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48 4. SMALL PASSENGER VESSEL LIGHTSHIP VERIFICATION Importance of Lightship Verification for U.S. Small Passenger Vessels Incremental growth (or weight creep) generally occurs slowly over many years, unlike major conversions or significant alterations. USCG requires a vessel to undergo a stability review if its lightship weight changes more than 2% or the longitudinal center of gravity shifts more than 1% of the length between perpendiculars. Although potential weight creep may not exceed these values from the result of any one-change action, accumulated weight creep over time could be an issue. However, detecting any of these small changes so that USCG completes the necessary stability reviews can be an issue. The small incremental changes in the vesselâs draft or trim could go unnoticed by the master or crew, potentially creating unnoticed reductions in a vesselâs stability. During the annual Certificate of Inspection (COI) review, USCG inspectors are expected to catch changes in a vesselâs lightship over the preceding year. However, this outcome may not happen for several reasons. Inspectors examine numerous vessels over the course of 1 year and simply may not remember a particular vesselâs condition from one year to the next. In addition, a vessel may not have the same inspector each year, so a change is not noticed. Although the committee is unaware of any reported stability casualties, this does not guarantee that one could not occur in the future. The U.S. passenger vessel fleet has evolved greatly in design, configuration, and markets served and will continue to do so. It is very important to remember that what worked safely for past designs may not work for new vessel designs. The committee is unaware of any formal studies on weight creep and its potential impact on the U.S. domestic passenger vessel fleetâs stability. Although there is anecdotal
49 evidence that weight creep does occur, the amount of weight creep occurring on various types of passenger vessels and its impact on vessel stability are not known. Past Efforts to Require Periodic Lightship Verification for U.S. Passenger Vessels No regulations currently exist for formal periodic lightship verification after USCG inspects a Subchapter T and K small passenger vessel for its initial COI stability review. In addition, USCG does not have formal requirements for lightship verification at its annual or 5-year COI inspection, although it has attempted such requirements twice. USCGâs first attempt at periodic lightship verification was part of a February 13, 1990, NPRM,11 which was a result of the Herald of Free Enterprise ferry disaster. The NPRM included concerns for draft indicators, onboard stability computers, periodic stability tests (lightship verification), the closing of loading doors before going to sea, and additional stability criteria for new passenger vessels. The Final Rule was proposed on September 11, 1992 (see Federal Register, Vol. 57, No. 177, p. 41812), but the effective date for implementing the proposed periodic lightship verification rule was delayed indefinitely based on public comments received in December 1992 (see Federal Register, Vol. 57, No. 238, p. 58406).12 After advancing periodic lightship verification as part of the rule, the proposed requirement was removed due to resistance from stakeholders. The second USCG attempt to require periodic lightship verification occurred after the M/V Lady D pontoon passenger ferry capsized in Baltimore, MD, in 2004. The Advance Notice of Proposed Rulemaking (ANPRM), issued in 2005 (USCG 2005-22732) and titled Passenger 11 See https://www.gpo.gov/fdsys/pkg/FR-1990-02-13/pdf/FR-1990-02-13.pdf. 12 See https://www.gpo.gov/fdsys/pkg/FR-1992-12-10/pdf/FR-1992-12-10.pdf.
50 Weight and Inspected Vessel Stability Requirements, was revised in 2007. In August 2008, the formal NPRM appeared in the Federal Register.13 This NPRM attempted to address two main areas: an increase in the average weight of passengers used in the stability calculations and a requirement for periodic lightship verification every 10 years. Of the 42 comments received by USCG about the proposed lightship part of the regulations, 41 opposed the periodic lightship verification requirement, mainly based on the following concerns: ï· It would be prohibitively expensive for the vessel owners. ï· It was redundant given other proposed rules requiring masters to review their stability information every year. ï· There was a lower risk of casualties because of the proposed increase in average passenger weight. ï· A formal study on weight growth in the U.S. small passenger vessel fleet was not completed. Based on the comments received, USCG removed the proposed periodic lightship verification regulations from the Final Rule adopted in December 2010.14 Potential Data Sources on Lightship Weight Growth The committee was not able to locate any formal studies or casualty databases on weight growth in U.S. passenger vessels. Accident reports that documented weight growth as the principal or a 13 See https://www.gpo.gov/fdsys/pkg/FR-2008-08-20/pdf/FR-2008-08-20.pdf. 14 See https://www.gpo.gov/fdsys/pkg/FR-2010-12-14/pdf/2010-30391.pdf.
51 major contributing factor to the accident were located.15 These accident reports covered vessels from the United States, the United Kingdom, and Canada. Other maritime administrations, both international and national, have implemented regulations requiring periodic lightship surveys of passenger vessel weight.16 The rationale and data used to implement the regulations could be a good source of information for USCG. If the regulations have been in place for more than 5 years, these maritime administrations may have data from the required periodic lightship surveys. In addition, the classification societies and recognized organizations could be a valuable source of lightship weight growth for two reasons. First, classification societies and recognized organizations often act on behalf of a maritime administration and may have similar data from the periodic lightship checks, witnessed on behalf of a maritime administration. Second, USCG has an Alternate Compliance Program (ACP) with various classification societies that allows a vessel to meet alternate standards and inspections from a classification society instead of those in the CFRs. The required stability reviews from these inspections could be a data source of lightship weight growth. 15 For example, see https://www.ntsb.gov/investigations/AccidentReports/Reports/MAB1416.pdf; https://www.ntsb.gov/investigations/AccidentReports/Pages/MAR0603.aspx; https://www.ntsb.gov/investigations/AccidentReports/Reports/MAB1103.pdf; http://www.tsb.gc.ca/eng/rapports- reports/marine/2015/m15p0286/m15p0286.pdf; and https://assets.publishing.service.gov.uk/media/54c1704ce5274a15b6000025/FormalInvestigation_HeraldofFreeEnte rprise-MSA1894.pdf. 16 For example, see UK Maritime and Coastguard Agency (MCA) LY3 11.5.3: https://www.gov.uk/government/publications/ly3-the-large-commercial-yacht-code; See UK Merchant Shipping Notices (MSN) 1823: https://www.gov.uk/government/publications/msn-1823-m-safety-code-for-passenger-ships; See Transport Canada, Transport Publication 10943: https://www.tc.gc.ca/eng/marinesafety/tp-tp10943-part-iii- 465.htm; See Denmark, Danish Maritime Authority, https://www.dma.dk/Vaekst/Rammevilkaar/Legislation/Notice%20B/Samlet%20Medd%20B-2013.pdf; See Australia, Maritime Safety Authority, Part C, Subsection 6C: www.amsa.gov.au/vessels-operators/regulations-and-standards-vessels/national-standard-commercial-vessels.
52 As part of its effort to obtain actionable data on lightship weight creep on passenger vessels, USCG could work with interested members of the U.S. domestic passenger fleet to study weight growth and assess the necessity of a lightship verification for small passenger vessels regulated under Subchapters H, K, and T.17 Potential data could include vessel identification, casualties, voluntary measurement of selected vessel lightship particulars over time, and historical and current weight surveys, as well as subsequent analysis of the collected data. Lightship weight measurements made after a known modification to a vessel can offer some guidance on weight changes that may have occurred prior to the modification if the calculated modification weight changes are subtracted from the post-modification lightship weight. This could provide a calculated value for the pre-modification lightship weight, which can then be compared to the previous measurement results. A lightship weight study could include such type of analysis as a data source for estimating how prevalent lightship weight change is over time in passenger vessels. The USCG could also undertake a sensitivity study on the existing passenger vessel fleet to estimate the potential impact of lightship growth on various types or classes of passenger vessels. Such a study could involve selecting representative vessels from each class of inspected domestic passenger vessels, such as charter fishing boats, dinner/excursion vessels, fast passenger only ferries, car ferries, and cruise ships. For each vessel class selected, a hypothetical range of weight growth could be added to the vesselâs current USCG-approved lightship condition and then the vesselâs stability could be recalculated accordingly. From this study, the USCG could determine if there are certain classes or types of passenger vessels that are 17 For example, ferry operators, such as Washington State Ferries and the Alaska Marine Highway system, have studied their fleet weight changes and could provide insights to the USCG.
53 potentially more susceptible to stability concerns from lightship weight growth. Such a study could allow the USCG to focus their efforts if results were to show a particular vessel type or class with a potential sensitivity to lightship weight growth. An example of a sensitivity study on a small passenger cruise ship is provided in Appendix H. The USCG Marine Safety Center (MSC) keeps intact and damage stability calculation files that were used for a vesselâs required stability review. These existing calculations could be modified to add incremental weight growth as a weight item and then different stability calculations could be produced. The MSC completed a similar sensitivity study when undertaking the rulemaking to increase the average passenger weight from 140 pounds to 185 pounds (see USCG 2005-22732, Passenger Weight and Inspected Vessel Stability Requirements). For this previous rulemaking, the MSC recalculated the stability for more than 300 vessels with the proposed new passenger weight value of 185 pounds to determine the impact of this weight increase on the U.S. domestic passenger fleet. The lightship weight sensitivity study, as proposed in this report, would be similar to the MSCâs previous study for the rulemaking. If lightship weight changes are assessed periodically, it is important to include the following elements in the assessment: 1. Document and address a vesselâs weight growth at regular intervals before it becomes an issue. 2. Accurately compare the current lightship displacement and longitudinal center of gravity (LCG) to the approved condition. 3. Use a method that is implemented by the vesselâs owners and masters and verified by the Officer in Charge, Marine Inspection (OCMI).
54 Potential Options for Lightship Verification Passenger vessels currently use four basic lightship verification options, which are explained in more detail in Appendix H. 1. Written Declaration. An option for vessel owners when no changes or only minor changes (well below the 2% weight change threshold and clearly documented) have occurred since the last lightship verification. 2. Weight-Tracking Program. The basic weight-tracking program consists of the owner and master recording the changes made to the vessel after the vesselâs initial inclining. 3. Lightship Verification Condition Loading Marks or Freeboards. This approach uses âlightship verificationâ marks or freeboards to check if the vesselâs lightship weight has changed or if its LCG has shifted. 4. Formal Deadweight Survey. Verification of a vesselâs lightship condition through a formal deadweight survey. One of the main complaints from industry about the requirement to periodically retest all passenger vessel lightship weight is that it is an unnecessary burden for the majority of vessels when no significant change occurred. In other words, periodic measurements are not needed when there are no documented casualties or data showing passenger ship lightweight changes over time create undue risk to the stability and safety of the vessel. However, a periodic lightship weight assessment that includes the option of self-certification could alleviate some of this concern since it will allow the vessel operator to state that no significant changes were made. A joint vessel survey by the operator and the attending USCG marine inspector during a COI renewal could validate whether any weight changes occurred. When significant weight changes