Enhancing Safety at Sea

The following text was e-mailed from me to a large number of key individuals, Superyacht management companies and relevant editors on 5 January. It's focused at the Superyacht community as that's where my company work but it's just as relevant to the remainder of the maritime industry. I thus thought it may be beneficial to publicise via LinkedIn to the wider audience.

Firstly, (belated) Happy New Year.

No doubt we are all hoping for a better year than the last (lockdowns aside) and to get things started I wanted to take this opportunity to highlight some concerns which have been evident over the past few years when we have worked with clients in respect to navigation and firefighting. 

With so many yachts having spent an extended period alongside in the past 12 months, a deliberate focus should be placed on crew training prior to resuming operations. Points within this message are not directed at any one specific vessel but have been collated over the last decade and represent just a pinnacle of issues we have identified on board.

I fully recognised many of you in well-known / run management companies may believe these are not relevant to your vessels as you feel you run a tight ship so what am I bleating on about? However, with over30 years at sea and the past 11 working directly in the Superyacht industry I hope you will afford me the opportunity to highlight what I and my trainers have seen that maybe you do not when conducting expected audits. This is all evidence based collated during visits to vessels but so much more could be forthcoming if the industry were not so wrapped up in the excessive confidentiality agreements that limit the release of information post incident and which would be of great benefit to all training organisations and regulators as points for learning and improvement. On too many occasions we visit new build yachts where crew sit frustrated knowing they are facing the same problems the previous build had but no-one seems to learn from it. Accidents at sea are no doubt being repeated but again, as so many remain legally stifled, lessons are not being learnt. Is that really an effective way to operate in the 21st Century?

Those who know me will know my motivation is to enhance safety at sea and with continual emphasis on crew welfare these days, more needs to be done to ensure these individuals are not just given the right training, but that it is refreshed properly and regularly. Crew should be cautious when they chose not to refer to training experts as this can lead to the blind leading the blind. If owners expect their crew to come to their rescue in a fire, flood, grounding or man overboard, then it is time to start improving the training and providing dedicated time to conduct it more effectively. Conducting man overboard exercises alongside or at anchor in daylight, light winds and sea state zero does not necessarily prepare for the real event at 0300 underway in a force 5. 

I am not saying you need to use us as there are many companies out there providing training, but too often we are finding errors in procedures on board which will lead to a dramatic accident after which there will be an unnecessary industry knee-jerk reaction on regulations that already exist. They are just not being followed.

Below are the key points for which a more detailed breakdown of what we are talking about can be found at the end of this e-mail:

Navigation and outfits

·        Masters Standing Orders are not personalised. 

·        Poor understanding of COLREGs.

·        Failure to maintain an up-to-date paper chart outfit in an effective manner.

·        Poor passage planning. 

·        Poor passage execution. 

·        Incorrect navigation lights on display with towed tenders.

ECDIS

·        Lack of understanding between an ECDIS and an ECS.

·        OOW’s not competent in operating the ECDIS.

·        ECDIS incorrectly set-up by the manufacturer.

·        A lack of understanding of ECDIS ‘type familiarisation’ training.

·        Not conducting annual or post leave familiarisation refreshers on the ECDIS.

·        Risk Assessments (in accordance with MGN285) are lacking or wrong.

·        Installation of permits, charts and updates is sporadic or the OOW lacks certainty of how to complete it.

·        A failure to download all the necessary best scale charts for the passage prior to sailing.

·        Not understanding the survey data (CATZOC’s).

·        Routes are not scanned prior to sailing.

·        Cross Track Distances (XTD’s) are set incorrectly. 

·        Safety contour and safety depth settings are incorrectly set for the vessel.

·        Passage plans either not conducted or missing key information.

·        Management representatives or auditors not aware of the functionality and capability of the ECDIS or how to check for updates.

·        Inability by the OOW to demonstrate fixing by alternate methods into the ECDIS despite this usually being in the Master Standing orders or ISM.

·        SMS and Master Standing Orders lacking clarity or providing legal loopholes.

Firefighting

Without wishing to sound derogatory or condescending, crew are not firefighters. Breathing Apparatus (BA) is carried on board as a dispensation under SOLAS to provide some form of emergency equipment to be used by in-date crew. It is there for possible extraction of casualties from a smoke-filled environment or if no suppression system is fitted or functioning, to attempt to fight a fire, if it is safe to do so. Subsequently it has to be considered, are crew really safe to operate and use the BA if they’ve only attended a two-day basic course and then 5 yearly refresher? While drills may take place on board on a ‘regular’ basis, are the procedures which are carried out correct and in accordance with the latest industry standards?

What does not help is shore fire training establishments using land-based firefighters to train mariners. If you have not served at sea you do not understand the differences involved and a case in point is boundary cooling. Anyone who says you boundary cool with a fire hose spraying all over a bulkhead, deckhead or deck clearly does not understand stability. With different training schools around the world all teaching procedures slightly differently it leaves crew with no definitive manner in which to execute procedures safely on board.

Our experience when conducting on board training has found the following to be regular points for improvement:

 ·        Dressing procedures for the BA are not in accordance with the guidance provided by the BA manufacturers. 

·        Lung demand valves wrongly disconnected from masks in storage.

 ·        Face seal checks with the BA are either not done or are not carried out IAW the manufacturers guidance. 

·        A failure to understand the differences between strategic, tactical and operational roles in an emergency on board.

·        Incorrect stair drills, door opening and firefighting procedures.

·        Lack of awareness on when BA gauge checks are required.

·        Incorrect boundary cooling techniques.

·        A lack of understanding between training and drills.

·        Not rotating crew through different positions in the emergency muster list.

·        Dry Powder extinguishers used internally.

Summary

As stressed at the start, I am not sending this e-mail to pick-up faults with management companies but very much to work with those companies who do not employ specialists within the area of navigation and firefighting. We spend everyday dealing in these areas and thus know the pitfalls vessels fall into which is why we work so hard to help our clients not just understand these areas but also find the most efficient and effective way to operate.

There is more that should be done in respect to refresher training for crew to ensure their standards are of the highest level and to subsequently keep the yacht and all those on board as safe as possible. Subsequently we believe there should be closer and more open engagement between yachts, management, regulators and most importantly, training centres to ensure lessons are learnt and procedures or equipment adapted to aid the mariner.

Owners should have it made clear to them their crew are their lifeline. As much as they rely on them to ensure an enjoyable experience is had on board, they should therefore make it clear they wish their crew to receive the highest level of training with external assistance from experienced trainers and not just rely on self-instruction. This should result in time and funds being allocated into the programme to achieve it rather than trying to shoe-horn it in or worse, falsify records of having done training.

We therefore hope the above will be of use and remain available to answer any questions you may have or points you wish clarification on.

Clarification of the points raised above can be found after the e-mail signature block.

Wishing you and all crew the very best for 2021.

Steve Monk

CMMar FRIN AFNI

Navigation and outfits

·        Masters Standing Orders are not personalised. Captains should take pride in using the 1st tense to emphasise they wrote these, not management. You are the Captain / Master so make that clear to your crew / bridge team as it will gain you greater respect.

·        COLREGs understanding. When was the last time the bridge team did a Rules of the Road test? We set them during our nav training and the average yacht score is between 45 – 55%. Rule 19 (restricted visibility) is a particularly misunderstood rule. The answer I was once given of “I don’t go out in fog” does not cut it and demonstrates a flippant attitude to safety.

 ·        A failure to open bridge wing doors in restricted visibility to hear other vessels or warning signals. Perhaps if you place a lookout on the upper deck you could get away with this but the OOW should really be able to hear the sounds in accordance with Rule 5 (lookout).

 ·        Staying on Rule 5, are you really sure you want to a) allow music on the bridge or b) write it in the Master standing orders that it is permitted? Irrespective of how low you may state the volume should be to hear the VHF, a legal team will love to pick this apart after a collision or grounding.

 ·        Paper charts are not up-to-date for the current or next voyage or not replaced by new editions when issued. Too many ‘private’ yachts play the ‘private’ card and will not have a leg to stand on with the subsequent legal case when on the rocks dealing with a MARPOL issue too. Similarly, with so little training in outfit maintenance on formal courses, the knowledge of how to maintain an outfit is severely lacking.

 ·        Poor passage planning. For those still using paper charts as the primary means of navigation, nearly every single chart we have seen either on board or returned to us for storage lacks anything like the level of detail which is taught on course in both planning and execution. Parallel Indices are rarer than Noah’s Ark. 

 ·        Passage execution. For those on paper charts, placing a single GPS fix once per hour when less than 12nm from the safety contour or limiting danger line is unsafe and contravenes most Masters standing orders (that usually state ‘fix regularly’). With no DR or EP on the chart you have no idea where you are unless of course you are relying on the electronic navigation system which unless it is a certified ECDIS and you are primarily operating on ECDIS, raises the question why are you on paper charts? More likely it is an ECS and thus not cleared for primary means of navigation.

 ·        For yachts which tow a tender, do you have and display appropriate lights in accordance with the COLREGS? Those who simply put the normal ‘underway’ lights on the tender are wrong and asking for trouble when someone tries to cut between you and the tow.

ECDIS

·        There is a lack of understanding between an ECDIS and an ECS. One is legally compliant on which to navigate and one is not. Some vessels are consciously navigating on unofficial electronic charts without necessarily understanding the difference. Many of the sub-50m yachts at Charter Shows fall into this category and would give a port state inspector a field day in the event of an unannounced inspection.

 ·        OOW’s are not competent in operating the equipment effectively, do not set up the display to the most effective modes and lack familiarisation knowledge. Not setting ‘profiles’ on Transas is a classic example.

 ·        ECDIS incorrectly set-up by the manufacturer with no account made for the offset of the GPS arial or other sensors.

 ·        A lack of understand of ECDIS ‘type familiarisation’. The IMO changed the rules in 2017 yet still many out there don’t understand the requirements. There is huge skill fade in the equipment use and as the generic course is not designed to teach you how to use the ECDIS, operators need to be more competent in the operation of the ECDIS.

 ·        Not conducting annual or post leave familiarisation refreshers on the ECDIS. The commercial shipping industry is getting closer to mandating annual refreshers but yachts also need to consider implementing not just annual refreshers but reminding bridge officers when they return from rotational leave to conduct a short refresher on the equipment.

 ·        Risk Assessments (in accordance with MGN285) are poorly written and fail to demonstrate an understanding of chart handling.

 ·        Installation of permits, charts and updates is sporadic or an uncertainty of how to complete it. While this is the fault of the OOW who shouldn’t proceed to sea without knowing how to do this, it’s also the fault of the manufactures who write manuals over 400 pages long that no one reads and they don’t explain how to do this simply.

 ·        A failure by the vessel to download all the necessary best scale charts for the passage prior to sailing. Classics here have been panicked phone calls to our office asking how to get charts to install when on passage and approaching a blank screen.

 ·        Not understanding the survey data (CATZOC’s) or where to find them and certainly rarely referring to them when passage planning. Captain’s who say they would never navigate in areas of CATZOC ‘U’ should look carefully at some of the most common superyacht cruising grounds.

 ·        Routes are not scanned prior to sailing. This is inexcusable but sometimes it is missed as the OOW does not want to have to deal with clearing warnings and alarms. If the ECDIS is trying to alert you to dangers ahead on the route, it leaves you with no mitigation when standing in front of the judge because you chose to not scan the route to check for hazards.

 ·        Cross Track Distances (XTD’s) are set incorrectly. They should NOT be as small as possible with the intention to limit the number of cautions and warnings. This demonstrates a failure to think of the big picture when executing the passage.

 ·        Safety contour and safety depth settings are incorrectly set for the vessel with a misunderstanding of how to use these effectively or vary them as the yacht moves in or away from land.

 ·        Passage plan briefs to the bridge team either not done or lacking information key to the intended route. Excessive time spent printing documentation (ADP’s SD’s etc) which will not be referred to. Lists of waypoints sent to management which is meaningless if not then all plotted to prove the yachts planned passage is safe.

 ·        Management representatives or auditors not aware of the functionality and capability of the ECDIS or who lack familiarity on checking charts, updates, route planning / scanning and checking.

 ·        Inability by the OOW to demonstrate fixing by alternate methods into the ECDIS despite this usually being in the Master Standing orders or ISM. Too much emphasis is put on satellite systems to ‘confirm’ the position and subsequently no checks are done to compare that with radar or visual fixes even though it is generally recorded in most standing orders.

 ·        SMS and Master’s Standing Orders lacking clarity or providing loop holes which could be exploited in the event of an investigation.

Firefighting

Our experience when conducting on board training has found the following to be regular points for improvement:

 ·        Dressing procedures for the BA are not in accordance with the guidance provided by the BA manufacturers and subsequently slow things down in getting the team ready for executing the Command Aim. 

 ·        Drager BA sets (one of the most prevalent in the industry) are being stowed with the face mask disconnected from the Lung Demand Valve (LDV) which is against Draeger instruction. This is being done as BA teams dress by putting on the mask but do not conduct the right face seal checks and thus believe they’re ok to leave the LDV disconnected.

 ·        Face seal checks with the BA are either not done or are not carried out IAW the manufacturers guidance. Sticking fingers between the mask seal and face is not in the Draeger manual. Shaking your head with the mask on is not in the Draeger manual. There are however four checks that Draeger do advise but these are rarely followed by (untrained) crew.

 ·        A failure to understand the differences between strategic, tactical and operational roles in an emergency on board. For example, why are BA teams dressed and committed to tackle a fire in a compartment when the doors have been closed, ventilation shut down, all personnel accounted for, boundary cooling established and suppression system activated?

 ·        Incorrect stair drills, door opening and firefighting procedures. ‘Pulsing’ has slipped its way into some training schools but this can only be achieved with the right equipment which not all yachts carry. However, while it is a highly effective way of knocking down a fire, if you get it wrong you will make things much worse. Shoreside firefighters receive two days training in this annually. Mariners do not.

 ·        Lack of awareness on when BA gauge checks should be conducted but these are not done as crew have forgotten what they are or get distracted. They exist for a safety reason and must be followed.

 ·        Incorrect boundary cooling techniques. As mentioned earlier, using a fire nozzle to soak a bulkhead is not necessary and does not help the stability issue. Boundary cooling can be achieved with a bucket and sponge but that is not taught at the fire schools as it is not deemed exciting. Subsequently crew do not do this for real on board.

 ·        A lack of understanding between training and drills. Drills should identify weaknesses in the training from which training should be targeted to review those procedures and rectify problems. The next drill should determine if the training has worked. The emphasis should not be on full drills but improving the training which can be done by the crew if they are following appropriate and correct procedures.

 ·        Not moving crew through different positions on board. Why is it assumed the BA team members will always be available and why are Captains rarely the casualty? Well worked up crew should be rotated into different positions for some drills to provide back-up capacity in an emergency. All crew must be competent and confident to wear the BA set.

 ·        Dry Powder extinguishers in accommodation spaces. These were never intended for use in accommodation spaces as they were developed for the Petro-chemical industry to fight oil and fuel fires however because they are usually the cheapest out there, they are often found in internal spaces where they will cause more damage to a compartment than a small fire. They are also dangerous to crew who enter a space without breathing apparatus and could lose their situational awareness to an exit.