Options for Improving the Safety of DUKW Type Amphibious Vessels (2021)

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13 Safety experts have known for a long time that DUKWs have had hazards that can increase the risk of loss of life for passengers and crew. Some haz- ards are connected to obsolete design elements unique to an amphibious vehicle that must travel safely on land and water. Other hazards date back to its original use as a military vehicle intended to be operated and occupied by healthy, fit men in an already high-risk combat environment. Restrictive canopies, however, are a hazard that have been added to the vessels specifi- cally to facilitate their use for sightseeing tours. The United States Coast Guard (USCG) oversees safety for DUKWs using a mix of regulations and guidance policy documents. DUKWs, as small passenger vessels, are regulated under a structure that requires the Officer in Charge, Marine Inspection (OCMI) to exercise significant independent judgment when determining what is safe for unique vessels such as DUKWs. Part of the challenge of DUKW safety is to create procedures that will sup- port OCMIs in making consistent evaluations of diverse vessels in a variety of operating areas. This chapter provides of brief history of DUKWs and the major casu- alty events—accidents or incidents—that led to investigations, studies, and recommendations by government agencies and that also formed the core set of examples for committee study. The chapter presents summary data on fleet size, location, and casualty types and events and provides an overview of the current regulatory structure, key regulations, and the guidance docu- ment, “Navigation and Vehicle Inspection Circular No. 1-01 (NVIC 1-01).1 1 See https://www.dco.uscg.mil/Portals/9/DCO%20Documents/5p/5ps/NVIC/2001/n1-01.pdf. 2 DUKW Boats and Safety

14 OPTIONS FOR IMPROVING THE SAFETY OF DUKW TYPE AMPHIBIOUS VESSELS Recommendations stemming from the major casualty events in the United States and United Kingdom are reviewed. The chapter closes with an over- view of the concept of survivability with respect to both the vessel and the persons on board. BRIEF HISTORY DUKWs were originally produced for the U.S. military during World War II. The design, funded by the National Defense Research Committee, modified a cargo truck manufactured for the military by General Motors Corpora- tion. Commonly known as “ducks,” DUKW is not an acronym but nomen- clature for the design: D = 1942, U = utility, K = front-wheel drive, and W = two rear-driving axles. Although intended to meet immediate war needs only, DUKWs went on to serve in the Korean War and were deployed for scientific research, search and rescue operations, and tourism. Military surplus DUKWs saw use for sightseeing tours as early as 1946. Tour operators acquired them as unique and interesting vehicles for making combined land and water tours, and many of the tour opera- tions celebrate the vessels’ historic ties to World War II. Tours are typi- cally advertised as family-friendly and welcome infants and children. To accommodate sightseeing, operators have made numerous modifications to the military DUKWs for passenger safety and comfort and to comply with regulations. Common alterations include adding passenger seating, accommodations to ease boarding, and canopies with and without side curtains. Although many of the DUKWs still in use are from the 1940s, Ride the Ducks International of Branson, Missouri, modified the original DUKW design to develop the Stretch Duck in the 1990s and the Truck Duck in the 2000s for use in sightseeing tour businesses. For Stretch Ducks, they used the original WWII chassis, resulting in a freeboard similar to WWII DUKWs. Truck Ducks are built around a different chassis and the freeboard is higher than for the other DUKW types. For the purposes of this report, the World War II DUKW, Stretch Duck, and Truck Duck are all considered DUKW vessels; their specifications are summarized in Box 2-1. In recent years, DUKWs have been used for sightseeing tours in Boston, Massachusetts; along the Gulf Coast in Alabama and Galveston, Texas; Hot Springs, Arkansas; Chattanooga, Tennessee; Wisconsin Dells, Wisconsin; and the island of Guam. Tours were also offered by Ride the Ducks Inter- national and its franchisees in Baltimore, Maryland; Branson, Missouri; Philadelphia, Pennsylvania; San Francisco, California; Seattle, Washington; and elsewhere until a string of fatalities on water and land ended the busi- nesses. Internationally, World War II DUKWs have been used for amphibi- ous tours in London, Liverpool, and Dublin.

DUKW BOATS AND SAFETY 15 Amphibious passenger vehicles (APVs) must operate safely both on land and on water. The three types of DUKWs are more like a truck that floats, as opposed to a boat that can go on land. The DUKWs’ unique design has presented numerous challenges to safe use on water. Moreover, the DUKWs of the WWII era are now over 75 years old, and the Stretch Ducks and Truck Ducks are no longer being produced and their developer is no longer in business. MAJOR CASUALTY EVENTS ON WATER The committee studied eight marine casualty events involving DUKWs that have occurred since 1999 in the United States and the United Kingdom. This overview provides basic information about the casualty events; more detailed descriptions of specific issues will be highlighted in the relevant chapters. DUKWs proved to be unusually fast sinking during the casualty events in the United States and the United Kingdom that involved progressive flooding. As shown in Appendix B, a 4-inch diameter hole below the waterline could cause a DUKW with a freeboard of 24 inches to sink in 15 minutes. The actual time to sink would likely be less than 15 minutes, depending on winds and waves and the likelihood that the passengers and BOX 2-1 DUKW Vessel Types WWII DUKW Amphibious Truck • Typical Length and Beam: 31.0' L × 8.0' B • Freeboard: About 12" to 24" Stretch Duck • Sold by Ride the Ducks International, Branson, Missouri • WWII GMC chassis stretched by 15", new hull, new engine and drive train • Typical Length and Beam: 33.0' L × 8.0' or 8'-6" B • Freeboard: About 12" to 24" Truck Duck APV • Sold by Ride the Ducks International, Branson, Missouri • Similar design and layout to WWII DUKW, but with different chassis and larger hull • Purpose built for tours • Typical Length and Beam: 33.0' L × 8.0' or 8'-6" B • Freeboard: About 24" to 33"

16 OPTIONS FOR IMPROVING THE SAFETY OF DUKW TYPE AMPHIBIOUS VESSELS crew moving around the vessel would increase the rate of flooding. More- over, WWII DUKWs and Stretch Ducks may have a freeboard as low as 12 inches. During the sinkings with mass fatalities, survivors and witnesses reported that their boat submerged in just a few minutes or even less. Events with Fatalities Three incidents led to multiple deaths: the Miss Majestic flooding and sink- ing in 1999 that killed 13; the collision of a barge with DUKW 34 in 2010, which led to 2 passenger deaths; and the Stretch Duck 7 flooding and sink- ing in 2018 that resulted in 17 deaths. All victims drowned. The Miss Majestic, a WWII DUKW, sank in Lake Hamilton, Hot Springs, Arkansas, on May 1, 1999, with 20 passengers and the master on board. Among the 13 fatalities were 3 children ages 3, 4, and 5. The vessel flooded and then sank after a driveshaft boot seal in the hull failed following an improper repair to the seal. The bilge pumps were inadequate to remove the incoming water. Once the DUKW sank low enough to flood over the stern, the boat became completely submerged in about a minute. Passengers attempted, but failed, to don life jackets. Passengers also strug- gled or failed to escape the vessel because of a canopy with small window openings that impeded exit over the sides and a windshield surrounded by plastic curtains that blocked forward egress.2 DUKW 34, a Stretch Duck, sank after a collision with a barge in the Delaware River, Philadelphia, Pennsylvania, on July 7, 2010. Of the 33 passengers and 2 crew on board, 2 passengers—a young adult male and a female teenager—did not survive. The series of events that led to the sinking began when the master of DUKW 34 executed procedures for a fire emer- gency that included anchoring the vessel. After anchoring DUKW 34, its crew and the crew of the barge’s tugboat failed to follow safety procedures intended to prevent collisions. At the time of the collision and rapid sinking, all passengers were still on board the vessel, scrambling to don life jackets.3 Stretch Duck 7 sank in a storm on Table Rock Lake, near Branson, Missouri, on July 19, 2018. Of the 31 persons on board, 16 passengers and 1 crew member died. Among the fatalities were 4 children under age 10, 5 adults in their 60s, and 4 adults in their 70s. Although a severe thunder- storm warning had been issued for the area including Table Rock Lake, 2 National Transportation Safety Board (NTSB), 2002, “Sinking of the Amphibious Passenger Vessel Miss Majestic, Lake Hamilton, Hot Springs, AR, May 1, 1999,” Marine Acci- dent Report NTSB/MAR-02/01, April 2. https://www.ntsb.gov/investigations/ AccidentReports/ Reports/MAR0201.pdf. 3 NTSB, 2001, “Collision of Tugboat/Barge Caribbean Sea/The Resource with Amphibious Passenger Vessel DUKW34, Philadelphia, PA, July 7, 2010,” Marine Accident Report NTSB/ MAR-11/02, June 21. https://www.ntsb.gov/investigations/Pages/DCA10MM025.aspx.

DUKW BOATS AND SAFETY 17 the operators “likely believed,” according to the National Transportation Safety Board (NTSB), that they “could safely complete the waterborne portion of the tour before the thunderstorm arrived.” Instead, the weather suddenly shifted and large waves, which exceeded the vessel’s operating limits, led to progressive flooding. The vessel foundered and then capsized. As water surrounded their feet, survivors reported standing up in an at- tempt to retrieve life jackets, which were stored overhead in the canopy, and suddenly being up to their necks in water. The vessel’s canopy, with one of two side curtains still covering the windows, likely slowed or prevented escape.4 Other Casualty Events Additional casualty events, fortunately with no or only minor injuries, provide insights into the safety risks of flooding and fire for DUKWs. These events include several in the United Kingdom. A Stretch Duck on Lake Union, Seattle, Washington, sank in Decem- ber 2001 while under tow back to the maintenance facility. The cause of the flooding was a mechanic’s failure to replace a 4.5-inch hull drain plug, which was not caught during inspection, after a repair. Stretch Duck 7, the DUKW that sank in 2018, was involved in an earlier flooding incident in 2015; the master created a large splash when entering the water, and water came in through the engine compartment vents and the vessel lost propulsion. In the United Kingdom, two WWII DUKWs operating for tours at Salthouse Dock, Liverpool, sank in March 2013 and June 2013 after hull penetrations. Both DUKWs had been modified with buoyancy foam that proved inadequate to prevent sinking. Wacker Quacker 4 sank from a miss- ing drain plug. The passengers had already disembarked, and the vessel, which had also suffered a steering failure, was under tow at the time of the sinking. Wacker Quacker 1 sank with its passengers still on board. As the boat began to take on water, the passengers attempted to pass out life jackets and many began jumping out over the sides. Fortunately, the vessel was in shallow waters near the shore, and the stern of the boat did not become fully submerged, allowing all passengers and crew to escape.5 The Cleopatra, a WWII DUKW operating on the Thames River, London, suffered a fire while on tour in September 2013. Investigators 4 NTSB, 2020, “Sinking of Amphibious Passenger Vessel Stretch Duck 7, Table Rock Lake, near Branson, MO, July 19, 2018,” Marine Accident Report NTSB/MAR/20-01, April 28. https://www.ntsb.gov/news/events/Pages/2020-DCA18MM028-BMG.aspx. 5 Marine Accident Investigation Branch (MAIB), 2014, Very Serious Marine Casualty Report NO 32/2014, December. https://assets.publishing.service.gov.uk/media/54c1722240f0b6158d00002b/ MAIBReport_32-2014.pdf.

18 OPTIONS FOR IMPROVING THE SAFETY OF DUKW TYPE AMPHIBIOUS VESSELS concluded that the fire started when overheated machinery ignited the buoyancy foam, which was tightly packed into the hull and had become contaminated with grease. Upon noticing the fire, the master maneuvered the DUKW close to the shore. As flames engulfed the passenger compart- ment, passengers escaped over the sides or down the ladders at the stern and into the water.6 Casualty Events on Other Small Passenger Vessels According to a recent report, 6,097 Subchapter T vessels held a valid Cer- tificate of Inspection (COI) during the 2020 calendar year.7 Of these 6,097 vessels, only 127 were listed as amphibious vessels, approximately 2 per- cent of the entire Subchapter T fleet. In comparison, charter fishing vessels numbered 1,005 vessels (16 percent) of the fleet and excursion/tour vessels numbered 2,248 vessels (37 percent) of the fleet. While the number of DUKW vessels in operation has decreased over time, the total number has never been a large percentage of all Subchapter T vessels. To compare DUKW casualty events to similar events on other Sub- chapter T vessels, the committee examined casualty incidents for all small passenger vessels from 1995 to present from NTSB’s accident reports that resulted in deaths or injuries.8 The results are summarized in Table 2-1. Of the casualty events between 1995 and 2021, 3 of the 12 events involved amphibious vessels (specifically DUKW boats) and included 39 percent of the total deaths (32) and 38 percent of the total injuries (33), while repre- senting roughly 2 percent of the Subchapter T fleet. Furthermore, all three DUKW casualties involved a flooding or capsizing event while carrying passengers. In comparison, the remaining 98 percent of the Subchapter T fleet suffered 61 percent of the total deaths (51) and 62 percent of the total injuries (53). Three of the remaining nine events on other Subchapter T ves- sels involved flooding or capsizing, representing 16 deaths and 24 injuries. DUKW FLEET SIZE AND LOCATION The DUKW fleet in the United States is made up of vessels under two regulatory structures: vessels requiring a COI issued by USCG and vessels subject only to the regulations of their respective states. About 130 to 150 DUKWs are located in Wisconsin and operated under state jurisdiction by 6 MAIB, 2014, Very Serious Marine Casualty Report NO 32/2014, December. https://assets. publishing.service.gov.uk/media/54c1722240f0b6158d00002b/MAIBReport_32-2014.pdf. 7 See Table 2 of USCG-PVA Quality Partnership Annual Report, 2018-2020, https://www.dco. uscg.mil/Our-Organization/Assistant-Commandant-for-Prevention-Policy-CG-5P/ Inspections- Compliance-CG-5PC-/Office-of-Investigations-Casualty-Analysis/Marine-Casualty-Reports. 8 See https://www.ntsb.gov/investigations/AccidentReports/Pages/Reports.aspx.

DUKW BOATS AND SAFETY 19 two major DUKW tour operators, Original Wisconsin Ducks and Dells Army Ducks. As of early 2021, 58 DUKWs had an active COI, the majority of which were Truck Ducks. Only 3 Stretch Ducks still have active COIs. Examples of fleets under USCG jurisdiction include Boston Duck Tours, Boston, Massachusetts; Gulf Coast Ducks, Orange Beach, Alabama; National Park Duck Tours, Hot Springs, Arkansas; Chattanooga Ducks, Chattanooga, Tennessee; and Ride the Ducks, Tumon, Guam.9 As recently as 2019, the DUKW fleet with COIs numbered 123, and between 2000–2021 197 DUKWs have been active in the USCG-regulated fleet. Although many of these vessels have been taken out of service or scrapped, the potential fleet size under USCG jurisdiction is larger than the current 58 vessels.10 The fleets operate in a variety of environments. Table 2-2 describes the numbers of DUKWs under USCG’s jurisdiction for years 2019 and 2021 that operate in rivers versus lakes, bays, and sounds and in protected versus partially protected waters. Partially protected waters (defined in Box 2-2) are a higher risk envi- ronment for DUKWs. Currently, only Truck Ducks, which have a higher freeboard, follow routes in partially protected waters. The safety implica- tions of the route types are discussed more fully in Chapters 3 and 4. USCG REGULATORY OVERSIGHT USCG has regulatory oversight over DUKWs that engage in commercial operations on the navigable waters of the United States. As small passenger vessels, safety on DUKWs is regulated under Title 46 of the Code of Federal Regulations (CFR) Chapter I, Subchapter T, Small Passenger Vessels under 100 Gross Tons (hereafter “Subchapter T”). These regulations cover all as- pects of the DUKWs, from hull fabrication, machinery and electrical, safety equipment, stability and seaworthiness, and vessel operations. Stability regu- lations in Subchapter S may also apply. Box 2-3 lists the key applicable regulations in Subchapters S and T. USCG applies the regulations through the process of issuing a COI and, in some cases, stability letters. Vessels with a COI are inspected annually, and the inspections include safety operations. The OCMI has the discretion under Subchapter T to accept alternatives to Subchapter T’s requirements. However, the OCMI must determine that 9 Boston Duck Tours, https://bostonducktours.com; Gulf Coast Ducks, http://gulfcoast- ducks.com; National Park Duck Tours, http://rideaduck.com; Ride the Ducks, Guam, https:// bestguamtours.com/cruises/ride-the-duck. 10 Committee review of USCG, Marine Information for Safety and Law Enforcement (MISLE) database, data provided by USCG.

20 OPTIONS FOR IMPROVING THE SAFETY OF DUKW TYPE AMPHIBIOUS VESSELS TABLE 2-1 Summary of NTSB Subchapter T Small Passenger Vessel Accident Reports from 1995 to 2021 NTSB Report Name and Accident # Date of Accident Type of Vessel Inspection Subchapter Type of Accident Deaths Injuries Total Number Onboard P/V Conception (DCA19MM047) 9/2/2019 Overnight T Fire in Accommodation Space 34 2 38 P/V Stretch Duck 7 (DCA18MM028) 7/19/2018 Stretch DUKW T Flooding by Storm Conditions 17 7 31 P/V Island Lady (DCA18FM010) 1/14/2018 Passenger Shuttle T Fire in Engine Room 1 14 53 P/V Tahoe Queen (DCA16FM054) 8/16/2016 Day Excursion T Fire, Crew Only Onboard 0 2 4 P/V Adventure Hornblower (DCA16FM035) 3/31/2016 Whale Watching T Collided with Dock 0 8 149 P/V DUKW 34 (DCA10MM025) 7/7/2010 Stretch DUKW T Flooding, Run Over by Barge 2 26 37 P/V Express Shuttle II (DCA05MM002) 10/17/2004 Passenger Shuttle T Engine Room Fire, Crew Only Onboard 0 1 3 P/V Lady D (DCA04MM015) 3/6/2004 Pontoon Water Taxi T Capsized from High Winds 5 16 25 P/V Taki-Tooo (DCA03MM035) 6/14/2003 Charter Fishing T Capsized Bar Crossing Heavy Seas 11 8 19 P/V Panther (DCA03MM018) 12/30/2002 Small Day Excursion T Flooding from Known Leak 0 1 34 P/V Port Imperial Manhattan (DCA01MM008) 11/17/2000 Commuter Ferry T-L Fire in Engine Room 0 1 11 P/V Miss Majestic (DCA99MM021) 5/1/1999 WW2 DUKW T Flooding, Driveshaft Seal Failure 13 0 21 Total of All Subchapter T Vessels 83 86 425 Total of Subchapter T Vessels (Excluding DUKWs) 51 53 336 Total of DUKWs Only 32 33 89 NOTE: NTSB = National Transportation Safety Board; P/V = passenger vessel. SOURCE: https://www.ntsb.gov/investigations/AccidentReports/Pages/Reports.aspx.

DUKW BOATS AND SAFETY 21 TABLE 2-1 Summary of NTSB Subchapter T Small Passenger Vessel Accident Reports from 1995 to 2021 NTSB Report Name and Accident # Date of Accident Type of Vessel Inspection Subchapter Type of Accident Deaths Injuries Total Number Onboard P/V Conception (DCA19MM047) 9/2/2019 Overnight T Fire in Accommodation Space 34 2 38 P/V Stretch Duck 7 (DCA18MM028) 7/19/2018 Stretch DUKW T Flooding by Storm Conditions 17 7 31 P/V Island Lady (DCA18FM010) 1/14/2018 Passenger Shuttle T Fire in Engine Room 1 14 53 P/V Tahoe Queen (DCA16FM054) 8/16/2016 Day Excursion T Fire, Crew Only Onboard 0 2 4 P/V Adventure Hornblower (DCA16FM035) 3/31/2016 Whale Watching T Collided with Dock 0 8 149 P/V DUKW 34 (DCA10MM025) 7/7/2010 Stretch DUKW T Flooding, Run Over by Barge 2 26 37 P/V Express Shuttle II (DCA05MM002) 10/17/2004 Passenger Shuttle T Engine Room Fire, Crew Only Onboard 0 1 3 P/V Lady D (DCA04MM015) 3/6/2004 Pontoon Water Taxi T Capsized from High Winds 5 16 25 P/V Taki-Tooo (DCA03MM035) 6/14/2003 Charter Fishing T Capsized Bar Crossing Heavy Seas 11 8 19 P/V Panther (DCA03MM018) 12/30/2002 Small Day Excursion T Flooding from Known Leak 0 1 34 P/V Port Imperial Manhattan (DCA01MM008) 11/17/2000 Commuter Ferry T-L Fire in Engine Room 0 1 11 P/V Miss Majestic (DCA99MM021) 5/1/1999 WW2 DUKW T Flooding, Driveshaft Seal Failure 13 0 21 Total of All Subchapter T Vessels 83 86 425 Total of Subchapter T Vessels (Excluding DUKWs) 51 53 336 Total of DUKWs Only 32 33 89 NOTE: NTSB = National Transportation Safety Board; P/V = passenger vessel. SOURCE: https://www.ntsb.gov/investigations/AccidentReports/Pages/Reports.aspx.

22 OPTIONS FOR IMPROVING THE SAFETY OF DUKW TYPE AMPHIBIOUS VESSELS TABLE 2-2 Number of DUKWs with Active COIs by Type and Route, 2019 and 2021 WWII Stretch Duck Truck Duck Total Water Body of Route 2019 2021 2019 2021 2019 2021 2019 2021 Rivers 19 5 32 1 30 28 81 34 Lakes, Bays, & Sounds 17 13 9 2 16 9 42 24 Total 36 18 41 3 46 37 123 58 WWII Stretch Duck Truck Duck Total Type of Waters of Route 2019 2021 2019 2021 2019 2021 2019 2021 Protected Waters 36 18 39 3 22 21 97 42 Partially Protected Waters 0 0 2 0 24 16 26 16 Total 36 18 41 3 46 37 123 58 SOURCE: USCG, Marine Information for Safety and Law Enforcement (MISLE) database. BOX 2-2 Definitions of “Waters” from CFR 46 175.400 Protected waters is a term used in connection with stability criteria and means sheltered waters presenting no special hazards such as most rivers, harbors, and lakes, and that is not determined to be exposed waters or partially protected waters by the cognizant Officer in Charge, Marine Inspection (OCMI). Partially protected waters is a term used in connection with stability criteria and means: 1. Waters not more than 20 nautical miles from the mouth of a harbor of safe refuge, unless determined by the cognizant OCMI to be exposed waters; 2. Those portions of rivers, estuaries, harbors, lakes, and similar waters that the cognizant OCMI determines not to be protected waters; and 3. Waters of the Great Lakes from April 16 through September 30 of the same year (summer season). SOURCE: Code of Federal Regulations, https://www.ecfr.gov/current/title-46.

DUKW BOATS AND SAFETY 23 BOX 2-3 Key Regulations: Code of Federal Regulations, Title 46 Shipping, Volume 7, Chapter I Coast Guard Subchapter S, Subdivision and Stability • Part 170 Stability requirements for all inspected vessels o 170.170 Weather criteria o 170.173 Criterion for vessels of unusual proportion and form • Part 171 Special rules pertaining to vessels carrying passengers o 171.050 Passenger heeling requirements Subchapter T, Small Passenger Vessels (under 100 gross tons) • Part 175 General provisions o 175.400 Definitions of terms used in this subchapter • Part 176 Inspection and certification o 176.110 Routes permitted • Part 177 Construction and arrangement o 177.500 Means of escape o 177.820 Seating • Part 178 Intact stability and seaworthiness o 178.310 Intact stability requirements—general o 178.330 Simplified stability proof test (SST) • Part 179 Subdivision, damage stability, and watertight integrity o 179.350 Opening in the side of a vessel below the bulkhead or weather deck o 179.360 Watertight integrity • Part 180 Lifesaving equipment and arrangements o 180.71 Life jackets o 180.72 Personal flotation devices carried in addition to life jackets • Part 182 Machinery installation o 182.520 Bilge pumps • Part 185 Operations o 185.304 Navigation underway o 185.506 Passenger safety orientation o 185.508 Wearing of life jackets o 185.516 Life jacket placards o 185.520 Abandon ship and man overboard drills and training SOURCE: Code of Federal Regulations, https://www.ecfr.gov/current/title-46.

24 OPTIONS FOR IMPROVING THE SAFETY OF DUKW TYPE AMPHIBIOUS VESSELS these alternatives provide an equivalent level of safety. DUKWs, because of their unique design, typically cannot meet all of the Subchapter T regu- lations directly. USCG’s NVIC 1-01 describes methods or configurations that USCG has pre-determined to meet a level of safety equivalent to the intent in Subchapter T. NVIC 1-01 is based on recommendations from the USCG Marine Board of Investigation and NTSB’s reports on the sinking of the Miss Majestic. The guidelines are also intended to better educate both USCG inspectors and DUKW operators on recommended safety measures. Owners may employ means or methods other than those in NVIC 1-01, provided that the owner demonstrates they are equivalent to the Subchapter T regulations. NVIC 1-01 guidelines may recommend more stringent or conservative standards for DUKWs, or the guidelines may, in effect, recommend waiving the Subchapter T standards, allowing lower standards in recognition of the origins of DUKWs as military cargo vehicles and their equally important need to travel safely on land given an equivalent level of safety is provided by other means. NVIC 1-01 guidelines for bilge pumps are an example of a recommen- dation that the OCMI apply more stringent standards to DUKWs. Under Subchapter T, small passenger vessels require bilge pump capacity adequate to remove water from normal operations only, because the assumption in Subchapter T is that structural integrity and through hull fittings can be relied on to prevent flooding. NVIC 1-01 instead advises the OCMI to only issue a COI to DUKWs that also have a high-capacity bilge pump “for emergency operations, which can offset uncontrolled flooding of the largest penetration in the hull until the vehicle can be safely beached.”11 For passenger seating, NVIC 1-01 guidelines allow lower standards, which reflect, in part, that the width of many DUKWs was determined back in 1942. Under NVIC 1-01, • Seats in rows can be 28 inches apart, seat front to seat front, two inches shorter than under 46 CFR 177.820(d)(3). • Centerline aisle width can be as narrow as 14 inches, significantly narrower than the minimum 24 inches or 30 inches required, depend- ing on centerline aisle length under 46 CFR 177.820(d)(1) and (2). • Number of passengers is limited to one passenger per 17 inches width of fixed seating, one inch shorter than under 46 CFR 176.113(b)(3). 11 USCG, NVIC 1-01, p. 32. https://www.dco.uscg.mil/Portals/9/DCO%20Documents/5p/5ps/ NVIC/2001/n1-01.pdf.

DUKW BOATS AND SAFETY 25 USCG justifies standards that allow more cramped conditions in the pas- senger compartment of DUKWs through another guideline that stipulates the primary means of escape is over the side of the DUKW. Because of this, the narrow aisle width and tighter seating are not considered unacceptable safety hazards by USCG. REVIEW OF CASUALTY DATA Casualty data available from USCG’s MISLE database provide insights into the reliability and weaknesses of DUKWs. The operators of DUKWs under USCG’s jurisdiction reported 267 casualty events and 519 casualty types from 1999–2021. For individual vessels, 70 percent had at least one casualty type. (A single casualty event may have more than one casualty type.) Table 2-3 summarizes the number of casualty types and events. The World War II DUKWs were less prone to incidents than the Stretch Ducks or Truck Ducks. Of the 78 WWII DUKWs active during this time, only 33 of them had at least one casualty type, representing 42 percent of the WWII fleet. Table 2-4 lists the number of casualties by type and shows that DUKWs have historically had reliability issues, particularly in their propulsion or steering systems. For all DUKW types, the two most frequent casualty types by far were Loss/Reduction of Vessel Propulsion/Steering (220 total casualties) and Material Failure/Malfunction (210 total casualties). The actual number of times a DUKW had difficulties in the water may be higher than as recorded in Tables 2-3 and 2-4. Statements by operators during the committee’s open sessions revealed that not all stoppages are considered reportable to USCG. TABLE 2-3 Summary of DUKW Casualty Types and Events, 1999–2021 Number of WWII DUKW Stretch Duck Truck Duck Total Boats that had one or more casualty types 33 65 41 139 Casualty types over all events 77 225 217 519 Events 43 121 103 267 Boats active in the fleet, 2000 to 2021 78 70 49 197 % of fleet with at least one casualty type 42% 93% 84% NOTE: A single casualty event may have more than one casualty type. SOURCE: USCG, Marine Information for Safety and Law Enforcement (MISLE) database.

26 OPTIONS FOR IMPROVING THE SAFETY OF DUKW TYPE AMPHIBIOUS VESSELS TABLE 2-4 Number of Reported Casualty Types, 1999–2021 Casualty Type WWII DUKW Stretch Duck Truck Duck Total Abandonment 1 1 Allision 1 2 3 Collision 2 2 Discharge/Release - Pollution 1 1 2 Fire - Initial 2 2 4 Flooding - Initial 3 4 6 13 Flooding - Progressive 1 1 Fouling 2 1 3 Grounding 10 4 5 19 Loss of Electrical Power 2 4 3 9 Loss/Reduction of Vessel Propulsion/Steering 25 105 90 220 Material Failure/Malfunction 17 89 104 210 Set Adrift 4 1 5 Sinking 1 2 3 Vessel Maneuver 3 5 8 16 Total 64 225 222 511 SOURCE: USCG, Marine Information for Safety and Law Enforcement (MISLE) database. RECOMMENDATIONS FROM CASUALTY REPORTS AND SAFETY BULLETINS After each DUKW marine casualty event with loss of life, NTSB and USCG have carried out investigations, prepared reports analyzing the reasons for the casualty, and made recommendations to enhance safety by design and operational improvements to prevent future casualties. The United Kingdom issues similar reports after significant marine incidents. Recommendations from key reports relevant to the committee’s work are summarized below and discussed in more detail in the relevant chapters. In addition to these reports, the committee also reviewed letters, safety bulletins, and announcements by USCG and NTSB regarding recommenda- tions and measures to improve DUKW safety.

DUKW BOATS AND SAFETY 27 Recommendations After Miss Majestic Sinking The report of USCG’s Marine Board of Investigation on the Miss Majestic makes multiple recommendations and led to the creation of NVIC 1-01.12 Key recommendations in this report include: • Listed DUKW documents that should be available to operators and the OCMI, • Required in-water testing of vessel integrity after repairs to hull or appendages, • Required testing of bilge pumps with water at every USCG annual inspection, • Recommended that USCG issue policy on inspecting DUKWs’ unique features with emphasis on shaft housings and boot seals (which led to the creation of NVIC 1-01), • Recommended that USCG establish a working group of operators and industry experts to develop DUKW safety best practices, and • Recommended considering a requirement for more than one crew member on board when that crew member is acting as a tour guide. NTSB’s Marine Accident Report on the Miss Majestic was released in 2002, after USCG had issued NVIC 1-01.13 The report contains new recommen- dations and reiterates some existing ones. Most significant to the commit- tee’s work, NTSB recommended that USCG require that DUKW passenger vessels have sufficient reserve buoyancy through passive means to remain upright and afloat with full passenger complement in the event of flooding. For DUKWs that lack reserve buoyancy, NTSB recommended that USCG require them to do the following: • Remove canopies, • Close all unnecessary access plugs, • Install independent bilge pumps of sufficient capacity to dewater flooding from the largest remaining penetration, • Install four independent bilge alarms, • Inspect the vessel in water each time a through-hull penetration has been removed or uncovered, 12 Marine Board of Investigation, USCG, 1999, “Circumstances Surrounding the Sinking of the M/V MISS MAJESTIC on Lake Hamilton, Hot Springs, AR, on May 1, 1999, with Multiple Loss of Life,” September 29. 13 NTSB, 2002, “Sinking of the Amphibious Passenger Vessel Miss Majestic, Lake Hamilton, Hot Springs, AR, May 1, 1999,” Marine Accident Report NTSB/MAR-02/01, April 2. https:// www.ntsb.gov/investigations/AccidentReports/Reports/MAR0201.pdf.

28 OPTIONS FOR IMPROVING THE SAFETY OF DUKW TYPE AMPHIBIOUS VESSELS • Verify the watertight condition of the vessel at the start of each waterborne departure, and • Comply with remaining provisions of NVIC 1-01. Recommendations After DUKW34 Collision In its Marine Accident Report on DUKW34, NTSB focused its recommen- dations on cell phone use by safety critical personnel, as this was one of the root causes of the collision. NTSB also recommended that DUKW opera- tors develop improved methods of ensuring safety, including that emergency management procedures be well understood by safety critical employees.14 Recommendations After Wacker Quacker 1 and Cleopatra The United Kingdom’s Marine Accident Investigation Branch issued a joint report on Wacker Quacker 1 and the Cleopatra. The report contains mul- tiple recommendations including to improve DUKW operations, prevent foam flotation from becoming a fire hazard, improve emergency proce- dures, reduce the possibility of entrapment from canopies, and improve the availability of life jackets.15 Recommendations After Stretch Duck 7 Sinking After the sinking of the Stretch Duck 7 in 2018, NTSB issued a Marine Safety Recommendation Report in 2019 and its Marine Accident Report in 2020. The Marine Safety Recommendation report focused on two of NTSB’s Miss Majestic recommendations—to either require reserve buoy- ancy through passive means or remove canopies—and provided additional background information and explanations.16 The NTSB Marine Accident Report reiterated the recommendations to provide reserve buoyancy or to remove canopies and also included three new recommendations for USCG17: 14 NTSB, 2011, “Collision of Tugboat/Barge Caribbean Sea/The Resource with Amphibious Passenger Vessel DUKW34, Philadelphia, PA, July 7, 2010,” Marine Accident Report NTSB/ MAR-11/02, June 21. https://www.ntsb.gov/investigations/Pages/DCA10MM025.aspx. 15 MAIB, 2014, Very Serious Marine Casualty Report NO 32/2014, December. https://assets. publishing.service.gov.uk/media/54c1722240f0b6158d00002b/MAIBReport_32-2014.pdf. 16 NTSB, 2019, “Improving Vessel Survivability and Passenger Emergency Egress of DUKW Amphibious Passenger Vessels,” Marine Safety Recommendation Report MSR1901, Novem- ber 6. https://www.ntsb.gov/investigations/AccidentReports/Reports/MSR1901.pdf. 17 NTSB, 2020, “Sinking of Amphibious Passenger Vessel Stretch Duck 7, Table Rock Lake, near Branson, MO, July 19, 2018,” Marine Accident Report NTSB/MAR/20-01, April 28. https://www.ntsb.gov/investigations/AccidentReports/Reports/MAR2001.pdf.

DUKW BOATS AND SAFETY 29 • Require the closure of forward hatches, • Update NVIC 1-01 to address the issue of severe weather and egress during a rapid sinking event, and • Examine training and knowledge of operators. NTSB also made three recommendations for the operator, Ripley Entertainment: • Revise current operating policy to update guidance on adverse weather operation, • Modify the spring-loaded forward hatch to enable closure during waterborne operation, and • Re-evaluate emergency procedures for donning life jackets. USCG recommended, but stopped short of requiring, that “vessel owners and operators of DUKW passenger vessels remove canopies, side curtains, and associated overhead framing to improve emergency egress for passengers and crew” in its Marine Safety Information Bulletin (MSIB) issued in April 2020. USCG also stated in the bulletin that it would “consider implementa- tion of further safety measures for DUKWs” at the conclusion of its investi- gation of the Stretch Duck 7 and “initiate a policy update to NVIC 1-01 with input from public and industry stakeholders.”18 OVERVIEW OF SURVIVABILITY Survivability formed the organizing principle of the committee’s approach to the Statement of Task. The committee considered two types of surviv- ability: of the vessel and of the persons on board. Survival of the vessel should also help the persons on board to survive; however, persons on board should be able to survive even if the vessel does not. The goal of stability regulations, as discussed in more detail in Chapter 3, is the survivability of the vessel. Chapter 4 exams certain restrictions on opera ting areas that aim to increase the survivability of the vessel, given conditions in its operating environment. The goal is for the vessel to stay afloat and stable at all times. For intact and damage stability requirements, this includes even after a casualty occurs. However, persons on board may still be injured or killed during a casualty event such as a fire or a collision. 18 USCG, 2020, “Recommendation for DUKW Passenger Vessel Canopy Removal,” Marine Safety Information Bulletinv15-20, April 22. https://www.dco.uscg.mil/Portals/9/DCO%20 Documents/5p/MSIB/2020/MSIB-15-20_Recommendation%20for%20DUKW%20Passenger%20 Vessel%20Canopy%20Removal.pdf.

30 OPTIONS FOR IMPROVING THE SAFETY OF DUKW TYPE AMPHIBIOUS VESSELS Survivability of all persons on board is the goal of lifesaving regu- lations. The examination of canopies and escape during emergencies in Chapter 5, the focus on life jackets in Chapter 6, and the review of safety operations, such as training and drills on escaping the vessel, in Chapter 7 are examples of methods to increase the survivability of all persons on board. The waived passenger seating standard, discussed in the section on USCG regulatory oversight, is an example of determining that lowering a standard will not materially affect the survivability of persons on board. There are trade-offs involved in all methods of increasing the surviv- ability of a vessel or of the persons on board. For DUKWs, which must operate safely on land and on water, evaluating the trade-offs can become even more complex. Chief among the trade-offs is cost versus added sur- vivability. The costs may be direct, such as the cost of retrofitting the ves- sel, or both direct and indirect, such as removing canopies or wearing life jackets, which may make the vessel and its tours less attractive to poten- tial customers. Ultimately, it is USCG’s responsibility to consider the cost and the practicality of implementing any potential changes by performing a formal cost–benefit analyses as part of any future federal rulemaking process. Another trade-off is weighing uncertainty around effectiveness. For example, methods that depend on the ability of the crew and passen- gers to understand and execute what is required of them, especially in an emergency, may be more vulnerable to human error than techniques that incorporate “passive safety.” Passive safety may be even more crucial for DUKWs than for other small passenger vessels. Because of their design and equipment, DUKWs tend to be far more sensitive to operator mistakes than other classes of Subchapter T boats. DUKWs also rely, to a greater extent, on passengers to be responsible for their own safety and even the safety of others. The higher cost and likelihood of human fallibility puts even more importance on achieving acceptable levels of safety by minimizing the possibility of a casualty event occurring in the first place. The potential costs and the uncertainty around the effectiveness of vari- ous techniques is why the committee considered it critical to consider both types of survivability from all aspects and to examine multiple, comple- mentary risk mitigating actions. Because of the variations among DUKWs and their operating areas, the committee also sought to avoid “one-size- fits-all” approaches to survivability. Instead, the committee divided DUKW operations—the vessels and operating areas—into higher risk and lower risk operations. The factors leading to higher risk operations are listed in Box 2-4, explained more fully in the subject-specific chapters, and summa- rized in the final chapter on recommendations.

DUKW BOATS AND SAFETY 31 BOX 2-4 Higher Risk and Lower Risk Operations Related to the Vessel Design, Systems, and Operating Area Factors Leading to Higher Risk Operations • Fast Sinking Times • Low Freeboard • Lack of High-Capacity Bilge Pump • Multiple Hull Penetrations • Engine Air Cooling Vents • Potential Exposure to High Winds and Waves • High Traffic Areas • Restrictive Canopies Lower Risk Operations • None of the Factors Above • Reserve Buoyancy, Unless in High Winds and Waves