• Safety and Procedures Manual
  
  
• Resources
  
  
• Bulletins
  
  
• Policy
  
  
• Stem T' Stern
  
  
• FAQ

On July 10th through 12th, 2001 OMAO Program Services and Outsourcing Division hosted the first NOAA Small Boat Workshop.  Nineteen people from OAR, NMFS, NOS, and OMAO, who are involved with the operation of small boats in the field, attended.  The interactive dialog conducted during the workshop was extremely valuable toward attaining the goal of improving NOAA small boat management and safety.

The following topics were addressed in break out groups or by the entire workshop:

. Operator Training and Certification
. Small Research Vessel Definition and Standards
. OMAO and Line Office Interaction in Developing Operational Risk Management Plans
. Responsible Person - Definition and Function
. Resource Requirements
. Small Boat Inspection Program
. Small Boat Visual Identification and Numbering
. Small Boat Program Website
. General Comment on Current Draft Policy

Detailed findings from these agenda items are presented in the attached summary.

The next steps in development of a strengthened and tenable safety policy will include:

. Specific case studies to determine and better quantify resources required to implement and comply with the draft NOAA Administrative Order (NAO).  Findings will be presented to Line Office Management.
. Inclusion of the significant proceedings from the workshop in the draft NAO.  Final review and comment of this post-workshop draft will be solicited from the Task Team prior to initiating the administrative review process.

I will be contacting several Senior Field Managers immediately after completing the next draft of the NAO to solicit information regarding estimated additional resources required by Line Office programs.

Input from the Task Team field representatives has provided  perspectives and insights which will be crucial to development of a tenable safety policy.  Task Team members who were unable to attend the workshop are encouraged to send comments to me via email.  I sincerely thank you for attending and encourage you to continue to provide your input during this policy development process.  I also encourage you to share the detailed workshop summary with your Senior Field Managers.

Enclosure: Detailed Workshop Summary

Distribution:
 

DETAILED SMALL BOAT WORKSHOP SUMMARY

Break Out Groups and Topics

Operator Training Standards and Certification

OMAO: Beth White (facilitator)
NMFS: John Pierson, Wade Blake
NOS:  Jeff Govoni, Larry Krepp

Due to the heterogenous nature of boat operations through out NOAA, the need to mandate additional training requirements was not viewed as being practical or cost effective.  Specifying additional training requirements (such as weather interpretation training) or skill-based proficiency should remain the responsibility of the specific program Senior Field Manager.

The topic of requiring CPR and First Aid training for all boat operators was discussed.  The USCG requires CPR and First Aid for all documented merchant mariners, from Able-bodied Seaman to licensed Deck Officers.  Based on NOAA's intent to meet or exceed all applicable regulations or standards, it was decided that the policy requiring all NOAA boat operators to maintain CPR and First Aid qualification was not deemed to be unreasonable and therefore will continue to be required.
 

Small Research Vessel (SRV) Definition and Standards

OMAO: Bob Taylor (facilitator), Paul Parsons, Jamie Hutton
NMFS: Scott Sirois
OAR:  Dennis Donahue
NOS:  Dave Score

The discussion of standards for SRVs addressed the difficulties in applying existing regulations to research vessels less than 300 gross tons.  There are no existing USCG regulations pertaining to oceanographic research vessels less than 300 gross tons.  Applicable regulations based on an evaluation of operational risk can and should be drawn from several sources.  The regulations and standards which will be applied to SRVs will be extracted from at least the following sources:

. 46 CFR Subchapter T - Small Passenger Vessels less than 100 tons
. 46 Subchapter L - Offshore Supply Vessels
. 46 Subchapter U - Oceanographic Research Vessels
. 33 CFR - Navigation and Navigable Waters
. ABS Rules for Pleasure Yachts less than 20 meters
. ABYC Standards and Recommended Practices
. ABYC Rules and Regulations for Recreational Boats
. Industry Standards
. United States Coast Guard
. International Maritime Organization

The definition of an SRV was proposed to be a vessel of greater than 50 gross tons but less than 300 gross tons and capable of conducting 24 hour operations.  Gross tonnage is determined by the following forumula: ((L × B × D) × 0.67) ÷ 100, where L = length, B = beam, D = depth (not draft).   The tonnage limits of this definition may be lowered.  Additional discussion and regulatory research is in order to further refine and establish the gross tonnage parameters of this definition.  However, boats meeting the motorboat class length definitions and able to be classified as an SRV will be managed under the guidelines for SRVs.

The group recommended the formation of a Small Research Vessel Committee.  Membership of the committee would be composed of persons nominated from Line Offices and OMAO.  The Small Research Vessel Committee would be tasked with developing uniform resolutions to conflicts regarding the intent of regulatory and safety requirements applied to small research vessels, developing a compendium of applicable regulation for SRVs, addressing applications of new technology to marine safety, and assisting in the determination of content for a Small Boat Program website.
 

OMAO and Line Office Interaction and Responsibilities in Developing Operational Risk Management Plans

OMAO: Mel Asato (facilitate), Jerry Adams
NMFS: Bob Emmett, David McClellan, Wayne Hoggard
NOS:  Todd Jacobs

The break out group recognized the need to keep the authority and responsibility for boat safety together, in one location.  It was unanimously decided to keep authority and responsibility for safety with the line offices while tasking OMAO with technical assistance and inspection oversight and reporting functions.  Even if OMAO had resources to assume responsibility and authority of line office small boats, it would be inefficient and disruptive to add a third party to the routine operational management of small boats.  Occasional technical support, iterative risk analysis and scheduled inspections should provide the most appropriate and cost effective assurance of safety.

There was discussion regarding possible exemptions for Class II boats from individualized risk management plans, i.e., Vessel Operations Manuals.  It was decided that Class II boats should be exempt, at the discretion of the Senior Field Manager, from an individualized risk management plan if they are of an open design, powered by outboard engine(s), unmodified for special mission requirements, operated within 3 miles of the shoreline on a 12 hour or less day trip basis, and do not have AC electrical generating capability.  It was felt that the risks involved in operating a boat meeting these criteria would be adequately addressed by a program Vessel Policy which would already be based on the principles of operational risk management.

The group recognized that boats smaller than Class II may be involved in high risk operations and may therefore require an individualized operational risk management plan.  If a boat is Class A or I and is:

. engaged in overnight trips, or
. engaged in night operations, or
. conducts operations for greater than 12 hours, or
. transporting students, observers, VIPs, guests, or visitors and outnumber qualified crew by a ratio of greater than 2 to 1, or
. operating over 3 miles from shore, or
. altered for specific mission requirements, or
. engaged in an operation for which the boat was not originally intended, i.e., trawling from a center console outboard boat, or
. has been involved in a reportable incident,

it should have an individual risk assessment and corresponding risk management plan.

Although OMAO's role in developing operational risk management plans is intended to be advisory in nature, the paper trail generated during dialog with a program could have the potential to generate a de facto authority.  As such, the potential for disputes in the interpretation of applicable regulations and requirements may arise.  It was decided that such disputes should be addressed by binding arbitration through either a Small Research Vessel Committee or through a marine safety organization such as the USCG Marine Safety Office.

An administrative flow diagram was developed to detail the role of OMAO in assisting programs with the development of risk management plans.  The flow diagram may be added as an appendix to the draft NAO.

The group tasked with this item, as well as most of the workshop attendees, felt that the interaction between OMAO and the Line Offices must be kept at the lowest management level possible in order to eliminate excess structure which may impede safety.  This concept is advocated by the USCG through their "Prevention Through People" program.  A lower level interaction is not intended to keep Senior Field Managers unaware of the management of their small boats.  It is intended to facilitate the dialog and actions necessary to attain an efficient and effective small boat safety program by placing authority, responsibility and action with the persons most concerned with safe marine operations - the boat operators.
 

Entire Workshop Topics

OMAO: Jerry Adams (facilitate), Bob Taylor, Beth White, Paul Parsons, Jamie Hutton, Jack Burks, Mel Asato
NMFS: Scott Sirois, Wayne Hoggard, Wade Blake, David McClellan, Bob Emmett, John Pierson
NOS:  Jeff Govoni, Larry Krepp, Todd Jacobs, Dave Score
OAR:  Dennis Donahue

Definition and Function of a Responsible Person

It was recognized that a Responsible Person may not be cost effective for programs that operate only one or two Class I boats.  For this reason, the basic functions of a responsible person were defined and listed to allow senior field management the discretion to either create and fill a position to manage small boats, or delegate these responsibilities to several people, or delegate the responsibilities to an existing staff member.

The need to assign responsibility to a person for a boat, or fleet of boats, was unchallenged and viewed as critical to the success of the NOAA Small Boat Program.  An analogy to management of GSA vehicles  was drawn to illustrate the current state of small boat management within NOAA.  An analogy to the professional maritime community was drawn to illustrate the ideal, and hopefully future, condition of small boat management.

The Responsible Person must not be assigned responsibility without having unquestionable direct access to dedicated resources, and final authority as to the readiness of a boat.  The Responsible Person must hold the authority to change or reschedule operations and the resources to assure safe operations.  The Marine Superintendent position may be a reasonable model of a responsible person, or a reasonable model for supervising responsible persons, in most organizations which have a boat over 65 feet or a boat which meets the SRV criteria.

It was noted that the lack of a Responsible Person was common to all activities where management was not committed to preserving material condition or maintaining the highest level of safety.  Furthermore, several field activities had, based on their need to adequately address boat safety and material condition, created either a Marine Superintendent or Field Operations Manager through their own initiative.
 

Resource Requirements to Meet Draft NAO

An estimate of additional resources required to meet the draft NAO will be presented to Line Office Managers.  A small sample of boats will be examined in accordance with the draft policy in order to determine resource requirements.  The requirement for a Responsible Person will have to be evaluated and quantified by Senior Field Managers on a case by case basis.  The need in OMAO for two Small Boat Engineers (specification writing, procurement management experience, and program liaison) and one Small Boat Inspector/Coordinator (inspection, operations and NOAA related experience) was recognized by the workshop attendees as reasonable.  Additional resources to support an effective inspection or engineering support program may be necessary as the Small Boat Program develops.

At activities where the need for a Responsible Person was recognized and a person was assigned, the condition of the boats and efficiency of their operations were in a better state than the field activities without a designated or clearly defined Responsible Person.  However, in both instances where Responsible Persons positions were created, the designation and assignment of the Responsible Person resulted in the reassignment of a mission critical researcher to manage field operations.

A distinct and separate marine operations budget was identified as beneficial to supporting small boat material condition so that boats would not have to "compete" with science for essential safety, maintenance and repair funding.  It was also noted that through a separate and distinct program marine operations budget, the ownership of a boat would effectively be transferred to the field unit and may be viewed as an asset for an entire activity rather than the sole property of a specific investigation or branch.

General costs associated with small research vessel operation and maintenance were discussed and listed to provide guidance to field operators wishing to estimate operating and maintenance budget requirements.
 

Small Boat Visual Identification and Numbering

There was general agreement for the need to maintain a uniform marking scheme for the purpose of greater public recognition and to credit NOAA.

The most cost effective approach for compliance with a uniform scheme was agreed to be a gradual implementation over time in accordance with a boat's normal maintenance painting schedule.

Guidance should be provided for appropriate sized flags to be flown from each class of boat and how flags should be flown.

It was noted that numbering of boats was not uniform due to the fact that the current NAO did not specifically state where program activities should attain hull identification numbers.  A direct result of this problem with the current policy was manifest in the discovery of 10 uninventoried Class III boats during October and November of 2000.  Most of these boats were not in compliance with the established inspection schedules because they did not exist on inventory records.

A uniform numbering scheme is required by United States Code.  Many boat operators were unaware of this requirement.  Hull identification numbers need to be issued to all unnumbered and improperly numbered boats.

Certain exemptions from the uniform visual identification marking scheme will have to be included in the draft policy.  Exemptions should be allowed for aluminum and rigid hull inflatable boats, or when an established public image exists, or when identification as NOAA property is deemed to be hazardous to personnel.
 

Vessel Inspection

The need to increase the frequency and scope of inspections for Class II and III boats and SRVs was discussed.  Typically, some operators could only justify boat related procurements when the required resource was noted as a deficiency in a Fleet Inspection Report.  Fleet Inspection Reports are not intended to be procurement justifications and should not be relied upon as the sole basis for an efficient and tenable safety program.  Unfortunately, inspection reports have commonly been the impetus driving the allocation of resources to correct material condition deficiencies after the material condition deficiency progresses to the point of becoming a safety concern.

The workshop identified the need to mandate a formal inspection program of all Class I and A boats.  A Courtesy Marine Examination (CME) by the USCG Auxiliary was not deemed to be sufficient for all operating scenarios.  A CME does not provide a certification of seaworthiness.  Because of this, third party inspections utilizing boat specific attribute lists and conducted by either a marine surveyor, an experienced and trained government employee, or other marine safety expert should be employed in addition to the use of CMEs.

Some participants voiced the opinion that the best advocate for the safety and material condition of a boat is the regular operator of the boat.  However, in a few field activities, there is the perception that Senior Field Managers do not value the expertise of their regular operators.  Because of this situation, the material condition, safety, or regulatory related and bona fide concerns of these regular operators were frequently dismissed or left unfunded.

Senior Field Managers should retain the option of designating an employee as an inspector.  If such a designation should occur, the field manager and the designee must be aware of the rights and responsibilities of an inspector.  This option may prove crucial to compliance with the draft NAO for remote field investigations where access to professional inspection services may be impractical.

The overall material condition of boats was identified as the greatest weakness in attaining 100% safety.  The current triennial inspection program primarily addresses post accident survival equipment, not planned accident prevention, boat condition, operational planning, operator qualification, or configuration of vital systems.
 

Small Boat Program Website

During discussion a common comment was the value of the workshop in exchanging information and ideas across line offices.  A Small Boat Program website has been created at the Marine Operations Center - Pacific Intranet for the purpose of acquiring and disseminating information applicable to NOAA small boats.  Task Team members provided valuable input on potential website content and uses.  Several ideas that will eventually be included as part of the site content include:

. Inspection Schedules
. Current Points of Contact
. Link to NAO
. Small Boat Inventory
. Pictures of Small Boat Operations in the Field
. Inspection Check Lists
. Sample Vessel Policies and Vessel Operations Manuals
. Surplus Equipment Lists
. Lessons Learned
. Bulletin Board Style Discussion Forum
. Training Vendors
. Best Practices or Equipment

The site is currently located at http://intranet.pmc.noaa.gov/sbp/  and is still in the early development stage.
 

General Comment on Current Draft Policy

Concern was raised regarding terminology used to identify persons assigned specific roles and responsibilities in the draft NAO.  One of the initial issues identified as a serious weakness of the current NAO was that it lacked clear guidance and delegation of authority and responsibility.  The current draft of the NAO will attempt to use unambiguous yet generic terms in order to specify, to the extent possible, analogous positions of authority and responsibility across all line offices.  This approach is necessary in order to address the differences in management structures across Line Office field activities.  One solution offered was to speak to the new risk based policy in general terms in the body of the NAO and to include specific details in appendices to the Order.

Differences in the level of formality for different types of risk assessments needs to be addressed.  It is not the intent of the draft policy to require a formal OMAO and Line Office dialog with resultant written findings and guidelines for all risk assessments.  Thus far, only the development of operational risk management documents requires an OMAO and Line Office dialog.  Guidance or advice in determining potential risks involved in the acquisition or procurement of boats smaller than Class III should remain voluntary, at the discretion of the Senior Field Manager.   A risk analysis and OMAO review was recommended prior to procurement, or finalizing acquisition, of Class II and smaller motorboats which will:

. engage in overnight trips, or
. engage in night operations, or
. conduct operations for greater than 12 hours, or
. operate greater than 3 miles from shore, or
. engage in operations for which the boat was not originally intended.  For example, trawling from a center console outboard boat.