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OCR for page 35
OPERATIONAL AND ADMINISTRATIVE CONSIDERATIONS
Apart from safety issues associated with system design and operation, there are also a variety of
background issues dealing with the qualification of personnel, the management of passengers, and
contingency planning for dealing with emergencies. These clearly are also matters essential to the safety
of tourist submersible operations.
MANNING, TRAINING, AND LICENSING
Manning, training, and licensing do not of themselves present operational hazards affecting
passengers, crews, or property. However, the selection of unreliable or unqualified personnel, inadequate
training, or inadequate licensing procedures could result in operational hazards. The safety of the
passengers and crew as well as the protection of property involved in tourist submersible operations requires
careful attention to personnel selection, training programs, and licensing procedures.
Manning
The OCMI determines the manning requirements for a particular vessel and specifies the minimum
complement on the vessel's certificate of inspection. These requirements vary depending on the type of
submersible and the operation envisioned.
The contents of a required "manning and licensing proposals will be discussed later in this section
(see "Licensings). In order to fulfill the requirement for such a proposal, management should first formulate
a complete operational scenario, then design an organization with a clearcut chain of command capable of
carrying it out. The organizational chart should cite the title of each position ~nr1 the. re.~nnncihilitiec
authority, and duties that go with it.
~—1~ ~ _ ~~~ ~ ~1 A ~~ ~ ~ A_
~ ~ ~ r _ ^ ~~ ^ ~ ^ ~ ^ —~ TV ~
lilt; amp prouaule vaslc operational scenario will include provisions for a ferry vessel to carry
passengers to and from the operating site, a surface support safety boat to follow the submersible and
maintain communications, and the submersible itself.
In the committee's view, the tourist submersible should carry a minimum of two qualified operations
personnel, at least one of whom must be licensed by the Coast Guard. A third crewman may be provided to
aid in passenger management and assist in emergencies. The configuration of the individual submersible and
its complexity may dictate additional personnel.
Since the ferry vessel can be expected to carry at least six passengers, the master must be licensed
as a master of an inspected vessel of appropriate tonnage.
*In accordance with 46 CFR paragraph 15.501.
35
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36
The ferry vessel should have at least one crewman in addition to the master who can handle lines
and provide crowd control and who is qualified to operate the vessel if the master is incapacitated. The
surface support safety boat should be manned by a minimum of two crewmen both of whom are qualified
to operate the boat and its communications equipment. In addition, there are two qualified divers operating
from the support boat, both equipped with necessary diving gear. One diver maintains visual contact with
the other diver who is attending or accompanying the submersible.
As backup for emergency rescue, submersible operators should assure that either an additional
support diving team (at least two persons) or a remotely operated vehicle (ROY) will be rapidly available.
The ROV will be essential should these entrapment circumstances extend in time and depth beyond diver
capability.
Training
Training of submersible operators has been addressed in other reviews. For example, a
comprehensive analysis is presented in Section D of Safes arm Operational Guidelines for Undersea Vehicles,
published by the Marine Technology Society (MTS) in 1974.i This treatise, although 16 years old, is
considered to offer an excellent and still contemporary guide to development and approval of training plans.
The committee's views on training needs, using the MTS guidelines as a starting point, are presented in
Appendix D. It is important to note, however, that the committee has added recommendations that address
ncriterion-referenced" or "competency-based" training standards (Appendix D, page Dog. Competengy-
based training standards provide for:
· determining what level of competency is needed,
· establishing a standard for measuring that level of competency, and
· training to that level.
Training time—such as a two-week standard—does not guarantee a level of competency. Rather, some
agreed-upon standard is needed that provides a level of competency established as being adequate for safety
and operational need.
Basic indoctrination of crew members should thoroughly familiarize the trainee with the basic
concepts, hardware, and principles of operation of every system and subsystem aboard the vessel.
Concurrently, operational training beginning with a maintenance apprenticeship aboard the submersible
and advancing to an apprenticeship under the chief pilot should provide the trainee with on-thejob
experience leading to a full capability to operate the vessel competently in solo mode under all expected
operating conditions.
In brief, the selection and training of all members of a submersible operating team must be done
with the same care and attention to detail given to the design of the pressure hull or life support system.
There is no substitute for the understanding imparted through training and subsequent experience.
Licensing
Paragraph 10.201 of 46 CFR covers the general requirements for licensing of personnel for surface
vessels, including age, experience, character references and recommendations, physical examination,
citizenship, training, and professional examination.
The Coast Guard has prepared a draft navigation and inspection circular that addresses the
requirements for licensing masters of tourist submersibles. The draft circular requires "that individuals
serving as master or mate on inspected submersibles will be required to possess the appropriate license" and
"that license must authorize service on inspected passenger carrying vessels of similar gross tonnage and
route." In the case of currently operated tourist submersibles, this is a 100-ton near coastal license, which
must contain an endorsement for the submersible or class of submersibles to be operated. The draft
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circular also provides for the local OCMI to approve a Manning and licensing proposal" submitted by the
company operating the submersible and based on levels of personnel training, qualifications, and number
of personnel required for safe vessel operation.
The draft circular requires that an individual complete a training program approved by the local
OCMI at a regional examination center. The training program requirements include vessel systems, vessel
operations, emergency procedures, and Hands one qualification dives. To obtain a license, the applicant
is required to pass an examination that is vessel-specific and prepared by the Coast Guard after studying
the specific vessel's operation and technical manuals. In the committee's view, the applicant should be
required to demonstrate his ability to perform all required operations.
The circular also addresses approval by the Coast Guard of levels of personnel training and
qualifications as well as the number of personnel considered necessary for safe operation. In view of the
fact that the safety of the passengers depends on the interaction of the vessels and crews—not just in the
sense of the "rules of the road," but in the minute coordination of all operational assets and personnel—the
Coast Guard should also require that the manning and training level of the total system be addressed in
the required manning and licensing proposal.
The circular contains several other requirements that should be clarified. Chapter 10, Section C,
paragraph 1, states that "normally two licensed individuals will be required so as to ensure the vessel can
be safety operated under all conditions, including incapacitation of the master." If this means two licensed
masters, it exceeds the requirements for surface vessels and would seem to impose an unnecessary hardship
for the manning of tourist submersibles. Paragraph 3 states that "individuals serving as master or mate on
inspected submersibles will be required to possess the appropriate license. There is no mention anywhere
else of a mate's license for submersibles; the mention of mate should be eliminated or explained.
Finally neither the draft circular nor 46 CFR addresses specific physical requirements other than
visual acuity and color sense. For a submersible pilot the physical requirements should be at least the
equivalent of a Federal Aviation Administration's third class medical certificate.
Recommendations Relating to
Manning, Training, and Licensing
Manning of the tourist submersible, Deny, and surface support safety boat must account for the possibility
of incapacitation of the master by including at least one other individual who is qualified (through accredited
training, practical demonstration, or formal eucan~inationJ to operate the vessel.
References in the Coast Guard draft circular to requirements for Two licensed individuals onboard each
vessel and for licensed mates need to be clarified or corrected
The current licensing examination for tourist operations is a book exam. This examination should also
require a demonstration that the trainee is capable of performing all operations to an acceptable level of
competency.
The Coast Guard should require that vessel manning and licensing proposals address the manning and
training levels of the total marine system (the submersible, feny boat, and all support vessels), including support
crews.
Physical requirements for submersible pilots should be at least the equivalent of an FAG third class
medical certif cate file., the minimum requirements for pilots of private aircraft).
* The FAA third class medical certificate is required of pilots of small, private aircraft. It certifies that the individual is in
good health, with properly corrected eyesight and no predilection for sudden serious illness.
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PASSENGER MANAGEMENT
Proper passenger management during the entire system operation (ashore, on a transfer boat, and
on a submersible) is an essential element of safety. Even if an abnormal or emergency event is satisfactorily
mitigated from the standpoint of equipment, it is equally important that injury or emotional trauma to the
passengers be avoided or minimized. Passenger management cannot be leD to common sense, but must be
planned for in every phase of operations—normal, emergency, ashore, and sea.
Passenger management includes such responsibilities as indoctrination, passenger movement, and
passenger behavior control. In all cases, the objective is to ensure the safety and well-being of the
passengers. Passenger management planning must consider what kinds of passengers they are likely to
serve: they probably have never been on a submersible before; they do not necessarily know how to swim;
they can range in age from the very young to the elderly; they may have disabilities such as hearing loss,
heart disease, shortness of breath, etc.; they may not speak English; and they will be naive about the
operation and hazards of submersibles.
Normal Operations
Normal operations have been characterized in a preliminary Coast Guard policy statement as
procedures for: Submerging and surfacing, surface operations' underwater operations (visibility, currents,
communications, surface traffic, etc.), and ferrying and transferring passengers.~l7 Normal operations and
their impact on passenger management issues can be discussed in terms of shore site, ferry boat, and
submersible operations.
Shore Site
Shore site operations consist of activities in which passengers may make inquiries, purchase tickets,
and rendezvous for the trip to the submersible. This is the first opportunity for the company to reduce
passenger anxiety and instill confidence in the professional and safe operations of the entire organization.
There should be no particular direct hazards at the shore site, but the first passenger indoctrination
should be given here to initiate their safety awareness. Topics to be covered should include such things as:
general description of operations;
the environment aboard the submersible (e.g., air conditioned, with purified air);
prohibition against smoking or possession of cigarette lighters (should be given to crew attendant
before the voyage), eating, or drinking on the submersible;
· any restrictions on age, illnesses, or disabilities; and
· how to proceed to the ferry boat.
This initial passenger indoctrination should be a required part of the total safer operation, and the
indoctrination topics should be described in the operations manual and safety plan.
Ferry Boat
Most operations will require a ferry boat to transfer passengers from the shore to the submersible
—although, if site conditions were appropriate, passengers could board the submersible directly from a dock.
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Assuming a ferry boat is involved, the principal activities during this phase would be to safely board and
seat the passengers, brief them on safety considerations of the ferry boat trip and its facilities, brief them
on safety considerations for embarking to the submersible, and carry out the safe embarking procedures.
Similar activities are required for the return trip from the submersible, but special consideration must be
given to the situation in which passengers are embarking and debarking at the same time.
In the opinion of the committee, the most dangerous activity during normal operations is the
transfer of passengers in both directions between the submersible and the ferry boat. The amount of hazard
involved in this activity is a function of several things: (1) the match between the decks of the ferry boat
and the submersible, (2) the roll or motion of the two platforms due to sea conditions, (3) availability of
brows (a gangplank usually fitted with rollers), (4) assistance provided by the crew members, (5)
environmental conditions (e.g., light, rain, wind, etc.), and (6) the degree to which the passengers comply
with instructions. Obviously, this activity is a question of practicing what is preached during the
indoctrination prior to the boarding process.
One final potential hazard is a function of the capacity of the ferry boat vis-a-vis (1) the number
of passengers on board the ferry boat and (2) the number of passengers debarking from the submersible.
This can present a problem in passenger management when there is a full load on the submersible and a
full load on the ferry. Embarking and debarking passengers should be separated on the ferry boat, should
debark and embark from different locations, and should debark and embark at approximately the same rate.
Ideally, the ferry boat's capacity should be at least twice that of the submersible, including crew.
The safety of ferry boat passengers is governed by existing regulations in 46 CFR Subchapter T.
Small Passenger Vesselsn (less than 100 gross tons). These requirements are also the only ones in effect
for submersibles and are obviously not directly applicable. New guidelines or regulations governing the
issues raised above must be developed. The Coast Guard has included in the draft navigation and
inspection circular two proposed requirements for railings under Section F. "Rails and Guards.
Submersible Operations
Once the passengers are aboard and the debarking passengers are safely on the ferry boat and away
from the submersible, the submarine phase of operations can begin. The principal activity concerning
passenger management is a briefing (or series of briefings) concerning (1) the safety and life support
equipment, (2) unusual or unexpected occurrences or sensations (e.g., noises, sitting on the bottom, and
sudden shifts in direction or floor angle), (3) expected passenger behavior in the event of any abnormal or
emergency situation, particularly emphasizing the possibility of rapid ascent and evacuation, and (4)
debarkation procedures and safety.
A number of regulations or technical considerations relate to passenger management during the
submersible phase of operations. These are briefly noted below:
· The Coast Guard has suggested a separation (e.g., a partition) between the control area and the
passenger area to prevent passengers from interfering with operator performance.~9 The basis for this
requirement is not clear. All tourist submersibles observed have a large, circular viewing area in the front
for the pilot to see through for navigation. Passengers can also look down and see out through the front
of the submersible, which may be reassuring as well as enjoyable. Both passenger viewing and pilot security
needs can be met by a partial transparent bulkhead.
· The need for life support equipment is obvious and the requirement well documented in the
draft circular.20 Rebreathing equipment is discussed in Chapter 3.
· The requirement for passenger indoctrination is identified in another recent Coast Guard
document as follows: "passengers are to be trained by the crew members in the use of personal life-saving
equipment under any expected emergency condition.n2i It is assumed the use of the word "trainings is
satisfied by thorough briefings and does not require practice (as it does not in airline operations with
similar briefings). It should be noted, however, that a later draft version of this document appears to have
omitted the requirement concerning passenger training.
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· The Coast Guard has a requirement in the operations manual and safety plan for emergent
procedures for Evacuation out of and off the vessel.n22 The committee also notes that the interior design
of the submersible should ensure efficient flow of passengers in the event that evacuation is required;
however, no such requirement currently exists.
Abnormal or Emergency Operations
The Coast Guard has defined emergency operations as those emanating from scenarios such as
inability to surface, loss of power, controllable leakage of hull, collision, and/or evacuation out of and off
the vessel.23 The need to consider abnormal and emergency situations as part of the Coast Guard
responsibility has been stated by Johnson and Veentjer.24 Some issues that affect passenger management
considerations are paraphrased below.
Considering the unique operating parameters of a submersible, there are certain areas where the
Coast Guard will focus particular attention. For example:
· Escape and rescue from a submerged vessel will be difficult and hazardous, so the submersible
must be capable of returning to the surface in the event of failure of any system except the main pressure
hull.
· Access to life-saving equipment and means of exiting the submersible on the surface may also
be difficult. Adequate freeboard and stability should be available on the surface to permit the safe
debarkation of passengers under the worst expected surface conditions.
· During the time it takes to surface and evacuate, provisions should be made for personnel
protection from hazards such as smoke or toxic vapors in the event of a fire, or flooding in the case of hull
damage.
For purposes of the present report, abnormal and emergency operations as they affect passenger
management can be discussed in relation to seven hazard scenarios in the system safety analysis developed
by the Transportation Systems Center for the Coast Guard.2s These scenarios are fire, flooding, inability
to ascend or descend, collision, vessel isolation, air contamination, and passenger illness or injury. In each
of these cases the predominant action is immediate surfacing. Crew training and passenger indoctrination
are the essential ingredients in maintaining passenger calm and orderly behavior while surfacing and
evacuation are carried out—generally requiring on the order of one minute for operations with a 50-meter
(165 feet) depth.
Special Considerations
There are certain special considerations for passenger management that must be part of the
operating manual and emergency plan as they apply to a particular operation. The following are typical
special considerations:
· Night diving If diving is to be performed at night, special indoctrination, lighting for embarking
and debarking, and other appropriate considerations must be planned.
· Non-English speaking passengers. If there are passengers aboard who cannot understand the
briefing or instructions, they should be accompanied by someone who can interpret for them, or else they
should not be permitted to board the submersible.
· Passenger-caused incident. The possibility of passenger-caused incidents (e.g., claustrophobia-
induced panic, accidental activation of controls, or injury) has been identified by the Coast Guard.26
· Maximum occupancy. The Coast Guard has stated that "the maximum occupancy for passenger
submersibles and submersibles intended for recreational purposes is not to exceed the number obtained by
dividing the net internal volume of the vehicle in cubic feet by 53, or the number obtained by dividing the
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net internal volume in cubic meters by l.s.n27 The basis of these numbers is not known. However,
comparable volumetric requirements have been determined by the National Aeronautics and Space
Administration28 as (1) 31 cubic feet to accommodate the body motion envelope of the 95th-percentile
American male (page 8.6-4), and (2) 53 cubic feet for sleeping compartments on long-duration space
missions (page 10.4-3~. The latter requirement indicated that the Coast Guard's 53-cubic-foot allotment is
fully adequate for short-duration stays underwater, on the order of one hour. In any event, passenger
occupancy should never exceed the available designated seating on the submersible.
Some of the unusual and unlikely events, which are listed within the special considerations, cannot
be individually anticipated or trained for. General training in first aid and crisis management, together with
a confident crew, should be sufficient to handle most situations.
Operations Manual and Safety Plan
An operations manual and safety plan are required by the Coast Guard for review whenever
jurisdiction has been established and a contract has been awarded for construction.29 Specific requirements
for the "plan" review are identified in the preliminary Coast Guard policy statement30 and draft navigation
and inspection circular.3i A similar requirement has been stated by ABS.32 The content specified by the
Coast Guard or ABS is essentially the same. It includes: - -
any dive.
support craft functions and capabilities;
normal operating procedures;
emergency procedures;
mooring and operational area proposals;
dive site location; and
· minimum amounts of air, oxygen, and battery power that must be available before commencing
ABS rules also place limitations on Lea states—the acceptable envelope of weather and water conditions
in which the vessel may operate. The Coast Guard requires compliance with those rules.
There are no specific requirements that address passenger management issues. However, it should
be noted that the System Safely Analysis Report prepared by the Transportation Systems Center addresses
the topic of operational countermeasures (i.e., to counteract hazards), and specifically recommends that
Guidelines should be established regarding passenger indoctrinations The committee believes that the
operations manual and safety plan should contain a specific section on passenger management dealing with
all of the issues previously discussed in this chapter for normal and emergency operations ashore and at sea.
Training in Passenger Management
Passenger management for both normal and emergency operations will be facilitated greatly by
proper design of the submersible and availability of appropriate procedures in the operations manual and
safety plan. However, the effectiveness of passenger management by the submersible crew will be dominated
by the training the crew has received. The Coast Guard appears to require very little in the way of
passenger management training. The only requirement identified by the committee during review of
available documents was in a draft update of Rules for Underwater Systems and Vehicles.~33 Paragraph
12.17, "Training of Operations Personnel," provides some guidance for training of the submersible's crew.
In very general terms, the document states that the crew must be fully capable of performing tasks related
to emergency procedures and is to be fully aware of the submersible's capabilities in order to maximize
the safety of the dive under the expected conditions. It is also stated that the crew should be aware of the
physiological effects of breathing the onboard emergency gas mixtures under the submersible's environmental
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and hyperbaric conditions. These statements (while in draft form) relate only vaguely to passenger
management.
The System Safety Analysis Report (Transportation System Center, 1989) recommends that Training
programs should be developed for all safety-related phases of the tourist submersible operation.n34 The
report further states that the training program should clearly represent a systems approach to training (this
is presumed to mean competency-based training, in which capability must be demonstrated). A training
assessment, if performed, would determine the need for passenger management training by the crew.
The requirements implied by the recommendations below should be included in the operations
manual and incorporated in the training of personnel.
Recommendations Relating to Passenger Management
Embarking and debarking the submersible are the most dangerous activities during normal operations.
Special diligence should be exercised by the Coast Guard in reviewing and approving the process proposed,
including design features' procedures, and crew training.
Passenger indoctrination should occur at least three times, as indicated below and detailed in the text:
· shore site~nitial safety awareness;
· feny boat: (1) feny boat safety, and (2) submersible embarkation safety; and
· submersible: (1) use of safety and life support equipment, (2) unusual or unexpected occurrences or
sensations, (3) expected passenger behavior in the event of an abnormal or emergency condition, and f4)
debarkation safer.
The operations manual and safety plan should contain a separate section on passenger management.
(The topics in that section could follow the general structure of this section of the report.J
A training needs analysis should be done to determine reaming objectives and curriculum requirements
for a competency-based training program in passenger management. The curriculum should include, as a
ntmlmum:
basic first aid,
life support requirements and equipment,
passenger management and emergency procedures,
· crisis management, and
· passenger safer indoctrination.
EMERGENCY RESPONSE PI^NNING
Importance of Contingency Planning and Preparation
The purpose of contingency plans for use in the event of an emergency is to make possible a rapid
and safe response to the emergency. A secondary purpose or benefit is that, in the proper development
of such plans, and during the various reviews by levels of management, frequently ways are found to make
operations safer by either eliminating hazards or providing improved response. Several examples of sound
emergency and contingency response plans can be cited.35~37
Fortunately, tourist submersibles have not yet been called upon to carry out an emergency response,
although there is considerable experience with emergencies for other types of submersibles. This experience
base, along with the substantial experience acquired by the U.S. Navy and Coast Guard in handling maritime
emergencies of all kinds, has led to some well-established principles. Perhaps the most important of these
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is that when an emergency occurs, an established plan of action for all hands is absolutely vital. This
section emphasizes the need for such plans and urges the Coast Guard to require and exercise the plans
for all operations of this kind.
The committee observed an encouraging degree of confidence on the part of operators that they
could operate safely under all expected conditions; but this confidence should not be allowed to divert
operators' attention from the need to know how to respond when the unexpected but inevitable accident
occurs.
An analysis of submarine operations indicates that, with some indeterminate frequency, and even
with the best precautions, accidents will occur. The U.S. Navy has periodically lost submarines, as have
other navies—most recently the Soviet Navy.38 As of late summer 1989, the U.S. Navy was assisting the
Peruvian Navy in the salvage of one of their submarines that was lost in a collision with a surface ship.
Research and work submersibles have also been involved in accidents, some of them fatal.
The ability of people to respond properly and quickly in the event of an emergency is greatly
improved by adequate prior planning and preparation.39 For example, the success of the airport emergency
response personnel in Sioux City, Iowa, in minimizing fatalities associated with a DC-10 crash in the
summer of 1989 has been widely credited to the planning and drills previously conducted there.
Frequently the outcome of an emergency is determined by the actions taken immediately after the
accident. In nearly all emergency situations involving the sea, time is critical.40 Thus, proper planning will
facilitate response and reduce the final costs in the event of an emergency.
Nature of Contingency Plans
Contingency plans should be compatible with, and follow the procedures of, the National Search
and Rescue Plan if other than local assistance may be required. (See Appendix F for this plan and the U.S.
Navy submarine missing/lost instructions.)
Contingency plans provide an opportunity to examine possible accident scenarios, and to determine
an optimum course of action. They enable others to review and contribute to emergency response.
Frequently, a side benefit is the opportunity to eliminate hazards, and for management to make key
decisions that will lessen the impact of emergency situations.
Proper plans should not only address those things that could happen to the submersible in
operation, but should also contain plans for external events such as hurricanes. They should make
provisions for loss of the support craft as well as loss of the submersible. Above all, emergency response
planning must consider the nature of accidents and emergency situations, and the human errors and failures
that can lead to them, as well as the possibility of simultaneous accidents involving more than one aspect
of the operation. For example, a serious accident (such as a collision) involving both the submersible and
the ferry or surface safety support boat might beggar more significant than one involving just one of these
vessels.
Appendix E presents a discussion of what a contingency plan for submersibles ought to encompass,
including the necessary drills and training. Submersible design and operational features that will affect
emergency response are also outlined in the appendix. (Most significant among these are salvage air fittings
to permit hoses to be run from the surface to a submerged vessel, standard mating rings for attaching a
decompression chamber to the submersible after salvage, and standard lifting attachments to which a
remotely operated vehicle [ROY] can be attached.)
Recommendations Relating to Emergency Response
The Coast Guard should require a written and approved emergency response plan for each operating
submersible, using Appendoc E as a guide. This plan should be exercised by each operator on a regular basis
(perhaps quarterly). This exercise need not be a full-blown exercise every time. Some of the exercises might
well be ones in which the participants ensure that the recall list works, after which the key participants gather
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Representative terms from entire chapter:
passenger management
