APPENDIX

I

Survival and Emergency Equipment: Technical Analysis

This appendix provides a technical analysis of basic survival and emergency equipment issues as they pertain to the commercial fishing industry. The analysis is based principally on interviews with Coast Guard and Underwriter Laboratories (UL) staff with functional responsibilities for safety and survival equipment.

EQUIPMENT REQUIREMENTS

Survival equipment required by federal regulations prior to July 1990 varied by size of vessel, operating area, nature of employment or use, and personnel complement of vessel. Table I-1 summarizes safety and survival equipment required aboard uninspected fishing vessels. At a minimum, all uninspected fishing vessels must carry one readily accessible, wearable personal flotation device (PFD) of the appropriate type and size for each person on board. A prescribed number of fire extinguishers and certain other equipment must also be carried. Visual distress signals are not required. All equipment must be installed, accessible, or worn, as appropriate, according to Coast Guard regulations and specifications for approved equipment. Lifesaving devices that are not Coast Guard-approved may be carried aboard vessels to augment that which is required. Life rafts and VHF-FM portable radios are not required by the Coast Guard as survival equipment but may be carried aboard uninspected fishing vessels as additional gear (see McCay et al., 1989; National Transportation Safety Board [NTSB], 1987). It is also noted that basic safety equipment items such as protective headwear, flexible wire mesh gloves, and high-traction



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FISHING VESSEL SAFETY: Blueprint for a National Program APPENDIX I Survival and Emergency Equipment: Technical Analysis This appendix provides a technical analysis of basic survival and emergency equipment issues as they pertain to the commercial fishing industry. The analysis is based principally on interviews with Coast Guard and Underwriter Laboratories (UL) staff with functional responsibilities for safety and survival equipment. EQUIPMENT REQUIREMENTS Survival equipment required by federal regulations prior to July 1990 varied by size of vessel, operating area, nature of employment or use, and personnel complement of vessel. Table I-1 summarizes safety and survival equipment required aboard uninspected fishing vessels. At a minimum, all uninspected fishing vessels must carry one readily accessible, wearable personal flotation device (PFD) of the appropriate type and size for each person on board. A prescribed number of fire extinguishers and certain other equipment must also be carried. Visual distress signals are not required. All equipment must be installed, accessible, or worn, as appropriate, according to Coast Guard regulations and specifications for approved equipment. Lifesaving devices that are not Coast Guard-approved may be carried aboard vessels to augment that which is required. Life rafts and VHF-FM portable radios are not required by the Coast Guard as survival equipment but may be carried aboard uninspected fishing vessels as additional gear (see McCay et al., 1989; National Transportation Safety Board [NTSB], 1987). It is also noted that basic safety equipment items such as protective headwear, flexible wire mesh gloves, and high-traction

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FISHING VESSEL SAFETY: Blueprint for a National Program TABLE I-1 Federal Safety and Survival Equipment Requirements for Uninspected Fishing Vessels in Effect July 1990 Required Survival Equipment1 Under 26 Ft 26-39 Ft 40 Ft & Longer Life Preservers/PFDs2 Type I/II/III Type I/II/III Type I Type V Antiexposure Coveralls3 No No No Exposure (Survival, Immersion) Suit2 No No No PFD Light4 Yes Yes Yes Type V Wet Suit (Diver Style)3 No No No Life Rafts No No No Lifeboats No No No Ring Life Buoy No Yes Yes Life Floats No No No EPIRBs5 Yes Yes Yes Visual Distress Signals6 No No No VHF-FM radios7 No No No Fire Extinguisher Yes Yes Yes First Aid Kit No No No Notes: 1Consult pertinent 33 and 46 CFR subchapters and product labels for specific federal requirements, product descriptions, and special provisions and instructions for usage. 2An exposure suit or commercial Hybrid Type V PFD meeting criteria specified in 46 CFR Part 25 for commercial vessels may be substituted for a required life preserver, buoyant vest, or marine buoyant device. 3Not required but may, if worn, be used to satisfy the requirement for Type I/II/III devices aboard uninspected vessels under 40 feet long. 4Required for ocean, coastwise, and Great Lakes voyages. 5A 406-MHz EPIRB with automatic activating devices is required aboard all uninspected fishing vessels on or after May 17, 1990, when these vessels operate on the high seas (generally considered as outside of 3 nautical miles from shore). Within certian constraints specified by the Federal Communications Commission, older Type A EPIRBs are grandfathered until August 1, 1991. Vessels without galleys or berthing facilities were exempt pending action on a proposed rule allowing a manual in lieu of an automatic device. 6Required for recreational vessels but not for uninspected commercial vessels. 7There is no requirement for portable VHF-FM radios as safety or survival equipment. waterproof footwear are not required aboard uninspected fishing vessels by federal regulations and are not in widespread voluntary use (Nixon and Fairfield, 1986). Ongoing Coast Guard rulemaking under authority and direction of the Commercial Fishing Industry Vessel Safety Act of 1988 (CFIVSA) will add or expand requirements for survival equipment including life rafts and, above a prescribed latitude, immersion suits (Federal Register, 1990). During a meeting of the Commercial Fishing Industry Vessel Advisory Committee (CFIVAC) in Seattle, Washington, during October 1989, it was stated that some manufacturers had not achieved favorable economic returns when they surged to produce immersion suits to meet earlier Coast Guard rulemaking requiring them aboard certain inspected vessels (CFIVAC, 1989). Manufacturers were reported to have no economic incentive for surging production to meet similar requirements that

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FISHING VESSEL SAFETY: Blueprint for a National Program may be applied to the fishing industry. Regardless of the validity of the statements before CFIVAC, phasing of new equipment requirements must be consistent with manufacturing capability. Coast Guard-Approved Equipment Formal approval normally requires manufacture to Coast Guard standards and testing by accepted independent laboratories, although the Coast Guard has occasionally approved equipment in advance of formal standards in order to meet special needs. Approvals typically take several months, although several years is sometimes required to complete the process if a manufacturer experiences difficulty in meeting requirements. To satisfy Coast Guard equipment requirements, there is no intermediate Coast Guard designation analogous to “patent pending.” Survival equipment is either Coast Guard-approved or not approved. Coast Guard construction and performance standards applicable to approval of prototype safety and survival equipment are extensive and exacting. It is important to note that for PFDs, the Coast Guard emphasizes safety of the recreational boating public, which comprises the principal market segment for this equipment. The agency attempts to minimize the opportunity for recreational boaters go inadvertently defeat equipment design. For example, flotation material must be fixed to the device rather than removable. This policy does not preclude the Coast Guard from approving two-piece systems as long as each component meets all other applicable criteria. The same standards also apply to basic personal flotation equipment that is required aboard most uninspected fishing vessels. Promising policy and technological advances in Canada have resulted in adoption of standards for special-purpose, two-piece work suit systems specifically designed for use aboard Canadian commercial fishing vessels. This standard potentially could be adapted for use in the United States. A summary of Canadian fishing industry safety activities is presented in Appendix C. Use of Equipment Not Approved by the Coast Guard Equipment for which a manufacturer has requested but not received Coast Guard approval may not be carried aboard a vessel in place of required Coast Guard-approved equipment. Likewise, the Coast Guard does not accept as approved any item acquired for use before it grants an approval to a product and the appropriate label is affixed by the manufacturer as an element of product construction. Catalogs offering Coast Guard-approved equipment are required by Coast Guard and UL guidelines to be consistent with use constraints. However, manufacturers are not prohibited from advertising that equipment has been submitted

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FISHING VESSEL SAFETY: Blueprint for a National Program for approval, a common practice in catalogs and promotional material. The Coast Guard has occasionally intervened with some manufacturers to motivate better catalog representation of approval status and usage criteria for lifesaving equipment. Use of nonapproved equipment is permitted aboard uninspected fishing vessels as long as the required Coast Guard-approved equipment is also carried as prescribed by regulations. Performance of nonapproved equipment varies greatly (see Castle, 1988; National Transportation Safety Board, 1989a). Coast Guard technical personnel report that effectiveness may vary among comparable types of Coast Guard-approved equipment, but each item must fully satisfy the agency's standards. Equipment Costs Survival equipment costs range from reasonable to expensive. Actual costs depend on equipment type and nature. Basic PFDs, fire extinguishers, and visual distress signals are inexpensive, whereas a small, covered life raft or emergency position-indicating radio beacon (EPIRB) can cost well over $1,000. For example, extremely portable, lightweight, Coast Guard-approved, covered life rafts (“valise packs”), about the size of a large backpack, are available for use as optional lifesaving equipment on small, uninspected vessels. This equipment is expensive, typically $2,400 to $5,000. EQUIPMENT AVAILABILITY A wide variety of lifesaving equipment is available for use by operators and crews of uninspected fishing vessels. Table I-2 lists general categories of survival and emergency equipment and availability of Coast Guard-approved equipment in each category. In some cases, various items within categories bear dual Coast Guard approvals to satisfy carriage requirements for both recreational and commercial vessels. Applicable regulations and labeling on each item must be consulted to determine whether it satisfies regulations for the vessel on which it is used. Personal Flotation Devices The five types of Coast Guard-approved PFDs are summarized in Table I-3. Nearly all Coast Guard-approved PFDs, including work or deck suits (antiexposure coveralls) and immersion/exposure (survival) suits, require inherent, permanently fixed flotation. Inherent flotation material adds bulk. Some manufacturers have reduced impacts to mobility through design modifications. For example, Type III devices are usually designed for convenience, such as the well-known “float” coats. Under Coast Guard standards, approved Type III PFDs are not required to hold the face of an unconscious wearer clear of

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FISHING VESSEL SAFETY: Blueprint for a National Program TABLE I-2 Safety and Survival Equipment Availability Type of Equipment CG-Approved Available Non-CG-Approved Available Personal Flotation Devices (PFDs)1,2 Yes Yes Antiexposure Coverall (Deck Suit, Work Suit) Yes Yes Immersion Suit (Exposure Suit, Survival Suit) Yes Yes Hybrid PFDs3 No Yes Inflatable PFDs4 No Yes Wet Suit5 No Yes Ring Buoys Yes Yes Life Floats Yes6 Yes Life Rafts Yes Yes EPIRBs Yes6 No Visual Distress Signals Yes Yes VHF-FM Radios No Yes Fire Extinguisher Yes Yes First Aid Kit No No Yes Notes: 1Available in a wide variety of types and styles. 2Coast Guard (CG)-approved immersion suits and Type V lifesaving devices are not available for small children and infants. Type III lifesaving devices are available for children 30 pounds in weight or greater. 3Hybrid PFDs combine inherent flotation and air chambers. Coast Guard-approved hybrids are available for use aboard recreational vessels. No hybrid types have been submitted for Coast Guard approval for use aboard commercial vessels. 4No inflatable lifesaving devices with dual air chambers and automatic inflating devices have been submitted for Coast Guard approval for use aboard commercial vessels. The Coast Guard does not approve inflatable PFDs for recreational use. 5No wet suits have been submitted for Coast Guard approval for use aboard commercial vessels. One diver-style wet suit has been approved as a Type V PFD for recreational use by water skiers. 6Self-activating EPIRBs are available and became mandatory for some uninspected fishing vessels operating on ocean waters on May 17, 1990. EPIRBs and VHF-FM radios are type approved by the Federal Communications Commission. It is illegal to use nonapproved radio devices on U.S. vessels. the water, nor are they intended to support extended survival in rough water. Hybrid PFDs combine inherent flotation and air chambers, reducing overall bulk and minimizing impacts on mobility. Hybrids have been approved as Type V special-purpose PFDs for recreational use. These hybrids are often advertised as Coast Guard-approved Type V PFDs without reference to approval for recreational use only. Similar equipment is feasible under existing Coast Guard standards for commercial use. However, no equipment of this latter type has been submitted to the Coast Guard for approval. Any hybrid PFD subsequently approved by the Coast Guard for commercial use would also be identified as a Type V special-purpose PFD (as are approved work vests and antiexposure coveralls). Potential buyers and users must read the entire manufacturer 's label,

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FISHING VESSEL SAFETY: Blueprint for a National Program TABLE I-3 Coast Guard Personal Flotation Device Definitions Offshore Lifejacket (Type I PFD) Designed for use in open, rough, or remote water where rescue may be slow coming. Required to turn most unconscious wearers face-up in the water. Must be of highly visible color. Nearshore Buoyant Vest (Type II PFD) Designed for use in calm, inland water or where there is a good chance of fast rescue. Required to turn many unconscious wearers face-up in the water. Not intended for long hours in rough water. Flotation Aid (Type III PFD) Designed for calm, inland water, or where there is a good chance of fast rescue. Not designed for extended survival in rough water and will not hold the face of an unconscious wearer clear of the water. Generally, the most comfortable PFD for continuous wear. Available in many styles, including vests and flotation coats. Throwable Device (Type IV PFD) Designed for calm, inland water with heavy boat traffic, where help is always nearby. Not intended for unconscious persons, nonswimmers, or for many hours in rough water. Special-Purpose Devices (Type V PFD) Approved only for special uses or conditions. Must be used in accordance with limits specified on the label. Type V Hybrid Device Combines inherent flotation and inflatable bladders. Has high flotation when inflated. May not adequately float some wearers unless partially inflated. Equal to either Type I, II, or III performance as noted on the label, but must be worn and used as specified on the label in order to be counted as a regulation PFD. which states the scope of approval, to detetrmine whether individual items would satisfy Coast Guard criteria for use aboard uninspected commercial vessels. Coast Guard-Approved Inflatable PFDs Although possible under Coast Guard regulations, the only inflatable PFDs approved to date for commercial application are for use aboard commercial passenger vessels with limited stowage space (e.g., passenger submersibles). The Coast Guard standard requires dual air chambers and automatic inflation among other extensive requirements needed to obtain approval. A fully functional automatic inflation device at all water temperatures is estimated to cost as much as $120. A device of this type is used as a basic component of U.S. Navy inflatable PFDs (to which Coast Guard regulations do not apply). The Coast Guard does not approve fully inflatable PFDs for recreational use because of maintenance considerations.

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FISHING VESSEL SAFETY: Blueprint for a National Program Infant- and Child-Sized Immersion Suits There are no Coast Guard-approved PFDs or immersion suits that provide hypothermia protection for infants and small children. A number of fishermen from coastal Alaskan waters, in response to the Coast Guard 's Notice of Proposed Rulemaking under the CFIVSA, petitioned the Coast Guard to encourage the manufacture, sale, and approval of such equipment. The need was attributed to family fishing operations in Alaskan coastal waters where—by choice or economic necessity—the boat doubles as workplace and home (see Page, 1989). The Coast Guard corresponded with various manufacturers concerning this matter. Some were not interested because of the small market segment and product liability, but several manufacturers developed and tested infant/small child immersion suits in Alaska with mixed results. The Coast Guard has received no proposals from manufacturers requesting approval of protective clothing of this type. However, the Coast Guard has advised manufacturers that it will, on a case-by-case basis, consider approving immersion suits in sizes other than the three prescribed by regulation. PFD Lights PFD lights are required for uninspected fishing vessels operating on ocean waters, coastal waters, and the Great Lakes. The PFD light must be fully operable and properly attached in order for it to count as required equipment during a Coast Guard boarding. Because they are not required to float, if the light is not properly attached to the PFD, it may sink. A wide variety of designs and battery types are used by manufacturers with variations in performance. Some lights require manual activation; others are water-activated. Marker lights that float are available with either manual or automatic activation devices. EPIRBs EPIRBs are used by offshore or distant-water fishing vessels throughout the industry. Of nearly 40,000 first alerts from EPIRB signals detected by satellites during calendar year 1989, 92 percent were not heard a second time. Furthermore, the source of only 2 percent of the total number of alerts was determined, and only 35 were verified as distress cases. The poor alert record is directly associated with use of 121.5 MHz as the transmitting frequency for older classes of EPIRBs. This frequency is shared with the aviation community, and an undetermined number of false alerts undoubtedly came from those units. The older EPIRB beacon is inadequate for satellite position fixing. In view of these factors, the Coast Guard does not consider a first alert on 121.5 MHz as sufficient justification to initiate a search endangering rescue aircraft and

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FISHING VESSEL SAFETY: Blueprint for a National Program personnel (Embler, undated; Lemon, 1990a,b; Pawlowski, 1987; unpublished Coast Guard statistics, 1990). A vivid demonstration of the marginal effectiveness of 121.5-MHz EPIRBs occurred during March 1990. A 60-foot steel dragger transiting from Washington State to Prince William Sound, Alaska, with three persons aboard was reported overdue after departing from Cape Spencer, Alaska, and a search began. The vessel was equipped with a life raft, 121.5-MHz EPIRB, and survival suits. Coast Guard rescue aircraft located the vessel's life raft and attached EPIRB on the beach near Cape Spencer. The life raft was sighted visually before a weak signal was detected from the EPIRB. On-scene personnel recovered the gear and determined that the life raft had self-deployed and the EPIRB self-activated. The survival suits were not located and the operator and crew are missing (unpublished Coast Guard situation reports, 1990). The new EPIRB technology is impressive. Each Category 1 EPIRB will be electronically coded, thereby providing a means to immediately identify the vessel from which the signal is emanating. The signals will be received by satellites capable of fixing a signal position to within about 2 miles. A 1210.5-MHz homing beacon that coactivates with the 406-MHz signal will permit localization by rescue aircraft once on scene. Test circuits are designed to indicate power status; however, there are no live transmissions of test signals. An automatic activating device will be required for Category 1 units. The technology is further designed to permit maintenance by authorized service centers only (see Embler, undated; Lemon, 1990b). While impressive, the technology is not foolproof. It is possible to install some Category 1 EPIRBs in their float-free holders without arming them. Where a mercury-type switch is installed for automatic activation when the EPIRB is vertical, it remains possible to inadvertently activate the device if it is stored armed in a vertical position inside a vessel while moored. However, the position-fixing aspect of the new system and electronic, vessel-specific signature will make it easier to resolve such occurrences. Another potential problem for which limited information was available is the suitability of new Category 1 EPIRBs aboard smaller fishing vessels constructed of plastic with built-in flotation. Some EPIRBs may remain in their float-free holders if the vessel does not sink. Further examination of this issue was not feasible with available information.

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FISHING VESSEL SAFETY: Blueprint for a National Program Personal Locator Beacons (PLBs) The personal equivalent of an EPIRB is a personal locator beacon (PLB). This device is most closely associated with transmitters worn in avalanche areas to alert rescuers to anyone buried in snow. PLBs are being considered by some countries for maritime use, but they are illegal in the United States except for a few restricted applications (Lemon, 1990a). The Federal Communications Commission recently warned a manufacturer to discontinue marketing an aircraft emergency locator transmitter (ELT) for PLB use. INSTRUCTIONS FOR USING SURVIVAL EQUIPMENT Regulatory Requirements for Instructions Each manufacturer of a Coast Guard-approved PFD designed for recreational vessels is required to furnish an information pamphlet with each PFD sold (33 CFR 181). This pamphlet was recently upgraded to a nonalterable, 16-page booklet to overcome significant variations in format and content in previously published materials. A separate pamphlet is required for hybrid recreational PFDs (46 CFR 160). Because of the unique nature of recreational hybrids, formal donning and operating instructions must be included in the hybrid pamphlet. Other than hybrid PFDs, manufacturers of safety and survival equipment are required by Coast Guard regulation to provide written instructions only to purchasers of immersion suits. The Coast Guard has not required either informational pamphlets or written donning instructions for PFDs or other equipment sold for use aboard uninspected commercial vessels. This is partly because commercial users traditionally have been thought to have more maritime expertise than recreational boaters. However, where a PFD has been granted dual approval for recreational and commercial use, a copy of the recreational pamphlet must be provided. Manufacturers are not required to provide instructional videotapes demonstrating proper care and use of PFDs, immersion suits, and EPIRBs, and they don't. Various generic manuals, handbooks, guides, and videotapes covering the care and proper use of survival equipment are available from private vendors, training institutions, and trade associations at reasonable to moderate costs (Hollin, 1982; Sabella, 1989). Several safety manuals with sections covering survival equipment are specifically tailored to the North Pacific and Gulf Coast (Sabella, 1986; Hollin and Middleton, 1989). An Atlantic Coast manual is being developed by the University of Rhode Island (Hollister and Carr, eds., 1990). A computer-aided audit program to track vessel maintenance and safety status is also available (Moran, 1989). Safety and survival courses are offered by academic and vocational institutions, trade associations, and private vendors (DeAlteris et al., 1989; Sabella, 1987; Pennington, 1987; Walker and Lodge, 1987; Keiffer, 1984).

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FISHING VESSEL SAFETY: Blueprint for a National Program Coast Guard Survival System Publications The Coast Guard publishes a circular entitled Voluntary Standards for U.S. Uninspected Commercial Fishing Vessels (U.S. Coast Guard, 1986b). Commonly referred to as NVIC 5-86, this circular is a technical document covering fishing vessel design, construction, and equipment. It covers safety and survival equipment requirements, recommends equipment beyond minimum requirements, provides an overview of selected equipment performance, and offers guidelines on selected equipment maintenance. First published in August 1986, NVIC 5-86 was distributed to trade and fishermen associations. It remains available for purchase through the Coast Guard. No data were developed to indicate the extent to which NVIC 5-86 is available to operators and crews, and if available, how well the material is used in practice to improve the safety of fishing operations. A comprehensive manual is published by the Coast Guard covering Coast Guard rescue and survival systems (U.S. Coast Guard, 1988a). It is widely available to Coast Guard forces. This manual provides comprehensive technical guidance on commercial and Navy survival equipment used by the Coast Guard as well as use guidance on operational use of selected equipment. Some of the commercial equipment used by the Coast Guard is identical to equipment found aboard some uninspected fishing vessels. The Coast Guard manual provides detailed maintenance guidance, while commercially available manuals tend to focus more on cursory checks that can be performed by persons with limited formal training.