Wednesday, June 13, 2012

Alternate Safety Compliance Programs

USCG and affected industry parties strategize to target safety performance variability

By Leslie Hughes and Cdr. Chris Woodley

The Coast Guard Authorization Act of 2010 provides for the development of regional and fishery-specific safety programs, known as alternate safety compliance programs (ASCP). Such programs provide an alternative safety standard to existing vessels that cannot meet future requirements of vessel classification and loadline.

In fact, the 13th and 17th Coast Guard Districts have had much success with this kind of regional approach. Additionally, the recent Alternate Compliance and Safety Agreement has resulted in a comprehensive vessel inspection and training program for more than 50 catcher-processor vessels operating in the Bering Sea/Aleutian Island region.

Measuring Risk in the Fishing Industry
Since 1990, the National Institute for Occupational Safety and Health (NIOSH) Alaska Pacific Regional Office has monitored the safety performance of fishing fleets throughout Alaska by measuring individual fleet fatality rates. Fatality rates are measured by comparing the ratio of the number of fatalities to an occupational risk exposure.

This operational risk exposure measurement is based upon several variables including:
• The number of vessels operating,
• The number of days the vessel is at sea,
• The number of crewmembers exposed to the occupational risk.
Review of this data clearly demonstrates that fatality rates and causal factors are highly differentiated among vessel types, fishery gear, species being fished, and geographic region.

Risk is Regional
For example, a recent safety study found that in the waters of the state of Alaska there were nearly 60 different vessel/gear/species combinations, with each fishery having significantly different fatality rates and casual factors.

Some of these fisheries had high rates of falls overboard related to gear-specific operational practices, some had problems with vessel stability, and other fisheries had a large number of capsizing events due to poor weather and local geographic features. Other fisheries had virtually none of these problems.

Alternate Safety Compliance Programs
Once a fishery has been determined to be high-risk and considered for an alternate safety compliance program, the Coast Guard and affected industry parties consider which strategies could prevent fatalities or vessel losses. Specifically, mitigation strategies should focus on achievable improvements, with some of the following considerations in mind.

Training: Are the risks associated with a particular fishery such that crewmembers would be better prepared to deal with the most common emergencies if they had more extensive training and/or if additional crewmembers received training? Is there a need for customized training to address the particular hazards a gear type encounters? Do crews actually conduct drills on a regular basis? Is there a need for increased compliance?

Structural Considerations: Are vessel losses due to poor hull condition, downflooding, overloading, or a combination of these? Are vessels seaworthy and able to withstand the sea conditions encountered? Do crews maintain watertight and weathertight closures? Do vessels have adequate stability for typically encountered loading conditions? Are captains adhering to vessel loading limits?

Operational Factors: Does a vessel need to cross a hazardous bar to get to the fishing grounds? Does the vessel operate in remote areas, far from Coast Guard search and rescue? How many people are aboard the vessel? Is processing conducted on board? Is fatigue an issue? Do crews adhere to watchkeeping standards?

Equipment Issues: Does the onboard safety equipment address the most common types of fatalities within the fleet? Is there better or more appropriate lifesaving equipment? If man overboard fatalities are a problem, do crewmembers wear flotation when working on deck? Do crewmembers wear strobe lights on their immersion suits?

Compliance: Are fatalities occurring within a fleet despite high levels of participation with the Coast Guard Dockside Exam Program? What is the level and quality of interactions with the Coast Guard? Could fatalities be reduced with increased compliance with existing fishing vessel safety regulations? Does the vessel carry required lifesaving appliances? Is lifesaving equipment well maintained and serviceable?

Implementing an ACSP
For an alternate safety compliance program to be successful, the Coast Guard must have a solid under­standing of actual industry practices, and risk to the fleet. Industry needs to acknowledge risks and be willing to move forward in order to mitigate them.

True collaboration with industry is vital. As such, each side must sublimate its own agenda to the overall goal of effectively reducing risk. Some guidelines include:

  • All parties should understand that quantifying the safety improvements might take years. This should not be viewed as a deterrent to establishing incre­mental safety improvements.
  • All entities must be realistic about what will be required to implement an alternate safety compliance program and adequate resources must be dedicated to conduct the program.
  • Both Coast Guard and industry must be flexible regarding how risks can be mitigated as well as how a safety regime can be upgraded. As the alternate safety compliance program for a particular fleet evolves, additional concerns may be discovered and changes to the requirements may result.
  • The Coast Guard must assume the lead for compliance with ACSP provisions by providing clear program guidance.
  • The Coast Guard must exercise continuous evaluation of industry’s progress and assess the effectiveness of the ACSP.
Leslie Hughes was the executive director of the NPFVOA vessel safety program until 2008, when she became the director of industry and government affairs. She has been actively involved with the commercial fishing industry for more than 35 years and currently serves on the Coast Guard’s Commercial Fishing Industry Vessel Safety Advisory Committee. She has received two Coast Guard meritorious public service awards for promoting safety for commercial fishermen.

CDR Chris Woodley is currently chief of the Prevention Department at Sector Puget Sound. As a 20-year career marine safety officer, he has enjoyed being able to collaboratively work with the North Pacific fishing industry in multiple tours and capacities as a senior marine inspector, an investigating officer, an oil spill responder, and as a fishing vessel safety/fishery management policy analyst. CDR Woodley graduated from the University of Oregon and also has a Master of Marine Affairs degree from the University of Washington.

This article originally appeared in the Winter 2010-11 US Coast Guard Proceedings.

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