NVIC 01-03: Subchapter W safety assessment alternative for survival craft

COMDTPUB P16700.4 NVIC 01 03 FEB 6 2003 NAVIGATION AND VESSEL INSPECTION CIRCULAR NO. 01 03 Subj: GUIDE TO SUBCHAPTER W SAFETY ASSESSMENTS UNDER 46 CFR 199.630(f)

Guide to Subchapter W Safety Assessments under 46 CFR 199.630 (F). — PURPOSE. This Circular provides guidance on the Subchapter W safety assessment alternative for survival craft as permitted by 46 CFR 199.630(f) for passenger vessels of at least 100 tons gross tonnage (Subchapter H) in Great Lakes; lakes, bays, sounds; and rivers service. The alternative safety assessment is not available to Subchapter H vessels in international, oceans, or coastwise service. In addition, this alternative is on

1. PURPOSE. This Circular provides guidance on the Subchapter W safety assessment alternative for survival craft as permitted by 46 CFR 199.630(f) for passenger vessels of at least 100 tons gross tonnage (Subchapter H) in Great Lakes; lakes, bays, sounds; and rivers service. The alternative safety assessment is not available to Subchapter H vessels in international, oceans, or coastwise service. In addition, this alternative is only available to those Subchapter H vessels in Great Lakes or lakes, bays, and sounds service that are ferries or have no overnight passenger accommodations. This circular describes the type of information and extent of analysis expected in the alternative safety assessment, as well as guidance on the evaluation and approval of the safety assessments.

Guide to Subchapter W Safety Assessments under 46 CFR 199.630 (F). — ACTION.

a. Officers in Charge, Marine Inspection (OCMIs) and the Commanding Officer, Marine Safety Center are encouraged to bring this Circular to the attention of the passenger vessel industry and other marine interests within their areas of responsibility. It is available on the World Wide Web at http://www.uscg.mil/hq/g-m/nvic/index.htm. Internet release authorized. b. The cognizant OCMI should verify and concur with the safety assessment if submitted as an alternative to the requirements of 46 CFR 199.201(b). c. Owners and operators of passenger vessels are encouraged to review the guidance contained in this Circular before conducting and submitting a safety assessment as an alternative to the survival craft requirements in 46 CFR 199.201(b). DISTRIBUTION SDL No. 140 NON-STANDARD DISTRIBUTION: (SEE PAGE 2 - 3)

Guide to Subchapter W Safety Assessments under 46 CFR 199.630 (F). — DIRECTIVES AFFECTED. None.

DIRECTIVES AFFECTED. None.

Guide to Subchapter W Safety Assessments under 46 CFR 199.630 (F). — BACKGROUND. One of the changes to the primary lifesaving requirements for vessels as a result of 46 CFR Subchapter W is the requirement for non-SOLAS passenger vessels over 100 gross tons on routes other than oceans or coastwise to carry survival craft. As shown in 46 CFR 199.10(h), this is required at the time of construction for vessels constructed after October 1, 1996. Vessels constructed prior to October 1, 1996 are requir

4. BACKGROUND. One of the changes to the primary lifesaving requirements for vessels as a result of 46 CFR Subchapter W is the requirement for non-SOLAS passenger vessels over 100 gross tons on routes other than oceans or coastwise to carry survival craft. As shown in 46 CFR 199.10(h), this is required at the time of construction for vessels constructed after October 1, 1996. Vessels constructed prior to October 1, 1996 are required to have survival craft by October 1, 2003. The detailed survival craft requirements are contained in 46 CFR Table 199.630(a). However, as permitted by 46 CFR 199.630(f), an alternative to the prescriptive survival craft requirements in 46 CFR 199.630(a) is provided on the basis that a safety assessment is completed and found acceptable to the OCMI. The safety assessment consists of an analysis of the hazards facing the vessel and the completion of a Shipboard Safety Management and Contingency Plan (SSMCP). Together, these must show that an alternative method for evacuation will provide a level of safety equivalent to that provided by the survival craft. The safety assessment permitted by 46 CFR 199.630(f) is but one of several alternatives allowed by 46 CFR 199.630.

Guide to Subchapter W Safety Assessments under 46 CFR 199.630 (F). — DISCUSSION.

a.

The safety assessment described in 46 CFR 199.630(f) is a performance-risk-based approach to a vessel evacuation as an alternative to the prescriptive survival craft requirements.

The safety assessment consists of two separate but related items.

The first item, which is described in 46 CFR 199.630(f)(1), is an assessment of the hazards that could be encountered on the vessel due to normal operations, other vessel traffic, the port configuration, climate and environmental factors.

The second item, which is described in 46 CFR 199.630(f)(2), is a Shipboard Safety Management and Contingency Plan (SSMCP).

The SSMCP includes guidance for response to catastrophic vessel damage, mobilizing emergency teams, protection of passengers from fire and smoke, evacuation, and emergency communications.

The results of the hazard assessment should be used to develop the SSMCP.

The safety assessment is accepted by the OCMI as an alternative to the requirement for the vessel to be equipped with survival craft when the OCMI is satisfied that the hazard analysis and the SSMCP provide a level of safety equivalent to that provided by the prescribed number of survival craft.

It must be kept in mind that the reduction or elimination of survival craft carriage requirements does not alleviate the need to have an effective means for an evacuation of the passengers and crew. b.

The overall process for completing the safety assessment and for the OCMI to accept it as an alternative to the survival craft requirement is described in enclosure (1).

Note that vessel owners/operators and OCMIs need to refer to the earlier guidance on completing the SSMCP contained in NVIC 1-97, "Shipboard Safety Management and Contingency Plan for Passenger Vessels." c.

It is recommended that the safety assessment, especially the hazard analysis, be completed as a team effort involving representatives of the vessel owner/operator, the OCMI, and other local port entities or emergency agencies as deemed necessary.

The Coast Guard Quality Assurance staff, Commandant (G-MO-1), can be requested to facilitate or assist in this process.

The hazard analysis is best completed using a scenario-based analysis.

Enclosure (2), a generic scenario based hazard assessment matrix, is provided to facilitate conducting the necessary hazard analysis.

It represents a process that systematically answers the following questions for identified accident scenarios: 1) What aspects could lead to an accident?; 2) If the accident scenario occurs, what mitigating factors are available?; and 3) Considering the accident scenario with available mitigating factors, what is the likelihood that it will lead to an evacuation?

Enclosure (3) gives examples of mitigating factors to also help in completing the hazard analysis. d.

When a vessel owner/operator, that has obtained approval of a safety assessment in lieu of the survival craft, requests limited operation outside the vessel's certificated route; it should be treated as a temporary excursion operation using Form CG-949.

Thus, it is not necessary for the owner/operator to complete a new safety assessment.

However, the conditions assumed in the original safety assessment should be reviewed for the temporary excursion to ensure that the assumptions in the vessel's original safety assessment will remain valid.