6

Safety and Survival

An accident occurs and a fishing vessel begins taking on water; within minutes it lists and capsizes, and the captain and crew end up in the water. In another accident, a boat rolls in heavy seas and a crewman on deck loses his footing on the slippery surface. In an instant he is overboard. These are typical tragic scenarios in which fishermen have died because they were not wearing protective clothing, available life jackets, or survival suits. In all but a few incidents, fishermen in correctly worn immersion suits survived their ordeal. The continuing yet preventable loss of life among fishermen calls for a special assessment to identify ways that equipment can improve survival.

The committee considered equipment availability, testing, approval, labeling, performance, and effectiveness; use patterns; federal requirements; consumer issues; survival system information and literature; and equipment developments in Canada. Personal protection devices receive extended treatment because of the high loss of life that results when they are not used. The assessment presented in this chapter reflects the committee's experience; discussions with representatives of the U.S. Coast Guard (USCG), Canadian Coast Guard (CCG), Underwriters Laboratories, and survival equipment manufacturers; and regional assessments. Discussions and explanations of technical issues are provided in Appendix I.

DATA AVAILABILITY

Although there is considerable information about survival equipment, it is not comprehensive. Data concerning the performance of safety and survival



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FISHING VESSEL SAFETY: Blueprint for a National Program 6 Safety and Survival An accident occurs and a fishing vessel begins taking on water; within minutes it lists and capsizes, and the captain and crew end up in the water. In another accident, a boat rolls in heavy seas and a crewman on deck loses his footing on the slippery surface. In an instant he is overboard. These are typical tragic scenarios in which fishermen have died because they were not wearing protective clothing, available life jackets, or survival suits. In all but a few incidents, fishermen in correctly worn immersion suits survived their ordeal. The continuing yet preventable loss of life among fishermen calls for a special assessment to identify ways that equipment can improve survival. The committee considered equipment availability, testing, approval, labeling, performance, and effectiveness; use patterns; federal requirements; consumer issues; survival system information and literature; and equipment developments in Canada. Personal protection devices receive extended treatment because of the high loss of life that results when they are not used. The assessment presented in this chapter reflects the committee's experience; discussions with representatives of the U.S. Coast Guard (USCG), Canadian Coast Guard (CCG), Underwriters Laboratories, and survival equipment manufacturers; and regional assessments. Discussions and explanations of technical issues are provided in Appendix I. DATA AVAILABILITY Although there is considerable information about survival equipment, it is not comprehensive. Data concerning the performance of safety and survival

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FISHING VESSEL SAFETY: Blueprint for a National Program equipment were not available from the principal sources used for this study—the Coast Guard's main casualty (CASMAIN) and search and rescue (SAR) data bases—but they were useful in identifying the types and frequencies of events that might necessitate the use of safety and survival equipment. SAR data were also useful in identifying the geographic density of these events. The most notorious fishing vessel disasters have been systematically evaluated by the National Transportation Safety Board (NTSB). NTSB accident reports include information on availability, use, and effectiveness of safety equipment and lifesaving devices, but are available only for major casualties. Experience from disasters at sea and hypothermia research have established the need for buoyant devices to prevent drowning and protection against hypothermia. These needs are well publicized by the government, fishing industry trade associations, periodicals, educators and vocational trainers, manufacturers and retailers of lifesaving equipment, and even a phone company (National Council of Fishing Vessel Safety and Insurance [NCFVSI], 1989; NYNEX Information Resources Company, 1989; Texas Shoreline, 1989; Hollin and Middleton, 1989; Sabella, 1986; USCG, 1986b; Shafer and Beemer, 1984; Finley 1982a,b; Johnson, 1982; Myers, 1982). The effectiveness of survival equipment in providing emergency buoyancy, maintaining dry environments, and conserving body heat has been evaluated under controlled conditions (Offshore Research Focus, 1989; Steinman and Kubilis, 1986; Finley, 1982b; Johnson, 1982). THE NEED FOR SURVIVAL EQUIPMENT Survival Situations The data presented in Chapter 3 indicate that the fishing industry has a high incidence of sudden catastrophic loss of vessels, which frequently leads to fatalities. Although these events occur throughout the industry, some geographic areas are more prone to total loss of vessels and fatalities, which needs to be considered in forming safety strategies. Exposure to vessel- and life-threatening situations occurs year round, whether fishermen operate offshore, inshore, or on inland waters, and regardless of vessel size. Thus, all fishermen need suitable survival training and equipment. This information has not been effectively communicated to fishermen. Effects of Exposure The effects of hypothermia and exposure are generally well understood. Research and experience have demonstrated that staying out of the water and conserving body heat are very important to survival (see Mercy, 1990; Zanoni, 1988; Alaska Fisherman's Journal, 1988b; Finley, 1982a; Johnson, 1982).

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FISHING VESSEL SAFETY: Blueprint for a National Program Survivors from the fishing vessel Rainy Dawn huddle with crabpots after their vessel sank near Kodiak, Alaska, September 8, 1989. (Andy Hall, Kodiak Daily Mirror) For example, a 1986 Coast Guard research project examined the effects of protective clothing and survivor location after abandonment on body core and skin temperatures. Significant differences were found between bodily cooling rates in the water and on rescue platforms: “Survivors maintain higher skin temperatures and slower cooling rates out of the water, even when exposed to continuous wind, spray, and waves, than when they remain immersed in rough seas” (Steinman and Kubilis, 1986). Manufacturers have incorporated this information into innovative designs for life rafts and protective clothing. EVIDENCE OF SURVIVAL EQUIPMENT INADEQUACIES The Fishermen's Response Some vessel owners, operators, and crewmen, particularly those operating offshore in northern climates, have voluntarily invested in immersion suits and float coats with fixed or inflatable flotation (USCG, 1989b; see Hamilton, 1989; Johnson, 1982). Inshore and midshore (within approximately 20-25 nautical miles of the coast) fishermen appear less inclined to perceive the need for immersion suits, citing proximity to shore and shorter running times to and from the fishing grounds as factors that lessen their exposure to life-threatening events (see McCay et al., 1989). Protective clothing, such as Coast Guard-approved, Type V antiexposure coveralls (i.e., deck and work suits), is infrequently provided by fleet or vessel owners. Such clothing is not used routinely while working on deck or in skiffs or tenders, although their use appears to be increasing aboard some large factory trawlers. The most commonly used outerwear is oilskins and similar waterproof rainwear, which do not have inherent flotation or thermal protection. Owners and captains

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FISHING VESSEL SAFETY: Blueprint for a National Program sometimes view falls overboard and the failure to recover personnel as the result of crew member carelessness or inattention, overlooking nonuse of lifesaving equipment as a contributing factor. Many fishermen consider their profession to be overregulated and are not receptive to requirements for costly equipment that does not contribute to their ability to catch fish (Correspondence on proposed rulemaking to U.S. Coast Guard, 1989; McCay et al., 1989). This attitude is particularly strong in fisheries with management practices that have significantly altered fishermen's fishing opportunities and negatively affected their income. Such perceptions were prevalent in comments from fishermen responding to the Coast Guard's Notice of Proposed Rulemaking, announcing prospective regulations for survival equipment prescribed by the Commercial Fishing Industry Vessel Safety Act of 1988 (CFIVSA). At the same time, the committee observed that fishermen routinely invest in items they consider important, such as the newest electronic navigation and fish-finding equipment (see Dewees and Hawkes, 1988; Levine and McCay, 1987). Proficiency with Survival Equipment Lifesaving equipment must be used quickly and correctly in order to be effective. It is not unusual for entire crews to be lost, even though their vessels are equipped with immersion suits and life rafts, or for immersion suits to be recovered still in their carrying bags or only partially deployed after an accident, suggesting someone unsuccessfully attempted to don the suit (see NTSB, 1989e). Such incidents occurred during this study (Alaska Fisherman's Journal, 1989b; Degener, 1989a,b): In November 1989, a 72-foot lobster boat equipped with seven immersion suits, a Coast Guard-approved life raft, VHF-FM and HF radios, a cellular telephone, and two emergency position-indicating radio beacons (EPIRBs) was reported overdue from offshore lobstering in Hudson Canyon (southeast of Long Island, New York). A signal from one of the vessel's EPIRBs was detected by a satellite and received by an Air Force ground station before it was reported overdue, starting an intensive air and surface search. Despite recovery of the EPIRB on the fourth day, multiple flare sightings, and sighting of what looked like a life raft below the surface, five fishermen and all other lifesaving equipment on board were not recovered (Booth, 1990; USCG, unpublished reports, 1989). In December 1989, a loaded clammer that had been in radio contact with the owner ashore disappeared in 6- to 8-foot seas during a snow squall near Cape May, New Jersey. A partially submerged, uninflated life raft and a partially deployed immersion suit were recovered. The vessel was located in 40 feet of water several days later. Three fishermen were lost (Degener, 1989a,b; Degener and Strawley, 1989).

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FISHING VESSEL SAFETY: Blueprint for a National Program Similar cases suggest that while many fishermen understand the potential benefits of lifesaving devices and have them aboard, many do not know how to properly use them (see Matsen, 1990; Nalder, 1990; Johnson, 1982). Familiarity with survival equipment was critical to recovery or loss of personnel during life-threatening situations. Some captains conduct abandon-ship drills and hands-on practice with safety and survival equipment (see Alaska Fisherman's Journal, 1989a), but the practice is not widespread (see Matsen, 1990; Nalder, 1990; Alaska Fisherman's Journal, 1988a,b; Miller, 1985). Although many fishermen have had to use lifesaving devices, many others are not familiar with them. A study of marine safety in New Jersey found that almost half of the fishermen surveyed had never been in the water wearing a personal flotation device (PFD), only 34 percent had been in the water with an immersion suit on, and only 17 percent had ever inflated or used a life raft. Costs of repacking and the regional structure of the life raft inspection and repacking industry contributed to limited familiarity with life rafts (McCay et al., 1989). Although no similar research was found for other regions, the committee believes that the New Jersey findings generally reflect the state of familiarity with lifesaving equipment throughout the industry. Survival equipment that was properly maintained, accessible, employed in time, and used properly by fishermen in good physical condition extended survival times sufficiently to permit rescue and recovery in almost all of the incidents reviewed (Alaska Fisherman's Journal, 1989a, 1988b; Zimmerman, 1989; NTSB, 1987, 1989e; Pollack, 1989; Johnson, 1982; Finley, 1982b; Matsen, 1990). Early deployment decisions provided the time necessary to overcome problems donning equipment and to conduct orderly abandon-ship procedures, including safe egress into life rafts, skiffs, or the water (McCay et al., 1989; NTSB, 1989a,b,c,d; Walter and Morani, 1986; Miller, 1985). Where any one of these factors was not present, the effectiveness of survival equipment was diminished or negated (Rostad, 1989b; Poggie and Pollnac, 1988; Castle, 1988; Alaska Fisherman's Journal, 1988b; Miller, 1985; Finley, 1982b; Johnson, 1982). Despite the growing availability of survival equipment aboard many vessels beyond basic PFD requirements, anecdotal information indicates that it is often stowed out of sight or neglected until it is urgently needed (Nixon and Fairfield, 1986; see Matsen, 1990). This practice contributes to equipment failure. Some inferior equipment has been prone to failure (see Appendix I). Improper maintenance, unfamiliarity with use, and delays in employing the equipment played a significant role when available survival equipment did not perform to its advertised potential (NTSB, 1987, 1989a,b). Frequent problems affecting survival equipment use include inoperable zippers on immersion suits and improperly mounted or inaccessible life rafts (Matsen, 1990; Nixon and Fairfield, 1986; NTSB 1988b, 1989a,b,e; see Alaska Fisherman's Journal, 1989b). These problems are aggravated if fishermen have to learn how to use

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FISHING VESSEL SAFETY: Blueprint for a National Program them during an emergency or do not have time to correctly deploy or correct problems with equipment before catastrophic loss of their vessel (Matsen, 1990; Rostad, 1989b; Alaska Fishermen's Journal, 1988b; NTSB, 1988b, 1989a,b,e; Nixon and Fairfield, 1986; Sullivan, 1984b; Johnson, 1982; Poggie and Pollnac, 1988). Technical Issues Safety and survival equipment required by federal regulations administered by the Department of Transportation (DOT) and its affiliated agencies must be “Coast Guard-approved,” but not all equipment sold is approved (see NTSB, 1989a,c). How much nonapproved survival equipment is in use cannot be ascertained from existing data, but anecdotal references indicate that approved protective clothing is not widely used on deck (see Nixon and Fairfield, 1986). According to fishermen, the reason they do not buy or use Coast Guard-approved lifesaving devices such as antiexposure coveralls is that they are bulky, restrict their mobility on deck, or are not suited for wear in hot weather. In numerous falls overboard and sudden vessel losses, whatever the fisherman was wearing was his or her sole protection (Walker, 1990a; NCFVSI, 1989; Alaska Fisherman's Journal, 1988b; Rostad, 1989b; Zanoni, 1988; NTSB, 1989e, 1987; Dobravec, 1987; Nixon and Fairfield, 1986; Finley, 1982a; Gleason, 1982; Johnson, 1982; see Walker, 1990b). Nonapproved Inflatable PFDs Nonapproved inflatable equipment sold for recreational and commercial users is designed for convenience, such as color-coordinated jackets with yoke (“Mae West”)-style air bladders hidden between the outer shell and inner liner. This equipment usually has a single air chamber, may not inflate to minimum Coast Guard standards for commercial use, may not have automatic activation devices to assist someone who is unconscious or disabled, and provides little protection against hypothermia. However, that they do not interfere with mobility is a strong selling point for deck work, and they are designed to be put on quickly in an emergency. The Coast Guard is studying “in-service reliability” for continuous-wear inflatable PFDs. However, there is no market research by manufacturers that might indicate whether enough fishermen would purchase this gear so that it could be developed and sold at reasonable prices. Some nonapproved inflatable PFDs, worksuits, and immersion suits are designed with removable air bladders or flotation liners to facilitate cleaning. Outer shells can be worn without flotation liners attached. Devices of this type do not satisfy current Coast Guard standards.

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FISHING VESSEL SAFETY: Blueprint for a National Program Emergency Position-Indicating Radio Beacons EPIRBs are electronic devices used to communicate distress to rescuers. A category 1, self-activating, 406-MHz satellite EPIRB incorporating updated technology was required on most uninspected fishing vessels operating on the high seas in May 1990 by federal regulations, with phase-in provisions. The conversion to the newer EPIRBs is motivated by the unreliability of the older classes of emergency beacons (Embler, undated; Lazarus, 1990b; Lemon, 1990b; The Westcoast Fisherman, 1989a; Pawlowski, 1987). The improved 406-MHz EPIRB is expected to greatly reduce the unresolved alert rate (98 percent of all alerts in 1989, which includes signals from aircraft, were unresolved [Coast Guard data]), providing sufficient signal reliability to justify immediate launching of rescue aircraft. The Coast Guard believes this will greatly improve rescue service to mariners in distress while concurrently reducing false alerts (Lemon, 1990b). There are several issues of concern to fishermen. Category 1 EPIRBs are expensive, $1,700 or more. Category 2 EPIRBs have the same capabilities as category 1 EPIRBs but are manually activated and cost less. They may be carried as supplemental equipment, as may older style class B and C EPIRBs, which are still useful for homing purposes (see Commercial Fishing Industry Vessel Advisory Committee [CFIVAC], 1989; see NTSB, 1987, 1989a,b,c,d). They may be carried in lieu of a category 1 EPIRB in small, open vessels that do not have galleys or berthing facilities (Federal Register, 1990). Some fishermen who invested in the earlier models are irritated at having to purchase another EPIRB. They are also concerned that the costly new ones will be tempting targets for thieves (McCay et al., 1989). Similar concerns were expressed to the CFIVAC concerning life rafts. In New England, several high-quality, “free-floating” life rafts were stolen from their racks in 1989. Category 1, 2, and 3 satellite EPIRBs were intended to be registered with the National Oceanic and Atmospheric Administration (NOAA). Each comes with a postcard form for voluntary registration. Mandatory registration was not adopted by the Federal Communications Commission (FCC). Voluntary registration of EPIRBs and life raft serial numbers is being considered by the Coast Guard. Another issue is whether self-activating EPIRBs will work properly when used aboard small boats that are manufactured to stay afloat when swamped or capsized (C. Bond, personal communication, 1990). However impressive this new technology, the end result may still be a search for bodies if the EPIRBs are not installed or maintained properly, or fishermen do not wear protective clothing or have access to a life raft to keep them alive until help arrives. Incremental implementation of safety initiatives, no matter how well intended, makes it difficult to ascertain their economic impact and overall contribution to improved safety. Even with conversion to

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FISHING VESSEL SAFETY: Blueprint for a National Program the new EPIRBs, the absence of suitable protective deckwear leaves a significant gap with regard to the full range of equipment needed to enhance survival. The Impact of Changing Technology Fishermen, especially those with small-scale operations, often find it difficult to remain current on changes in technology. Many find it difficult to compare the relative value of equipment similar in appearance and function. Manufacturers and retailers confuse buyers by attaching Coast Guard-approved accessories to nonapproved protective clothing, failing to distinguish recreational and commercially approved devices in their promotional materials, including lifesaving devices approved only for recreational use in industrial catalogs, selling survival equipment not approved by the U.S. Coast Guard, and making misleading references to Coast Guard approval status (e.g., “not USCG-categorized”). Promotional literature sometimes encourages the use of nonapproved in lieu of approved equipment. For example, one manufacturer's promotional literature attributes the following quote to a Coast Guard technical authority: “If these garments work for your application, then you should seriously consider them. Protection you wear is much better than approved devices you keep under a seat or a locker.” Except for special requirements for commercial hybrid PFDs and immersion suits, and pamphlets for dual recreational-commercial-use PFDs, pamphlets, manuals, videotapes, or other instruction aids for safety and survival equipment have not been required or approved by the Coast Guard for use aboard uninspected commercial vessels. Except for basic information of varying thoroughness about products, such materials are not usually provided by manufacturers with this equipment. Thus, some fishermen don't have a sufficient frame of reference for determining what is good, what is not, what will satisfy their safety needs within their budgets, and what will satisfy existing and prospective Coast Guard requirements (see Alaska Fisherman's Journal, 1989a; NTSB, 1987). Fishermen who have participated in safety or survival training programs using a variety of gear appear better prepared to assess the relative value of lifesaving equipment. Even then, some of them choose not to purchase or use certain equipment. Some fishermen are delaying purchasing decisions until the Coast Guard issues its final regulations under the CFIVSA. Others cite infrequent encounters with hazardous conditions, inshore operating areas, costs, and limited onboard storage space (see McCay et al., 1989; NTSB, 1988a). The underlying reasons that fishermen don't carry the latest lifesaving gear are complex. Research in this area is limited, but suggests that technology adoption is related to economic advantages, perceived risk, tradition, long-established or inflexible work habits, and simplicity of use. The research further suggests

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FISHING VESSEL SAFETY: Blueprint for a National Program that varied individual attitudes and perceptions, technological advances, innovations, fisheries, and economic circumstances require a situational approach to implementing strategies requiring adoption of new technology (Levine and McCay, 1987; Dewees and Hawkes, 1988). Gaps in Survival Equipment Protective Deckwear Over 61 percent of all fatalities recorded by the Coast Guard between 1982 and 1987 were fishermen who fell into the water or disappeared for unknown reasons. Most of them probably were not wearing lifesaving equipment or protective clothing, or their vessels were suddenly overwhelmed by catastrophic events. The reasons for not wearing existing equipment have some merit. The inherent flotation in most work suits is bulky, and use of work suits containing flotation devices is impractical for the manual work conducted aboard small vessels. Fishermen routinely use rainwear that is practical and convenient, but practical protective clothing that is also convenient to wear and offers full-time lifesaving protection is not widely available on the U.S. market. Some gear that is available (such as inflatable flotation coats) has not been submitted to the Coast Guard for approval. The CCG's fishing vessel safety study found that a special work suit for fishermen was needed in lieu of the more traditional “keyhole”-type life jackets (CCG, 1987). Canadian standards would improve thermal protection while maintaining flotation capability, without impairing mobility during normal work (Canadian General Standards Board, 1989). The new standard is specifically intended to result in an attractive and affordable alternative to commonly worn rainwear. Regulations requiring work suits meeting the new standard were scheduled to be in place by the end of 1990. The Canadian standard permits either a one- or two-piece system; a two-piece work suit meeting the standard is currently being marketed (promotional materials). The U.S. Coast Guard has an approved standard for two-piece wet suits for special applications. This provides a precedent for considering approval of a two-piece fisherman's work suit should manufacturers choose to seek formal Coast Guard approval. Survival Platforms U.S. fishermen have expressed considerable concern over the need to equip vessels operating inshore with life rafts, especially where they typically operate in sight of land. However, SAR data demonstrate that all fishermen, including those working inshore and on inland waters in coastal regions, are exposed to life-threatening situations to a larger degree than many acknowledge. Storage space aboard a small vessel can be extremely limited, so highly portable life

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FISHING VESSEL SAFETY: Blueprint for a National Program rafts or survival platforms suitable for small fishing vessels merit consideration. The U.S. Coast Guard is developing proposed rules in this regard. As part of the Canadian mandate to improve fishing vessel safety, the CCG Ship Safety Office is also overseeing development of a prototype coastal life raft especially designed for small fishing vessels. The prototype is still in early stages (see Appendix I). It would be prudent to monitor the results of this project, as well as experience with the new fishermen's work suit system, for potential application aboard U.S. fishing vessels. STRATEGIES FOR ADDRESSING SURVIVAL PROBLEMS Major survival problems uncovered during this study include: inadequate protective clothing suitable for routine use on the deck of a fishing vessel, inadequate or insufficient survival equipment, inadequate routine use of protective clothing, weaknesses in knowledge and practical skills in maintaining and using survival equipment, and weaknesses in timely decision making to employ survival equipment. Most survival problems can be addressed as either a personnel- or vessel-related issue, with the exception of suitable protective clothing for use on the deck of a fishing vessel. Correcting this problem could be approached as a research and development project leading to suitable standards and prototype equipment and subsequent marketing of a commercial product. The committee has identified three survival-specific safety-improvement alternatives (the sequential numbering begun in Chapter 3 continues) as follows. Alternative 23: Require Manufacturers to Provide Installation, Maintenance, and Use Instructions This alternative would expand the Coast Guard's existing requirements for instructional materials for survival equipment to include materials specifically designed for fishermen. Both written materials and, in most instances, instructional videotapes could be required. They would provide basic technical and performance information, maintenance instructions, and installation, activation, donning, and other instructions. Although not a substitute for practical training, videotapes could provide a way to convey important information about survival equipment, including a demonstration of actual use. Alternative 24: Develop and Require Carriage of Fishing-Industry-Specific Survival Equipment This alternative envisions an approach like that taken by the Canadian

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FISHING VESSEL SAFETY: Blueprint for a National Program government, which has developed a standard for a work suit for the fishing industry, has worked with the manufacturers of lifesaving equipment to bring the suit to market, and is establishing regulations requiring these work suits aboard each commercial fishing vessel in sufficient number for all aboard. Fishermen, as a rule, do not wear protective clothing with flotation or thermal protection, or clothing, including headgear, designed to guard against occupational hazards. The usual complaint is that the available protective clothing is difficult, inconvenient, or impractical to wear while working on a fishing vessel. It is also true that some fishermen do not wear protective clothing regardless of how well designed and constructed it is. There is an urgent need for protective, convenient-to-wear gear. In this alternative, the U.S. Coast Guard could develop parallel standards for a work suit, inflatable PFDs, and similar equipment and, if necessary, fund prototype development to bring this equipment to market. The Occupational Safety and Health Administration (OSHA) and the Coast Guard, in consultation with the commercial fishing industry, could jointly develop personal workplace safety equipment suited for the fishing industry. Implementation issues include accepting prototype development as a Coast Guard or OSHA responsibility, and funding. Alternative 25: Prohibit Use of Survival Equipment That Is Not Coast Guard-Approved This alternative envisions that only equipment approved by the Coast Guard would be permitted for carriage aboard commercial fishing vessels. The logic is that because this equipment must meet strict standards, the probability that it will work correctly on demand would be greater than that for nonapproved equipment, for which there is no Coast Guard oversight during development and manufacture. This alternative, if adopted, would necessarily have to follow development of a full range of suitable survival equipment convenient for use aboard commercial fishing vessels. This would be necessary so that levels of protection available through certain conveniently used equipment not bearing Coast Guard approval, yet used by some fishermen, will not be lost. The fishing industry as a market segment may not be sufficient by itself to support this alternative. Prior to implementation, the benefits and costs would have to be carefully analyzed to ascertain the effects on development and marketing of survival equipment. SUMMARY The problems associated with survival equipment are that the equipment is not available, not used at all, not used in time, or not used properly or fails to perform as intended. Nonuse of PFDs was frequently associated with

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FISHING VESSEL SAFETY: Blueprint for a National Program man-overboard fatalities. Fishermen throughout the industry do not ordinarily wear lifesaving devices of any type while working on deck, either during transits to and from the fishing grounds or while fishing. Fishermen operating in environmental conditions where exposure is a major factor usually wear some type of protective clothing. However, protective clothing with thermal or inflatable protection that is designed for convenient wear in the fishermen's workplace has been developed and marketed in Canada. This equipment, as of August 1990, has not been submitted for U.S. Coast Guard approval. Other nonapproved safety and survival equipment designed for special purposes or convenience of the wearer is available. Equipment not approved by the Coast Guard may be carried aboard uninspected vessels as optional equipment. The quality of nonapproved safety and survival equipment is highly variable. The effectiveness of this equipment in survival situations is not known. Safety improvement alternatives (continued from preceding chapters) that could be employed are: require manufacturers to provide installation, maintenance, and use instructions, develop and require carriage of fishing-industry-specific survival equipment, and prohibit use of survival equipment that is not Coast Guard-approved.