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Summary
on Small Passenger Vessels
EXECUTIVE SUMMARY
GENERAL
The Marine Regulatory Directorate
of Transport Canada contracted MIL Systems Engineering (MIL
Systems) to carry out technical investigations relating to the
comparison of regulations and accident statistics for United
States and Canadian passenger vessels, and the determination of
regulatory philosophies behind these regulations.
The approach to the study involved
the following tasks:
- The determination of
regulatory requirements of Canadian and United States
regulations applicable to the construction and operations
of small passenger vessels;
- The comparison of the
differences between the Canadian and United States
requirements;
- The review of Canadian and
United States philosophies with respect to the
development and content of the regulations for vessels
operating in the domestic trade
- The review of Canadian and
United States accident statistics for the vessels under
review;
- The comparison of accident
rates in the two countries;
- The selection of
representative passenger vessels for use as a basis for
costing differences;
- The estimation of the cost of
disadvantage (if any) to the Canadian Industry; and
- The provision of conclusions
and recommendations based on the results of the study.
CONCLUSIONS
The conclusions developed as a
result of carrying out this study are summarized as follows:
- The impact of low tonnage
measurements on updated passenger vessel regulations is
now much less significant than previously, due largely to
the revision of United States regulations and their use
of length and number of passengers as a basis for
regulation in lieu of Gross Register Tonnage (GRT). The
impact of low tonnage on US vessels is no longer
significant for acquisition costs, but remains
significant for operational costs due to manning level
requirements, maintaining the disadvantage to Canada in
this area;
- Major differences between the
two countries' regulations for passenger vessels
summarized as follows:
Inspection
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Canada has a
requirement for annual inspections as well as four or
five year and drydock inspections; US has similar
requirements for vessels not more 100 Tons (new
regulations) but retains more frequent intermittent
inspections during the year, as well as annual and drydock/haulout inspections for vessels more than 100
Tons.
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Structural
Fire Protection |
Similar requirements
for fire-rated bulkheads and decks. Canada requires
fire detection and alarm system; US has no such
requirement except for vessels carrying overnight
passengers.
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Lifesaving
Equipment |
Where Canada requires liferafts, US allows inflatable buoyant apparatus. US
lifejackets are less costly than Canadian models,
having a noticeable cost impact for large numbers
required on passenger vessels.
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Fire
Protection Equipment |
Sprinkler system
required on Canadian passenger vessel No.1, but not
the US equivalent. Two fire pumps required on
Canadian passenger vessels no.2 & 3, US requires
only one. Passenger vessel No.4 requires CO2
system, US vessel does not.
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Navigation
Equipment |
Canadian passenger
vessels No.1, 2, and 3 require a radar and plotter,
US requires neither on standard tonnage and radar
only on "T-Boat" (as a result of recent
regulatory changes). Canadian passenger vessel No.1
requires gyro, US requires magnetic compass only.
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Manning |
Canada is at a
disadvantage primarily due to the requirement to
carry a Chief (Senior) Engineer as well as a Mate on
the three larger Canadian vessels.
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Subdivision |
On the larger vessel
Canada must meet certain load line requirements - the
US standard vessel requires the same but the
"T-boat" (see glossary) has no such
requirements. |
The largest single difference is due to lifesaving equipment,
followed by manning, structural fire protection, navigation
equipment, and fire detection systems. It should be noted
that manning costs have been assumed (see Table 2.3.18). It
is recognized that such costs are independently negotiated
between personnel and passenger vessel owners/operators and
therefore, in reality, may differ significantly from the
assumptions made by MIL Systems;
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- The largest difference
between Canadian and US passenger vessel regulations for
a given size vessel is no longer directly attributable to
tonnage measurement of US vessels and the existence of
"T-Boats"(vessels which would normally be over
100 Tons having a Gross Register Tonnage below 100), due
primarily to revised passenger vessel regulations in the
United States. Tonnage measurement and the existence of
"T-Boats" however, still remains an impact on
operational costs for manning, with estimated costs of
disadvantage between $5,000 for the smallest vessel to
$45,000 for the larger vessel (with overnight passengers)
evaluated;
- Major areas of differences
between US and Canadian passenger vessel regulations are:
structural fire protection, lifesaving equipment, and
navigation equipment. Other regulatory differences were
not found to be significant in terms of cost impact, with
the exception of manning requirements, where there was a
significant variation (see above). Acquisition cost
impact estimates ranged from a $4,000 advantage to a
$154,000 disadvantage to Canadian vessels. For the vessel
with $154,000 (a US "T-Boat"), the three
largest impacts were estimated at $25,000 for structural
fire protection (fire detection and alarm systems),
$88,000 for lifesaving equipment (US use of inflatable
buoyant apparatus versus Canadian requirements for liferafts), $18,000 for Navigation equipment, and $15,000
for subdivision and stability (Load Line requirements).
For the same US vessel with a normal GRT over 100, these
values would be revised to $30,000, $57,000, $33,000 and
$0 for the same topics respectively. Other smaller
impacts made-up the remainder of the overall cost
disadvantage to Canadian vessels (see Table 2.3.28);
- Larger passenger vessels had
significantly higher acquisition cost disadvantages to
Canadian vessels compared to smaller passenger boats. The
two small passenger vessels would in general seem to have
only minor costs of disadvantage over their US
counterparts other than for manning, where cost of
disadvantage to Canadian vessels was estimated at $4,000
to $7,800 / year for a 12 metre boat. Other requirements
had cost impacts of some $5,500 disadvantage to Canada
for Passenger Vessel No.4, and a $4,300 advantage for
Passenger Vessel No.5.
- Passenger vessel accident
statistics varied considerably between United States and
Canadian vessels. Accidents in the US normalized to
Canadian accident rates ranged from as low as 6% of
Canadian strikings for vessels 15<GRT≤100 (US Fleet size 3,873), to over nine
times Canadian incidents of fire for vessels GRT>500
(US Fleet size 129). US collisions, groundings, strikings, and incidents of fire had a general uptrend
with increased GRT normalized to Canadian values (see
Table 3.7). US vessels with a GRT≤100
had 6%-87% of Canadian incidents with the exception of
four times as many collisions and 1½ times more
floodings in the US than Canada for vessels GRT<5.
Surprisingly, vessels 5<GRT≤100
exhibited the best safety record in the US, better than
Canada's, considering that this range of tonnage includes
"T-boats";
- Although Canadian values for Other-Misc. incidents were unavailable at the time of
writing, US statistics, which include disablings and
material failures, exhibited a strong upward trend at the
upper end of the GRT range. Vessels GRT≤100 had one to three incidents per 1000
vessel fleet per year, whereas vessels 100<GRT≤500 and GRT>500 had 77 and 360
respectively. The latter indicates that on average, in
any given year, some 36% of vessels with a GRT>500
will incur an incident of material failure or disabling,
and some 19% of vessels GRT>500 will have a reportable
incident, including collision, grounding, etc.;
- Differences in philosophies
between Canada and the United States for regulatory
development seem to be primarily restricted to the
implementation of international regulations (IMO) to
domestic fleets, where Canada uses this approach, the US
develops most of its own requirements for vessels
operating in US waters, although recent amendments to
lifesaving regulations incorporate many IMO requirements,
with waivers given depending on a vessel's operations and
risk to passengers; and
- The regulatory development
process for Canada and the United States reflects similar
intents for input into the process from all interested
parties, although the US system would seem to reflect a
more open system of regulation, offering additional
explanations and detailed rationale for new regulations
and changes to existing ones.
RECOMMENDATIONS
- Accident statistics
comparisons for passenger vessels between the United
States and Canada show considerable variations of
accident rates, with the United States having generally
fewer incidents for vessels GRT≤100,
and considerably more for larger vessels. Although
reasons for these differences are difficult to identify
without further study, it suggests that the approach
taken by the United States for rulemaking, with domestic
requirements developed by the United States Coast Guard (USCG), in lieu of basing regulations on IMO initiatives,
is equally effective in limiting loss of life and damage
to property for vessels GRT≤100
(Fleet size of 3,873 and 71% of passenger vessels in US,
including "T-Boats"). To this end, it may be
beneficial to review the current practice of Transport
Canada, Marine Regulatory Directorate of applying IMO
requirements to vessels on domestic trade. It should be
noted however, that these statistics do not reflect newly
revised regulations in the United States. Under these new
regulations however, the US still provides exemptions for
vessels not on international voyages and not subject to
IMO requirements. In light of these issues, Canadian
regulators might reconsider their approach to the
application of IMO requirements to the domestic fleet;
- As the large increase in
accidents for US vessels over 100 Tons GRT would seem
unusual, further analysis of these statistics and their
underlying causes might be beneficial in better
understanding regulatory impacts vessel safety.
- During the process of
reviewing United States regulations it was noted that the
U.S. system of issuing, tracking, and revising
regulations seemed somewhat more open. Proposed rulings,
and rulemaking revisions were clearly explained in terms
of rationale and all comments were addressed and
published, including the U.S. Coast Guard's acceptance or
rejection of proposed changes from the public sector, as
well as background of the process to-date. This approach
made it extremely easy to pick-up a document for a U.S.
rulemaking and know the background for the change, the
rationale for it, and the actual regulations proposed. As
Transport Canada, Marine Regulatory Directorate, is
presently revising its approach to the design of
regulations, it might be useful to consider an approach
similar to that used in the United States.
- Although there remains a
disparity in tonnage measurement between United States
and Canadian systems, allowing the existence of vessels
with a Gross Register Tonnage (GRT) much lower than that
which would normally represent a given size vessel for
United States Flag vessels (T-Boats), the significance of
this disparity will become less of an issue in the
future. Although new U.S. regulations will allow existing
passenger vessels with a GRT<100 to maintain the same
equipment and meet the same requirements as when they
were built irrespective of size or number of passengers
carried, new U.S. regulations will impose stricter
requirements on new vessels based on size and number of
passengers in lie of tonnage, thereby eliminating the
advantage of meeting more relaxed requirements for
vessels with a GRT less than 100. To this end, it is
recommended that Canada not change their tonnage
measurement system to a that which would allow tonnages
outside those providing a good representation of vessel
size. As existing U.S. vessels retire and new ones are
built, the disparity between Canadian and U.S. vessels
due to tonnage
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