U.S. Coast Guard NBSAC97 meeting part 3
U.S. Coast Guard National Boating Safety Advisory Council (NBSAC) 87th meeting in Arlington Virginia March 23-25, 2017. Part 3 of our coverage.
Thursday Late Afternoon 25 March 2017.
Boats & Associated Equipment Subcommittee continued
Recent Propeller Injuries & Discussion of Potential Mitigation Strategies
Brian Goodwin gave the presentation.
PropellerSafety.com note – this presentation was a followup presentation on the discussion at NBSAC96 about pontoon boat bow riding propeller injuries. Prior to NBSAC96 we sent the Coast Guard a link to our post about a cluster 6 pontoon boat bow riding accidents in 8 days in the summer of 2016. As a result of those accidents they began to look into the issue. In NBSAC96 they announced a study of pontoon boat accident data would be undertaken.
When we were here in the Fall we heard about a rash of accidents that were happening on pontoon boats and what was looked at was bow riding. As a result a Resolution 2016-96-04 was passed.
As a result, USCG reached out to ABYC and that project is what he will be talking about.
The resolution called for:
recommends that the U. S. Coast Guard initiate a project in collaboration with the American Boat and Yacht Council (ABYC), National Marine Manufacturers Association (NMMA) certified pontoon boat manufacturers, staff and contract engineers, and other interested parties to develop the analysis determining the factors that led to each of the accidents involving pontoon boats over the past 5 years;
Recommendations from that analysis may include but are not limited to:
• Development and issuance of a USCG Boating Safety Circular or USCG Recommended Practice,
• An enhancement to a current ABYC standard or creation of a new standard, noting that a voluntary collaborative approach might be more efficient and more rapidly implemented than by direct regulation.
For ABYC’s bowriding study they will be focusing on people that are outside of the enclosure of pontoon boats.
You can see in the photos that people want to be up here. These boats are obviously anchored. We are talking about when boats are underway.
You can see it happens in much larger boats as well.
“The obvious issue is you go off the front you’re not going to be able to stop the boat, the operator’s not going to be able to avoid the person, you’re not going to be able to put it in neutral, you’ll most likely get struck by the prop.”
Then he described the process as he showed the image below:
Mr. Goodwin said, you have a low proximity to the water, they will go right under and struck by the prop.
He described the process they used to select accidents from 2011-2015 BARD data. There are over 28,000 accidents in that dataset. Then they cut it pontoon boats (1,238 accidents). Then they looked at how many of those accidents fell overboard or were ejected (132). They did not include accidents where people voluntarily departed the boat. Then looked which ones of those 132 accidents were struck by the propeller or by the vessel. 66 accidents remained. They looked at the narrative of those accidents and tried to decide where that person was. Were they outside the enclosure or were they within the confines of the pontoon boat enclosure. Were they in the stern?
Also looked at some vessel dynamics, what was going on. Was the vessel changing speed, changing direction, cruising, idling, manufacturers, models, years, horsepower. When you get down to it and you look at the bow riding and focus down on those narratives there were a couple trends they observed. Some of these shouldn’t be a bit surprise. “A lot of drinking factors, of alcohol and operator inattention.”
PropellerSafety.com note – It is interesting that percentages were provided for most of the variables, but not for the causes (alcohol and inattentiveness).
The vessels were generally cruising, going in a fairly straight line, fairly calm conditions. Not making turns, Not making sudden speed changes. The perception is its a fairly comfortable environment.
The non-bowriding accidents were often caused by a sudden change in speed.
All the accidents were single engine boats. That is just a reflection of what the market share looks like, pontoons are single engine boats.
Over half of these accidents were rental boats.
The market the user group at most risk is rentals.
In 2007 there’s over 800,000 registered pontoon boats out there, but over half these accidents are rentals.
36 accidents were bowriding.
Whats the next step? We’re going to look a little deeper at the actual design of the boats and see if there are trends we can analyze and reach out to the manufacturing community.
Reality is we can say all day long that if you get rid of this front section this problem goes away, but does it really? Do people just open the gate? Do they sit there? Are there legitimate reasons to have a deck area on the boat that is wanted by the customer / the boater? They may be fishing. They may be a fish and ski model where they want to have that deck for fishing.
The person that knows their product best is the manufacturer. They know their customers and what know they do. If we can bring this discussion to them we can help steer the discussion on what is viable changes that may be incorporated into the standards.
He found this picture interesting in that it kinda promotes being in a bad place on the boat when underway.
PropellerSafety.com note – he was speaking of the boat shown near the bottom of the slide above. I enlarged a portion of that image and show it below. As to promoting being in a bad place on a boat when underway, the recent popularity of stern facing seats comes to mind.”
ABYC’s H-35 standard addresses pontoon boats. It has a warning that’s supposed to go on that gate (shown below).
The warning warns the operator not to go up there.
ABYC standards cover the the railing and the gates. We’ve actually made improvements in the last couple years to gate strength. We want to be able to withstand a 400 pound load. Just like the safety railing lifeline around the boat itself.
From a standards perspective, there are standards there. So what is the next step. I talked about working with manufacturers and identify possible engineering solutions, and taking these recommendations, and we’d look at including them in a standard and publish it out there.
There are some other things / opportunities out there, such as to work with NASBLA for a model act. What is the oversight of this rental community? Its a large percentage of the accidents. Its a limited user group. Are those boats built to the standards. Do they need to be? Is anyone inspecting those boats? Do they have the appropriate warnings? Does someone know they shouldn’t go up there. And lastly, targeted outreach to these rental companies.
He showed some of the new designs coming to pontoon boats in the slide below.
That’s where we’re at right now. We’re going to keep digging at this.
Captain Boross thanked him for taking the project on and for putting things into context. On average for that five year period we lost two people per year and one person per month on average is going to get struck off a pontoon boat by the propeller and either seriously injured or killed. We’re damned because of statistics inform us. So that helps us be able to provide that narrative, because numbers do matter. In terms on the targeted approach I appreciate the honing in on the fact that more than half of the mishaps happened on rented pontoon boats. So outreach to rental companies would be an appropriate mitigating measure by us, by our auxiliaries, and by our power squadron personnel as well. Thank you for presenting that information. We will put it into the context you just heard. Thanks.
Chairman Maxim said it was a very important presentation, thank you.
Rich Jepson said he was interested in what controls or standards exist for the rental companies now. Not so much in terms of manufacturing, but their operations and their choices of clients.
Someone asked if someone with the Coast Guard(Phil?) had anything to add to that, but it is his understanding that is mostly a state issue, BLA’s could speak to it better than he could.
Pete Chisholm said:
Comment by Pete Chisholm
“I think the sad part about it is there is really not a lot of standards involved in the rental industry. I’ve had some personal experiences with a rental company that is literally in my backyard in Wisconsin. When the person who went to rent the pontoon boat, which is my manager, looked at the lanyard switch which was missing and said something to the rental operator. The rental operator basically went on a tirade about well its not there because your just gonna trip it, your gonna call me. I’m gonna have to drop what I’m doing, get a boat and go find you to put the switch back on, and then your gonna want your money back. They just totally disregarded it. Obviously they had not had any kind of conversation with their insurance agent or a lawyer.”
Jeff Johnson, Alaska BLA, said they were losing people in some paddle board rental operations. They came up with a vendor checklist that they required vendors to provide to renters when they are under the auspices of waters controlled by the state parks or DNR. It hits the high points. There is an opportunity to control that type of activity through the commercial permit system (rental operation is permitted to operate in a state park, etc.)
Bruce Rowe, said something like that exists. RentalBoatSafety.com Checklists, everything, videos. Its been out there for about ten years.
There was some talk of a resolution.
Pete Chisholm said the report is not finished yet. He said when the report is finished, a resolution may be a way to bolster its findings.
I made a public comment at this time.
Public Comment by Gary Polson
“I’ll go with Mr. Rowe on they had a very nice flip chart. I’ve got one, this big flip over printed chart they’re really nice, they had them a long time ago. I’ve got one . You can still see the charts online at RentalBoatSafety.com
We were the ones that kind discovered the burst of pontoon boat accidents, there were roughly six of them in eight days last year. One thing that we missed in the presentation here was children. Children are very big factor in bow riding often and they’re often not paired with alcohol. They’re just mom, dad, kids up front, and kids falling off. We put up actually two post that covered a lot of ways to try to prevent this accident all kinds of ways. Some of them aren’t feasible. We just tried to point out ideas that might be able to address some issues. One we pointed out a lot was defensive architecture. Trying to do something up front to make it uncomfortable to sit there and one thing we showed was in big cities, like we’re in right now, they do things on to the benches and other things to make them hard to sit on them . If you go around the corner somewhere past Buffalo Wild Wings turn right, they’ve done it to some benches out there, you can sit on them, but you sure can’t sleep on them. You do something up there like a piece of angle iron over the edge where the angle iron toes up kinda so you could puts your toe into it or something like that. You wouldn’t wantabe hanging your legs over that. Another one is they make a bunch of grills for stairways and that kind of stuff. You don’t like sitting on a grill if your in a swimsuit and those kinda things. There’s a lot of opportunities that if you still want to put something up front, you can make it uncomfortable to sit there. Thank you.”
PropellerSafety.com note 1 – when I said “grill” above, I meant to say “grate” or “grating”. Like this stuff:
PropellerSafety.com note 2- our two posts covering ways to prevent these accidents are: Preventing Over the Bow Pontoon Boat Propeller Accidents and Preventing Over the Bow Pontoon Boat Propeller Accidents by Design.
We also have a list of pontoon boat over the bow propeller accidents.
PropellerSafety.com note 3 – in retrospect we identify “over the bow accidents”, they (ABYC) limited the study to people who started outside of the rails. Our list of over the bow pontoon boat propeller accidents includes several people who fell over or through the rails or the gate and met the same end (struck by prop). It would be good to keep this broader perspective in mind when evaluating mitigations and some mitigations might prevent these “start inside the rails” accidents as well. Our 2011-2015 data identified about 57 people going over the bow struck by the propeller including about 11 fatalities. My data includes some accidents in which those struck fell over the rail or through the gate. The ABYC study found 29 bow riding injuries and 7 deaths (36 total). They tried to read the narratives to determine how they entered the water. We have media reports of many of these accident that also provide insight into how they entered the water. I supplied our accident list to USCG back when we identified the accident cluster. When this project began, I was told they had the list and would ask for my assistance if they needed additional information about any accidents on the list. In addition, ABYC should have had access to the accidents data from the states we cannot see (states not reporting to Public BARD, unmasking more accidents than those seen by us). It would have been nice if we could have participated in the accident data review process.
Update of Review of Federal Manufacturing Standards (33 CFR Parts 181 and 183) & Discussion of Potential Recommendations
presented by Phil Cappel USCG.
He thinks these questions were answered this morning. There really is not an environment for us to introduce or even start as large a project as we have. We did have a Congressional mandate that we were supposed to change the outboard motor weight table but that is a very small portion of the regulations we want to update and it was put in our authorization by bill Congress to do this. We got as far as getting the Department to approve it on the 19th of January and on the 20th of January it was stopped. It has been appealed because it is not a large change. The Department has told us to change some wording on it so it might be able to be published. But as of yet, we are still waiting for the Department to go ahead and let us publish it.
So for use to start a project on our own of basically changing a third of our regulations by updating them, its really not worth trying to attempt it and put it into the hopper right now. But it is ready to go if we can just get a little change in the regulatory environment.
The standards for boat manufacturers in the Federal Code of Regulations (CFR) are out of date and it is very challenging to update them, especially in the current environment.
New Business and Public Comment on Issues Related to Boats & Associated Equipment Safety
Larry Meddock WSIA said if he remembers correctly, last year the Coast Guard moved forward on a CFR (I think Mr. Meddock is referring to the Code of Federal Regulations) for the engine cut off switch. He thinks he heard Nicole say a few minutes ago that one of NMMA’s goals was to see something on the engine cut off switch to move forward.
He wants this Council to know that he personally will go to the board of directors of the Water Sports Industry Association and ask them to support and engine cut off switch and hopefully a CFR. His question is, What is it going to take to get this done? I don’t know if you can make a resolution on top of a resolution but if that’s what we gotta do or he just stands up here and pitches a fit.
What’s it gonna take if the Coast Guard knows the NMMA is behind this. If their behind this, what’s the problem? I’ll leave it at that.
Captain Boross responded to Mr. Meddock. He highlighted Mr. Viggiano’s article in the Proceedings. On the right hand side of the page, he has the NMMA verbiage appended to the article there. All I can ask you all to do, is to continue your advocacy as often and as fervently as possible. Then he thanked Mr. Meddock for getting up and speaking on this issue.
Phil Cappel (I think), said the Coast Guard can’t approach Congress directly. We rely on other people. NMMA has their office here in D.C. to basically help move things forward for them by going down and seeing their Congressman and Senators. NMMA was able to put a directive into the USCG bill that was able to change the engine weight table for outboards. It was NMMA that basically did that for us. USCG did not ask the to do it and they are not asking them to insert engine stop switch requirements in USCG’s next authorization bill. But it might be a way forward. He thanked Nicole (NNMA)for attempting that.
Captain Boross noted the Proceedings article notes NMMA sent a letter in support of mandatory installation of engine cut off switches and mandatory use of lanyards in 2011. He has brought up this support to the Admiral. We have been moved up on the priority list, but we have not been moved any further along.
Read Admiral Thomas is carrying this forward. It will be passed forward. Rear Admiral Thomas is departing Washington D.C. this summer for another position.
Polson – I made a public comment noting the first two resolutions passed about 2006. One for putting them on boats and one for mandatory wear. I mentioned we have a kill switch study from about 1977 done by the Coast Guard.
We submitted a public comment letter and I think one of the paddle board guys noted we only had a four day submit period. Would be nice if it was a little longer than that. We were watching the Federal Register and only caught it on the last afternoon.
I went on to tell the audience we submitted a public comment letter on outboard motors breaking off and flipping into boats.
What we talked about was large outboard motors striking a submerged object, breaking off, and flipping into the boat. A comment by Captain Boross two meetings ago in which he talked about the study that found 21,000 BARD entries from 2010-2014 and identified 888 propeller injuries (I should have said “accidents”, not “injuries”). He said:
Captain Boross from NBSAC 95 minutes
“Some of these incidents occurred when a propeller of an underway vessel struck a submerged object and the propeller recoiled and the engine launched and came up out of the water and came inside the boat which amazed him and members of his staff, as there were hundreds of those events.”
We really appreciate the attention he brought to this issue. We would just like to add that its typically the leading edge of the drive, the skeg or the nose cone or something that strikes, its not usually the propeller that make this happen..
We had a chart up earlier and recently posted a different one. Its part of the stuff that we distributed. It shows some of the paths by which these accidents could be prevented. We just like to call it to the attention of everybody. Thank You.
I also said we really appreciated Mr. Hoedt who will not be with us much longer. I’m are sure Marion does as well. I am not a real SPIN person but he helped her a lot and I’m sure she appreciated that.
A link to our written public comment on large outboard motors.
Dave Marlow said we had a good presentation from ABYC remarking pontoon boat rental operations appear to be ripe opportunity for education and Mr. Rowe brought to our attention there is a site out there, RentalBoatSafety.com to address some issues that the Coast Guard sponsors as well as NASBLA sponsors. I had a look at the website and the information claims to be brought forward by the Coast Guard and by NASBLA. Anyway, as I have reviewed it in subsequent conversations it appears that it could be updated. There is no mention of the emergency cut off switch or use of the words cut of switch that I could find. It might be in the video’s I didn’t have a chance to view. But I wonder if this serves as an opportunity to revisit and update that material given the information we have today.
Bruce Rowe talked about the origins of what is now RentalBoatingSafety.com. It started out with 6 or 7 of us working on it as a BSAC project. Wound up with him and Fred doing it. They did it at one his marinas and he paid the gas to get the videos done. Its been out there for he believes ten years now. Everything has been redone on it. They now have it in English and Spanish. There are also quizzes on the website and on the videos. He will take a look at it and if there is nothing on there about the ignition kill, they will get that on there.
An actor, Michael Copon, a Power Ranger did a PSA for it an the visitation went up astronomically. So they have been continuing to upgrade it. At the next BSAC meeting he will bring copies of the different videos to hand out to the Council.
Pete Chisholm asked him if he could provide some additional information to the subcommittee at their next meeting and Mr. Rowe said he would.
Pam Dillon of NASBLA said just to correct the record, that was a grant to Safe Boating Council (the RentalBoatingSafety.com materials). NASBLA assisted on it with the Coast Guard.
Bruce Rowe said it was a BSAC initiative that Fred and he worked on to get it done. Pam Dillon said she stands corrected. Bruce said he sent copies of it to someone at NASBLA and that year at the Summit the Coast Guard got the award for the best safety video of the year.
Chairman Maxim asked if there was anything they (NBSAC) needed to do to cause this to happen (the materials to be updated). Bruce said, no. He will look at it and make sure there is something on there about the ignition kill switch and the safety lanyard and on the check sheets. Bruce thinks its on there, but if its not they will get it added on the website immediately.
Polson – I made a comment that about 2005-2006 there was a BSAC project of which Marion was a part that developed a flip chart. I actually have one. They put together roughly 20 slides and there is a flip chart that is pretty big. When you flip the slide over the person being trained sees the slide, while the person training them sees the backside of the next slide and reads what they are training them about. It’s really slick and a very nice thing. Those slides are online. I think they distributed like ten or twelve of the flip charts to test them out. They did not get any feedback, and it died.
Jeff from the Coast Guard said that for the record, that is the Water Solutions Group grant.
PropellerSafety.com note – as seen above, there was considerable confusion about the origin of the materials on RentalBoatSafety.com. I think part of the confusion about who did this project comes from the project having many pieces.
Among the pieces are the materials on the flip chart, the videos shot by Bruce and Fred, and the website running under Water Solutions Group, originally under a grant.
As to the source of the materials (content of the flip charts) back in November 2005 at NBSAC76, a group was formed to address propeller injury avoidance. (see page 16 of the NBSAC76 minutes).
That group reported at the next NBSAC meeting in April 2006 (See page 6 of NBSAC77 minutes). The findings of that workgroup, of which Marion Irving deCruz was a member, is both interesting and sad. That portion of the minutes are copied below.
NBSAC77 Minutes April 1-4, 2006 page 7.
Propeller Injury Avoidance Workshop Report
John Adey presented on the Propeller Avoidance Workshop. Much of what he had to report was covered in the Chief’s report. He expressed excitement about the possibility of a unique solution. The workshop was in Alexandria, VA, and four ideas came out of the meeting. The first was an educational package for rental boats, which would quickly teach people about boating rules and safety. The second was that every original equipment manufacturer (OEM) install a cutoff switch and the cutoff switch be installed immediately on all boats. Third, a law could be passed requiring that, if the boat has a cutoff switch, it must be attached to the operator. The last idea, which was similar to California’s AB 2222, was that if you are in the water holding onto a boat, the engine must be turned off. All of these items were to be addressed at the Boats and Associated Equipment Subcommittee.
Those same ideas continue to be bounced around in NBSAC over a decade later.
The flip charts and check sheets now on RentalBoatSafety.com were an outgrowth of that project.
END of part 3 of our coverage
Links to the meeting agenda and all 5 parts of our NBSAC97 coverage are below.