitoring system(VMS) position was at 10:03 p.m. on Jan. 31, followedfour hours later at 2:00 a.m. on Feb. 1 by an emergencyposition-indicating radio beacon (EPIRB) signal. Thevessel’s EPIRB was located within 48 hours of the ship’sdisappearance, and when the ship itself was found onthe ocean floor at a depth of more than 500 feet aboutone month later, it was not feasible to salvage it so as tothoroughly evaluate its physical condition.

The Coast Guard and the Marine Safety Center reliedon available evidence, including footage from a remote-operated vehicle (ROV), and later conducted computer-aided evaluations of the vessel’s stability characteristicsto analyze different scenarios as to the most likely causeof the casualty. The ROV revealed no catastrophic dam-age to the vessel’s hull or superstructure. It also pro-vided images of the life raft, which was deployed butstill attached to the cradle, which indicated that thepainter may have fouled, that there was a failure of theweak link that should have freed the raft, or that theweak link was improperly installed.

Because investigators could not determine the exactcause of the sinking, they studied a number of potentialcauses, including the possibility of flooding and cap-sizing due to a collision with another vessel. The CoastGuard also relied on results from the MSC stabilityevaluation and its use of a computer model of the ves-

Lost at SeaA small fishing trawler’s sudden sinking and loss of its young crew leave questions unanswered.

by MS. DAISY R. KHALIFATechnical Writer


Lessons Learned Lessons Learned

sel to demonstrate these possible causes. In-vestigators concurrently analyzed the per-formance of the vessel’s lifesavingequipment—in particular the apparent fail-ure of the life raft’s weak link to release theraft from the vessel.

Timeline of EventsThe master and deckhand had only mar-ginal success with shrimping on their firstday out in the early hours of Jan. 30, 2007.They cut their initial fishing trip short, re-turning late that morning to Portland Har-bor to re-rig to a larger net size. The masterdrove from Portland to Newburyport thatsame afternoon to retrieve the larger net. They wouldset out the next day for some ground fishing south ofPlatt’s Bank in the Gulf of Maine.

By 7:00 p.m. on Jan. 31, the vessel was underway car-rying an estimated 1,000 gallons of fuel and eight tonsof ice aboard. The first mate had not worked for 36hours, and had celebrated his birthday the night before.His father said he witnessed the first mate drink onebeer after midnight.

Heading outbound that evening, the vessel passed theinbound F/V Jubilee near Spring Point Light in Port-land Harbor, and the master of the Jubilee stated thatthe Lady Luck’s port, starboard, and masthead lightswere not energized. The Jubilee’smaster said he hailedthe Lady Luck twice by radio to alert the crew about thelights, but he did not receive a response and did not seethe vessel energize its lights after the call.

At 7:45 p.m., the master spoke with his father and saideverything seemed fine, and at 9:30 p.m.—one hour be-fore the vessel was believed to have sunk—the deck-hand contacted his family, stating it was a little roughand that he would behome Friday. He alsosaid during his callthat the master wasbelow in the forwardberthing area, butwhether he wassleeping or not couldnot be confirmed.

Search and RescueThe investigationprovides the VMSpositions of the ves-

sel from around 7:00 p.m. to its last known position at10:03 p.m. as the fishing trawler made its way throughthe Gulf of Maine. Four hours elapsed between theship’s last known VMS position at 10:00 p.m. and theEPIRB first alert, which came at 2:01 a.m.

Upon getting the beacon’s electronic signal, the DistrictOne command center notified Coast Guard SectorNorthern New England. Sector Northern New Englandissued an urgent marine information broadcast for thevessel, and a search and rescue mission ensued. Dur-ing the Coast Guard’s search and rescue effort, no dis-tress calls were heard from the crew, there were noflares seen in the vicinity of the vessel, and the vessel’slife raft was never located. During the search and res-cue operations, the Coast Guard located an oil slick anda small debris field.

At 9:04 a.m. on Feb. 2, a smallboat from Coast GuardCutter Seneca found the casualty vessel’s EPIRB. TheEPIRB was found in the automatic position, indicatingthat neither the master nor deckhand manually activatedit, but that it had self-deployed during the sinking. The

search and res-cue mission wassuspended thatsame day.

Several weekslater, on March13, Coast GuardSector NorthernNew Englandenlisted a pri-vate contractorto provideequipment and

Vessel’s charted track line.All graphics USCG. LADY LUCK

trackline

ROV view of the life raft.



technicians for an ROV to find and visually survey thevessel in the vicinity of the location where the EPIRBwas discovered. Using the Coast Guard Cutter MarcusHanna as the staging platform, Coast Guard investiga-tors and contractors analyzed the casualty from theocean floor in the Gulf of Maine, where the ROV foundthe vessel 12 miles offshore in approximately 530 feet ofwater.

ROV FindingsThe ROV operation provided investigators and MarineSafety Center analysts the raw data they would needto conduct a comprehensive analysis of the casualty.Through video and photographs taken of the vessel inits position on the ocean floor, investigators observedthe vessel resting on its port side, with all of its win-dows intact and the hull in much the same conditionas shown in pictures of the ship before the accident.

The rail around the port to starboard bow was intact,and there was a small indent on the starboard quarter.The fishing gear was stowed, and the outriggers werein the “up” position. The ROV video revealed that theforward watertight door leading to the forwardberthing of the vessel was open. According to the ship’sowner, that door would normally be kept closed while

underway, though investi-gators and the ship’s ownerspeculated that the doormay have been used toabandon ship or it sprangopen due to air pressure asthe vessel sank. The ROVfootage also showed thatthe watertight door at therear of the pilothouse ap-peared to be closed, as didthe starboard side pilot-house door.

The boat was equippedwith three freeing ports fordrainage on each side of thework deck, and the ROVvideo indicated that two ofthe three freeing ports onthe starboard side wereclosed. The ROV videocould not view the freeingports on the port side. Theinvestigation report assertsthat closed freeing ports

may have prevented water on deck from quickly drain-ing, and therefore may have impacted stability.

The life raft was observed deployed and inflated withthe sea painter still attached to the cradle. The ROVfootage showed the inflated life raft lying about 40 feetin front of the bow on the ocean floor. From this obser-vation investigators ascertained that the life raft de-ployed as designed but the sea painter never separatedfrom the cradle. The ROV could not determine theweak link configuration or whether the painter fouled.

Vessel CharacteristicsThe young master of the casualty vessel was the son ofthe resident agent and manager of the company thatowned it. The master, who was the ship’s primary op-erator, was instrumental in overseeing about $100,000worth of upgrades to the 22-year-old vessel, includingnew rigging and electronics since the vessel was ac-quired by the company in April 2004.

For the most part, the condition of the vessel was up todate. The Coast Guard casualty investigation re-searched the ship’s history as far back as 1997 to recordsfrom the boat’s previous owners to better understandthe ship’s condition. They learned, for example, that the

previous owner had installed two net reels on a steelpipe “A” frame aft on the work deck—features anddata that would need to be factored into stability eval-uations and computer modeling.

The last Coast Guard boarding of the vessel in Decem-ber 2006 found that all the safety equipment was onboard, and the boarding team conducted a high waterbilge alarm test, verifying that the bilge alarm was inplace and functional. During this visit, the Coast Guardindicated that the vessel’s EPIRB had expired, but thecrew re-registered the EPIRB as indicated by the newregistration sticker on the beacon when it was recov-

ered after the sinking. During the December boarding,the Coast Guard noted that as per a previous CoastGuard survey in September 2006, the watertight scuttlecover to the lazarette was corroded.

A fishing vessel safety decal was issued to the ship inNovember 2005. Though it was an uninspected com-mercial fishing vessel and not required to hold a cer-tificate of inspection from the Coast Guard, the vessel’sowner took part in the voluntary Commercial FishingVessel Safety (CFVS) Program. The vessel received thesafety decal following a voluntary safety exam in whichthe fishing boat was found to be in compliance with allapplicable CFVS regulations. The last servicing of thelife raft was completed in October 2006.

MSC Stability InvestigationA vessel stability test was not performed on the fishingtrawler. At 52.3 feet in length, the vessel did not need tomeet stability requirements for commercial fishing ves-sels, as per the requirements of Title 46 of the Code ofFederal Regulations, Part 28, “Requirements for Com-mercial Fishing Industry Vessels,” which applies to ves-sels 79 feet and greater in length.

Following the casualty, it was important to evaluate thevessel’s stability characteristics. Marine investigatorssought the technical assistance of the Coast Guard’sMSC. Because the ship was unsalvageable and therewas limited raw data available, the team was only ableto provide a general qualitative analysis based on theboat’s configuration and the weather conditions. TheMSC stability evaluation used the requirements of 46CFR 28.570 as a benchmark, even though the vessel didnot have to meet stability requirements for commercialfishing vessels. Their study, using a computer-gener-ated model of the ship based on rough vessel data, in-

dicated that the small fishing trawler lackedstrong righting energy in a regulatory com-parison to the requirements of 46 CFR28.570.

The issue of stability requirements loomedlarge following the loss of the vessel and itstwo crewmembers. Just one week before,another stern trawler, the F/V Lady of Grace,sank in 50 feet of water in Nantucket Sound,and all four crewmembers died. Severe iceaccumulation caused that vessel to sud-denly capsize, and because her length was75.8 feet—just shy of the 79-foot regulatorylength—the Lady of Grace also did not have

to meet stability requirements set forth by Title 46 of theCode of Federal Regulations.

The MSC evaluation shed light on a number of othervessel characteristics that helped illustrate possiblecauses of the sudden sinking in the Gulf of Maine.Using their computer model of the vessel, the MSCteam noted that even limited quantities of water ondeck impacted the model’s stability. They observed thatflooding of the engine room resulted in a slow reduc-tion of the model’s righting arm. Given the issue withthe lazarette, the MSC investigators explored lazaretteflooding, observing the following:

“In the study, flooding through the rudder post (asmentioned in the 1997 survey) was analyzed. Furtheron a September 15, 2006 boarding by CGC Jefferson Is-land, the boarding officer noticed the vessel rode low inthe water and the lazarette cover appeared corroded.Although not documented as a potential factor, thequartering seas and demands on the steering system ina quartering sea made the scenario pertinent. Floodingthe lazarette induced trim, which after immersion ofthe deck, quickly reduced the model’s stability. Themodel capsized beyond the 50 percent flooding point if

Photo of open door.



the bulwark was submerged for any reason. At 90-100percent flooding, the aft main deck of the model wassubmerged.”

Possible Causes: Collision, Flooding, CapsizingThe painstaking MSC stability analysis allowed marineinvestigators and the MSC team to analyze three po-tential causes of the casualty. Presented as opinionsbased on findings of fact, possible causes that were ex-plored in the investigation included a ship strike or col-lision, flooding, and capsizing.

The notion that a ship strike or collision could havecaused the vessel to sink was considered the most un-likely cause. Coast Guard Sector Northern New Eng-land compiled a list of deep-draft vessels potentially inthe area of the fishing vessel, and they determined thatthere were no large vessels close enough to the smalltrawler within the specified time frame. Furthermore,the vessels closest to the fishing boat were inspected bythe Coast Guard and found to have no damage to thehull that would have resulted from a collision. Thesunken vessel’s owner advised the Coast Guard he be-lieved there had been a large vessel inthe vicinity, though this vessel wasnever identified. The Coast Guardqueried all commercial facilities in thePortland, Portsmouth, and Searsport,Maine areas, and verified that all largevessels (including tugs and barges) wereat least 12 nautical miles away. Lastly,the ROV footage indicated there was nodamage to the vessel that would be con-sistent with a collision, while noting thatabout 40 feet of the port side could notbe viewed.

The MSC evaluation into flooding as apotential cause of the sinking providedtwo possible scenarios. Investigators de-termined that flooding in the engineroom would have been gradual enough for crew to re-

spond, and they did not consider this to bea likely cause of the sinking. With regard tolazarette flooding, investigators consideredthe 2004 and 2006 survey reports that stated,respectively, the hatch was not watertight,and that the lazarette cover may have beencorroded. MSC investigators observedthrough their modeling that lazarette flood-ing would lead to more rapid and less de-tectable flooding. Thus, investigators did not

rule out lazarette flooding, stating it could be supportedbased on past survey information as well as a 1997 sur-vey report that highlighted a rudder post packing leak.The investigation report did state, however, that therewas no more recent information available aboutwhether the lazarette hatch was or was not watertight.

The Coast Guard investigation asserts that capsizingdue to a rapid loss of stability was the most likely causeof the sinking. The MSC evaluation supports the as-sumption that capsizing due to water on deck or a com-bination of water on deck with a flooding lazarettewould leave the vessel prone to rapid capsizing, basedon the response of the computer model. Moreover, theinvestigation states that a rapid capsizing supportedthe lack of distress signals from the crew.

Investigators considered vessel modifications made bythe vessel’s previous owner, including two net reels onher stern, but the weight and placement of the modifi-cations were not known. According to photographs ofthe vessel from a few weeks earlier, it was possible that

it might have had low freeboard compared to other ves-sels. The previous owner stated his opinion about the

Starboard bow of downed vessel.

ROV view of freeing ports.

vessel’s stability, indicating that it was not “snappy” asfar as righting was concerned, meaning the vesselrighted itself slower than other vessels.

Investigators also considered the eight tons of ice in theholds, which could have shifted and contributed to in-stability if the boards in the hold were not in place(which they were not able to determine). Lastly, inves-tigators considered ice accumulations caused by seaspray and freezing temperatures, which would addtopside weight to the vessel, thus causing instability.The Coast Guard determined that the vessel did not ex-perience icing in the three and half hours it was under-way. This assumption was based on testimonies offisherman who were also underway that night whosaid icing conditions were not severe enough to impactstability; rather, the ice was only “a little skim coat.”

The MSC analysis focused on degradation of stabilityfrom water on deck. Based on the computer model,only limited amounts of water were needed to nega-tively affect stability. The vessel’s course exposed it toa quartering sea, making it susceptible to shipping seasfrom the stern, and if any freeing ports were closed—which they believed to be the case—water on deckwould cause a free surface effect, causing the vessel tofurther lose stability.

Life Raft Deployment and Lifesaving EquipmentThe deployment of the life raft was another issue toarise from the sinking of the fishing trawler. Based onROV footage, the vessel’s life raft deployed properly.However, the sea painter appeared to be attached to thecradle, which prevented the raft from separating fromthe sinking vessel. The ROV operation observed the liferaft 40 feet forward of the bow of the vessel and still at-tached to the location of the weak link.

The Coast Guard investigation indicated that investi-gators could only ascertain from the video that the liferaft deployed as designed but the sea painter never sep-arated from the vessel, and it remained unknown if thelife raft surfaced at any time, but only that the life raftwas not released from the vessel.

Investigators explored the question of the four-hourdelay between the vessel’s last known VMS positionand the emergency transmission from the EPIRB. Thereport noted that the VMS is possibly misunderstoodas a means for search and rescue, when its purpose is asa living marine resource tool used by the NationalOceanic and Atmospheric Administration (NOAA) tomonitor fishing activity. However, as with the case of

the sunken fishing vessel, the VMS track was used dur-ing the search and rescue mission. Furthermore, whilethe EPIRB automatically deployed and transmitted, in-vestigators speculated that the EPIRB, because of thefour-hour delay in sending a signal after the last VMStransmission, may have been caught in the rigging ofthe vessel as it tried to float free, or it was trappedunder the vessel, or that its release may not haveworked properly when initially submerged.

Likely CausesThe Coast Guard investigation cited two primary fac-tors that contributed to the sinking of the vessel on Jan.31, 2007:

1. The vessel sank in a rapid event that prevented thecrew from issuing a distress call, and the life raft’sweak link assembly failed to release the raft fromthe vessel, bringing it to the ocean floor. Investiga-tors believe the sinking was caused by a combina-tion of rough seas, possible flooding in thelazarette, and water on deck that led to instability.

2. With regard to the life raft, investigators stated thatthe painter may have been fouled as the vesselsank, which may explain the painter’s non-release,and raises visibility of the criticality of life raft andbuoyant apparatus weak links and their proper in-stallation.

Recommendations and Lessons LearnedThe recommendations and actions that emerged fromthe casualty investigation focused principally on stabil-ity requirements and on raising awareness about safetyequipment. The first of three recommendations calledfor the Coast Guard to expedite publishing the stabilitystandards for commercial fishing vessels less than 79feet in length. The office of the Commandant concurredwith the recommendation, noting that the Coast Guardis considering new regulations to establish stability stan-dards for vessels between 50 and 79 feet in length.

The second recommendation advised that there be con-tinued outreach within the fishing community aboutproper installation of safety gear on fishing vessels. Thereport stressed the importance of educating ship own-ers about proper weak link installation and to educatelife raft owners on the purpose of the weak link and liferaft deployment theories. The Commandant’s officeconcurred and said the agency would continue to im-plement a strategy for educating members of the com-mercial fishing industry.



The final recommendation called for a study to exam-ine the feasibility of re-engineering weak link locationsfrom the raft cradle to inside the life raft’s tamper-proofcanister for Coast Guard-approved life rafts. The Com-mandant’s office did not concur with the third recom-mendation, stating “The weak link is an installationrequirement and, in practice, is usually part of the hy-drostatic release unit (HRU), not the life raft.” TheCommandant’s office said, instead, the Coast Guardwould update the Navigation and Vessel InspectionCircular (NVIC) 4-86, and said the revised NVIC wouldtake into account new disposable HRU designs and il-lustrate correct—and incorrect—HRU installations.

Finally, investigators provided comments on the analy-sis of the casualty that underscored concerns about thedeployment of lifesaving equipment. Without hardfacts to support their opinions, investigators said theybelieved one or more of the following were factors inthe failure of the life raft to separate from the sinkingvessel: · The hydrostatic release unit, if one existed, did not

work. · The painter was secured directly to the cradle, by-

passing the weak link. · The life raft became tangled up in fishing gear as

the vessel sank, preventing it from inflating untilit was too deep for the inflation systems to over-come hydrostatic pressure.

The fact that the life raft remained tethered to the ves-sel because of a design flaw resonated with the public

and within the commercial fishing community, wherea fair amount of speculation as to exactly what wentwrong with the raft continues. Many in the industrytook away from the casualty an important lessonlearned with regard to checking weak links before get-ting underway on another fishing trip.2

The vessel casualty in the Gulf of Maine in which thelives of two young men were taken came only oneweek after the tragic sinking and loss of four crewmem-bers on the F/V Lady of Grace in Nantucket Sound. Bothcasualties bore striking similarities, characterized by in-stability and rapid sinking in the rough January seasoff the coast of New England. The urgency of publish-ing new stability requirements, conducting industryoutreach on safety equipment and the purpose of VMSmonitoring, and gaining a better understanding of liferaft weak link installation surely hit home within thecommercial fishing industry.

Acknowledgments:Proceedings gratefully acknowledges the support of CAPT David Fish, Mr.Charles Barbee, LCDR Paul Rudick, LT Stephen Thompson, and Mr. KenOlsen, U.S. Coast Guard Office of Investigations and Casualty Analysis.

About the author: Ms. Daisy Khalifa is a freelance writer who has worked in the commu-nications field for nearly 20 years. She has written feature and businessarticles for a variety of publications covering law, technology, telecom-munications, real estate, architecture, and history.

Endnotes:1. David Abel and Kay Lazar, “Another Fishing Vessel Feared Lost,” Boston

Globe, February 2, 2007.2. Commercial Fisheries News, “Lady Luck: Life Raft Weak Link Failed,” Vol.

35, Number 7.

Prepared by NMC Engineering Examination Team

NauticalEngineeringQueries

QuestionsNauticalEngineeringQueries

1. Coast Guard regulations (46 CFR) concerning shutoff valves located inside fuel oil tanks state that the valves __________.

A. shall be arranged for local controlB. must be made of steelC. must be power-operatedD. may be made of cast iron

2. The distance between a generator and its load is 100 feet. What would be the approximate total voltage drop across atwo-wire supply cable if the current was 5.5 amperes and the resistance of the wire was 2.525 ohms per 1,000 feet?

A. 0.5 voltsB. 1.38 voltsC. 1.90 voltsD. 2.77 volts

3. In a closed feed and condensate system, the drain from the second-stage air ejector returns directly to the __________.

A. auxiliary condenserB. loop sealC. atmospheric drain tankD. de-aerating feed tank

4. Which of the turbocharging systems listed operates with the least average back pressure in the exhaust manifold?

A. constant volumeB. constant-pressureC. pulse-pressureD. radial flow



NauticalDeckQueries

NauticalDeckQueries

uestions

Prepared by NMC Deck Examination Team

Q1. A vessel of not more than 65 feet in length must have a collision bulkhead if it carries more than_______.

A. 6 passengersB. 12 passengersC. 36 passengersD. 49 passengers

2. How many portable fire extinguishers are required to be located inside the machinery spaces of a small pas-senger vessel?

A. None are required.B. One B-I, C-I is required.C. One B-II, C-II is required.D. One B-II is required.

3. Which statement is true concerning the placard entitled “Discharge of Oil Prohibited”?

A. It is required on all vessels.B. It may be located in a conspicuous place in the wheelhouse.C. It may be located at the bilge and ballast pump control station.D. All of the above.

4. A cargo of canned foodstuffs is packed in cartons. Each carton is 36 cubic feet and weighs 380 pounds. Whatis the stowage factor of the cargo?

A. 9.5B. 62C. 212 D. 237


Answers

Engineering

1. A. shall be arranged for Incorrect answer. See explanation for choice “D”. Valves installed in the inside of fuel tanks must bearranged for remote control.

B. must be made of steel Incorrect answer. 46 CFR 56.50-60(D)(2) states: “Valves for local control outside the tanks must be madeof steel, ductile cast iron ASTM A 395, or a ductile nonferrous alloy having a melting point above 1,700°F.”

C. must be power-operated Incorrect answer. See explanation for choice “D”. Shutoff valves located inside the fuel tank are to bearranged for remote control only, and are not required to be power-operated.

D. may be made of cast iron Correct answer. 46 CFR 56.50-60(d)(2) states: “If valves are installed on the inside of the tank, they maybe made of cast iron and arranged for remote control only.”

2. A. 0.5 volts Incorrect answer. Choice “D” is the only correct answer. B. 1.38 volts Incorrect answer. Choice “D” is the only correct answer.C. 1.90 volts Incorrect answer. Choice “D” is the only correct answer. D. 2.77 volts Correct answer. Solution is as follows:

Resistance of wire per foot: 2.525 Ω ÷ 1000 feet = 0.002525 Ω / ftTotal resistance of 200 feet of wire: 200 ft (0.002525 Ω / ft) = 0.505 ΩVoltage drop across wire cable: V = (I)(R) = 5.5 amperes(0.505 Ω) = 2.77 volts

3. Note: A steam jet ejector is a type of air ejector used to remove air and other non-condensable gases from a condenser. The ejector has no moving parts, and receives the en-ergy to operate from pressurized steam that creates a “pumping action” as it passes through the ejector. Air ejectors are generally multi-stage, consisting of severalejector elements arranged in series.

A. auxiliary condenser Incorrect answer. In a two-stage air ejector unit, saturated non-condensable gases removed from the con-denser are initially drawn into the suction chamber of the first-stage air ejector. The gases become en-trained in the first-stage ejector steam jet, and the mixture is discharged into the shell of a heat exchangercalled the intercondenser. Condensate discharged by the condensate pump passes through the intercon-denser tubes and condenses the mixture in the shell. Water formed from the condensing mixture is re-turned to the condenser via a “U”-shaped loop seal.

B. loop seal Incorrect answer. See explanation for choice “A.” To prevent air and other non-condensable gases from theintercondenser being drawn back into the condenser, the intercondenser drain line is fitted with a water-sealed “U”-shaped loop.

C. atmospheric drain tank Correct answer. Gases remaining in the intercondenser shell are drawn into the suction chamber of the sec-ond-stage ejector and become entrained in a second jet of steam. The steam and gas mixture is then dis-charged into the shell of a heat exchanger called the aftercondenser. Condensate discharged by thecondensate pump passes through the aftercondenser tubes and condenses the mixture in the shell. Waterformed from the condensing mixture is under a slight positive pressure and drains by gravity to the at-mospheric drain tank. Non-condensable gases are vented to the atmosphere.

D. de-aerating feed tank Incorrect answer. The de-aerating feed tank’s operating pressure prevents its use as a direct return for thelow-pressure drains of the air ejector.

4. Note: In a diesel engine, the two methods utilized for transmitting the energy in the exhaust gases to drive the turbocharger are the constant-pressure system and the pulsesystem.

A. constant volume Incorrect answer. Constant volume is the term used to describe combustion in a gasoline engine. Refer to the “OttoCycle” for spark-ignition engines.

B. constant-pressure Incorrect answer. In the constant-pressure system, the exhaust gases from the individual cylinders are dischargedinto a large common manifold. Since the pressure in the manifold tends to be the average of the cylinder outputs,the turbocharger is provided with a fairly constant-pressure gas supply.

C. pulse-pressure Correct answer. The pulse system permits operation of the turbocharger with the least average back pressure in theexhaust manifold. With the pulse system, the exhaust gases from each cylinder or group of cylinders are admitteddirectly to the gas turbine through a short exhaust pipe. As a result, the flow of gases to the turbocharger “pulsates.”The turbocharger is designed to utilize both the velocity and pressure energy in the pulsating gases.

D. radial flow Incorrect answer. Radial flow is the term used to describe the direction of gas flow in a turbocharger.

local control


nswersADeck

1. A. 6 passengers Incorrect answer. B. 12 passengers Incorrect answer. C. 36 passengers Incorrect answer. D. 49 passengers Correct answer. As per 46 CFR 179.210, a vessel of not more than 19.8 meters (65 feet) in length

must have a collision bulkhead if it:1) Carries more than 49 passengers;2) Operates on exposed waters;3) Is of more than 12.2 meters (40 feet) in length and operates on partially protected

waters; or4) Is constructed of wood on or after March 11, 2001, and operates in cold water.

2. A. None are required. Correct answer. None are required inside the machinery space. A minimum of one portable fire extinguisher is required, of CG class B-II, C-II, to be located just outside the machinery space exit. See 46 CFR 181.500, Table 181.500(a).

B. One B-I, C-I is required. Incorrect answer.C. One B-II, C-II is required. Incorrect answer.D. One B-II is required. Incorrect answer.

3. A. It is required on all vessels. Incorrect answer. B. It may be located in a conspicuous Incorrect answer.

place in the wheelhouse.C. It may be located at the bilge Correct answer. As per 33 CFR 155.450, a ship (except a ship of less than 26

and ballast pump control station. feet in length) must have a placard of at least five by eight inches made of durable material fixed in a conspicuous place in each machinery space, or atthe bilge and ballast pump control station, stating the following: “Dischargeof Oil Prohibited.”

D. All of the above. Incorrect answer.

4. A. 9.5 Incorrect answer. B. 62 Incorrect answer. C. 212 Correct answer. The formula for stowage factor computation is cubic capacity divided by weight in long tons.

1 long ton is equal to 2240 lbs. The weight of the cargo is given in pounds and must be converted to long tons.380lbs / 2240lbs = .1696 long tonsStowage factor = 36 cubic feet / .1696 long tons = 212.26.

D. 237 Incorrect answer.

COMMANDANT (DCO-84)ATTN PROCEEDINGS US COAST GUARD2100 2ND STREET SW STOP 7681WASHINGTON DC 20593-7681

Official BusinessPenalty for Private Use, $300

FORWARDING SERVICE REQUESTED

PRSRT STD

POSTAGE & FEES PAID

U.S. COAST GUARD

PERMIT NO.G-157

Personal Flotation Device

Immersion Suit

Dockside Examination

Navigation Safety

Safety Drills

Firefighting

Load Limits

Life Raft

Fish Safe

Personal Flotation Device

Immersion Suit

Dockside Examination

Navigation Safety

Safety Drills

Firefighting

Load Limits

Life Raft

Fish Safe

Documents

Proceedings - United States Coast Guard