Review and Update of U.S. Coast Guard Vessel Stability Regulations and Guidance (2019)

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Committee to Revise and Update U.S. Coast Guard Ship Stability Regulations A Consensus Study Report of Review and Update of U.S. Coast Guard Vessel Stability Regulations and Guidance TRANSPORTATION RESEARCH BOARD SPECIAL REPORT 332

Transportation Research Board Special Report 332 Subscriber Category: Marine transportation Transportation Research Board publications are available by ordering individual publications directly from the TRB Business Office, through the Internet at www. TRB.org or nationalacademies.org/trb, or by annual subscription through organi- zational or individual affiliation with TRB. Affiliates and library subscribers are eligible for substantial discounts. For further information, contact the TRB Business Office, 500 Fifth Street, NW, Washington, DC 20001 (telephone: 202-334-3213; fax: 202-334-2519; or email: TRBsales@nas.edu). Copyright 2019 by the National Academy of Sciences. All rights reserved. Printed in the United States of America This publication was reviewed by a group other than the authors according to the procedures approved by a Report Review Committee consisting of members of the National Academy of Sciences, the National Academy of Engineering, and the National Academy of Medicine. This study was sponsored by the U.S. Coast Guard, U.S. Department of Homeland Security. International Standard Book Number-13: 978-0-309-49721-3 International Standard Book Number-10: 0-309-49721-3 Digital Object Identifier: https://doi.org/10.17226/25565 Library of Congress Control Number: 2019953051

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v COMMITTEE TO REVISE AND UPDATE U.S. COAST GUARD SHIP STABILITY REGULATIONS Eugene A. van Rynbach, Herbert Engineering Corporation, Annapolis, Maryland, Chair Hendrik Bruhns, Herbert-ABS Software Solutions LLC, Alameda, California H. Paul Cojeen, U.S. Coast Guard (retired), Arlington, Virginia Jaye Falls, U.S. Naval Academy, Annapolis, Maryland Jeffrey M. Falzarano, Texas A&M University, College Station Martha R. Grabowski, Le Moyne College, Syracuse, New York, and Rensselaer Polytechnic Institute, Troy, New York Timothy A. Graul, Timothy Graul Marine Design (retired), Sturgeon Bay, Wisconsin William B. Hale, General Dynamics NASSCO (National Steel and Shipbuilding Company), San Diego, California Patrick E. Little, Buffalo Marine Services, Inc., Houston, Texas Donald Liu (NAE), American Bureau of Shipping (retired), Seattle, Washington Jane Louie, U.S. Naval Surface Warfare Center–Carderock, Potomac, Maryland John Womack, Chesapeake Shipbuilding Corporation, Salisbury, Maryland Transportation Research Board Staff Mark S. Hutchins, Study Director, Consensus and Advisory Studies Thomas R. Menzies, Jr., Director, Consensus and Advisory Studies Anusha Jayasinghe, Associate Program Officer, Consensus and Advisory Studies

vii Preface In September 2017, the U.S. Coast Guard (USCG) Office of Design and Engineer ing Standards asked the National Academies of Sciences, Engineer- ing, and Medicine (the National Academies), through the Transportation Research Board’s (TRB’s) Marine Board, to review USCG regulations and policy documents that establish stability requirements for U.S. flag vessels. The USCG has the authority to inspect commercial vessels to ensure their safety under 46 U.S. Code Chapter 33. The associated regulations in 46 Code of Federal Regulations Chapter I contain requirements for vessel stability that apply to certain vessels used in commercial passenger and cargo service. Subchapter S is generally applicable to all vessels; Subchapter T applies to certain small, inspected passenger vessels; and Subchapter C applies to certain uninspected vessels (primarily commercial fishing industry vessels). The USCG asked for the review to identify and suggest options to make and keep stability requirements current, align them better with interna- tional standards, and improve their consistency and clarity. The National Academies formed a study committee comprised of members with expertise in naval architecture, vessel design and construction, regulation and inspec- tion activity, safety standards development, and marine transportation and vessel operations. Appendix A contains the committee members’ biographi- cal information. In September 2018, the committee issued a letter report that identifies a series of promising options for improving the consistency, clarity, and usability of the USCG’s vessel stability requirements, as well as

viii PREFACE for coordinating with industry advisory groups and collecting, managing, and analyzing data to inform regulatory decisions.1 Shortly after the committee issued its report, the USCG requested a follow-on study to provide a more in-depth and critical assessment of the options identified in the letter report, review ship stability regulations that exist outside Subchapter S (to include Subchapters C and T), and review and suggest improvements that can be made to any policy documents that supplement the Subchapters S, C, and T regulations.2 In addition, the USCG noted that legislation was being considered that could affect the agency’s priorities in making improvements to its stability requirements, and it there- fore wanted the study to take these developments into account. To conduct this follow-on study, or second phase review, the National Academies reappointed most of the members who served on the original study committee, adding some additional expertise in small vessel design and construction. The study committee met four times during the first half of 2019. During its first meeting in January 2019 and a follow-up meeting in February 2019, the USCG explained that the Save Our Seas Act, enacted on October 11, 2018,3 contained provisions relevant to vessel stability regulations. Accordingly, the USCG asked the study committee to provide advice that takes into account the issues raised in these statutory provisions. The details of this USCG request are provided in Chapter 1 when discussing the study’s Statement of Task. ACKNOWLEDGMENTS The committee would like to thank the following individuals who par- ticipated in the committee meetings: Lieutenant Jonathan Duffett, USCG; Marcus Ewardo, USCG; Thomas Gruber, American Bureau of Shipping; Tom Jordan, USCG; James Person, USCG; William Peters, USCG; and Jaideep Sirkar, USCG. Mark S. Hutchins managed the study and assisted the committee in the preparation of its report under the guidance of Thomas R. Menzies, Jr., Director, Consensus and Advisory Studies. Anusha Jayasinghe, Associate Program Officer, provided extensive support to the committee in arrang- ing its meetings and in managing documents. Karen Febey, Senior Report Review Officer, managed the report review process. 1 See the Phase 1 letter report at http://www.trb.org/Main/Blurbs/178088.aspx. 2 For reasons explained in this report, the committee did not review Subchapter C vessel stability regulations. 3 The text of the Save Our Seas Act of 2018 is available at https://www.govinfo.gov/content/ pkg/BILLS-115s3508enr/pdf/BILLS-115s3508enr.pdf.

PREFACE ix This Consensus Study Report was reviewed in draft form by individuals chosen for their diverse perspectives and technical expertise. The purpose of this independent review is to provide candid and critical comments that will assist the National Academies in making each published report as sound as possible and to ensure that it meets the institutional standards for quality, objectivity, evidence, and responsiveness to the study charge. The review comments and draft manuscript remain confidential to protect the integrity of the deliberative process. The committee thanks the following individuals for their review of this report: Greg Beers, Shearer Group, Houston, Texas; Charles Cushing, C.R. Cushing & Co., Inc., New York City; John Edgar, Jensen Naval Architects & Marine Engineers, Seattle, Washington; Neil Gallagher, Webb Institute, Glen Cove, New York; RADM Tom Gilmour, USCG, Retired, Eugene, Oregon; Tom Gruber, American Bureau of Shipping, Arlington, Virginia; Craig Philip, Vanderbilt University, Nashville, Tennessee; Robert Tagg, Herbert-ABS Software Solutions LLC, Singapore; and John Waterhouse, Elliott Bay Design Group, Seattle, Washington. Although the reviewers listed above provided many constructive com- ments and suggestions, they were not asked to endorse the conclusions or recommendations of this report, nor did they see the final draft before its release. The review of this report was overseen by Chris T. Hendrickson, Carnegie Mellon University, Pittsburgh, Pennsylvania, and R. Keith Michel, Webb Institute, Glen Cove, New York. They were responsible for making certain that an independent examination of this report was carried out in accordance with the standards of the National Academies and that all review comments were carefully considered. Responsibility for the final content rests entirely with the authoring committee and the National Academies.

xi Contents Acronyms and Abbreviations xiii Summary 1 1 Introduction 7 Phase 1 Study Summary, 8 Phase 2 Study Charge, 9 Organization of This Report, 11 2 Background 13 Vessel Stability Concepts and Terminology, 13 U.S. Fleet Subject to Coast Guard Stability Regulation, 18 The SS El Faro Sinking and the Save Our Seas Act Provisions, 22 3 Lightship Weight Change Tracking 25 Past Efforts to Require Lightship Weight Change Tracking, 26 Existing Guidance on Lightship Weight Tracking, 29 Sensitivity of Passenger Vessel Stability to Lightship Weight Changes, 30 Sensitivity of Freight Vessel Stability to Lightship Weight Changes, 32 Desirable Qualities of a Lightship Weight-Tracking Program for Freight Vessels, 34 Summary, 37

xii CONTENTS 4 Methodology for Evaluating Effectiveness of Current Stability Regulations 41 Defining Effectiveness, 41 Needed Technical Studies, 45 Variability in Stability Risk by Vessel Types and Service, 47 Assessing the Role of International Regulations and Class Rules, 49 References, 50 5 Improving the Stability Regulations Outside of Subchapter S 51 Subchapter T Simplified Stability Clarifications, 52 Potential Supplemental Requirements, 55 Summary, 68 References, 69 6 Review of U.S. Coast Guard Policy and Guidance Documents 71 Publicly Available Stability-Related Policy Documents, 72 Method for Reviewing Stability Policy Documents, 74 Example Document Review of Protocols from Other Organizations, 80 Options for Consolidating Policy Documents in a Searchable Website, 81 Summary, 85 7 Methodology for Prioritizing Subchapter S Updates and Changes 87 Risk-Informed Ranking Methodology, 87 Application of the Prioritization Methodology, 90 Summary, 103 Appendixes A Study Committee Biographical Information 105 B U.S.-Inspected Fleet—Vessel Data 113 C Results of Lightship Weight Sensitivity Analysis for Selected Freight Vessels 125 D Results of Lightship Weight Sensitivity Analysis for Selected Small Passenger Vessels 131 E Cargo Ship Weight-Tracking Programs 145 F Current State of Second Generation Stability Criteria 157

AAWPP Assumed Average Weight per Person ABL Above Base Line ABS American Bureau of Shipping APA Administrative Procedure Act ASME American Society of Mechanical Engineers ASTM ASTM International (formally American Society for Testing and Materials) CFR Code of Federal Regulations CG-CVC Office of Commercial Vessel Compliance, USCG CG-ENG Office of Design and Engineering Standards, USCG COI Certificate of Inspection DVG Design Verification Guide ft feet ft-ABL feet above baseline GM metacentric height GMI metacentric height, increment (used in grain calculations) GMR metacentric height, required GPM gallons per minute GZ Righting Arm Acronyms and Abbreviations xiii

xiv ACRONYMS AND ABBREVIATIONS HEC Herbert Engineering Corporation IACS International Association of Classification Societies IMO International Maritime Organization IMO HSC International Maritime Organization High Speed Craft Code IMO MSC International Maritime Organization Maritime Safety Committee IS Code Intact Stability Code, IMO ISO International Organization for Standardization ITC International Convention on Tonnage Measurement of Ships KM height of metacenter above the keel LBP length between perpendiculars lbs pounds LCG Longitudinal Center of Gravity LT long ton(s) m meter m-ABL meters above baseline MARAD U.S. Maritime Administration MARPOL International Convention for the Prevention of Pollution from Ships MBI Marine Board of Investigation MISLE Marine Information for Safety and Law Enforcement MMT Merchant Marine Technical Center MSC Marine Safety Center MSM Marine Safety Manual mt metric ton MTN Marine Safety Center Technical Note MTWB main transverse watertight bulkhead NAE National Academy of Engineering NASSCO National Steel and Shipbuilding Company NPRM Notice of Proposed Rulemaking NRC National Research Council NTSB National Transportation Safety Board NVIC Navigation and Vessel Inspection Circular pct percentage PFM Policy File Memorandums

ACRONYMS AND ABBREVIATIONS xv PRG Plan Review Guideline PVA Passenger Vessel Association RA Righting Arm (also referred to as GZ) RHFC Rigid Hull Foam Collar RHI Rigid Hull Inflatables RIB rigid-inflatable boat ro-ro/RO-RO roll-on/roll-off ships SDC Sub-Committee on Ship Design and Construction SNAME Society of Naval Architects and Marine Engineers SOLAS International Convention for the Safety of Life at Sea SST Simplified stability proof test TGMD Timothy Graul Marine Design TRB Transportation Research Board USCG U.S. Coast Guard VCG Vertical Center of Gravity