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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 timesuch as a two-week standarddoes 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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37 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 crewsnot just in the sense of the "rules of the road," but in the minute coordination of all operational assets and personnelthe 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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38 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 operationsnormal, 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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39 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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40 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 outgenerally 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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41 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 statesthe 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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42 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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43 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 naviesmost 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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