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9.0 CONCLUSIONS AND RECOMMENDATIONS

9.1 Data Collection and Organization

• One of the greatest problems encountered in the process of this study was determining the veracity of the recorded data. It was frequently impossible to determine the nature of an incident or even sometimes the nature of the vessels involved based on the elementary field entries:
  
  

  - THE ACCURATE INITIAL ENTRY OF DATA IS OF PARAMOUNT IMPORTANCE FOR THIS TYPE OF RESEARCH
  
  

• Entries very frequently misrepresented the nature of the incident by confusing cause and effect issues:
  
  

  - DATA ENTRIES MUST BE VERY CLEAR AS TO WHAT WAS THE ROOT "CAUSE" OF THE ACCIDENT, AND CLEARLY IDENTIFY THE "CONSEQUENCES" OF THAT EVENT
  
  

• Efforts should be made to harmonize the terminology used in accident reports, and the definitions used:
  
  

  - A COMMON, STANDARD FORMAT SHOULD BE ESTABLISHED FOR USE IN RECORDING AND REPORTING ACCIDENTS, AND RECORDING OFFICERS MUST BE AWARE OF THE IMPORTANCE OF COMPLETING ALL FIELDS. IDEALLY ALL AGENCIES INVOLVED IN RECORDING SUCH DATA WITHIN CANADA AND THE USA SHOULD USE THE SAME FORMAT

9.2 Excessive or Redundant Regulations

9.2.1 General

• The analyses performed indicates that the regulatory regime under which Canadian owners operate incurs a cost disadvantage in the order of 5-10% of initial capital costs, and approximately the same in terms of ongoing inspection and operating costs. However the capital penalty is readily eliminated if one considers the alternative sources of low-cost, new-builds (e.g. China) available to Canadian operators which are not available to US owners who are constrained by the Jones Act
  
  
• The comparison is complex and complicated by the fact that in the USA, in the absence of much regulatory requirement at all, owners are left to determine for themselves what is required for safe and sensible operation. Thus there is more variation in standards of outfit in the US. It is thus impossible to perform a true direct comparison between two sets of regulations when one side of the equation is largely un-prescribed

9.2.2 Unique Canadian Regulations

• Canadian owners ARE burdened by the proliferation of "uniquely" Canadian regulations and standards. There is absolutely no justification for ships built for Canadian owners to have different standards of construction or outfit than those built in Europe or the US
  
  
• Requirements that manufacturers and suppliers must meet unique CSA or TC-SSB standards, rather than simply showing compliance with more universally accepted standards, causes many suppliers to either charge excessive premium costs for their components in this country, or to simply abandon the Canadian market

9.2.3 Canadian Inspection Regimes

• Canadian operators are governed by an outdated set of calendar-based inspection regulations which are considered by the industry to be punitive. It is felt that individual inspectors have far too much discretionary power to call for sometimes unnecessary and expensive removals and/or overhauls:
  
  

  - SWITCH ALL INSPECTIONS TO AN OPERATIONAL TIME-BASED REGIME

  - WHERE CONDITION MONITORING SYSTEMS ARE IN USE, AVOID UNNECESSARY AND EXPENSIVE PHYSICAL INSPECTIONS
  
  

• It is difficult to quantify the cost penalty that is incurred by crossing the thresholds where tugs switch from either no inspection to quadrennial (at 15 GRT), or from quadrennial to annual (150 GRT). There is ample evidence that the industry considers regulatory inspections to be a major penalty as witnessed by the proliferation of vessels at the GRT inspection size boundaries:
  
  

  - ELIMINATE ILLOGICAL SIZE-BASED THRESHOLDS SUCH AS 150 GRT FOR IMPOSING REGULATIONS ON TUGS. A FAR MORE LOGICAL MEASURE FOR REGULATION IN THIS INDUSTRY WOULD BE SOME MATRIX OF POWER AND VOYAGE AREA
  
  

• There is no evidence gained in this study to suggest that US tugs are in general less well maintained or less safe than Canadian tugs. Thus one could surmise that the "free market" system works well in the US without the intervention of government inspectors, and could work equally well in Canada:
  
  

  - ELIMINATE THE UNIQUELY CANADIAN INSPECTION REGIME IN FAVOUR OF AN OWNER/INDUSTRY REGULATED SYSTEM MODELLED ON THE AWO RESPONSIBLE CARRIER PROGRAM

9.2.4 Stability Regulations

• There is a distinct need to harmonize Stability Regulations for towing vessels on an international basis. The Canadian regulations for towing vessels are out of date and inadequate in relation to the type of towing vessels being built today. The US regulations are far more comprehensive, and are based on realistic criteria for towing vessels, but are also considered by many to be overly conservative:
  
  

  - INITIATE A MOVE TOWARDS AN INTERNATIONALLY ACCEPTED COMMON STANDARD FOR TOWING VESSEL STABILITY

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