CED Propeller Guard Testing @ SUNY
ABYC and CED have completed the rough draft of their propeller guard protocol, titled “The Effectiveness of Propeller Guards” and are now putting it out for public comment before delivering the final draft the the U.S. Coast Guard later this Spring. Read More→
We propose a tax on fatal boat propeller accidents similar to a tax on pollution as a means of encouraging marine drive companies to prevent propeller injuries.
The U.S. Coast Guard Advanced Notice of Proposed Rulemaking surrounding propeller and carbon monoxide safety (USCG-2011-0497) asked for public comments on possible strategies to reduce propeller injuries. Thinking about the continuing inaction of the boating industry when many good tools are readily available, I began to look to examples in other industries, where firms previously resistant to human welfare issues had been energized for change. I quickly came to the automotive industry and how they originally resisted calls to improve mileage and/or reducing emissions. Established regulatory targets forced them to action (new car emission limits and fleet mileage targets).
Propeller Fatality Permit mockup
We regulate emissions for public welfare. Beyond the desire for clean air, emissions kill asthmatics and others with breathing issues, as well as bring on other medical problems. Automotive mileage is regulated to reduce fuel consumption which reduces emissions.
Our parallel idea is to consider fatalities from boat propeller accidents to be parallel to boating emissions and regulate them with a cap and trade system as well.
We are not saying the program as described below should be implemented. We are just presenting it to generate discussion. Some version of this approach might be an effective incentive in encouraging the industry to take action while not placing too large of a burden upon them. We welcome your comments.
We note the U.S. Coast Guard added a data field to their Boating Accident Database (BARD) in 2009 for “engine manufacturer”. Many accident reports have no entry in that data field, but it offers an opportunity to associate propeller fatalities with the manufacturer of the stern drive or outboard motor involved in that accident. We suggest strongly encouraging state boating law administrators to encourage those recording accident data to make sure they record the engine manufacturer data for propeller fatalities and possible propeller fatalities. We also suggest they capture a digital image of the drive on the boat when possible to backup that identification.
We also encourage providing a means by which those reporting accidents can accurately distinguish between OMC and Bombardier drives (paint color, markings, decals, significant features, build dates, etc). This would be useful in distinguishing boats powered by legacy OMC drives, vs. boats powered by more modern (2001 or later build date) Bombardier drives.
Armed with that information, the annual number of recreational boat propeller fatalities tied to each marine drive manufacture can be determined, as well as annual trends by manufacturer.
Below we present a Propeller Fatality Cap and Trade with a Tax on Over Cap Fatalities. This approach is a hybrid of two methods we presented earlier Propeller Fatality Tax, and a Propeller Fatality Cap and Trade.
Please note, the numbers and dollar amounts below in bold are just placeholders to begin a conversation. Read More→
We discuss Propeller Fatality Cap and Trade With a Tax on Over Cap Fatalities as a means to reduce recreational boat propeller fatalities in another post. While developing those concepts, we explored some other venues as well. The less desired approaches are provided here as reference material.
In general, they present an approaches similar to cap and trading of emissions.
Two such approaches are presented here
The numbers presented in bold are merely placeholders to generate discussion. Read More→
We are working on a propeller safety proposal that requires an estimate of the percentage of U.S. outboard and sterndrive boats powered by the various outboard and sterndrive manufacturers that are in the field, called the boat park by other nations. These numbers may be considerably different than current market shares due to some manufacturers having large populations of legacy drives in the field. In addition, some manufacturers no longer in operation (like OMC) still have a large population of drives in the field.
We notice the U.S. Coast Guard has supplied a data field for engine manufacturer beginning in their 2009 Boating Accident Report Database (BARD). While this information is only being captured for a fraction of the accident reports, we still submit it as one means of estimating the market share of boats powered by manufacturers of outboards and stern drives in the field.
We created a spreadsheet and examined 2009 and 2010 BARD. We established a subset of data by year that only included outboards and sterndrives, then we counted those belonging to each manufacturer. Several small manufacturers only had one drive. We eliminated manufacturers that did not have at least two drives listed in at least one of the two years we analyzed. Then we grouped the results by manufacturer (like OMC= OMC + Evinrude + Johnson). Read More→
The U.S. Coast Guard BARD (Boating Accident Report Database) is a vehicle for driving continuous improvement in boating safety, however, it is not being widely used.
We suggest all boat builders closely monitor their boats in all kinds BARD reported accidents, develop and test solutions where needed, and use those solutions to continuously improve the safety of their products. Read More→
Safety professionals turn to the U.S. Coast Guard Boating Accident Reports Database (BARD) to find the total number of recreational boat propeller accidents reported to USCG.
USCG acknowledges some propeller accidents go unreported. The boating industry claims the more severe an accident it is, the more likely it is to be reported, propeller accidents are severe, so they must almost all be reported.
Propeller safety activists point to countless unreported accidents and previous studies showing thousands of propeller accidents going unreported.
Without an estimate of the total number of propeller accidents, injuries, and fatalities it is difficult to decide how best to address the problem. This same problem exists in accident frequency studies in automobile crashes, industrial accidents, and other fields. We propose encouraging students searching for Senior Design Projects, Capstone Projects, Sr. Thesis, Masters Thesis, and similar projects to consider applying the techniques used to estimate actual accident frequencies in other fields (like automobile injuries and fatalities) to recreational boat propeller accidents. Read More→
We covered the National Marine Manufacturers Association NMMA public comments on the U.S. Coast Guard (USCG) Advance Notice of Proposed Rulemaking on Recreational Vessel Propeller Strikes and Carbon Monoxide Poisoning in our regulations section.
At the close of our coverage, we presented a wordle of NMMA’s comments.
This post presents a much larger version of that wordle. Read More→
Review of public comments on U.S. Coast Guard’s (USCG) Advanced Notice of Proposed Rulemaking titled, Recreational Vessel Propeller Strike and Carbon Monoxide Poisoning Casualty Prevention. Comments were due by November 25, 2011.
We were disappointed with the total number of responses, but thank all those on both sides of the propeller safety issue for responding.
As of today, December 2nd, USCG lists a total of 27 items in that docket. We will list and briefly summarize them below, by Docket Item Number. Read More→
The U.S. Coast Guard (USCG) requested public comments for their Advanced Notice of Proposed Rulemaking titled, Recreational Vessel Propeller Strike and Carbon Monoxide Poisoning Casualty Prevention. National Marine Manufacturing Association (NNMA) responded on November 25, 2011.
NMMA Public Comment Letter on USCG-2011-0497
NMMA’s letter is easy on the eyes, makes good use of open space, uses over sized top and bottom margins, and is arranged into six numbered sections, with section six being the conclusion. Their comments are printed on NMMA’s letterhead with the blue wave at the bottom of page one and NMMA’s logo in the top left. We discuss each numbered section of their letter below. Read More→
USCG published an advanced notice of proposed rulemaking (NPRM) for Recreational Vessel Propeller Strike and Carbon Monoxide Poisoning Casualty Prevention, USCG-2011-0497, in the Federal Register on August 26, 2011.
The deadline for public response was November 25, 2011.
The U.S. Coast Guard sought comments on specific measures to protect recreational boaters in the water at the stern. Similar to the earlier Kill Switch NPRM, it asked a large number of very specific questions. Read More→