Operators in fishing fleets anywhere in the U.S. that operate outside 3 nautical miles should take note of what the Alaska Independent Tenderman's Association has done. Not doing so could cost you a lot of money and long-term aggravation.
First, you have to realize that beginning July 1, 2020, boats 50 feet and over that operate outside 3 nautical miles, were built before July 1, 2013 and are 25 years old by 2020, or are built on or before July 1, 2013 and undergo a substantial change to their dimensions will be subject to construction and maintenance standards in the Alternate Safety Compliance Program.
The program is an attempt to reduce the number of casualties in the fishing fleets. The question has always been what will those rules be? Will a Gulf of Mexico shrimper be held to the same standards as a Bering Sea crabber? For that matter, will an Alaska salmon tender have to adhere to the same construction and maintenance rules as an Alaska freezer trawler?
The latter comparison is what got the Alaska Independent Tenderman's Association's attention. Alaska's freezer trawlers and freezer longliners, the H&G fleets, were subject to something called the Alternate Compliance Safety Agreement, and for a while it looked like other fishing fleets would be held to the same standards.
The Alaska Tenderman's Association's risk assessment of its fleet concluded that the tendering fleet is a relatively low-risk group. Alaska Tenderman's Association photo"At the time we were hearing that if you don't do anything, the agreement would be applied to your fleet," says Lisa Terry, association's executive director. "We looked at that agreement, saw what they were required to do and mildly freaked out."
The risks associated with the tendering fleet were not nearly the same as those the H&G boats face. So the tenderman's association elected to be proactive and develop a risk assessment study of their fleet to understand the scope, nature and causes of tender vessel incidents in the 17th Coast Guard district.
The group talked with the local Coast Guard, hired a consultant and gathered data from their own members, the National Institute for Occupational Safety and Health and the Coast Guard database for the period from 2000 to 2012.
Based on the number of fatalities (three in three separate incidents) and the number of casualties — 21, caused by things such as fires, flooding, collisions, human error and a rogue wave — the conclusion was that the tendering fleet "is a relatively low-risk group," says Terry. "Since we are low risk, we should address our risks and not apply engineering solutions to structural risks we didn't seem to have."
The report is a 42-page document "The Simple Truths of Safety at Sea for the Alaska Tender Fleet: a Study of Tenders in the 17th Coast Guard District" that was presented to a recent meeting of the Coast Guard and the Commercial Fishing Vessel Safety Advisory Committee in Providence, R.I.
Beyond that, the tenderman's association has begun a voluntary inspection plan with the Coast Guard and is developing a best practices manual for the fleet. Terry says the goal is that when the compliance program takes effect "there won't be a transition. We'll already be doing a lot of what's to be expected."
