As the Chief of Prevention for Coast Guard Sector Northern New England, I oversee our commercial fishing vessel fleet. I take this responsibility very seriously and dedicate significant focus and attention to improving the overall safety of the fleet. Commercial fishing vessels are the least regulated commercial fleet in the United States. For this reason, I would like to discuss some of my concerns and the things I believe will improve the safety of those who rely on commercial fishing to make their living.
The bulk of commercial fishing vessel regulations are in 46 Code of Federal Regulations (CFR) Part 28, including the regulatory requirements for state numbered and federally documented vessels broken down by area fished, vessel size, and number of crew. I urge you to review these regulations and determine if you meet the minimum requirements. I stress minimum requirements because vessel owners can outfit their vessels with additional equipment to best prepare them for an emergency. For instance, not all vessels are required to have an EPIRB, immersion suits, or a life raft onboard. This small investment, however, is extremely minor considering what we are protecting.
We are committed to our commercial fishing vessel examination program. We have two full-time civilian examiners on staff and are in the process of hiring a third. We are also training several active duty Coast Guard members to increase our available examiners and improve our service and response time to the commercial fishing fleet.
On October 15, 2015, it became mandatory for all vessels operating outside three nautical miles to pass a dockside examination and obtain a decal as evidence of compliance. These dockside examinations are non-punitive in nature and only result in a required worklist if all required equipment is not onboard. Those who fish outside of three nautical miles without the required decal risk being boarded at sea by one of our Coast Guard vessels and potentially having their voyage terminated if they meet one of the hazardous conditions contained in 46 CFR 28.65. If your voyage is terminated, you will be escorted back to port to remedy the hazardous condition before being allowed to continue your voyage. Not only is this a huge inconvenience, it will result financial penalties, lost fishing time, additional fuel consumption and possibly an extended stay at the dock. It makes sense to call us and complete your examination at the dock prior to heading offshore.
Unlike other vessels, commercial fishing vessels do not receive the level of oversight required of Coast Guard-inspected vessels. Consistent with marine casualty trends, this reduction in regulation for fishing vessels contributes to the relative increase in marine casualties. When fishing vessels are converted or altered from their original design to partake in another fishery, the stability of the vessel can be compromised. It is imperative to seek professional advice prior to making changes to your vessel, especially if the modifications increase overall weight, placement of weight in the hull, or require gear to be mounted above the gunwale. Even small changes can significantly reduce the vessel’s ability to recover and remain upright.
Another significant concern is fatigue experienced by vessel crews. Since there is no requirement for Coast Guard-issued credentials, there are no requirements limiting crew watches to 12-hour periods. Fatigue contributes to countless marine casualties, including injuries, collisions, allisions, and falls overboard. Vessel captains should pay particular attention to work hours and adjust schedules to balance work and rest.
As important as any topic concerning commercial fishing vessel safety is the need for vessel crews to wear lifejackets. There is a longstanding culture of fishermen not wearing lifejackets. This must change.
The technological advances to lifejackets have eliminated any excuse for not wearing them. Today’s lifejackets do not hinder movement or impede vessel operations. They save lives and likely provide the critical time it takes to deploy or use the safety equipment on your vessel or give the Coast Guard time to reach you should you find yourself in distress. If you choose not to wear a lifejacket, then ensure they are stowed in an area immediately accessible during all phases of the vessel’s operations.
As the Chief of Prevention, my primary mission is to enhance marine safety and eliminate maritime deaths. As a vessel captain, it is your responsibility to do the same. Your crew and your family depend on you to focus on coming home safely. I urge you to consider your operation, look at your vessel’s current configuration and determine if it has changed from its original construction, thus warranting a closer look at stability. Schedule a vessel examination. Remain conscious of the hours you work while underway and the role fatigue plays in mistakes and casualties. Conduct realistic drills with your crew and ensure they fully understand all equipment onboard the vessel; they may need to use it to save your life.
The world values and appreciates the work commercial fishermen do. We know that fishing comes with more challenges and hurdles each year. To schedule a dockside examination, contact Brian Smith at 207-664-3931, or Dan Hieter at 207-838-4440. Brian and Dan are ready to conduct your examination and answer any questions you may have with regard to fishing vessel regulations.