Alternate Safety Compliance Programs

USCG and affected industry parties strategize to target safety performance variability

By Leslie Hughes and Cdr. Chris Woodley

The Coast Guard Authorization Act of 2010 provides for the
development of regional and fishery-specific safety programs, known as
alternate safety compliance programs (ASCP). Such programs provide an
alternative safety standard to existing vessels that cannot meet future
requirements of vessel classification and loadline.

In fact, the 13th and 17th Coast Guard Districts have had much
success with this kind of regional approach. Additionally, the recent
Alternate Compliance and Safety Agreement has resulted in a
comprehensive vessel inspection and training program for more than 50
catcher-processor vessels operating in the Bering Sea/Aleutian Island

Measuring Risk in the Fishing Industry
Since 1990, the National Institute for Occupational Safety and
Health (NIOSH) Alaska Pacific Regional Office has monitored the safety
performance of fishing fleets throughout Alaska by measuring individual
fleet fatality rates. Fatality rates are measured by comparing the ratio
of the number of fatalities to an occupational risk exposure.

This operational risk exposure measurement is based upon several variables including:
• The number of vessels operating,
• The number of days the vessel is at sea,
• The number of crewmembers exposed to the occupational risk.
Review of this data clearly demonstrates that fatality rates and
causal factors are highly differentiated among vessel types, fishery
gear, species being fished, and geographic region.

Risk is Regional
For example, a recent safety study found that in the waters of the
state of Alaska there were nearly 60 different vessel/gear/species
combinations, with each fishery having significantly different fatality
rates and casual factors.

Some of these fisheries had high rates of falls overboard related
to gear-specific operational practices, some had problems with vessel
stability, and other fisheries had a large number of capsizing events
due to poor weather and local geographic features. Other fisheries had
virtually none of these problems.

Alternate Safety Compliance Programs
Once a fishery has been determined to be high-risk and considered
for an alternate safety compliance program, the Coast Guard and affected
industry parties consider which strategies could prevent fatalities or
vessel losses. Specifically, mitigation strategies should focus on
achievable improvements, with some of the following considerations in

Training: Are the risks associated with a
particular fishery such that crewmembers would be better prepared to
deal with the most common emergencies if they had more extensive
training and/or if additional crewmembers received training? Is there a
need for customized training to address the particular hazards a gear
type encounters? Do crews actually conduct drills on a regular basis? Is
there a need for increased compliance?

Structural Considerations: Are vessel losses due
to poor hull condition, downflooding, overloading, or a combination of
these? Are vessels seaworthy and able to withstand the sea conditions
encountered? Do crews maintain watertight and weathertight closures? Do
vessels have adequate stability for typically encountered loading
conditions? Are captains adhering to vessel loading limits?

Operational Factors: Does a vessel need to cross
a hazardous bar to get to the fishing grounds? Does the vessel operate
in remote areas, far from Coast Guard search and rescue? How many people
are aboard the vessel? Is processing conducted on board? Is fatigue an
issue? Do crews adhere to watchkeeping standards?

Equipment Issues: Does the onboard safety
equipment address the most common types of fatalities within the fleet?
Is there better or more appropriate lifesaving equipment? If man
overboard fatalities are a problem, do crewmembers wear flotation when
working on deck? Do crewmembers wear strobe lights on their immersion

Compliance: Are fatalities occurring within a
fleet despite high levels of participation with the Coast Guard Dockside
Exam Program? What is the level and quality of interactions with the
Coast Guard? Could fatalities be reduced with increased compliance with
existing fishing vessel safety regulations? Does the vessel carry
required lifesaving appliances? Is lifesaving equipment well maintained
and serviceable?

Implementing an ACSP
For an alternate safety compliance program to be successful, the
Coast Guard must have a solid under­standing of actual industry
practices, and risk to the fleet. Industry needs to acknowledge risks
and be willing to move forward in order to mitigate them.

True collaboration with industry is vital. As such, each side
must sublimate its own agenda to the overall goal of effectively
reducing risk. Some guidelines include:

  • All parties should understand that quantifying the safety
    improvements might take years. This should not be viewed as a deterrent
    to establishing incre­mental safety improvements.
  • All entities must be realistic about what will be required to
    implement an alternate safety compliance program and adequate resources
    must be dedicated to conduct the program.
  • Both Coast Guard and industry must be flexible regarding how
    risks can be mitigated as well as how a safety regime can be upgraded.
    As the alternate safety compliance program for a particular fleet
    evolves, additional concerns may be discovered and changes to the
    requirements may result.
  • The Coast Guard must assume the lead for compliance with ACSP provisions by providing clear program guidance.
  • The Coast Guard must exercise continuous evaluation of industry’s progress and assess the effectiveness of the ACSP.

Leslie Hughes was the executive director of the NPFVOA vessel
safety program until 2008, when she became the director of industry and
government affairs. She has been actively involved with the commercial
fishing industry for more than 35 years and currently serves on the
Coast Guard’s Commercial Fishing Industry Vessel Safety Advisory
Committee. She has received two Coast Guard meritorious public service
awards for promoting safety for commercial fishermen.

CDR Chris Woodley is currently chief of the Prevention
Department at Sector Puget Sound. As a 20-year career marine safety
officer, he has enjoyed being able to collaboratively work with the
North Pacific fishing industry in multiple tours and capacities as a
senior marine inspector, an investigating officer, an oil spill
responder, and as a fishing vessel safety/fishery management policy
analyst. CDR Woodley graduated from the University of Oregon and also
has a Master of Marine Affairs degree from the University of Washington.

This article originally appeared in the Winter 2010-11 US Coast Guard Proceedings.