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95 The DUKWâs operating personnel on boardâthe crewâare the key persons who control its safe operation. They take the lead in assuring passenger safety during both normal operations and in emergencies. Although the United States Coast Guard (USCG) licensing requirements, required drills, and inspections help to set minimum standards for crew knowledge and capability, they are not enough on their own. Safe operations require signifi- cant crew training and investment by the operator in a well-planned safety system to ensure that passengers will have a safe ride at all times. Even more than for other small passenger vessels, DUKWs require their passengers to take responsibility for their own safety and even the safety of others during an emergency. With only one or two crew members on board and the crowded conditions in the passenger compartment, the crew is unlikely to be able to assist most passengers. In addition, preceding or during all three major casualty events with loss of life, members of the crew or the support staff on land failed to execute some of the actions prescribed to maintain safety. This chapter examines policies for the number of personnel on board, tour preparations, such as safety checks and training, and the responsibili- ties of passengers during an emergency. Although there are ways to increase the likelihood that people will follow sound procedures and respond appro- priately during emergencies, depending solely on human behavior to attain adequate safety is less than ideal. 7 Operations and Safety
96 OPTIONS FOR IMPROVING THE SAFETY OF DUKW TYPE AMPHIBIOUS VESSELS REGULATIONS AND NVIC 1-01 The committee identified regulations covering the number of personnel re- quired on board (46 CFR 185 Subpart D Crew Requirements), the passenger safety orientation (46 CFR 185.506), and the operatorâs procedures for crew training (46 CFR 1985.520â524) as the most significant for safe operations, given the major casualty events. USCG has developed Navigation and Vessel Inspection Circular 1-01 (NVIC 1-01) guidance for all three of these topics, which is discussed in more detail in the sections below. Regulations and NVIC 1-01 guidance on means of escape and design requirements for the passenger compartment, discussed in more detail in Chapter 2, also impact how the crew will likely act during an emergency. NUMBER OF PERSONNEL ON BOARD The operators of DUKWs are responsible for movement over land as com- mercial vehicle operators and through the water as vessel masters. DUKWs generally operate with either a single master or with one master plus one deckhand, as stipulated in the vesselâs Certificate of Inspection (COI). Manning requirements for DUKWs are set by the Officer in Charge, Marine Inspection (OCMI) in accordance with 46 CFR 185, with additional guid- ance in NVIC 1-01. NVIC 1-01 sets the conditions to be met for operation by a master with no deck hand. A single master may be allowed if the operator can demonstrate control of the vessel while conducting normal operations and during emergencies. The OCMI is to consider numerous factors when stipu- lating required personnel, such as the vessel itself, tour route, maneuvering requirements, and number of passengers who are children. The OCMI will also likely witness emergency drills that are conducted annually. DUKW tour businesses deploy personnel in a variety of ways. In some cases, when a vessel is required to have a deckhand on board, the DUKW will operate on land with a single driver and then pick up a deckhand before entering the water. Some operations choose to have a single person with a commercial driverâs license (as required by the state) and a USCG masterâs license serve as both the on-land and on-water operator. Other businesses opt to change operators when the vessel enters the water. In general, vessels that operate on protected waters with very little water traffic often operate with only a master. For vessels operating on partially protected waters and areas with additional water traffic (such as rivers on which other commercial traffic operates), OCMIs typically require a master and a deckhand. Additionally, COIs often require a deckhand for night operations.
OPERATIONS AND SAFETY 97 For the DUKW casualty events with loss of life, the required number of personnel varied. The Miss Majestic carried only a master, who was also the driver for the land portion of the trip. For DUKW 34, USCG required a master and a deckhand. The master narrated the tour. The deckhandâs use of a personal cell phone during the incident leading to the collision contributed to the casualty event. The deckhand was also the only boat occupant to evacuate the DUKW before the collision. The Stretch Duck 7 required only a master for the water portion of the tour, who also narrated the tour. However, the driver for the land portion of the tour was on board and assisted the master as directed. The driver for the land portion was among the fatalities. TOUR PREPARATIONS There are demonstrated risks in depending on the actions of humans to achieve safety. This is particularly true for DUKW tour businesses, which are often seasonal and may have high crew turnover. Preparing for fast- changing weather is a specific concern. In the sinking of the Miss Majestic, the National Transportation Safety Board (NTSB) noted that there were no written procedures for maintenance inspections or other safety checks. The owner, who had been in business for 40 years, relied on assigning a specific DUKW to an operator who would get to know their vesselâs sounds and handling norms. The safety procedures outlined in NVIC 1-01 are an attempt to provide guidance in response to this ownerâs informal procedures.1 For the DUKW 34 collision, the NTSB found that the master did not follow all the safety procedures in the companyâs manual during the emer- gency, and, as mentioned earlier, the deckhand was texting on a personal cell phone.2 In the Stretch Duck 7 sinking, NTSB found that the tour busi- ness and the master lacked the specific guidance and training needed to effectively use information on impending weather conditions.3 1 NTSB, 2002, âSinking of the Amphibious Passenger Vessel Miss Majestic, Lake Hamilton, Hot Springs, AR, May 1, 1999,â Marine Accident Report NTSB/MAR-02/01, April 2. https:// www.ntsb.gov/investigations/AccidentReports/Reports/MAR0201.pdf. 2 NTSB, 2011, âCollision of Tugboat/Barge Caribbean Sea/The Resource with Amphibious Passenger Vessel DUKW34, Philadelphia, PA, July 7, 2010,â Marine Accident Report NTSB/ MAR-11/02, June 21. https://www.ntsb.gov/investigations/Pages/DCA10MM025.aspx. 3 NTSB, 2020, âSinking of Amphibious Passenger Vessel Stretch Duck 7, Table Rock Lake, near Branson, MO, July 19, 2018,â Marine Accident Report NTSB/MAR/20-01, April 28.
98 OPTIONS FOR IMPROVING THE SAFETY OF DUKW TYPE AMPHIBIOUS VESSELS Safety Checks, Drills, and Manuals NVIC 1-01 states that the operator should perform safety checks on the vessel before leaving for a tour. Operators generally have a checklist of items that must be run through at the start of the day; some conduct safety checks before each tour. Masters are responsible for conducting various emergency drills and for ensuring that all crew members are familiar with their duties during emergencies. While drills are conducted annually as part of the OCMIâs inspection for a COI, it is desirable for operators to perform drills quarterly or even monthly. High-quality drills are as realistic as practical, with limited time to react to an emergency and multiple persons donning life jackets in the confined space, replicating what would occur in a real emergency. NVIC 1-01 also strongly encourages tour businesses to develop operat- ing manuals with training, maintenance, operational, and emergency re- quirements. Because these manuals are not required, those that do exist vary significantly from operator to operator in both content and quality. Weather Weather preparation and monitoring are some of the most important active measures of safety an operator can take and are generally required by current regulations. Because OCMIs may place operating restrictions based on winds and wave height, weather preparations play a significant role in many companiesâ operations. Weather forecasts are expected to be watched by both shoreside staff and the masters of the vessels. Operators need to be able to cut short or cancel on-water tours if inclement weather threatens. Training A DUKW master is to receive training through the USCG licensing process and through the companyâs training program. The reality is that the level of training received by these masters varies greatly, as described in the acci- dent reports and testimony of operators. Some companies hire masters with licenses for suitable routes and tonnage (traditionally a 100-ton license for Subchapter T vessels). In contrast, because operating environments vary by region, some companies request and receive approval for the use of limited licenses. An operator with a traditional masterâs license may not necessarily have situational awareness or local knowledge of weather trends and safe refuge locations. Typical certification courses do not teach recognizing weather trends and what to do about sudden changes in weather. There is no test to prove competency in real emergencies.
OPERATIONS AND SAFETY 99 Under current regulations, the owner and operator are responsible for the content of and emphasis on crew training. Best practices would require developing a thorough training program as part of their opera- tions manual, constantly emphasizing training and drills, and maintaining complete training records. The importance of training and drills cannot be overemphasized, and a standardized DUKW training program would be a valuable addition to the industry. PASSENGER ACTIONS DURING EMERGENCIES DUKWs and other similar small âopenâ passenger vessels, such as water taxis, small excursion boats, and launches, require passengers to take responsibility for much of their own safety during an emergency. This reli- ance on passenger responsibility is just one more reason why it is critical to minimize the possibility of a casualty occurring on a DUKW in the first place. While it is the committeeâs judgment that safety orientations can be improved, relying on the assistance of passengers with diverse physical abilities and widely varying familiarity with safety on boats is still fraught with risk. Because of the DUKWâs unique design and lack of an open deck area, NVIC 1-01 allows narrower aisles and tighter passenger seating (see Chap- ter 2), with the stipulation that the primary means of egress is directly over the side. To escape in an emergency such as flooding, capsizing, or fire, passengers are to move from where they are seated, over the side, and into the water. The cramped conditions make it difficult to impossible for a crew member to assist passengers with tasks such as 1. Retrieving the appropriate (adult versus child) life jacket from overhead storage in a canopy. 2. Donning the life jacket. 3. Opening the side curtain on the window nearest them. 4. Exiting through side curtain opening. A safe escape requires passengers to make multiple decisions and take unfamiliar actions. Not only are passengers expected to be almost entirely self-reliant during an emergency escape, they may also feel an obligation to help others. Some of the challenges and tasks passengers face in an emer- gency are listed below. 1. The crew is located at the forward end of the passenger space and, during an emergency, will be occupied with many responsibilities and tasks. The crew will not be able to move about to assist pas- sengers with finding and donning life jackets, to show them how
100 OPTIONS FOR IMPROVING THE SAFETY OF DUKW TYPE AMPHIBIOUS VESSELS or where to escape, or to assist them with escaping through side curtains. 2. To egress out a side opening over seats and gunwales without assistance, particularly when the vessel may be heeling to one side or in heavy seas, will require a passenger to be reasonably fit. Small children, the elderly, and those with mobility issues may be unable to perform these actions without aid from other passengers. 3. Emergencies can happen very quickly, particularly in a capsizing or flooding event. There may be no time for the crew to give neces- sary instructions on how to escape once an emergency has started, especially in the case of a one-person crew. 4. If side curtains are in use, the need to open or release them may add to passenger and crew responsibilities to escape quickly in an emergency on the water. 5. If a one-person crew is allowed, the master may not be able to assist passengers who need assistance escaping the vessel. An able- bodied passenger may be asked to stay behind until all passengers are safely evacuated. Emphasizing passenger responsibility during the required safety orien- tation, mandated by 46 CFR 185.506, is one way to partially address these issues. During the safety orientation, passenger responsibility should be emphasized in the instructions for embarking/disembarking during normal operations and emergencies; locating instruction placards for life jackets; locating, donning, and adjusting life jackets; locating ring buoys, fire ex- tinguishers, and emergency exits; and removing any obstructions to exits. However, too many safety instructions may overload a passenger and result in their being unwilling to participate in the tour or assist in the egress of others once under way. Although detailed safety instructions can be provided for passengers before getting under way, the number of safety instructions required and the difficulty of doing them while an emergency is occurring underscores the need for passive safety on DUKW boats. SUMMARY Safe operations depend on well-trained personnelâon the boat and on the ground in a support capacityâwho act with confidence while following established, proven procedures. NVIC 1-01 emphasizes the importance of operations and safety manuals. These manuals should incorporate train- ing, maintenance, and operations standards, as well as emergency response plans. Procedures to monitor and act in response to impending weather conditions also need to be included.
OPERATIONS AND SAFETY 101 The reality on board a DUKW during a tour is that the master and crewâeven if well trainedâare not likely to have the capacity to assist all passengers during an emergency. Safety and emergency procedures need to be developed that convey the importance of passengers taking responsibility for themselves and others.