In its recent report on the Seastreak Wall Street’s 2013 allision with a New York pier, the National Transportation Safety Board (NTSB) recommended that the U.S. Coast Guard require ferries to carry voyage data recorders (VDRs).

It wasn’t the first time the NTSB has pushed for the maritime equivalent of aviation’s black box. And it won’t be the last.

NTSB has been advocating for recording devices such as VDRs on vessels in U.S. waters since 1976. International Convention for the Safety of Life at Sea (SOLAS) regulations in force since 2002 require all passenger vessels as well as cargo ships greater than 3,000 gross tons to have VDRs or simplified-VDRs (S-VDR). The rules don’t apply to U.S.-flag vessels operating only in U.S. waters. But Washington State Ferries (WSF), for example, has VDRs on two of its 22 vessels because they go to British Columbia. 

“VDRs do not directly prevent accidents. However, VDR data has greatly improved NTSB investigations and the safety recommendations” important in preventing future accidents, NTSB marine investigator Thomas Roth-Roffy said at the Seastreak hearing. “Staff believes that the safety benefits to the traveling public warrant the installation of VDRs on passenger ferries even if the costs of such installations are considered to be a financial burden.”

 

NOT JUSTIFIED 

 The Coast Guard and the U.S. passenger vessel industry disagree. The Coast Guard pushed back most forcefully in a 2008 report to Congress saying the benefit didn’t justify the cost. The estimated cost of retrofitting and maintaining VDRs over 10 years was $13.4 million for 64 ferries over 100 GT that carry more than 399 passengers. S-VDRs would cost $3.1 million. The agency maintains that the combination of Automatic Identification Systems (AIS) and the navigational data captured by an electronic chart system (ECS) could provide the same information as a VDR.

 “Our positions haven’t changed since then,” said Mike Sollosi, chief of the Coast Guard’s Office of Navigation Systems. “Every time we get a recommendation from NTSB, we treat it very seriously. We feel we are allowed to disagree sometimes.”

Given NTSB’s latest recommendation, the Coast Guard is deciding if it needs to do another study, he said.

 The issue of VDRs onboard may be resolved when the Coast Guard produces a new rule that requires some vessels to have an ECS. The Radio Technical Commission for Maritime Services (RTCM) is working on a standard for the Coast Guard that merges two systems. 

“Recording capabilities inherited or derived from S-VDR will be an ECS requirement,” said Capt. Joseph Ryan, an independent consultant who chairs the RTCM’s e-Navigation Steering Committee. If the Coast Guard adopts the RTCM standard, a separate piece of equipment and rulemaking for VDRs would not be needed. He expects the standard will be published in July.

“Adopting the simplified voyage data recorder capabilities in the RTCM ECS standard is far less complex than requiring the VDR,” Ryan said. Data would include factors such as time, position, velocity, depth, route and tracked radar targets.

 The Passenger Vessel Association “does not believe that there needs to be a requirement for voyage data recorders for passenger vessels in domestic service,” said Ed Welch, legislative director of the Alexandria, Va.-based trade group. “Marine investigations have not been compromised or frustrated by the lack of VDRs. People can figure out what happened and what lessons need to be learned.”

A VDR would have provided relevant information in 6 percent of the 691 incidents from 2000 to 2006 involving ferries that might be covered by a new rule, the Coast Guard report said. The incidents included everything from groundings to steering gear failures.

The Coast Guard concedes that a VDR or S-VDR “could help investigators piece together a crew’s actions shortly before a casualty, particularly when the investigator is confronted with conflicting accounts. A VDR could also identify types of equipment failure that could have contributed to an incident.”

The 2003 Staten Island Ferry accident involving the Andrew J. Barberi was the only one of the 691 with fatalities, “indicating that it may be an outlier, and therefore less informative than would be a larger number of similar incidents.”

But the NTSB said the Coast Guard’s analysis of only the largest ferries was not a representative sample, and the results likely would have been different with data for all ferries the board wants covered.

 The NTSB’s investigation of the 2008 collision of the Coast Guard cutter Morro Bay and the passenger ferry Block Island, for example, was hampered by the lack of a VDR, the board’s Roth-Roffy said. “Data such as audio recordings of crewmembers on the bridge, radar screen image recordings, and vessel propulsion and steering control data were not available to investigators.” 

In the Seastreak accident, “bridge audio recordings, detailed propulsion and steering information, and a record of alarm activations were not available,” he said. While NTSB had AIS and limited engine data, “the data sets were not correlated to a common time reference.” 

The accident in which 80 were injured was caused by the captain being unaware the propulsion system was in backup mode, the company’s “ineffective oversight of vessel operations,” and passengers being allowed on stairwells while docking, the NTSB said.

WSF’s 382'×73'×19' Elwha and 328'×79'×17' Chelan were retrofitted with VDRs to be SOLAS certified and able to operate in Canadian waters. They’re putting a new $43,000 VDR on the Elwha, and in late April were three weeks into the installation.

 And the cost “doesn’t include cabling,” said Steve Peters, a WSF project engineer. “The biggest thing is getting the new machine to communicate with the old machines. That takes quite a while.” 

 The entire fleet has AIS and ECS. And some of the ferries have recorders on the engines in the control room.   

 NTSB also argues that VDR data can be used to improve ship safety and efficiency by, for instance, identifying and analyzing near-miss incidents and helping with crew training.

So, has WSF ever used the VDRs? “Not to my knowledge,” Peters said.

Likewise, the VDRs that are installed on two of the San Francisco Bay Area Water Emergency Transportation Authority’s (WETA) 11 high-speed catamarans — the Pisces and Gemini — have never been used.

“There’s never been a need to look at them,” said operations manager Keith Stahnke. They operate in a Coast Guard Vessel Traffic Service zone, which provides monitoring and navigation advice in busy waterways, and “there’s quite a bit of data available,” he said. A previous WETA administration included the VDRs in the specs for the two vessels.

Even without ferry rules, there’s a U.S. workboat market for VDRs.

“Voyage data recorder sales are driven almost entirely by [SOLAS] regulatory requirements,” Matt Wood, sales manager for Furuno USA, said in an e-mail. “Continued construction of OSVs and PSVs in the Gulf of Mexico has kept our sales consistent. We have dealers in the workboat market that have customers who are planning complete fleet fitting in 2015 and beyond.”

NTSB VDR RECOMMENDATIONS 

 

The National Transportation Safety Board, which has no enforcement authority, recommended that the Coast Guard:

• Require installation of VDRs that meet the International Maritime Organization’s performance standard for VDRs on new Subchapter H and K ferries.

• Require installation of VDRs that meet the IMO standard for S-VDRs on existing Subchapter H and K ferries.

• Develop a U.S. VDR standard for Subchapter T ferries and require the installation of such equipment where technically feasible.

 

 

VDR STANDARDS 

 

VDRs record and save input signals from navigation equipment. Data includes bridge audio, GPS information, ship’s heading and speed, engine demand, fire alarms, watertight and fire door status, rudder order and wind speed.

Standards for VDRs and S-VDRs call for the continuous sequential recording and the capacity for built-in storage of data for at least 12 hours before it can be overwritten. Both must be connected to the ship’s emergency power source. If the emergency power fails, both must continue to record the bridge audio using a dedicated reserve power source (such as a battery) for at least two hours.

VDRs are in fixed or float-free tamperproof capsules. The fixed is “tested for shock, fire, and deep-sea immersion to the equivalent of the temperature and pressure at 6,000 meters.” The float-free, used only with an S-VDR, has a radio transmitter and a light that can operate for seven days.Source: U.S. Coast Guard Report to Congress on Use of VDRs on Ferries, 2008