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NATIONAL SAFETY COUNCIL 425 North Michigan Avenue Chicago, Illinois 60611
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VOLUME 14
NATIONAL SAFETY CONGRESS
TRANSACTIONS
MARINE SAFETY
NATIONAL SAFETY COUNCIL 425 North Michigan Avenue Chicago, Illinois 60611
58th NATIONAL SAFETY CONGRESS
Papers Delivered in the
MARINE SESSIONS
CONTENTS
Longshore Safety in the 70`s ..................... .............. .......... ................ Julius Stern 4 Independent Stevedore's Approach to Safety .............Christopher C. Morton 7 Experiences in Longshore Safety Training....................... Donald E. MacKenzie 9 Safe Locking Procedures ............................................... .. James A. Peterson 13 Know your Lines ........................... .............. .................... .. William Hagenbuch 16 General Dynamics Bio-Environmental Health Control
Center . ..................................... ........................ ............ John P. McCann, M.D. 18 U.S. Shipbuilding and National Safety ...... ........................... Edwin M. Hood 22 A Marine Accident Prevention Program ..... ....................... Sidney G. Pass 24 Safety--An Exchange of Ideas ........ ............ ..................... . Capt. R. P. Walker 28 A Master Looks at Safety Training................. .......... Capt. Oscar H. Gronwall 32 Marine Casualties---Causes and Prevention .........Cdr. John S. Lipuscek, USCG 35 IMOC--What It Is and What It Does...........Capt. Thomas W. Powers, USCG 40 Prevention of Water Pollution by Marine
Transportation ............... ...................... .......... Cdr. Albert G. Stirling, USCG 43 Cleanup and Control of Polluting Spills in the Maritime
Environment ............................. ................ Cdr. Daniel B. Charter, Jr., USCG 47 Address ...... ..............................................Admiral Chester R. Bender, USCG 50 Officers of the Marine Section 1970-71 ...................................... ........................... 54 Five years of Future Dates for the National Safety Congress . ...................... 58 Other Volumes in the 1970 National Safety Congress Transactions...... Back Cover
3
:
LONGSHORE SAFETY IN THE 7C*s
By JULIUS STERN
Welfare Officer, Local 10, International Longshoremen's & Warehousing Union, San Francisco, Calif.
May I extend my personal appreciation job, the accident rate goes up. If we continu and that of the ILWU for having the privi ously push hard to achieve safety awareness,
lege of participating in this most worthwhile conference. A conference of this magnitude, and the caliber of leadership, not only makes it possible to receive singular items of infor mation, but can, also present diallenging new perspectives and new horizons for all present. The International Longshoremen's and Warehousemen's Union has a background of progressive action for the betterment of human values and an active program of ac cident prevention from the humanitarian point of view. Since the acceptance of the principle of collective bargaining in mari time unions, safety and prevention of acci dents has been a major item of discussion in all our negotiations. Under the Association of Waterfront Employees and at the request of the unions as far back as 1929, the work of drawing up a Marine Safety Code was delegated to representatives of shipping
companies, delegates from waterfront em ployers, and longshoremen representing all major ports of the Pacific Coast.
This code was adopted at special meetings of the Pacific Coast Marine Safety Code Committee held in San Francisco on August 2, 1929, and remained as a voluntary code until 1946 when, in the Return to Work Agreement, the P.C.M.S.C., as it became known, was then made a part of the long shore contract between the Waterfront Em ployers Association and the ILWU. Between 1946 and 1948, an in-depth study was made of working conditions, and the results of these findings revised the existing code which was put into effect as the 1949 Revi sion of the PCMSC.
the number of injuries, goes down.
We are, today, in the maritime industry, confronted with a multitude of changes. We originated the agreement to modernize--the outgrowth of which has given us more "izes:" "container-ixe" -- "jnmbo-ize" -- ''mechanize" -- "Unitize" -- ail boiled down mean higher, faster and bigger. Along with these modernized phases of operation come "modernized hazards to life and limb." With the bigger, the higher and the faster, the worker must become "quicker," "smarter," and "alerter."
To compete in the world's shipping trade, minimal in port time is essential to the ship ping companies. Hence, we must increase the tonnage per working hour. All of tills can be accomplished with bigger machinery of greater capacity, but too little thought in de sign improvement is given to the basics of coordinating the movements of men with the motion of weight. Certain basic safety de vices are built into the construction of weight moving equipment, such as warning bells on traveling cranes, capacity markings on booms, and the like; but what we need are fail safe devices when safe stresses are exceeded, so the equipment or handling devices stop in operation. What we need is for the same concern to be given to protec tion as is given to production. We in the labor movement are constantly told these protective devices are costly and unnecessary. We in labor believe this theory is a twisted economical concept for any business firm to avoid a rigorous accident prevention proerarn.
Again, in the 1966-1971 agreement, the During our period of modernizing the ship PCMSC was revised for the purpose of up ping industry, design and construction of
dating the code to reflect the needs of a more modern and changing industry.
We certainly cannot review all of our ac complishments over the past years, nor can we review our disappointments. There have been too many. Over the years, the one fact that stands out clearly is that if we relent in our efforts toward achieving safety on the
huge weight handling equipment was and is priority; Methods of lashing or securing loads or containers are secondary. How this will be safely achieved is the last considera tion.
First, we must recognize that accident pre vention in the longshoring industry is unique, due to the vast difference between this indus
4
Murine Section
try and other industries. While many of them involve material handling, none have the complexity of materials nor the methods and differences in environment of work places. It is the accepted rule that manage ment controls the accident prevention pro grams in all other industries; the policy is established by the general manager through his own channels down to line supervisors. In our industry, we have no single general manager but many employers, all of whom are in competition with each other for busi ness. Therefore, establishment of policy and Site carrying out of the program for safety must be left to many persons with entirely different viewpoints on the subject.
Another aspect which should be mentioned is that, due to the wide variety of commodi ties handled, each employer is dependent on what his company principally works with and develops his own approach to the prob lems confronting him.
Other industries have employees tinder control of one supervisor or foreman, and these employees know what his expectations and policies are. On the waterfront, a long shoreman may work for as many as five different bosses every week, and even for five different companies.
With the longshore industry, every vessel is different, and every sling lord of cargo at the hatches presents a different set of circumstances to be coped with. Longshore men can never get wholly familiar with one operation before a new operation commences. Then, compound this confusion with the fact that every different company has their own iritis on how to best handle a specific com modity.
While, as stated earlier, we can look back on progress in achieving improved conditions, we have not achieved outstanding results in reducing accidents. In the ever changing era of modernization, we are faced with new problems and hazards which are resulting in far more serious injuries than in the past. Danger, hazard, and high accident rates have been too long a natural occupational devel opment in this maritime industry.
In the past ten years, the Federal govern ment has done much to improve the hazard ous conditions through inspection and legisla tion. Still, government intervention cannot be effective on its own. The industry itself must take an active part and concern itself
with building in safety along with the de sign and development of the new equipment
For the most part, a ships' cargo handling equipment is used to move cargo and may in volve use of derricks or cranes of conven tional or unconventional design. This brings about another problem--the safety of this equipment must lie with the ship, and when dealing with ships of all nationalities, each working under a different governmental safety code, uniformity is impossible.
While f!te International Labor Organiza tion did establish minimum standards for the inspection and maintenance of ship's cargo handling equipment, there arc many and varied opinions of what is accoxffable as minimum.
Certainly not a!! ships can be thoroughly inspected by surveyors on a regular recur ring basis. We recognize that we must rely on ship's crews to perform careful main tenance and replacement of worn equipment; however, you ran readily see why the steve dore accepting work involving use of heavy lifting machinery must be alert to watch for the telltale signs of weakness or impending failure, and so the longshoremen, too, must be alert to watch out for these dangers.
Like every labor organization, our work force grows and changes. Old timers retire; new young men replace tlwm bat cannot come into the industry with the wisdom that comer from experience.
In past years (and still, to* a large extent), the older and more experienced longshore men passed on to the new comers their know-how ami precautions, but with the changing methods and the introduction of mechanization in cargo handling, new sys tems must be learned as they are developed. Also, in this ever rapidly changing age of plastic and synthetics, science is introducing new materials and compounds. Exotic chem icals, I am told, are being produced at the rate of about forty new products a day. All of these, before much is known of their po tential, must be shipped from one location to another, and materials handling is our busi ness.
We have seen some very strange and very scarey evolutions take place in the holds of ships when a drum, bag, or sack of cargo bearing a long, unpronouncable name breaks open and its contents spill out.
S
19T0 Nuiiomr-! Safely i laora-:
To cope with these problems we must realize the need for training and education on how to avoid contamination, the injuries resulting from inhalation, and systemic poisoning from contact, all of which can seriously maim or cripple our people.
Our union has gone completely into pre training programs for safety and injury avoidance. In 1963 ILWU Resolution 86 was introduced. All locals on the Pacific Coast have adopted by popular vote a man datory safety training program of between 12 and 18 hours for all new men entering the industry. Our B-rlass men, on first reg istering, are assigned to training programs conducted by the U, S. Bureau of Labor Standards, the Pacific Maritime Association, the State of California Division of Industrial Safety, and union officials. Subject matter taught and literature provided results in their knowledge of injury avoidance from falls on ladders to handling chemicals and rigging gear--actually, 14 separate subjects are taught. Longer, more in depth training has been given our union officials. In addition our Stewards Council, comprised of a number of experienced longshoremen designated for each gang, are constantly alert as to the haz ards of the work and the compliance of the
safety codes.
The locals each publish a weekly bulletin which carries pertinent information of re quirements of the Pacific Coast Marine Safety Code as well as requirements of the Bureau of Labor Standards' Safety and Health Regulations.
To date the 3,000 pin* members of the ILWU have taken this safety training as part of fulfilling their requirements to become a union member. This time spent in safety training is a requirment the men fulfill on their own time; there is no pay or compen sation provided for completing this safety training. We are justly proud of our mem bership for this achievement and we expect to cite an improved accident rate as a result of this training.
Recent governmental regulations require that the stevedore company ascertain if any hazardous cargoes are to be loaded and to inform the longshoremen of the nature of the hazard. With some training behind them it is much less of a problem to persuade men to wear respirators and protective clothing when they are aware of the dangers in volved.
With a little safety training and a con tinuing program of safety awareness, it is becoming simpler to persuade men to use proper care in moving, lifting, lowering, stacking, and sorting cargoes. More im portant, the industry as a whole is realizing that increased safety and increased produc tion go hand in hand. We have our gripes about certain trends of management which we consider unsafe to our members. So does management have certain complaints about unsafe acts of our members.
To cope with this area of disagreement we have a joint accident prevention commit tee in each of our locals. Equal numbers of delegates from the union and representatives of management meet on a monthly basis. Conijilaints are voiced and the action re quired by either side is taken arid reported at tlse next meeting. These are all positive approaches toward the reduction of acci dents.
Proposals are currently under considera tion to be enacted into Federal statutes, such
as having load sensing devices on cranes to warn operators of dangerous stresses on the
cranes, and more stringent requirements on the proper labeling and marking of danger
ous chemicals. These are the modem ap
proaches to combat the new hazards brought
about by the mechanization of waterfront
operations.
As has been the motto of our union since
its founding: "An injury to one is an injury to all--and with dedicated continuing effort
we hope to prevent that injury."
6
Marine Section
INDEPENDENT STEVEDORE'S APPROACH TO SAFETY
By CHRISTOPHER C. MORTON Vice Pres., Operations, The Cleveland Stevedore Co., Cleveland, Ohio
Outside of the effective control of tlse operations of the longshoremen working for him, there is no more difficult task facing the individual stevedore than an effective safety program. The individual stevedore has all but faded from the waterfront, and the companies that survive have grown to such proportions that they have been acquired or merged into larger industrial concerns and, in a sense, lost much of their uniqueness. This has made the job of the individual stevedore just that much tougher.
Outside of bare labor costs, the next big gest hurdle for the stevedore has been the high cost of insurance along with the dam aging exposure from third party suits, re sulting from his catastrophic entanglement with the Jones Art. So, it is obvious that the stevedore must do more than just an adequate job in providing his employees with a safe place to work. Not only must the stevedore take pot-luck with the ship fie is provided to work with, the nomination of which he has no say in, but in most ports the people he must work the ship with are, more or less, recommended to him by a union hiring hall or a string piece. It is a brave .stevedore indeed who will refuse his ready-made place to work and work force.
Approximately 30 seconds after he starts to work, he is faced with an aggravated union steward informing him that unless he makes a 20 year old vessel ship-shape immediately, his men are not going to be working that day. If, at this point, he should refuse to load the ship because the ship's owner has not done his maintenance or has left an untidy situation from the previous port, there are four or five hungry steve dore companies in the wings just waiting for the opportunity to take advantage of his predicament.
What occurs next is what each of us face everyday--it is called "stevedoring." That is the split second, vitally important decision as to how to placate the union stew ard, unload the ship at something less than cost, and get everybody off without a lost
time injury. This decision normally is made by an under paid, over worked, and much
maligned individual called a foreman -- a foreman who normally, through excessive hours at sea himself has figured out that the sea is good for fish and he will take his chances with the land sharks on the shore. If lie ha-1 known what was in store for him. l,e would almost certainly still be sail ing. It is here that the thin red line between profit and loss is drawn and implemented. There is no question in my mind that the key to a safe stevedore operation starts with, and ultimately ends with, the ship's fore man Of comae, managemetst, and I mean
top management, must recognize his problem and not only provide him with good equip
ment and ample pay, but also the knowledge that they are behind him in every-way to achieve a safe, and thereby successful, steve dore operation.
Tops management must sooner or later come to the cottchiskm that there never was a safety program yet that was successfully carried out that -did not cost motley--money in the terms of the best equipment available and a top rate preventive maintenance pro gram. Money in the terms of special safety equipment provided free of charge to the employees, such as hard bats and safety shoes. Money in the sense of incentives to gang leaders, tick foremen and, of course, a compensatory wage to the foreman himself.
In addition, an active campaign must be carried out utilizing full co-operation of the U. S. Department of Labor's training service and constant reviews of violations and acci dent frequency tables, as provided by the Federal government:. Safety signs and slo gans, as well as adequate enforcement of No Smoking areas. Protective guards on all fork trucks and cranes must not only be installed and maintained, but also pointed out at frequent intervals.
We in the Great Lakes in general, and The Cleveland Stevedore Company in par ticular, have come up with a small' and con cise condensation of the U. S. Department
7
1970 National Safety Congress
of Labor's safety regulations for the longshoring industry. This booklet is given to longshoremen when the season begins in hopes that throughout the season they might digest some of the basic safety principles in a condensed form. In addition, most ports have in their labor agreement provisions for a joint safety committee whose function it will be to establish port-wide rules to cover specific operations. In most cases this is done with the help of the U. S. Dejsaitment of Labor, U. S. Coast Guard, and the various local fire departments.
There is something unique in the nature of a longshoreman who will bring his ob servance of several pieces of dunnage on deck to a port-wide work stoppage, and yet the next day the same individual will work a 12 hour day under an unlocked beam. This is something that has always plagued water front employers in their search for safety.
Also, we in the Great Lakes have felt it vital to establish workable rapport with the local investigating representative of the U. S. Department of Labor. We have seen all types. Our basic feeling is that if the U. S. Department of Labor inspector comes cm our ship and does not give us a ticket for an unlocked beam or failure to take a carbon monoxide reading where two fork trucks are working in deep tanks, he is not doing anybody a favor. We fed that these viola tions should be promptly issued and followed up with corrective action if the individual involved does not respond. On the other hand, we do not expect to be needlessly har assed with petty and inappropriate violations not directly effecting our work. These can normally be taken care of with a word to the foreman or superintendent and in good time be corrected with no danger to the gang. In all fairness to the Department of labor, over the years we have been blessed with dedicated and reasonable people who, we felt, have helped us immeasurably in our quest for safety. However, some day I would like to see the Department of Labor start issuing
violation'-, tor unsafe acts to the individuals involved and in this way, I think, the true responsibility will be better apportioned than is now the case.
We have been utilizing a special slide pro gram produced by the U. S. Department of Labor in co-operation with M.A.C H.S.C. Some ports are having one member of the committee go through the port unannounced with a camera, and at a subsequent safety meeting show slides with the workers them selves shown in sometimes embarrassing po sitions and circumstances.
Many ports have also used a small publi cation which is put on board the vessel and is a further condensation for the mate of the vessel so that he can be in compliance with those conditions over which he has con trol prior to the vessel commencing work. This is normally done through the vessel's agent, and, we feel, has been helpful in Cleveland in eliminating many of the condi tions which accumulate in previous ports and are left to the last stevedore down the line to eliminate.
Finally, we have urged our union to accept their responsibility in a three point program that, we feel, is their responsibility and duty to their union brothers: (1) acquaintance with the safety code in the interest of safety alone and to resist the temptation of using safety as a dub to ram some unrelated work condition down an employer's throat, under the guise of safety; (2) recognize, avoid, and discourage careless and reckless work practices of individuals who are risking in jury not only to themselves but to others; (3) an alertness to safety hazards along with a prompt report to their immediate superior in such instances where these hazards cannot be eliminated by their own actions. If the union will do these three things and the em ployer will provide the tools in a safe work ing condition, then safety can be achieved and Use stevedore foreman can be effective in not only a safe operation, but a profitable
OHS'.
Marine Section
EXPERIENCES IN LONGSHORE SAFETY TRAINING
By DONALD E. MacKENZIE District Supervisor, V. S. Dept, of Labor, Norfolk, Va.
In a recent newsca.it Coco, the down, said: "Circus days are over for clowns; we can no longer be funny. If you're funny today, legally, you will drive yourself out of business." He continued, "If I throw a bucket of shredded paper into the audience and a piece gets into someone's eye, the circus is held liable. If I run up into the audience and sit on someone's knee and they have a heart attack, the circus is held liable." "In plainer words, liability has had a major effect on tfie fun or laughs I can create." We have become, throughout the last twenty years, so legal conscious that it has destroyed to some extort the ability to laugh at. laugh with, or laugh for.
Our social values have changed. It was not so many years ago that if you had a slight rear-end collision with your private automo bile, you would jump out, offer the other party $20 to take the dent out, and leave. Today, do this and I c;ut guarantee, you will be getting sued for whiplash, broken back, or cracked rectum a month later. Our society has changed; with it, our social values. These same people whose social values have changed work and play with yon, for yon, and are you. Tf this were not true, I'm sure you would not be carrying workmen's compensa tion policies, homeowners' policies, extra ter ritorial policies, etc. I can't remember my father worrying about the height of a fence around his house arid whether he should insure it. I can remember him saving, "Get the. hell off there!" That was enough.
We have changed in our whole social out look. But, yet, we persist in not changing in our work practices. We stick to the adage, "This is the way I learned: I can't under stand why Joe can't learn the same way." Wiser, you learned, you could afford to make mistakes. Today, because of changing values, which in many ways are good and signs of progress, you can't afford mistakes, and the only way to escape these mistake^ is through proper training. I will go a little bit further and say you can keep making mistakes and let your cost? rise and eventually drive your
self from the competitive market; or you can sit back, take, a good hard look at your self, and say, "I'm going to do something about it," or, "What can I do about it?" You can justify yourself ami make all types of excuses and say, "I didn't do it that way; why does Joe?" But I don't think the steve doring industry is that large, that you're going to change the entire United States society or reverse the social changes that have taken place within the society. You had better start thinking, "What can I do about my segment of United States industry to make it competitive or healthy?'' and when you decide this you will find one of the fastest and most economical ways is through proper training and communications. When I say training and communications as one and the same, that's all training is: proper communications.
If you think for ten* minute that you can take a man or group of men and train them in a specific area and consider the job ip then done anti your safety problems are licked, you have another think earning. Training is a continuing process and consists of semi-formal classroom study followed by continued on-the-jnh instruction or applica tion and then periodic returns to the class room. Let*? remember, a large percentage of what is taught \% already known by the class. The big thing the instructor is doing U mak ing people re-think; or, better still, remember or refresh their thinking. Remember also that a very small percentage of anything
taught is retained. The human brain is not capable of storing to that degree. Who re
members the poem Barbara Fritckte, or the poem, Midnight Ridr of Paul Reveref Yet,
the average person had to recite these during his high school days. In fact, because we
don't recite the pledge of allegiance as often as we used to. 1 find people throughout our
nation are forgetting that! I highlight this area to demonstrate that retention of infor mation, including safety, is only accomplished by periodic training.
0
1970 National Safety Cvngress
Now, let us get into the mechanics of stevedore training--who should have it, and why; and I must start out by saying your training had better be total to be effective or to prevent the broken link in the chain.
The first group we had better start with is top management--presidents, vice presi dents, managers, and superintendents. I don't think we have to go into the technical area with this group but mainly create an under standing of what safety is. what part it plays in production, arid the economic factors involved. Also, to get across to them that all the training we may do will be to no avail unless they support it and back up statements with acts. There's not much sense for in stance, in the instructor spending time with employees, going through carbon monoxide testing and proper ventilation procedures, if management doesn't insist that it be done, It would be a waste of money and his time. There wouldn't be much sense to the instruc tor si>ending time cm the how or why of rig ging safety nets while working on benchedup cargos if the foreman can come back and say, "I didn't have a safety net handy so I proceeded without one" and management ac cepts this as an excuse. That's the time when vmt have to back up the program and find mit why he didn't have the net handy. Was it his fault for not preplanning? Was it the gear man's fault because he didn't deliver? Or, was it ymtr fault because it was never supplied? If yon in top management don't follow through, again, training is a waste of your money and the instructor's time.
You can imagine my dismay at one loca tion to find gangs standing by every morning for fifteen minutes until a net was placed under a gangway, whether it needed one or not All T could say to myself was, the money being thrown away by management not training their foremen to know which gangways should be protected by nets and why. Many times this was the difference between profit and loss for the day's opera tion. They must have a fairy godmother someplace.
During tins management training it should
be spelled out which of the following costs of stevedoring are competitive features and
which are not: acquisition costs, material costs, labor costs, supervisory costs, and in surance costs.
10
Acquisition Costs: Taper work, salesmen's salaries, entertainment, etc. Whether you en tertain at a church supper or a night club, at the end of a given period of time you have expended in dollars just about the same as your competitor to get or retain the busi ness.
Material Costs: Possibly you believe you Iiave a sharp purchasing agent. Your com petitor thinks the fame; and where your man may get a break with Allis and Chalm ers, your competitor may get a break with Towmotor. At any rate, to stay in the busi ness today, you Iiave to have forklifts, bridles, nets, honks, shackles, cic.., and you are all expending the same dollar content over a given period of time. It's not a com petitive item.
Labor: It's a known fact labor cost is the same in dollar content, whether you work Boston, New York, Chicago, Norfolk, etc It's not a competitive item.
Supervisory Casts: Now we get into a competitive cost, because if your supervisor lias super-vision, as hte name denotes, he see* thing* others don't He knows the game and the tricks involved with any number of commodities, so that he can produce, better than your competitor and thereby bring higher profits. When your profits arc higher, this gives you the edge on the next goarcund. This is known as the competitive spirit, or the American way of life.
Insurance: Or. direct and indirect costs of an accident or injury Tins ha* a tremendous bearing on supervisory costs because if this supervisor has super-vision, he's seeing the accident before it happens and eliminating it by good work practices within the given production system, thereby reducing your di rect or indirect costs of production. I believe you all recognize this when you receive your workmen's compensation insurance bill, whether you're on manual rate or the debit side or credit side, and I believe you recog nize that this is a competitive cost It can determine whether you get the business or not and, once you get the business, whether yon can make a profit from it or not.
This carries us into the next group, who
should be subjected to training and the rea
son*: why; namely, superintendents and ships'
foremen. Any foreman or superintendent who
thinks he does need training isn't worth his
salt; so, expect resistance when you get to
Marine Section
this area. This guy worked his way up from the bottom, and the main reason he holds liis present position is he could get others to produce for him. He feels, and should feel, that he knows the job better than any one else. However, in the rush of our daily work, little or no time has been spent with this man indoctrinating him into good busi
were no sideline expenses of injuries or damage to cargo. Until this type of training and re-training is accomplished, I doubt whether you're going to move the frequency or severity rate down much further. In plainer words, along with safety, we must teach good business. They are one and the same.
ness practices, the economics of the business, Now, let's get into the next phase of
and the total responsibility of his job. Oh, training-hatch foremen and gangway men;
he can recite tonnage figures, and he can the great, unused potential. If you miss train
show you that he can discharge or load ing these men, I know you will not reduce
more tonnage than any man that walks the frequency or severity and, consequently,
waterfront. But in most cases, he can't tell costs This group acts as the fingers of the
you whether he made economical tonnage or hand; the ship's foreman being the hand.
expensive tonnage. We just haven't indoctri Unless the hatch foreman, can act when he
nated people tills way on the waterfront.
see; the need arising, and unless the hatch
In this respect, we are behind the majority of American industry. This is very easily determined during routine inspections when safety practice is brought to the foreman s attention. The first thing you hear is, "What
jerk thought that one up?" "For cripes' sake, what's coming next?" When you take time to explain the economics of building safety in as the job progresses and how it can't possibly cost extra if you do it this wav, his immediate reaction is, "Another one
foreman can readily recognize the unsafe factor in order to act, he's going to take the ship's foreman to oblivion with him and.
consequently, you. The hatch foreman knows the potentialities of the men in his gang
better than anyone else. He takes the gang off the corner in the morning and it's his duty to return them at night. He has more
to lose than anyone in this struggle for safety. The quality of his gang can suffer, his pocketbook suffers, his self-esteem suffers.
of'those far-out S.O.B.'s telling me what We don't utilize him and he wants to be
or how I should do it." Don't blame him, utilized. Certainly, when five gangs arc rig
he's reflecting what he has been taught: get ging in the morning, the ship's foreman
the tonnage and get the ship out; not, get can't be every place at once. Certainly, when the tonnage economically and the ship out five forklifts are working in five holds, the
economically.
ship's foreman can't he taking tests at all
During this group's training, concentration holds or rigging proper ventilation at all must be placed on the technical factors of holds. If he is. I can guarantee you you're
stevedoring as these men are giving .direc tion. However, we are being unjust in our training if we can't explode each technical factor into an economic factor. Take for
example, the regulations for stevedoring as a base. There is not one regulation within
losing production. The hatch foreman can only be doing it if he's trained to do it.
There's no reason why a gang should be
standing by for a safety net until the ship's foreman is contacted and one ordered. If
the hatch foreman or gangwayman is trained,
the book that cannot be interpreted into dollars and cents, and unless the foreman is made aware of this through proper training and communications, he will always look at safety as something that slowed him. down or caused him troubles, even though it may have been of a temporary nature that he
he knows the reasons why and for a safety net and will in all likelihood have, one in his gearbox, or anticipate when he will need one and have it ready -when needed. We underestimate what this group can and will do for us. They, again, reflect the top man's thinking, and if the top man has not been
more than gained back throughout the day. imbued with the ecoiwtnics of safety and He should be able to interpret safety as .a the need for training to achieve safety, be
dollar value that makes him look good in lieve me, it has not filtered down. This is the boss's eye; that, because he did "such the reason I hear the retort from ships'
and such" at 8:00 a.m. that took five min foremen: "Cripes, Mac, X can't be everyplace utes, he gained one hour throughout the next at once." As part and parcel of safety train
eight; got his tonnage and more, and there ing and dove-tailed all through it should he
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1970 National Safety Congress
responsibilities and authority and their dele gation.
The. last group we mention is the group that are suffering the accidents. This is also through lack of training, and when it comes right down to the nitty-gritty, this group can do the most regarding reduction of accidents. That's Joe! The man in the hold or the slinger--that gny you can't load a ship without, and do we underestimate this guy! He's in the thick of it, knows what's wrong or knows what's coming up that's going to he wrong. Many times, he doesn't dare to change it, and many times doesn't know how to change it, and many times is not aware that he can diange it But, still he knows it's wrong, im-iiricth-ely or other wise. If we can get to him, recite the in stances, make him aware and reawaken what lie already instinctively knows through work practices, he goes home in one piece with his rightful day's pay, to return again. The hatch foreman goes home with his self esteem and his full gang, to return again. The ship's foreman has worked his tonnage economically which guarantees return work, are! top management sits back with their rightful profit and lower insurance costs, ready to charge out for bigger and better contracts.
Somebody else has gained here also; the instructor, during the. training process. Be cause. by his listening, he has picked up un believable conditions that are creating acci dents or will cause accidents Yes! From guys like Joe. He can utilize this informa tion with other groups. This is the purpose of safety training, Everybody should and must profit. We are not teaching anything new; we are refreshing people's memories to what they already knew and forgot
The next question may well be, "Sounds good, but where do I get the cash to train the waterfront?" I'm going to say this: $79,000 is the cost of one accident regarding carbon monoxide that I'm aware of, and there have been many before and many after. That $79,000 would give 9,875 men two hours' training in carbon monoxide control, testing, and ventilation; hopefully, eradicating the problem. Because of lack of training in production safety techniques, there are many delays and accidents, not necessarily Injuries, that can be readily con verted to dollar figures. I can't see how you can not afford it.
12
During the last five years we have had a revolution in the marine industry. During this period we have purchased sophisticated equipment; cranes, fifth wheels, ships, boxes, lifting gear, etc. What have we done to sophisticate the man to his surroundings? Not too much, I'm afraid. We are still work ing trial and error. Our types of accidents are changing, our downtimes are much more costly, but we persist in carrying on the thoughts of years ago. That's the way I learned, why can't Joe learn the same way? T don't believe there's a man who would say to the average man on the street, "Go ahead, take my Cadillac for the day." But, many times we do this with much more expensive equipment throughout the normal work day. I question the wisdom and with it I question the costs, and with that I question how long we will last.
Training is the answer. Let's revert back to the three "EV of safety: education, engi neering; and enforcement. Proper training will lick the education and engineering, and. hopefully, education and engineering will lick the enforcement.
Let's take a look at how safety training should be applied. Once again, I must tell you, "Don't underestimate your longshore men.'' Don't be afraid to discuss dollar con tent He's much more aware than you believe. He's aware that the dollar he takes home is generated from the amount of work you get, and he also knows that the amount of work you get depends on his ability to work economically. He also knows there is a con stant competition for contracts within a port, and from port to port. He is well aware that your insurance costs can be the differ ence of whether or not he is gainfully em ployed. He has his pride and self esteem. If you don't believe this, stand on the comer some morning during shape and listen. Joe's gang can tell you how Jim's gang made out the previous day: what he made for tonnage, who got hurt, and where the foolish or non productive moves were made. If you don't include him in your training and planning, if you don't include him in your communica tions, you are being unfair to him, which will show up in devious ways. You are also being remiss in your duties to your princi pals in not getting the most from what you've got, caused by lack of commutucatiems. He's as much a part of the team of production ns the loftiest executive--more
Murine Section
so; you depend on him to produce The job of any executive is to surround himself with people who can produce, and these can only produce if they have the tools of knowledge to produce with. One of the largest tools of knowledge in our particular game is safety, because it is a major competitive cost
What's wrong with spelling it out and leveling? Take, for example, hatch beams not moved hack far enough. Sure, it's dan gerous, and the winch driver can hit them coming out of the hold, possibly damaging bridles, cargo, or even dislodging the hatch beam by shearing pins off,
I don't think that's quite impressive enough. I don't think it's quite the selling job that will leave a lasting impression so that it will not be repeated. We must get to those concerned (and this is cveryhou..-). We can show and explain, that, by taking approximately five minutes during opening up to remove another hatch beam and set of boards, throughout the nest eight hours of work the winch driver doesn't have to slew down as he's coming out or going in fund he does this instinctively!) Everytime he slows down he forces the entire gang to slow down with him, so your cost must be figured on the entire gang. If you lose 30
seconds a draft by this slowdown, it is cost ing 7v; minute; per hour, or 60 minute; per eight-hour day. With a 21-man gang, this little venture is costing 1.260 man-minutes, or $84 and, worse still, the accident exposure never ..was eliminated. So, the slowdown stands the chance of being much worse, and site costs could be much more Magnify tills
cost on a five-gang ship and you're running
close to $500 per day, plus five-time; the
exposure. The cost of doing the job cor
rectly in the morning and eliminating expo
sure besides, would have been 105 manminutes, at a cost of less than seven dollars
When we train for safety in this manner and include it as part and pared of produc tion, we will start to cut into the accident rate. That's good business. What is the cost of not clearing the work area of tripping hazards throughout the day? What happens, cost-wise, when we don't stow hatch beams, pontoons, etc. properly and the gan&wayman or signalman has to slew down, as he doesn't Stave a clear walkway, or, worse still, de cides he's not p ring to walk the load because of obstructions? What happens, cost-wise, when the gang knocks off for fifteen minutes so the carbon monoxide content gets down to a workable level, .ill ho-ause someone didn't plan in the am. and rig his blowers con>x;ly? Let us keep in mind that the gang works in a unit and Use failure of one man effects 21.
You can't afford not to train now, with gang cost doubling, because Paceco crane cost is approximately the same as gang cost. Preparation is all the more important. What it amounts to, instead of having "Double the flavor, double the fun," you have "Double the trouble, and you're under the gun.'" With the fast iurauaronud of container ships on unit basis, you no longer have the opportu nity to recover Inst lime. You did when working break hulk cargo for three days' time, you may have lost on the first day, yon had the opportunity to recover on the second and third day. Our industry Iras changed and will be changing. We must change with It or suffer. Proper training could be the an swer.
Lot's talk to the man: he wants to hear you, and. If you're sincere, don't underesti mate what he can and will do for you That's good business.
SAFE LOCKING PROCEDURES
By JAMES A. PETERSEN Asst. Chief, Operations Div., U. S. Army Engineer District, St. Louis, Mo.
The St Louis District is one of tTie small est of 42 districts within the Corps of En gineers. However, because of its location we feel that it is extremely important to the inland waterway system. The St Louis District is responsible for obtaining and
maintaining a navigation channel in the Mississippi River from Cairo, Illinois, 300 miles upstream to Saverton, Missouri, and likewise the lower 80 miles of the Illinois River from Grafton, Illinois to La Grange, Illinois. We maintain the channel below St.
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2970 National Safety Congress
Louis by using regulating works (stone ence record similar to 1969, with a slight
dikes and revetment) and by dredging. increase in the number of lockages.
Above St. Louis we maintain our channel
Average damage to Government struc
by the use of navigational locks and dams. tures per accident--$3,200--is only a small
We are responsible for operating and part of the total cost of these accidents.
maintaining four locks and dams. Lock and Other items of cost that should be included
Dam 24 at Clarksville, Mo. (Mississippi are:
River mile 273) was placed into operation in
1. Repair of the damage to the barge or
March, 1940. It has one lock which is 110 towboat, drydocking, hiring of additional
feet x 600 feet. Next downstream is Lock towboat or emergency unloading equipment,
and Dam 25 at Winfield, Missouri (Missis loss of cargo, loss of earning power, and
sippi River mile 241) which was completed increased insurance premiums.
in May, 1939 and has one 110 foot x 600 2. Another cost that should be noted is the
foot lock. Our busiest lock is Lock and cost to the marine industry as a whole if the
Dam 26 at Alton, Illinois (Mississippi River damage is sufficient to the lock or dam to
mile 203). The Alton lock was completed require the structure to be closed. There is
in May. 1038 and has two locks. The main no good time to close a lock for repairs. If
lock is 110 feet x 600 feet, which is the one of the locks in the St Louis District is
same as Lock and Dam 24 and 25, and it dosed for any 12-hour period we begin to
has an auxiliary lock which is 110 feet x stack up traffic, and towboats that are wait
360 feet. We are now involved in precon ing aren't earning any money lor their own
struction planning to replace this structure ers. During the ice jams last January we
with a new modern lock just downstream had telegrams and calls from as far away
from the present location. This should he as New York and Italy.
completed about 1980. Lock 27, located in the 3. A third and final item of cost is the Chain of Rocks Canal, adjacent to Granite administrative cost to report analyze, nego
City, Illinois (Mississippi River mile 185) is our newest and most modem lock. It was completed in February, 1953 and has two locks, the main lock being 110 feet x 1,200 feet and an auxiliary 110 feet x 600 feet.
tiate, and settle the accident claims. This is a hidden cost to both the government and the firm having the accident I'm convinced that many of the larger firms have the same amount of red tape in their administrations
Since first going into operation at Lock as is often criticized in the government
and Dam 26 in May 1938, and up until last In discussing safe locking procedures and
week, we have Siad 245 reportable accidents accident* with the personnel on our locks
at all our locks and dams. Cost to repair the and with some of the people from industry,
damage to the government structures was the causes of most accidents can be attrib
$784,000, or an average of $-3,200 per acci uted to one of three basic, elements.
dent. Section 14 and 16 of the River and Harbor Act of 1899 places the liabilities of the accidents on the offender.
The first is equipment. You must have proper equipment of sufficient power to handle what you are pushing in all situations.
I have not been able to identify any speci The safe capability of each boat should fie
fic trend in these accidents, with the excep determined by barge line management for
tion that as the number of lockages increase, every river condition: normal pool, open
so does the number of accidents. A graph river, or ice. Once these capabilities are
of number of accidents versus years looks established, the boat shouldn't be allowed to
like the profile of the Grand Teton Moun take any additional barges. Each boat is
tains. It appears that the years divisible by different. There are good 3,200 hp beats and
five are bad years; 1960-1965, etc. 1969 was just plain 3,200 hp boats. The capability of
our worst year, with 23 accidents, a 55 per each of your vessels must be well known to
cent increase over any previous year, and a all pilots, dispatchers, and managers of your
64 per cent increase over 1968.
company.
Both 1968 and 1969 had approximately the same number of lockages:32,000.To date in 1970 we have had 18 accidents. If the pace continues, we should have an accident experi
Equipment must be properly maintained. The money saved in skimping on mainte nance can be quickly expended in an accident when the cost is figured as I explained
14
earlier. The slow response of an engine to reverse, or a rudder too slow to turn due to improper maintenance can cause real problems. I have seen the statement of pilots on accident reports many times "I threw it into reverse, but it just wouldn't stop." Ul timately, the boat stopped, but not until it liit a gate or a bullnose or something else.
The second basic element in safe locking is having trained, experienced personnel on your boats, and likewise for us on the lock wall. This is perhaps the most critical area in the whole program. Every barge line official with whom I have spoken in the last four years has indicated the problem of getting and keeping good towboat crews, pilots, engineers, mates, arid deckhands.
In solving this problem, perhaps part of the answer lies in the formal school ap proach, such as is being established at Helena, Arkansas. I am part of a committee of navigation people working with the junior College District in St Louis trying to estab lish courses for pilots and engineers. I have heard that similar schools are being con sidered in other parts of the country.
The navigation industry as a whole must put on an extensive public relations recruit ing program to lure additional people to work on the river. I keep emphasizing to all the people whom I interview for jobs on our vessels that I don't believe there is a more lucrative career field for a fellow with basic intelligence and a desire to get ahead than the marine industry.
As for the persons presently in the in dustry. don't push them too fast. Be sure a pilot is truly capable of handling the vessel before you let him take charge. The actions of one unqualified or inexperienced pilot or mate could bring disaster to your company and to the whole inland waterway system. Practice the Golden Rule: Be honest v :th other companies in personnel qualification referrals as you would have them be onto you.
The third basic element in the cause of accidents is a hybrid. It actually could have been covered as part of the other two stems. It is recognizing and allowing for the effects of natural phenomena or condi
tions. Have boats that can properly maneu ver and personnel trained in how to handle a tow approaching a lock with the dam at open river and an outdraft condition exist ing. The same holds true on windy days and when there is ice in the river. The boat and crew must master the situation.
In the St Louis District we have several natural phenomena problems which we have solved by the construction of the deflection situation at Lock and Dam 24 was partially solved by the construction of the deflection dike. A similar, but not as critical, problem exists at Lock and Dam 25. The January ice problem at Lock and Dam 26 is a con tinuing problem with no ready solution. Tim wind and lark of guidewalls at Lock 27 will be solved shortly. We go out for bids for gutdewalls next year.
In regard to problems in the area I solicit your help. Let's communicate. If you or your crews have a particular problem or
complaint, let me or the lodcmasters know about it. It is my belief, and I stress this with people who work for me, that we and the marine industry are partners. The locks and dams were built to serve the best in terest of the public. If you have problems with navigating the St. Louis District, let us know, and if you have any recommended solution, pass that along, too.
The sharp rise in the number of acci dents at our facilities during the increasingly heavy use is a matter of great concern to us, as well as to yon, the user. The cost of these accidents extends far beyond just the cost of repair to the structures. As I see it, the essential elements in eliminating these accidents are:
1. Management officials must know the capabilities of their vessels and operate within this capacity at all times.
2. Follow good maintenance practices on the vessel to prevent malfunction at a critical time.
3. .Hire the most competent people. Use of unqualified or Inexperienced personnel will lead to trouble.
4. Be aware of the inherent danger at each facility due to elements of weather or the natural conditions or the stream.
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1970 National Safety Congress
KNOW YOUR LINES
By WILLIAM HAGENBUCH Asst. General Mgr., Hooven & Allison Co., Xenia, Ohio
The use of rope is attended by certain hazards which cannot be met completely by prior engineering or any mechanical means, but only by the vigilance of an intelli gent, responsible user.
The first step in analyzing these hazards is to recognize two distinct categories in the application of rope. The first category is active service uses such as lifting and tow ing. These uses are characterized by the fact that the individuals (or workmen, or crews) who handle the rope are themselves the principal persons subjected to any hazards from rope failure.
All other uses are lumped together in the second category, transitive uses. These uses are transitive in the sense that any hazard is passed on to someone who had no part in the creation of the hazard. This category -would include standing rigging, concealed applica tions, recreational uses, etc. In these transi tive uses, the involvement of a second party, sometimes an innocent bystander, creates an entirely different situation and calls for dif ferent precautions in the safe use of rope.
Having established two categories of rope use, I now would like to develop two prin cipal requirements for safe use in each cate gory. Here we must distinguish between engineering requirements and supervisory re quirements. Engineering is simply the match ing of rope properties (size, type, safety factor, etc.) to the anticipated application. Supervision, then, should provide the assur ance that anticipated conditions and/or rope properties do not change to adversely affect safety. Also, supervision would indude the assignment of responsibility for this func tion.
In this paper we will emphasize super visory requirements, in contrast to engineer ing requirements, for several reasons:
1. Practically all rope failure accidents are caused by inadequate supervision rather than poor engineering or original product defect.
2, The need for vigilant supervision is not as obvious as is the engineering required
in the selection of size and type of rope and the rigging arrangements.
3. The supervisory function has been ig nored in most treatments of rape applica tions, not. to mention the safety manuals.
4. The rope user (or his agent, or prin cipal) is largely and of necessity on his own with respect to the supervisory function. Conversely, the rope user is deluged with published data and outside expertise in re solving the engineering factors.
Active Service Uses Supervisory Requirements
Active service requires, by definition, the presence of workmen who are in a position to observe prevailing conditions, including changes in the application as well as changes in the condition of the rope. One of these men should be given the responsibility for determining whether or not prevailing con ditions are safe. The responsible man should have received appropriate instruction regard ing safe practices and knowledge of the anticipated conditions (on which the rope selection was predicated). He should also he given authority to alter or stop the op eration as the situation may warrant. When the individual responsible for rope safety departs the site, the work should he stopped immediately, unless he imparts the essential instructions, responsibility, and authority to another person remaining on the site.
Senior supervisors, consultants, experts, etc. should refrain from accepting respon sibility for rope safety during visits to a job site. Instead, they should confine themselves to advising, instructing, and educating the workmen in authority, on the site. It should be noted that the experienced rope user can easily visualize many situations which would be highly hazardous, but he cannot anticipate or evaluate all actual hazards as they' occur on any particular job unless he is continu ously present. Thus, the man who is not present is not in a position to accept respon sibility for rope safety, nor should he at tempt to deprive the man on the job of the authority he needs to assure safe operations.
.i/urffio Section
Before the last man who might reasonably be expected to assume responsibility for rope safety departs the job site, work should he discontinued and he should choose one of the following actions: (1) remove rope to stor age; (2) remove lead from the rope and secure it to avoid the appearance of art at tractive hazard, and to prevent it's being damaged; (3) notify his supervisor (or le gally liable rope owner) of the prevailing situation, including specific mention of haz ards and appropriate precautions.
Engineering Requirements:
Published data on safe working leads (or btcaking strengths and safety factors) apply tty active sendee uses unless otherwise stated. Tite.se working loads are intended to provide adequate safety for life, limb and valuable property in well defined active service appli cations. This would exclude both impact loads and long sustained loads, arid situations where the rope has been damaged.
However, they would include the usual environmental conditions, which are typically limited to the extremes for human exposure with normal winter and/or summer clothing.
Higher working loads may he justified in some instances where the following condi tions are met:
(1) danger to life, limb, and valuable property is negligible;
(2) application conditions can be and are in fact more carefully controlled;
(3) severely limited service life is accept able. Under such circumstances, the higher loads should be determined and authorized only by a responsible, informed person on the job. Outside experts, management super visors, consultants, etc. should limit them selves to educating the man on the job, but they are not in a position to name higher working loads for jobs which they cannot keep under continuous personal surveillance.
Lower working loads are generally justi fied only by economic considerations, such as use of an oversize rope for extended serv ice life or use of an oversize rope because it is on hand or quickly available. Conversely', a lower working load for a given rope rig ging (or the substitution of larger size rope of the same type in same rig) is seldom an effective method to compensate for unusual conditions. For example, a large rope will cut or bum or melt or rot almost as quickly
as a small rope. Tor increased safety under unusual conditions, considerations should be given to other types of fiber rope, chain,
wire rope, or even non-fiexible structures. Data on safe working loads or safety fac
tors may be obtained from the rope manu facturers, and for the more, common types of rope they are published by the Cordage Institute, the U. S. government, various safety organizations, and in numerous engineering handbooks. It is worth noting that the same safety factor is not recommended for all types of rope. For instance, most U. S. sources recommend a safety factor of 5 for manila rope, f> for polypropylene and 9 for nylon and polyester. In addition, it should be pointed out that factors which further decrease safe working loads must he con sidered for most types of rigging, including slings, hitches, and especially simple knots.
For instance, the difference in safety fac tor means that it is unsafe to substitute a small synthetic rope for a large manila rope on the basis of the two having the same ulti mate strength. Does this seem, strange to you ? To convince you, I wish I were prepared to demonstrate how easy it is to cut a small diameter nylon rope when it is under consid erable tension. Anther demonstration I like to give scout troops who o:rne through our plant is to have each scout tie his best knot. Then, when we test the knot we find a considerable variation, but seldom do any knots have half the strength of a good splice--and you would be surprised how many kinds of knots pull apart without breaking the rope, especially in some, types of synthetics.
Transitive Uses
Transitive applications, though they are many and varied, have one feature in com mon: continual surveillance by an informed responsible individual is impractical, if not impossible. In view of this circumstance, spe cial attention must be given to the super visory requirements for safe use.
Supervisory requirements
The property owner who is legally liable must accept a high degree of personal and moral responsibility for the overall safety of the rope use. This involve', at least five func tions :
1. Obtaining competent advice on the en gineering of the original rope installation, including especially any limitations, and as-
17
1970 A -HOrmO 0;/vVV c'-v./'a-
suring himself that these limitations are real istic for the particular applications.
2. Making sure that the design of the rope installation is faithfully executed.
3. Posting notices of limitations when ap propriate.
4. Keep-iing informed of ali activities which bear on the rope installation, being alert for activities which may exceed the limitations. (Exposure to chemicals, high temperatures, and even severe weathering would be illus trative of these activities.)
5. Inspecting the rope periodically for signs of abuse as well as normal wear.
_ The owner's responsibility for these func tions may be delegated to an agent or em ployee who is more intimately associated with the rope use than is the owner. Con versely, the responsibility cannot be trans ferred to a more remote level, such as a con tractor or supplier.
Detailed engineering requirements for transitive rope uses would be too lengthy to incorporate in this guide. However, they generally fall into two categories:
1. Those which arc technically compli cated, though they may not appear so to the layman. This would include static applica tions which are left under sustained loads for long periods (two days or longer) ; im pact loading, where the stretch of a fiber rope is used to stop (or start) a load rela tively quickly (these applications involve acceleration forces equal to or greater than the dead weight of the load); concealed ap plications (such as elevator ropes) where rope wear or abuse are not normally visible, and certainly not apparent: to those whose
safety' may he jeopardized. When any sub stantial hazard may be involved in these ap
plications, expert advice is indispensable.
2. Applications which may seem trivial ex cept that they involve cliildren and/or
incompetents who cannot be expected to exercise mature judgment. For exampleplayground swings. In these applications the working loads should be reduced to 50(4 or less of the working loads recommended
for active service: uses in commerce and industry
GENERAL DYNAMICS BIO-ENVIRONMENTAL HEALTH CONTROL CENTER
By JOHN P. McCANN, M.D. Director of Health, Safety, & Security, General Dynamics Corp., New York, N. Y.
The threat to our environment, as evi denced by the precipitous rise we are seeing in the consumption of natural resources, plus the degradation of what remains by the dumping of wastes, is all too personal for us to ignore. The threat is to our aesthetic senses, our health, and even our very ex istence.
Thus we, as private industry and members of organizations such as the National Safety Council, cannot be against efforts to conserve and enhance our environment any more than we can be against any other program that is designed to preserve health and promote longevity. Our responsibilities in industry for positive action are quite dear. First, we are major contributors to environmental pollu tion. Second, since we have been recognized
18
leaders of technological advances and prob lem solving, we are looked to for solutions Third, since much of our business is of public contract origin, we are closely tied to all aspects of public legislation and should be example-setters from the standpoint of good practices. Finally-, pollution control is an item of major personal concern which de mands corrective action by all responsible citizens.
Environmental pollution has been de scribed, in a recent piece of proposed Federal legislation, as that condition resulting from the presence of chemical, physical, or bio logical elements or agents which (1) ad versely affect human health or welfare, (2) unfavorably alter ecological balances of im portance to human life, (3) affect other
Marine Section
species of importance to man, or (4) de grade the utility of the environment for aesthetic and recreational purposes. The reduction of environmental pollution requires consideration of the use and treatment of air, water, and land, and includes the abate ment of noise, the proper management of solid waste, radiant energy, and radioactive materials, as v.rii as the control of other
pollutants. Beyond this statement, which, in effect,
really has only reference to the maintenance of the status quo, is the concept of environ mental enhancement.
At General Dynamics, we have long been concerned that the environment in which our people work and live, shall be as safe and aesthetically acceptable as we can make it for their well-being. We also have this same concern for the inhabitants of com munities in which our operations are located.
Environmental control has been a costly item in our past budgets and will continue to be so. In the past decade, our capita! costs for air and water pollution control items atone have exceeded 8 million dollars. Op erating expenses have taken another 3.2 million dollars. Forecasts for the current decade indicate that these two items will exceed 38 million dollars.
Control of activities of this proportion require well thought out plans. Thus, in March 19 a corporate industrial pollution committee was established to formalize ma jor pollution control objectives. From this evolve^ the Bioenvironrnental Health Con trol Center which was established at the Fort Worth operations of our Convair Aero space Division in August 1959. This center was charged with the task of providing tech nical information and know-how in the areas of air, water, noise, and thermal pollution control, occupational health and safety, and all other facets of environmental hygiene.
In essence, it was given the charter to assess the problem, recommend solutions, and then participate in the development of getwell plans and establishment of priorities. The design and implementation of required fixes remained the task of facility engineer ing, and both functions were made sub servient to sound financial planning.
Before going into a detailed description of the Center, I would like to emphasize that we visualize air and water pollution a;
merely one facet of a much larger subject; namely, that of man's relationship to his entire physical environment. It makes little difference if we are considering the confined area of his immediate work space or that of the entire community he lives in. Further, it makes little difference whether we speak of it in terms of health, safety, or environ mental control.
It was for this reason that it seemed proper for us to establish a single activity to survey and monitor the entire subject area. Additionally, such a center would provide a major assist in developing a corporate-wide systematic approach in arriving at solutions.
From a Historical standpoint, it may inter est you to know that the name "bioenvironmerita!" was first coined by the U.S. Air Force about ten years ago. It is a contraction of the words biology and environment and connotes the relationship of living things to their surroundings. This same connotation, we feel, provides an excellent description of the mission we have assigned to the center; hence, the similarity of names.
To place General Dynamic!!' objectives in proper perspective regarding our concern for the world we live in and yet be practical, four guiding principles were established to provide a framework and basis for Center activities. We wanted to protect the health of our employes, to comply with all laws and regulations, to be a goal neighbor, and to make a profit.
Pressures to activate the Center came from many areas. Those of most immediate concern were; first, almost every material, chemical, alloy, and process utilized in our business brings with it environmental con siderations. Second, new experimental data has caused a lowering of permissible ex posure levels of environmental variables that we previously considered safe. Third, strin gent new Federal, state, and local pieces of legislation had been enacted or were in the offing. Many of which were confusing and, at times, even in conflict, making compliance complex, difficult, and costly.
Consequently, as a first order of business, the Center was requested to develop a capability that would enable them to assess our industrial activities, materials, and proc esses from nn environmental standpoint Further, to be capable of instrumenting and quantifying environmental variables and to
19
1970 jintional Safety Congress
have knowledge concerning available means to control them. Additionally, Center person nel were to become thoroughly conversant with existing and proposed safety, health, and environmental practices, standards, and laws.
In the accomplishment of the above, an excellent technical library and reference file has been put together. The organization has thus become our centralized repository of information and "know-how" for health leg islation and standards; air and water pollu tion; air and water sampling techniques, testing, and monitoring equipment; waste treatment and disposal methods; environ mental control technology, such as filters, scrubbers, and collectors; personnel protec tion equipment; sanitation; relative toxicides of chemicals; health aspects of new proc esses; noise, lasers, microwaves, radiation, etc. In addition, it provides a source point for information coneming the location of the many diverse corporate resources which have environmental control capabilities; as well as those available from outside consulting or ganizations.
From a standpoint of instrumentation and equipment, the Center maintains a capability to detect, analyze, and/or monitor environ mental pollutants such as fumes, vapors, dusts, mists, and gases. This includes phys ical characteristics of the environment such as noise, illumination, radiation, temperature, humidity, and vibration. By coordinating efforts with our various chemical and process control laboratories, a full range of other qualitative and quantitative capabilities are also available. Similar capability is avail able for evaluating safety devices and per sonal protective equipment. Because of the one-site nature of many of the problems requiring evaluation, much of the laboratory gear is portable.
The personnel resources of the center con sist of an administrator, industrial hygien ists, health physicists, technicians, and other company personnel who perform as consult ants on an "as needed" basis. Representative consultant talents include occupational medi cine, aerospace medicine, industrial safety, legal biology, chemistry, physics, and metal lurgy.
Utilizing this talent and equipment, the Center is now assisting our divisions and subsidiaries in a number of ways. For ex
ample, by providing fast answers to basic questions; accomplishment of literature sur veys and advising on specific problems; by providing men and equipment to evaluate specific problems; and by conducting sched uled comprehensive industrial hygiene and environmental pollution surveys. These are low cost services available to any group that requests them. The findings and comments go to the requestor for his use, thus obviating the connotation of a police or inspection organization.
In addition to these service;;, new processes or chemicals under consideration for use or purchase are reviewed; areas requiring re search are defined; personnel are furnished to serve on committees; and active participation is maintained in the proceedings of technical organizations such as industrial hygiene asso ciations, health physics societies, air and water pollution control and waste disposal associations.
Long range plans provide for the periodic publication of an environmental health and -afety newsletter; development of operating standards, manuals, training aids, and hand books on health arid safety; research of specific problems involving lab tests; investi gation of related cost savings and trade-off concepts; and encouragement of contracts to study health, safety, and pollution problems.
Since its inception, most of the Center's energies have been directed towards the ac complishment of a corporate-wide industrial hygiene and environmental survey, the pur pose being to establish base-line reference points of where we are, where we have to go, how long will it take to get there, and how much will it cost.
Our Surface Shipbuilding Division at Quincy, Massachusetts and the Electric Boat Division at Groton, Conn, were two of the early operational locations surveyed. To give you some idea of what these surveys entail, a brief review of the survey team's modus operand! may be of interest.
Initial action was the distribution of a corporate executive memorandum to all divi sion managers outlining our position con cerning environmental control, the reasons for the survey, the results desired, and a request that the survey team be provided their full cooperation. The team was then scheduled to look at like industries located in the same genera! geographical area.
20
il/in'inv Session
In the case of Quincy and Electric Boat, a four man team and equipment from the Center was put together. On arrival, both personnel and equipment augmentations were provided by the host division. Their subse quent survey activities utilized the better part of two weeks. This time element might have been longer except for the fact that much base-line information was already available and merely required updating and compilation.
Of prime concern was a review of our operations as they related to Federal, State, and local requirements. Thus, in the case of air pollution, emphasis was placed on an assessment of sulfur dioxide, suspended par ticulate matter sources, and airborne levels. Similar attention was also* given to hydro carbons, carbon monoxide, and photo-chemi cal oxidants.
Regarding water pollution, a review nf the local water shed and drainage systems was accomplished, evaluating both point dis charges and surface water runoffs. Analyt ical tests included those for coliform bacteria, pH, total organic carbons, biologi cal oxygen demand, and chemical oxygen demand.
Micro-environmental surveys of the im mediate work place environment were simi lar to those accomplished as part of our industrial hygiene program. They included analysis of atmospheric contaminants for lead, cadmium, zinc, beryllium, asbestos, polymers, solvents, carbon monoxide, etc. Again,1 source points, control methods, and existing levels were evaluated.
From the standpoint of physical agents, noise, illumination, ionizing, radiation, and lasers were included.
To round out the overall assessment of base-line conditions, rest rooms, food service facilities, and general yard sanitation meas ures were also evaluated.
Although a number of items were found at both yards that needed further attention, no major heretofore unidentified trouble spots were detected. Those requiring our immediate concern included better methods for the disposition of chemical wastes and more aggressive noise control programs.
each of which is now receiving local and corporate attention.
Of greatest value was the fact that for the first time we had a single document that described conditions as they existed in finite terms. Our follow-on action includes condensation of this material with similar type status reports from all other operating locations,. Proper corrective actions needed are then proposed and priorities for imple mentation established.
Hopefully, intelligent and practical inter pretations of new laws and regulations will allow us to progress with this approach in a sane and orderly manner.
In conclusion, the Center belongs to each of our divisions and subsidiaries. Its use fulness depends on the use made of it by management and their health and safety personnel. It has been in operation now for slightly over a year. During this time, we have accomplished detailed air, water, and industrial hygiene surveys of over threefourths of our manufacturing locations and work environments involving nearly 80,000 employees.
Returns have not been spectacular from the standpoint of discovering heretofore un known problemsTM They have, however, been invaluable in quantifying the problems and describing them in finite measurements that design engineers can work against in coming up with .solutions. To date, the solutions do not appear to be technically impossible, but are costly and time consuming.
As we see it, we still have a long way to go before we reach an optimum relationship with our environment In fact, we never expect to reach a complete end point.
Environmental health safety and pollution control are part of an evolving technology. New hazards are constantly being introduced and new and more efficient control methods dis covered. Each, in turn, require new evalua tion selection and implementation. Even more importantly, there will always be a constant requirement for review and enforcement of existing control techniques and procedures. Consequently, we see a continuing and grow ing need for the centralized bioenvironmental health control center we have established.
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1970 National Safety Congress
U.S. SHIPBUILDING AND NATIONAL SAFETY
By EDWIN M. HOOD President, Shipbuilders Council of America, Washington, D. C.
To a nation virtually surrounded by water, as the United States is, the seas--the oceans--have a three-fold purpose. They con stitute a moat with which to deter the aggres sive purposes of unfriendly or even friendlypowers. They provide a conveyor belt for the transport of essential commodities and products. And they represent a resource of infinite proportions in terms of foodstuff and minerals yet to be tapped.
The common denominator, in cadi of these three areas, is ships. But ships without sup porting shipyards are like butter without bread. U.S. sea power encompasses not only mercliant and naval ships, but also ship building and ship repairing capabilities, as well as the industrial and manpower vigor of America. By manpower, let me assure you, I have iu mind men and women skilled and unskilled, blue collar and white collar, professional and administrative disciplines, plus the promise of the future; our young people.
Any fair assessment of history suggests that a balanced industrial base, including shipbuilding, ship repair and ship component capabilities, is no less important to effective sea power than are the naval and merchant fleets themselves. History also suggests that the nation which builds the ships, carries the cargoes, collects the revenues therefrom, and keeps the sea lanes open for commerce has generally been internationally influential and economically affluent.
Without adequate sea power, as I have here echoed the definition of experts, our country could not long survive as a republic, as a bastion of freedom. Without adequate sea power, you and I would have little rea son to discuss interpretations of safety regulations or allied topics as they concern the marine industry.
In a crazy-quilt sort of way, our country, throughout most of the past two decades, has had available -what can only be described as a marginal degree of sea power. Use of the adjective "adequate" to imply sufficiency under all possible conditions of world tur moil and serenity would be stretching a point. The vital interests of the United States have
been served by naval forces, part old and part new-, and by maritime services, mostly old and minimally new.
New ships have not been ordered in suffi cient numbers to overcome the. high degree of obsolescence which has afflicted both the naval and maritime fleets. As a consequence, more than half of our Navy and nearly three-quarters of the American merchant marine arc today made up cd vessels 20 years of age and older.
Even more incredibly, the United States, the world's leading trading nation, has suf fered the humiliation of its own merchant marine carrying less than seven per cent of its own trade and commerce. The balance has tseen moved in ships flying foreign flags. Ships of other nations have brought to our shores better than 90 per cent o those criti cal minerals and metals without which our industrial and military enterprises could not exist, and without which our national safety would be gravely endangered.
The responsibilities of the U.S. Navy, by the force of world events, have been ex panded. Yet, budgetary strictures of recent times have compelled a decrease in the size of our naval forces. New ships plus World War II vessels, suitably upgraded, have been and are at this moment the mainstay of our Navy. During the past two decades, these ships, their armament, and their crews have made possible the preeminence of American .strength on the oceans.
But, the United States has been slowly and perceptibly losing its total sea power initia tive. Partial obsolescence, diminishing num bers, and reliance on foreign flag shipping contribute to this loss of momentum.
More sensitive, however, has been the rapid emergence of the Soviet Union as a sea power of impressive dimensions. Though the United States is considered by experts to possess a navy of unsurpassed capabilities, those same experts predict that the Russians will shortly be in a position to challenge, in an effective way, the supremacy of American sea power. Those same experts forecast that the Soviet merchant marine, within the next two years, will surpass the U.S. flag mer
22
chant marine in both numbers and tannage. With seemingly equal determination, the Russians arc exploiting, to their own advan tage, the developing spectrum of opportune ties associated with oceanography and ma rine sciences.
It is therefore important dint the changing balance between American and Soviet sea power and all that it foretells for free people everywhere be given the widest possible rec ognition. The national safety of the United States is at issue.. The equanimity of the world is in balance. A conest for supremacy on the seas, and thn-; n contest for the minds of men and women everywhere, is involved.
Control of strategic waters and sea lanes, and thus control of the fbw of vital trade and commerce, is at stake.
More than 80 per cent of the Russian merchant marine is less than 20 years of age, and 90 per cent of the Russian navy is less than 10 years old. Compared with the high level of obsolescence in our maritime and naval fleets, previously mentioned, these modernity indices suggest that the shipbuild ing programs of the Soviets have received high priorities in the alk^ation of ikeal, production, and manpower resources.
The output of intensive ship construction efforts, started in the mi*l-1950*s, has made it possible for Soviet sea jjower to expand around the globe---in the Mediterranean, in the Caribbean, in the South Atlantic,, in the Indian Ocean, and elsewhere. This spreading reach reflects the political, economic, foreign policy; and psychological objectives of the communist regime. Its motivations arc both military and mercantile.
By the end of this year, for example, the number of nuclear-powered submarines in the Russian navy will be equal to those in the United States fleet And, in the next four years, U.S. shipyards will deliver only 20 additional atomic subs, while it is esti mated Russian yards will deliver 60, plus a number of diesel submarines which are no longer ordered by our navy. Many of the submarines in the Red fleet, are, or will be, capable of launching missiles; at our indus trial and population renters, and the safety deterrent is our Polaris/Poseidon forces of 41 nuclear-powered submarines.
The employment of the Soviet merchant marine as a commercial tool has multipled over the past decade. New and modern mer chant ships, flying the emblem of the "ham
mer and sickle/' have been moving into established trade routes and creating new trade patterns. The occupants of the Kremlin in Moscow, in the words of our Chief of Naval Operations, "are dearly willing to undercut freight rates, in order to achieve political and economic leverages in the de veloping nations; financial profit is clearly secondary to their political motives in this regard."
With this kind of motivation in mind, one can hardly feel secure with the news that ships of the Russian mercliant marine will shortly call at U.S. ports on the West Coast on a regular basis. According to press ac counts, no American shipping interests op posed the application for this service at rates as much as 47 per cent below those offered by steamship conferences but com parable with those of some independent op erators in the same Far East to U.S. trade.
It has become increasingly evident that the Soviets have come to recognize the impor tance of the seas to their grand design of world domination and the sea. power initiative lias been slowly and perceptibly shifting from Washington to Moscow. Whereas poli ticians of yesteryears have tended to down grade the steady buildup of Russian ocean strength, the present occupant of The White House in Washington has been more positive and more constructive in his reaction.
President Nixon refuses to abdicate our maritime jiosition to the Soviet Union. Only last week he signed into law the Mercliant Marine Act of 1970 which incorporates his blueprint for the restoration of the United States as a first-rate maritime power. Under this landmark legislation, as many as 300 new, modem, efficient U.S. flag merchant vessels could be built in American shipyards over the next 10 years.
This maritime fleet of the 1970's would correct the errors and omissions of the past It will be structured to carry 30 per cent, not seven per cent, of our nation's trade and commerce by volume. It is intended to serve the national interest by making available sufficient shipping services to ensure that the needs for security, survival, and safety of our great nation can always be met by ships under our own flag and under our own jurisdiction.
To be sure, the results of this renewed effort will not be seen for another several years, and a similar blueprint for U.S. naval
23
1970 National Safety Congress
sufficiency to meet the Russian threat on the oceans is stall in the making. But. the im portant point is that a beginning has been made, a beginning toward reversal of a trend which has brought our total sea power capability to the precipitous brink of being swamped by the Russians.
The task of neutralizing this situation, in very large measure, rests with the shipyards of America. For until new ships are built and delivered, the deficiences in our nation's arsenal of sea power resources will not be remedied.
To complete these l'cuunks, it remains only to be said--and repeated -the private sector
of the U.S. shipyard industry has today the manpower, facilities, capacity, and capabilities to undertake much more work than is pres ently at hand. The industry is prepared to
expand facilities as market potentials mate rialize. It has an excellent manpower base which can likewise be expanded as market conditions require. The industry is fully con fident of its ability to meet the challenge of expanded merchant and naval building pro grams now in the process of development and stands ready to cooperate with the Congress, the Administration, the naval serv ice', and the ship-owning and ship operating communities in measures to strengthen the full spectrum of IIS. sea power resources.
A MARINE ACCIDENT PREVENTION PROGRAM
By SIDNEY G. VASS Safety Director, Marine Transport Lines, Inc,, New York, N. Y.
Marine Transport Lines owns and operates an extensive fleet of ocean-going ships, both in the worldwide and coastwise trades, total ing approximately 1,641,799 D.W.T. This tonnage comprises 14 bulk cargo, 22 tankers, and 18 specialized vessels. The ships are manned by American, Chinese, British, and Spanish crews. The specialized vessels con sist of multiple grade chemical ships; one presently' being built at Ingalls Shipyard will be capable of transporting up to 31 different products at a time; others transporting an hydrous ammonia at --28F., liquid sulphur at 275F., and tetraethyl lead, which can cause lead poisoning from breathing the vapors or liquid absorption through the skin. Incidentally, the latter has no known anti dote. These specialized vessels have, of course, many built-in safety devices and par ticular operating instructions [>ecific to their needs.
The chemical ships, as a group, have the best safety record and the lowest accident frequency rate in the fleet Because the source of seamen is identical for all ships, one must assume that they exercise a greater degree of caution in an environment where safety is practiced as part of the normal job routine.
Marine Transport Lines' loss prevention is based on 10 basic and essential procedures'
24
indoctrination of crew members, instruction of supervisory personnel, development of rules, inspections and observations, accident reporting procedures, accident investigation procedures, recording and analysis of acci dent data, reporting of progress, administra tion of the program, and coordination by loss prevention (directing).
1. Indoctrination of Crete Members
This is the very first step in an effective loss prevention program. When a seaman joins a vessel, his department head gives him one of our "Welcome Aboard" safety pam phlets printed in the language used aboard the vessel--English, Spanish, or Chinese. Not only is this an appropriate greeting to a new employee but, as it contains many safety tips, it will serve as a knowledgeable reminder to him for the entire voyage. We are particularly anxious to convey to all new employees our sincere interest in their safety and welfare. Department heads are instructed to take a few minutes to explain the safety feature of our loss prevention program re garding any particular safety item pertain ing to the vessel, as well as instructing him to report immediately any unsafe condition.
On the inside page of the leaflet alongside the safety tips, (made out to the company's initials) is a slogan which states: "Men who
Marine Section
are properly trained will stay healthier and ance of work aboard the vessels and shore
live longer." Backing this us, directly under facilities.
the sign "Obey Safety Rules" on the first "The safety of our employees and others
page, is a sentence stating: "If you are un certain how a job should be done, ask your department head." All too often we have found that accidents have occurred to crew
aboard the vessels is as always our primary objective and worthy of first consideration. Our second objective is to reduce waste, loss or damage of equipment, cargo damage, and
members time and time again due to a lack delays produced by accidents."
of knowledge of a particular job: conse Other instructions are issued in the form
quently, by informing a seaman ahead of of government publications, such as the
time we horse to eliminate this cause.
U.S.C.G. fire fighting booklet, reference
The last page of the leaflet contains an "Accident Sequence Chart" which outlines, with examples, four steps of an accident from the Reason Why to the Undesired Re sults of the Injury Damage Loss. By this chart we hope to encourage the shipboard supervisory staff to eliminate the reason for an accident on the spot immediately after an occurrence, rather than to indulge in
lengthy correspondence with the home office and consequently wait a number of weeks
before taking action.
books, or our Shipboard Port Emergency Directory, which is a standard form and is designed to provide the necessary informa tion on a particular port. Contained in the form are instructions on what to do in case of a shipboard fire or other emergency. The latter includes the correct procedures to fol
low in obtaining the telephone numbers of the local agent, police, ambulance service,
nearest hospital, etc. Vessels are instructed to post this directive in two conspicuous places aboard ship. Other instructions and general information on loss prevention are
2. Instruction ef Supervisory Personnel
also distributed to the ship in our Safety
As operators of ships, we arc indeed for tunate that our supervisory personnel are licensed to serve in their various capacities by such bodies as the U.S.C.G., as this pro vides us with a competent person for each position. However, over the years it has been shown by the large number of losses experi enced by property damage to ships, as well as personnel injuries, that additional training and instruction are required to control these
losses. '
Many of these instructions are of a re minder nature or tailored to the company's needs, but others give information on the latest government requirements, or upgrade existing practices to keep up with our in creasingly complex technological advances. This entails many forms and varies from vessel to vessel, depending on its type and class. However, each ship is supplied with a company safety manual which is prefaced with a statement of policy. Here are a few
Newsletter or by general letters.
In our opinion, the need for a radar re fresher training course is made very evident by the continued large number of collisions taking place between vessels fitted with radar and from the findings of the courts from investigation of these collisions, which in variably revealed that the incorrect use of radar, including non-plotting or incorrect plotting of targets, was a contributing fac tor. The 168th Annua! Report of the Liver pool Underwriters Association shows that for vessels of the world merchant fleet of SCO gross tons and upwards, 1,624 ships were partially damaged and 21 were total losses as a result of collisions in 1969.
While all these collisions cannot be attrib uted to the misuse of radar, a significant number can, and if this is coupled to the portion of the 903 standings reported in 1969, which resulted from incorrect radar use, the losses remain tremendous.
sentences from the policy which explain the The shipboard radar refresher training
objectives of our safety program rather well: course is in the form of a book entitled
"The safety policy of Marine Transport Lines is to eliminate unwanted, unplanned
occurrences which can result in personal injury, loss or damage to equipment, cargo, vessels and premises. These occurrences are often harmful to the well being of our em ployees and interrupt the orderly perform
Marine Radar and How to Use It, and a monthly radar newsletter, both of which we at Marine Transport Lines intend to give to each Master and desk officer aboard our ships to obtain the widest coverage possible.
The book is written in a manner easily understandable to seamen, and will be multi-
25
1970 National Safety Congress
colored to aid in describing the plotting system and diagrams. The text color and the portion of the diagram to which it refers are always the same, and the diagrams are arranged so that there is never a need to turn pages ahead or back to make reference to them, thus simplifying the normal task of correlation between text and diagrams. Among the contents of the book are the legalities of radar, which includes sections
Most of us are familiar with the rules de veloped for lifeboat drill and their value is obvious, but it is also preferable to have rules and safety checklists for the operation of such machinery as grinders, lathes, pumps, etc., as well as for performing such tasks
as chipping, mooring the vessel, etc., and we at Marine Transport Lines try to cover these areas.
on "Must You Use Radar," "Clear Weather 4. Inspections and Observations
Use of Radar," "Must Radar Be Kept in Good Repair," "Must you Plot," "Radar and Speed In Fog," etc. Other chapters deal with how radar functions, collision avoidance, har bor radar operations, to plot or not. The
latter describes all the different plotting methods so that the reader can choose the one he is familiar with, as well as being aware of the other methods.
Inspections and observations to detect un safe shipboard conditions or unsafe practices by crew members are a prerequisite of a conscientious captain, department head, or watchkeeper, and a significant part of our
loss prevention program is devoted towards backing up and encouraging these proce dures. We strongly urge that, whenever pos
sible, any deficiencies found are eliminated
The monthly Newsletter, as its name im immediately, and a crew member performing
plies, will be basically radar oriented, but in an unsafe manner stopped and the correct
other subjects of interest will be included. method demonstrated before lie is allowed
One of the main reasons for the Newsletter, to continue. Other hazards requiring ship
aside from its being a vehicle to present up yard work or requisitioning of equipment
dated information on radar and other navi are eliminated as soon as possible. The safety
gation aids, will be to maintain the initial director and other shore staff personnel also
appeal provided by the book and to generate conduct shipboard safety inspections, and
new interest in the subject matter with those tliis provides an effective check on a ship's who may warm up to the program more practical performance.
slowly than most
A separate company, called Operational Radar Service Publications, has been formed to handle publication, and of course the pro gram will be made available to all steamship companies, as part of its success will he due to maximum exposure Steamship companies should combine to perform needed services.
5, 6. Accident Reporting Procedures and Accident Investigation Procedures
After an accident, the insurance depart ment requires certain data for their records, and also, if necessary, to process hospital and maintenance claims or any other pay ments that can be incurred after an injury. Of course, from a loss prevention viewpoint,
3. Development of Rules
Loss prevention and the safe operation of systems and equipment is a part of every ship's operation manual. Its practice or lack of practice is evident on every job either by a trouble-free operation or by personnel ac cidents or down time of machinery.
Like most companies, we try to develop correct procedures before an accident or injury/damage loss results, but many rules are developed on the job from the experience gained by the men actually performing the work. We find this operational job analysis is invaluable, especially aboard new vessels or those with new equipment, where crew members' innovations play a major part in the formation of needed proper procedures.
we are primarily interested in the prevention of future accidents as a result of the same conditions.
By combining the two we have increased the quality of the data received from the ships and have also reduced the amount of paper work involved. The chip?, are required to report every accident regardless of whether any injury is sustained. The depart ment head or the supervisor in charge is required to investigate an accident immedi ately after its occurrence, if possible in the presence of the person involved, so that cor rective action can be implemented immedi ately. The officer conducting the investigation completes the following questions contained in the form: (1) What was injured person doing at time of accident, including equip-
26
Marine Section
raent involved? (2) What unplanned occur rence caused injury? (3) What did injured person do or fail to do which caused acci dent? (4) What is being done to prevent a
on a regular basis of progress in loss pre vention. A realistic yardstick should be adopted as a base, so that factual informa
tion can he provided.
repetition of this accident? The application of this method benefits all *>. Administration of Program
parties by publicizing the particular hazard Like all programs, we fee! it is essential
among employees, helping to determine facts for cases involving legal liability, but most significantly helps to prevent re-occurrences by establishing a cause, so that similar acci
to have a full time administrator for a company loss prevention program. Basically he must help management solve two princi pal problems--how to substitute safe prac
dents may be prevented by mechanical im tices for unsafe practices of employees, and provement, better supervision, nr employee how to remove physical hazards. Safety is
training.
7. Recording and Analysis of Accident Data
a part in all company operations and tre mendous savings are possible by a well ad
ministered program.
Shipboard accidents are recorded under Ul Coordination by Loss Prevention
definite cause and agency data so that any trends are revealed. An analysis of this accident data is reviewed and sent to the vessels monthly. Marsh & McLennan, our brokers, record a similar but more detailed accident analysis in booklet form tor ns on an annual basis. Besides noting any trends and the frequency of occurrences, selected outstanding accident causes for preferred attention are contained in their recommenda
tions.
All this information is reviewed and acted upon, but experience has proved that the most effective way to reduce accidents is to concentrate on one phase of the accident problem at a time rather than attempting to
In our company this takes the form of a management safety control committee com prised of a member of each department, with the exception of accounting. This com mittee meets once per month and reviews all aspects of safety, whether of an engi neering. purchasing, operating or personnel nature. On boar-:! our vessels, monthly safety meetings are held; written minutes are. kept and a copy sent to me. We attempt to con vey to our masters that physical conditions
aboard ship are only responsible, for a small
percentage of emr accidents.
Out of the three most expensive items in operating a ship--fuel, wages, and insurance
stop all accidents at once.
--only the latter Is directly controlled by a
This-analysis revealed, among other items, company, as the former two are usually the
that a dumber of serious and costly accidents were occurring during mooring operations.
After consideration of the facts, the com pany adopted a mooring line policy. We are now replacing mooring lines with polypropoletie/polyester line and all rope stoppers will be made from polyester. By the use of this
same for each operator of ships under the same national registration.
Insurance premium rates are known to vary widely between steamship companies, and this variation i? a direct reflection of the effectiveness of their safety program.
type of line, together with appropriate in Hull and P&I claims will be used in nego
structions in their use, we hone to greatly tiations on future insurance premiums and, reduce the frequency of mooring line acci while inflation and all company claims col
dents.
lectively will, no doubt, cause a rise in the
8. Reporting of Progress
This title speaks for itself, but it is im portant to keep management fully informed
rates, an effective company loss prevention program will keep these increases to a mini mum.
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1070 National Safety Congress
SAFETY AN EXCHANGE OF IDEAS
By CAPTAIN R. P. WALKER U.S. Fleet, Texaco, Inc., Port Arthur, Texas
We commence with the premise that safety is an exchange of ideas. If you will, an effluence of information influencing people to attain desired results. As with all premises, this one needs to be developed, and we pro pose to do this by constructing first a hy pothesis and then indicating how this trans lates into programs. The exchange of ideas has several levels.
First, but not necessar iy the most impor tant, is that of exchanging of ideas among management people such as we do at the National Safety Congress. Second, the ex change of ideas among our own people on the same level within our own organizations. Third, and probably the mast important, the exchange of ideas among the levels within our organization.
As this paper develops, we do not propose to set forth an ideal safety program, as we question whether there is such an animal; but it is hoped that before we finish, there will he sufficient guidelines for a skeleton from which anyone could develop a pro gram from the approach that we verbalize. When I say verbalize, I also mean that many of the thoughts and premises trans lated into active programs are known by most of us, but in the exchange of ideas in safety, it is well that we vocalize and rein force our thinking. We should put to test our premises so that as the years pass we become more astute and flexible and have greater understanding as to what safety is all about.
As we talk about safety, we are con tinually aware that it is not a separate func tion within an organization but rather an integrated aspect of operations. It is pulled to the side and emphasized because it is important. Because not only does it make a meaningful contribution to production but, more importantly, it carries with it a moral obligation to avoid human suffering.
We also are saying that safety programs are not mechanical because they deal with people, and we quickly add that this does
not mean they are Machiavellian because they deal with people. With this thought, we will attempt to explore with you some of the premises and their development.
We also believe `hat the average individual seeks involvement and responsibility and has a desire to make a meaningful contribution to whatever activity in which he may be involved. It is also believed that each individ ual is capable of self-direction and self-con trol and does not necessarily need pushing and `'whipping" in order to move forward.
In moving forward, the question arises, "Does our safety program move forward?"
Have we exerted the self-direction and self-control in our programs that will enable us to progress as rapidly as our people can? Or, do we Jiang on the programs that have long proved they are no longer worthwhile or no longer motivate or that need revision, just so long as we can say we have some sort of program?
In other words, are we loyal to an old
program called safety for no apparent rea
son?
,
One of the measuring gauges used in determining how modern our safety program is, is how we are managing it; whether by past experience, immediate expectations, or by pressures. If these pressures and expecta
tions are coming from outside the program, we feel that little value is being delivered to the program itself. This approach of "continually whipping" it into shape gen erally means we grasp for straws to build the semblance of a safety program.
It is believed that a program must be people-oriented and dedicated to meaningful goals. Will it continue to deliver the results whether there is a safety engineer around or not? Parenthetically, a program that always requires a safety engineer around, is not a safety program. What we are saying is that safety must be built into one's opera tions so it is impossible for supervisors to think of an operation without automatically having thought "safety." This means a fully
28
Marine Section
integrated position where safety is both con sciously and subconsciously considered in performing a job. Getting the job done is no
longer enough.
What we need is a total concern for the people involved with the realization that most people truly have a need and a desire to contribute, to be self-directed, to get involved, and to make a meaningful contri bution.
The "seat of the pants" approach to safety is like "seat of the pants" flying. There is net much need for it any more, and one doesn't go far or fast. One's program lias to be systematic. It should be carefully and professionally planned with >-m:iiii intuition and regard for people.
'This approach calls for developing longrange as well as short-range strategies and applying management techniques, reseai h, and quantitative decision making. The man ager must be concerned with the task and with his people so that he integrates them with their work, thus assisting them in utiliz ing the proper techniques. This may call for training, education and, sometimes, replace ment of people. One must frown on placing too much reliance on good intentions rather than on knowledge an-', rational approaches. But, we also say there must be objective concerns tempered with the humanistic ap
proaches. As we said earlier, it is the effluence of
information that influences people to achieve the dpsired result That means that we not -only examine the style and behavior of those who may be reporting to us but also our own style, behavior, and patterns of communi
cation. In communicating we know that words are
-only part of the story. Communication has been defined as "be
havior that results in an exchange of mean ing." Words, even word inflections, facial expressions, bulletin board notices, and staff meetings are ail examples of behavior which transmits feelings, facts, and ideas to some one else. Communication processes often result in communication misfires or misun
derstanding because: (1) the behavior of the sender is not clear or (2) the receiver in some fashion distorts or misinterprets the sender's signal or transmission.
Therefore, the basic definition of commu nications does not specify "good" or "bad"; rather, it indicates that any transmission that results in an exchange of meaning is communication.
The more critical question then is, "What is effective communication?" Our first as sumption might well he that an effective communication is one that is understood. However, it must go beyond that, for in the final analysis effective communication is that which results in positive action in line with the needs of the situation. This suggests that the sender ,nd receiver need to do more titan give and receive instructions. They must clarify purposes and situational needs. In complex situations there may be a need for a careful examination of alternative goals, and the possible consequences of a given course of action.
The safety-minded manager must influence his subordinates and associates in building positive action. Often the integration of conflicting viewpoints requires two-way in fluence with, an f-pp-nurnky for persons involved to - lunge their own viewpoint as a result of influence from others or to influence others to change part or all of their viewpoint. Words, ideas, facts, and feelings are communicated to others in order to influence behavior, to produce understand ing, acceptance and positive action.
Now, we might >-! . what does this have to do with our safety program, our people, and plans?
In developing safety programs, we cannot use pressure if we are not totally familiar with the problems. The supervisor who is attempting to instil! a new or stronger safety approach needs to have quite a few facts about the people involved--their experience, point of view and feelings--before he begins to try to control the situation. In the "old days" when there were few jobs around, people could often be treated in :i verydirect way, giver, orders, told what to do, and if they didn't like it they could be fired. There wore always other people to take their place. In today's mobile labor market we have changed our philosophy toward employees. We know if the supervisor or company "controlled" an individual we still would not have control of the individual's motives, feelings and attitudes. If the em ployee feels he is being bossed around, he
29
1970 National Safety Congress
may find very quiet and subtle ways of resisting. Psychologists tell us that this is passive resistance. The employee slows down his effort and does as little as possible or perhaps actually engages in work stoppages if lie feels over-controlled and over dominated.
In almost any situation we need tiic ideas of others, we need their commitment and motivation. We cannot operate unilateral!} if we wish to build team work and under standing between management and our people,
Sounds good, just like out of the textbook. How does one translate, into practice? In the program that I am familiar with, the exchange of ideas takes place on several level*;. Formally; attending safety cnngriv?;*: meeting with our officers ashore; and finally, meeting aboard ship. One can readily see that these three tyj**s of meetings fulfill the need of cross-fertilization of ideas and per mit them to be treated at the various levels.
In this paper one will not find an outline on how to hold a meeting or how a safety meeting should be conducted. Yet, most organization* will undoubtedly find a neces sity to conduct instructional meetings on how to have a successful safety meeting.
We must continually reinforce within the minds of all the people that safety is a (owiimiing thing, not just at meetings. This can be illustrated by a bump cap.
During the past six months the bump cap has become popular with our people. Pre viously. we had tried to persuade our men to wear safety helmets We found the bump hat t be lightweight and more practical on deck. We decided to give the hat out on request only, where previously we had put a supply of helmets aboard each ship. Before, two months expired, we were requested out of supply. Our men have received it very favorably with little or no pressure on our part The requests keep pouring in. The hat serves several purposes--it stops cut heads and is a constant symbol of safety.
This single happening illustrates the need for pressure for safety to come from within. On deck, they now" wear the. bump cap-- they wouldn't wear safety helmets.
Interpretation and persuasion are being added to information and entertainment, which have been the traditional twin ob jectives of communications. Where contro
versy is concerned we sometimes fail to voice effective communication to our people. Too, often we communicate on controversy in about the same tone, words, and style that lawyers would use in a Supreme Court brief. The opposite extreme of pitching a message at about the third grade level is also com mon. Both of these practices reflect a lack of understanding of the employee. Our com munication will he wholly ineffective if listeners interpret it as talking down to them.
This problem can be avoided by permitting any member of the ship to chair a safety meeting, so long as he does a conscientious job.
Your business and mine are changing. Growth, diversification, and increasing com petition are constantly forcing alterations in methods or structures. Whatever the goal, the hoped-for-benefits of change are .seldom fully realized. Many factors contribute to the difficulties of making changes. They included the structure of the plan, commu nications, and systems. But the greatest single factor is that the people who make the decision to change do not realize that an organization consists of people whose ca pacities, psychological make-up, personal goals, informal relationships, and value sys tems must be taken into account A fully integrated change must take place adapting safety strategies, policies, and relationships to this coutimial change.
Any proposed change that is to succeed must begin with a full examination of our past program and an analysis of our future goals and objectives. One may wish to ap point a team of people not connected with safety to study and evaluate the program already in existence mid, hopefully, discover new ways, fresh ideas that otherwise would never have been developed.
To achieve, any goal in safety requires paying a price. It would be unrealistic to design a plan which required a price higher than management is willing to pay. The amount of money spent Is not a gauge of a successful program.
A continual state of flux will bring out new ideas to develop the excellent perform ance we will expect from our officers and crews. We achieved success when we took a senior master mariner and made him a safety" inspector for two years. We benefited
Marine Section
from the exchange of ideas that followed his placement ashore.
It is essential that management be prepared to do what it must in order to make a program a success. If management does not carry out its part, resistance and inertia down the line will increase. In ~aich cases it is better never to have undertaker, change.
In planning change we must be vine that all the processes on which a safety system depends are aligned to conform to a new plan. It is important that procedures for planning and the measurement of results be immediately aligned to conform with the new structure.
A frequent remark, when change k sug gested is, "`You can't act now because the time isn't right:' Even if the time i<itt right, change is often resisted because we may upset people's feeling*?. The fact is that changes in prnceduies to benefit safety pro grams must change people's habits if they are going to succeed. Changes for the better improve morale.
Officer conferences are frequently lield to discuss problems, suggest changes, and evaluate reactions. Officer consultations en courage change and a better understanding of management's objectives..
Among the pressures opposing change in safety are* human attitude-, one or all of which are almost always present when peo ple fail to alter their habits: they <! not know what is expected of them; the} do not know it is important; they do not knuw how to change; and they fro! psychologically threatened.
These pressures can be reduced by: (l) presenting a safety program in a way that wins understanding and acceptance--this is the process of communication and persua sion ; (2) helping people change habits, re spond with new skills and attitudes; (3) establish confidence in safety.
But change is difficult and considerable pressure is usually necessary to get people to break deeply ingrained habits and develop proper safe ones. Training slides that are educational as well as those that are humor ous help communicate our safety message. They can break the ice in many areas and accomplish a meaningful purpose.
But discipline--pressure for change--is also required: imcoropromising insistence
that people do what they are expected to. This is reinforced by consistent use of re wards and penalties to attain high safety standards. We try to reward those that attain the proper safety performance.
Safety triangles were purchased for crew members of vessels that went through a calendar year without a lost time accident The triangle is used to warn motorists of impending danger ahead. The award is a safety item and does several things, the most important to reinforce th* idea of safety.
No matter how well our safety plans are introduce'.!, there k still a big gap between understanding awl action- Application of the learning theory cun contribute a great deed to effecting the dedred change*; fully, quickly and smoothly. Psychologists tell m Utat learning has four dements: drives, cues, responses, and rewards (or future rewards).
Learning typically require* repetitive ac tion over a period of time until new safe liabits are formed. IE we wish to speed this learning process, we must analyze our plans in terms of each of these elements..
What new ways of doing tilings does our safety program require?
What actions or events are likely to cue the proi*cr response?
How can the proper response be rewarded In terms of factors that appeal to self-in terest of the individual or group such as through incentives, or recognition?
Do we know what safe habits we require?
Have, we created the proper opportunities to practice .safety?
Learning the proper safety habits can be greatly improved if ways can be developed to determine whether people are responding correctly- The importance of this is demon strated by research conducted by a corpora tion which developed some interesting methods for reo-rding everything that took place in a work situation. The results were shown to the participants who were able to analyze their own mistakes and figure out the proper approach to the work. As a result, the productivity of the group rose to throe times what it had been in the past.
One can attempt to duplicate this practice through inspections and accident investiga tions within the group. Also, one can use a study group that is not connected with safety.
31
1970 National Safety Congress
The findings and information are then fed into the system.
Getting our people involved so that they don't merely acquire an intellectual under standing and acceptance is a challenge which we must rise to with new motivation. By involving outside people, our people become more deeply involved. People, both ashore
and afloat, tell people outside the company how they expect the job to be done safely. These people include pilots, contractors, tug boat crews, and anyone who has business with the vessel. Getting people involved en sures contribution to new plans and new safety programs. After all, safety is an exchange of ideas.
A MASTER LOOKS AT SAFETY TRAINING
By CAPTAIN OSCAR H. GRONWALL Master S/S McKee Sons, American Steamship Co., Buffalo, N. Y,
Aboard ships we have problems different from those faced in a permanently situated factory, but we try to instill the same safety thinking and safety habits as the shoreside programs.
"As long as there are ships, there will be accidents" is a phrase I have heard many times over in the 35 years I have been sail ing on the Great Lakes. This is a truism repeated by attorneys, investigating officers, ami sympathising fellow members in the shipping industry- From the larger amounts of insurance coverage carried and the re taining of legal representatives on a perma nent basis, we can gather that the rinpowners are believers, too. I have also been in volved in accidents as a victim, as a witness, and as the one who has to make out the reports for our office and the II. S- Coast Guard.
An observation on the subject was made in the 5th Century B.C by Thucydides, a Greek philosopher, who observed that, "A collision at sea can ruin your entire day." This can be translated to "An accident of any kind aboard ship can ruin your entire day and possibly many following days," whether it be to the vessel itself or any member of the crew.
From the planning stage to the completed construction of a vessel, safety is upper most in the thoughts of the architects, the builders, and the many technical professional societies with which the U.S. Coast Guard participates in generating meaningful stand ards. The National Safety Council, I am happy to say, is one of these groups. The Coast Guard also consults with many trade
association and industry groups in connection with its merchant marine safety program for ship and equipment construction.
Through the cooperation of these groups and their regulations, we are assured of the latest technological and mechanical advances in material, machinery, electrical systems, lifesaving appliances, cargo gear, and safe guards against explosion and fire. Constant checking and testing as construction goes on ensure that the component parts and systems of the vessel are in order, so that when ready to sail it is a safe ship.
Once in service, regular inspections are conducted by the U. S. Coast Guard to note any unsafe conditions which may have oc curred and recommend remedies. Corrections must be made before the vessel is given its certificate and permission to sail. When un derway during the season, the equipment aboard ship is checked regularly for any possible defects by the vessel officers.
Frograms for safe navigation of the ves sels on the Great Lakes are continually being checked for improvement through the co operation of the Lake Carriers' Association, the Maritime Safety' Committee, the Inter national Shipmasters' Association, and the U. S. Coast Guard. The excellent safety record of the Great Lakes vessels in the heavy traffic of these confined waters is taken for granted by so many, but it is the result of concerted effort of these groups and the individual vessel officers and is worthy of commendation.
Our vessels are equipped with the latest aids to navigation as improvements are made, and it would be impossible to estimate how'
32
Marine Section
many casualties have been averted by the proper use of radar, the, gyro compass, di rection finders, and the excellent radiotele phone communications system ir, use on the Great Lakes. The recent installation of bowthrust equipment on our ships has drasti cally increased safe performance during close maneuvering in port nnd around docks.
So we find that safety is built into the vessel and its component parts, and safety is provided for in the rules for navigation of the vessel and in equipment placed aboard to aid in navigation. This leaves us with safety aboard the vessel in daily' procedure, or personal injury, as our never-ending problem.
Figures gathered and tabulated from in surance investigations show that almost 90 per cent of the accidents aboard ship were caused by persons committing unsafe acts, and about 10 per cent were caused mainly by the existence of unsafe conditions. Cor rections can be made to the material factors, but the individual crew member is stiff the one we have to reach to improve our record.
Aboard ship there is a place for every thing, and when in place it ran be clamped, battened, lashed down, or stowed away se curely. The one completely unattached, con firming moving part which can't be kept secured in a specific place ip the seaman. Each and every crew member is a potential casualty looking for a place to happen as soon as he leaves his bed or bunk.
Therefore, we must impress every indi vidual to be safety minded. With the con tinuing turnover in personnel, this is a con tinuous job from Stout in March through layup in December,
Being ships, there are some hazards which have been with us a long time, and which will continue to be with ns. Among these hazards are open hatches, open gratings, lad ders, moving parts in unloading equipment, cargo spillage on deck, cables, and the un known conditions on the docks we have to make.
Each year we try to combat these with safety meetings, weekly drills, safety inspec tions, posters and literature, and safety equip ment. Through each of these mediums we hope to reach the crew members and try to make them safety conscious. However, daily examples and reminders by the officers and veteran employees who have developed
safety habits can do more to impress the other crew members than those impersonal factors.
Safely becomes a personal and individual objective. A little effort exerted in routine jobs to show the safe and proper way may be a big saving in lost time and pain to a fellow worker. An accident results when something is done contrary to the correct way of doing it. How much better for all concerned if an accident can be prevented or avoided, rather than remedied after it has taken place.
Bulk freighter fleets cm the Great Lakes have shown that with stress on safety an exceptional record can be mode. These fleets are to be congratulated for their fuse pro
grams and deserve the awards earned. Many ships in these licet* have gone through full seasons without a lost time accident. There is time between shorts cm these vessels to a t vs tc a good program.
Because of our unloading equipment and
the necessary components for handling this,
we have more potential hazards aboard than
the bulk freighters. Also, in our self unloader
fleet, our vessels are in port almost aery
day in the process of either loading or un
loading, -it1*' the runs *
ports some
times cover only ri few hours. This can be
evidenced by the fact that in a sailing sea
son of about 2f0 days, we will have about
120 loads in and out of the vessel. My own
vessel averages 14 to 15 loads a month.
Sometime1: we will be making three docks
a day, and our crews are working both dur
ing the loading and unloading processes. This
is not an excuse for having more accidents
than the other types of vessels. It is merely
a statement of fart about the different nature
of our business and points out why we must
try harder. There is no extended enroute
time for implementing a special program.
It is necessary to apply our safety mes sages as a constant factor in the regular working time during our schedule. New men
have to be shown by example and instructed on the job in safety measures. The veteran
seamen have to overcome the complacency that comes about when things are going smoothly. The minute there is a lapse and someone gets careless, an accident can take place.
We must be sure there is understanding of what is being done at all times. A lack
33
19/0 National Safety Congress
of understanding, a lack of communication,
Management is taking a more active role
ignorance, improper attitude, and error in in recent years in promoting a safety pro
judgment all lead to the same possible gram. A "Safety First" philosophy is being
casualties.
Fire and boat drills are conducted aboard ship once a week. This is the time when the men become acquainted with the types of extinguishers, oxygen masks, and other safe ty equipment we have aboard and learn how
stressed throughout the fleet. Booklets, pamphlets, and attention getting posters are received regularly for distribution and dis play as a constant reminder that safety is an all time thought. Many of these are from this National Safety Council.
to use them. They are checked on their Safety consultants have been sent to our
duties as designate! on their station cards vessels for talks and demonstrations, or just
and further instructed in the proper methods to observe anti report. Among these persons
of using the lifeboats, life rafts, and other are an insurance company marine accident
equipment in the event of a disaster. A prevention expert and a fire-fighting expert.
recent influx of alien seamen has uncovered The first hand communication has a decided
another problem, the inability to read or effect in promoting and imprinting safety in
understand English, therefore not knowing the minds of the seamen who are aboard at
what the Station Card means. This calls for tlie time. Again, the constant turnover in
further instruction and special treatment by personnel makes a weakness in the program.
the officers and fellow seamen, for that man's performance of his duties in an emergency might at some time be vital to all. Unfor tunately, these things arc not learned as quickly as such things as "overtime" and "coffee time"; therefore, again it calls for
more effort on our part
All of these usages are well worth the effort and we arc hopeful that they will prove effective and accomplish their ob jective in reaching the crew. We continually seek the prevention of accidents and hope to see a decline in these mishaps which can be attributed to human error, either in not
Once a month a safety meeting is sched knowing or being careless in the execution
uled aboard ship. Any unsafe conditions or practices in each department are brought up for discussion and remedies are sought At the same time many of the old safety meas ures are reread into the minutes of the meet ing, as another constant reminder that safety is each man's responsibility. Every attempt is made to make each man use common good
of a duty.
Pamphlets and posters, occasional visits from safety consultants, a weekly fire and boat drill, and a monthly safety meeting are not answers to an everyday problem, but they set the basis for our all out individual effort of safety thinking,
sense to help eliminate accidents. Accident I have introduced no new solutions to our
is an ugly word. There is nothing pleasant problems, and there is no panacea. I have
that can be associated with it in this busi merely restated our efforts to try and en
ness. The ideal situation would be if the force safety thinking and good safety habits.
efforts of safety programs could eliminate Our attempts at safety training may be the
the word, but such will never be the case. same archaic methods that have been used
We want to have safety conscious crews. We want them to make full use of the safety gear we provide, such as hard hats and work jackets. Proper attire should be worn at
for years against the same problems, but we try to update the approach to create a genuine desire for safety in each individual. Unless we can reach each crew member, the
all times while performing their duties.
accidents will continue to happen through
It is stressed that when any such condi negligence, ignorance, bravado, or careless tions or practices are noticed which may he ness. We hope our efforts lead to safety
considered unsafe they should be brought prone people rather than those infamous ones
to the attention of the officer in charge im known ns "accident prone."
mediately, not wait for the next scheduled monthly meeting. The safety meeting should be considered to be in session at all times in an effort to curb casualties.
This would lead to a smoother operation aboard ship and fewer of those "spoiled
days."
34
Marine Section
MARINE CASUALTIES-- CAUSES AND PREVENTION
By CDR. JOHN S. LIPUSCEK, USCG
Chief, Casualty Review Branch, Merchant Vessel Inspection Division, Office of Merchant Marine Safety, United States Coast Guard, Washington, D. C.
In an analysis of vessel collisions, a major category of marine casualties, we consistently find the personnel element present; and hence feel that safety must be an integral part of any mariner's training. The three causal fac tors of collisions are: attempting to meet or pass without mutual agreement; failure to communicate with another vessel by availa ble means; and other personnel fault
The study of marine casualties provides us with invaluable information in identifying programs which should ultimately lead to legislation designed to make our navigable waterways safer. An example of this process is seen in our present proposals. Three bills currently pending in Congress deal with the unification of the rules of the road, required bridge-to-bridge radiotelephone communica tion, and towboat requirements. Each of these bills is important within itself, and each has an impact on one or more of the three causal factors of collisions mentioned earlier. The Coast Guard supports all three proposals.
What about accident prevention? Where does_the solution lie? Is it in a licensing pro gram for towboat operators? Does it lie in bridge-to-bridge radio communications to as sure agreement in passing? Or, does it lie in the establishment of one set of ruses for the prevention of collisions on all waters?
The significance of the pending legislative proposals as tools in reducing vessel casual ties is best emphasized by looking at some recent disasters on the Mississippi River. While it is true that some problems are peculiar to the Mississippi, they nevertheless manifest themselves on all waterways in a variety of situations.
Unification of Rules of the Rodd
Here in the United States we have three separate sets of rules governing navigation on the Great Lakes, the Western Rivers, and other inland waters. Although these rules are similar, they nevertheless contain signifi cant variations among themselves. Each set
pointedly differs from the more recent Inter national Rules. The design of H.R. 214 takes this into consideration, and therefore the rules contained in this bill conform to the International Rules, The only exception is the inclusion of special rules designed to meet local conditions where necessary.
Unification will also alleviate the division problem currently existing in the different rules. A mariner will only be required to have knowledge csf one set of rules. My discussion deals with one facet of this prob lem.
The scene is a highly congested waterway tliat ranges some 200 miles between Baton Rouge and the Head of Passes on the Mississippi River. Recent years have seen an unprecedented growth in this area. Ever in creasing amounts of hazardous materials are being shipped by water, and the vessels transporting them keep increasing in number, size, and speed. These increases further complicate matters because it is here, within this zone, that the deep draft ocean freighter meets the conventional river tow.
When the entire Mississippi River was governed by the Western Rivers Rules, which allow ascending and descending ves sels to pass on either hand at the option of the downbound vessel, a custom was long judicially recognized that upbound vessels "took the points" and downbound vessels "took the bends,'' Recognition of the custom was easy, because there is no narrow channel rule on the Western Rivers; and the "head and head rule" was modified as to vessels ascending and descending to allow, as men tioned, the descending vessels to choose the mode of passing whatever the relative as pects of the vessels were on first sighting.
in 1','48 the river below the Huey P. Long bridge was placed under the Inland Rules, which do have a narrow channel rule and do not have a special rale for vessels ascend ing and descending rivers as a qualification to the "head and head" rule.
35
1970 National Safety Congress
The "Points and Bends Custom" is a neces sity for many vessels in order to safely navigate the river. This is particularly appar ent during times of high current velocity. A vessel using points and bends makes maxi mum use of the river current in this way. What happens is this: An ascending vessel comes up on the point or the inside of the bend. The current is at its weakest here and eddies Sowing in the opposite direction often assist the vessel. A descending vessel entering a bend stays on the outer or bend side of the river. The flow of current tends to set a vessel across the river towards the bend; atid with the following current a relatively high speed over the ground _ is realized, as well as an increased turning circle and increased difliculty in holding to the point. Assuming that half of the river bends are "bends to the right" and half are to the left, we are presented with a hazard ous condition fifty per cent of the time if two approaching vessels are expected_ to accomplish a "normal" port to port passing. We can dramatically demonstrate the danger of collisions by showing a descending vessel approaching a bend to the right. If she is required to pass port to port she must hold to the point and attempt to overcome the forces of the current which are setting her across the river toward the bend and toward the ascending vessel, which is keeping to her side of the channel under Article 25 of the Inland Rules.
Under Western Rivers Rules vessels are permitted to pass starboard to starboard or port to port, providing they can do so safely. Article 25 of the Inland Rules, however, requires that "in a narrow channel every vessel shall, when it is safe and practicable, keep to that side of the fairway or mid channel which lies on the starboard side of such vessel." This in effect calls for vessels to normally pass port to port.
Confusion, therefore, does result when an ocean going freighter meets a river towboat pushing barges ahead in the area of New Orleans above and below the Huey P. Long bridge; because here lies the demarcation point of Western Rivers Rules and Inland Rules.
Rules for navigation in this area must reflect the common sense and good seaman ship of the points and bends custom. This principle is recognized and allowed in the
proposed revision of Article 25 of the exist ing Inland Rules of the Road. In the pending revision, vessels in narrow channels, pro ceeding with the current, will have the right of way and elect on which side to pass.
The following description of a collision between two vessels, taken from the record of the Marine Board of Investigation, will demonstrate the need for legislation on rules of the road unification. Incidentally, this casualty also indicates the value of bridgeto-bridge. radiotelephone communication cap ability.
In April 1969 the New Orleans waterfront was the scene of an explosion and fire fol lowing a collision between the freighter Union Faith and the barge IOC No. 7, which was one of three loaded tank barges being pushed ahead by the tag Warren J. Dotted. The casualty occurred on a clear, dark night. At approximately 1730 it was found that the Warren J. Doucet, bound for Baton Rouge, could not make sufficient speed up the river to continue alone. The tow was turned around above the Harvey Canal about three miles above the Greater New Orleans Bridge at 1830. The vessel proceeded downstream at a speed of 4J4 miles per hour, maintaining a course which favored the right descending bank. At ap proximately one-half mile above the Great New Orleans bridge the course was changed to cross the river toward the bridge abutment located nearer the left descending side.
At 1840 the Union Faith weighed anchor and departed the general anchorage about five miles below the Greater New Orleans bridge, bound for a dock three miles above the bridge. At 1855, in the vicinity of mile 93, the Union Faith agreed both by bridgeto-hridge radiotelephone and whistle signals to a starboard to starboard meeting with the downbound 55 President. At this time, the Union Faith was making good about 10 miles per hour, favoring the right descend ing side in order to come up under Algiers Point. Before rounding Algiers Point, the Union Faith met and passed the M/V Mama Lear and tow starboard to starboard. After rounding Algiers Point, the Union Faith agreed by radiotelephone and wdiisile signals with the ferry Crescent and M/V Sassafras to a starboard to starboard meeting. The master of the Sassafras had called the mas ter of the M/V Toni Ann, whose tow was
36
Marine Seal. :
about 1,000 feet astern, advising that the
Union Faith would pass starboard to star
board if agreeable. The Toni Ann acknowl
edged and found this meeting agreeable. The
Toni Ann. as she cleared the Greater New
Orleans bridge, sighted the lights of the
Union Faith coming around Algiers Point.
After meeting the Toni Ann, the Union
Faith altered course towards the left des
cending bank of the river. The radiotelephone
possessed by the pilot on the Union Faith
operated on channel 13, 156.65 MHz, and
therefore was unable t communicate with
the Warren J. Dsv.cct, which had radio
telephone capabilities on frequency of 2,738
KHv. .HI vovc, t'---li- ,,i:u-
n'veiliriniK
requiring bridge-tc-bi ide radio communica
tion capability. The lights of the Union Fatih
were first sighted at a distance of 1JS miles
by the Warren J. Doucet. Shortly thereafter,
the Warreit J. Dotted blew a two blast
signal for a starboard passing which was not
answered. She then blew another two blast
whistle signal while maintaining her course
and speed across the river. No answer was
heard. The collision occurred at about 1915
just upstream of the Greater New Orlean
bridge. Twenty-five persons lost their lives
ill this collision, and the two vessels sank.
Bridge to Bridge Radiotelephone
Provisions for whistle signals have been in existence for a long period of time to show the intent of vessels when sailing on the inland waters of the United State*;. However, our statistics reveal that the fail ure to communicate and mutually agree upon the method of passing between vessels is one of the major factors contributing to collisions. Approximately one half of the vessels involved in collisions did not attempt to exchange whistle signals as required by national rules, thereby demonstrating per sonnel error in itself as a primary cause of collisions. The failure to arrive at an early passing agreement through whistle signals and voice radio inevitably results in the failure to make timely decisions which are essential if collisions are to be avoided.
There are three major problems associated with the use of and response to sound sig nals:
1. The failure to understand them.
2. The failure to hear or respond to them.
3. The failure to establish correctly the direction mid nature of their source.
The noise level and wind velocity and direction will frequently create a sound har rier to persons on the bridge. However, it is difficult to understand she reasons for the failure to respond to signals when heard and understood.
Perhaps a reason for our current problems with whistle rignals lies in the increased size and speed of ships entering inland waters. Coupled with periods of poor visibility, these increases make the effective use of whistles extremely difficult. To remedy this situation, legal requirements for direct radio communication between the pilot houses, or bridge-to-bridge radiotelephone, have been proposed in and are currently pending action by the Congress. These requirements are essential for safer navigation and, again., have the full support of the Coast Guard.
The collision previously described between the Union Faith and the tank barge IOC No. 7. being pushed ahead by the towing vessel Warren J- Doucet, showed the need for legislation roveriug unification of rules of the road as 'veil as bridge-to-bridge radio telephone. Another case which dramatically demonstrates the need for bridge-to-bridge radiotelephone legislation occurred during the. early morning of 16 March 1968. Again, this was on the lower Mississippi River and involved the 55 African Star and the barge Intercity No. 11 (one of two loaded tank barges being pushed ahead by the towing vessel Midwest Cities, piloted, incidentally, by unlicensed personnel). According to the Marine Board convened to investigate this casualty, the tank barge, was loaded with a cargo of highly volatile crude oil. As the vessels were closing prior to the collision, the upbound M/V Midwest Cities was direct ing her course at an angle across the river toward the left descending bank after passing Points a la Hache. The downbound African Star was about mid-river with the intention of conducting a starboard to starboard meet ing situation. The pilot on the African Star, using his portable radiotelephone, attempted communication with the Midwest Cities prior to the collision. There was no response. Why was there no response? Simply because the radiotelephones on the two vessels were designed to operate on different frequencies; the Midwest Cities had 2, 738 KHz and the
37
rCi) Xutionai Safety Ccaaeeee
African Star was designed for 156.65 MJU Consequently, it was impossible for the two pilots to communicate by radio. The tank barge and the freighter collided and a tire and explosion ensued almost immediately on both vessels. Twenty-one persons aboard the African Star lost their lives. The tank barge burned and sank in the river. The fiercely burning oil ignited many secondary fires in combustible material on board the African Star. Shortly after the collision, the African Star hacked out of die barge and was pur posely beached on the right descending bank. Heroic members of the crew successfully fought the fire in an effort to prevent its sprending.
CapUiin 1'au! Ives, when chairman of the Bridge-to-Bridge Radio Committee of the American Pilots Association stated, "Our pilots will attest to the fact that single chan nel bridge-to-bridge radio will work indeed under all imaginable conditions of adverse weather and traffic density. It is not unusual to have a traffic situation involving ten or more vessels in sight of one another at any given time."
Captain Ives' comments were made with reference to the Delaware Bay and River where bridge-to-bridge radiotelephone com munications have been in use since Novem ber 1, I960. During the five years and ten months preceding the implementation of bridge-to-bride radio, there was an average of 1.27 collisions per month. The first few years after the use of bridge-to-bridge radiotelephone, collisions gradually dropped to an average of 0.91 per month. Later, during 1966 and 1967, the number of colli sions dropped drastically to the figure of 0.23 per month. Our Philadelphia records show that for 1968 and 1969 not one collision occurred between vessels underway that were equipped and using radiotelephone communi cation. These outstanding results were achieved during that period of time when the Delaware River witnessed a large in crease in tonnage as well as a greater num ber of vessels, carrying with it the inevitable potential for a higher collision rate area.
The advantage of bridge-to-bridge radio telephone is quite obvious and reaches frui tion when communication between pilots, reduced to the essentials, results in early agreement leading to positive and timely decisions.
Towboat Legislation
In September of 1961 the Oast Guard initiated a comprehensive study of towing vessel casualty statistics in an effort to determine whether the inspection of steam towing vessels and the licensing of their operating personnel should be extended to include diesel towing vessels. The study indi cated that the inspection of all towing vessels and licensing of their personnel were essential in the interest of saving lives and property. The position has always been that it is inequitable for steam towing vessels to be subject to inspection and licensing whereas diesel vessels of the same type and sire were exempt Now statistical analysis of towing vessel casualties indicates a deficiency in safety due to the lack of qualified and properly trained towing vessel operators. The statistics have been updated each year, and each passing year reveals relatively little change in the basic comparisons. Personnel fault on the part of towing vessel operators was found to be a primary cause of towing vessel accidents. Therefore, we strongly support that aspect of a current House Bill, HR. 13987, requiring persons in charge of a towing vessels direction and control to be federally licensed. We feel that such a li censing program would be a significant first step in reversing the casualty trend and that once the program is in effect, both the extent of its impact on maritime safety as well as any need for supplemental legislation can be more accurately assessed.
Three important lessons were learned from the previously discussed tragedies which re emphasize the need for unification of the. rules of the road, bridge-to-bridge radio telephone, and licensing of personnel operating towing vessels. The African Star and Union Faith were in collision with vessels directed and piloted hy unlicensed personnel. There is no licensing requirement for personnel operating towing vessels similar in size and operation such as the Midwest Cities and Warren J. Doucct. In fact, the record of the Marine Board of Investigation revealed that the person in charge of the Midwest Cities at the time of the collision with the African Star had ability' to read and write limited to little more than signing his name.
The recent sinking of a towing vessel in
the Gulf of Alaska points out the potential
need for inspection of certain categories of
38
Meric- e- -r fe r:
towing ve.-sds. The Intn-fid, towing an Conclusions
inspected sea going freight Targe, was on a In summary, concerning the topics of
voyage from Seattle, Washington, to Whit passing methods, communication failure, and
tier, Alaska. Three person? lost their lives personnel fault, unification of the rules of
when the vessel sank during a severe storm the road would remove the confusion that
with seas reported to be 20 feet in height exists on vessels passing from one rules of
and winds in excess of 50 knots. The In the road zone to another. The "narrow-
trepid, built in 1965, was an uninspected, channel rule" under the Inland Rules and
welded steel, single screw, diesel propelled the. "points and bonds" customs would be
vessel of 199 gross tons. It was constructed compatible. Today, a vessel operating in the
and operated without any statutory require Gulf of Mexico could easily be faced with
ments relative to plan-review sad jreriedic the problem of operating under three differ
inspection or drydoeking. The vessel was ent sets of rules on the same dry. I have
not classed, but was in compliance with the shown earlier the dramatic effect bridge-to-
1930 Load Line Convention. There -wra3 no bridge radiotelephone has on reducing vessel
requirement for licensed personnel 10 he on collision-; in the Delaware Bay. What better
board Prior to her final voyage, the vessel way is there to k cu the occurrence of
was operated in Alasl&n waters and had a vessel collisions than establishing a positive,
history of hull fractures. The adequacy of sure, and exact method of deckling how two
repairs made to the hull arc not known, as vessels are to pass in inland waters? Bridge-
they were neither approval nor examined to-bridge would not dominate the require
by the Coast Guard or a classification society. ments for whistle signal-, but it would indeed
On the night of 19 February 1970 the provide an important t-*4 to supplement the
Intrepid took an unusual roll to starboard, whistle, and one which is entirely compatible
estimated to he sixty degree*, at atont 2100 with radar.
hours. The reason for the roll was never fully established; however, it was assumed to be the result of heavy* weather. At about 2115 an attempt was made to haul in s-cane of the tow wire; but because of the amount of water on the after deck, the crew was unable to reach the winch. Shortly after ward, an interna! examination of tfie vessel was made to determine v.hy the stern was riding so low in the water. It was found that the watertight door leading to tine laznrelte could not be opened because of the water in the lazarette. Pump suction was started on this compartment. Meanwhile,
Towboat legislation would provide licens ing requirements Cor vessel operating per sonnel. If we were to corr-trnct a graph from our statistical studies of inland towing vessel
casualties, it would reveal personnel fault as the major cause of such casualties. With regard to towing vessels operating on the high seas, our studies show vessel construc tion! ami maintenance deficiencies to be the major cause of casualties. Hence the Coast
Guard's position that, future legislation re quiring inspection of certain categories of towboat? may be required.
weather conditions worsened and the vessel's With each collision, the tvxd for legisla
heading was brought around into the wind tion in the areas of bridge-to-bridge radio
and sea. At approximately 2330 the Intrepid telephone, unified rules of the road, and
took another heavy roll to starboard. This towing vessels become? even more urgent.
roll, together with further submersion of the These tragedies should convince us that un
stern, allowed water to enter the engine room less preventive measures in the form of the
resulting in the loss of all power. The vessel legislation discussed are enacted, the same
started sinking by the stern and was totally types of casualties will occur in greater
immersed in 10 or IS minutes. We believe that the flooding of the after compartment and the starboard ballast tank was caused by fractures in the underwater body. The sink ing of the Intrepid possibly could have been
numbers.
Is the safety of life and property worth the effort necessary to effect the passage of and then implement remedial legislation?
prevented by timely mis! adequate inspection. I think it is.
39
JQJ'i't AatiyHiil Safety Ct>vgrcss
IMCO--WHAT IT IS AND WHAT IT DOES
By CAPT. THOMAS W. POWERS, USCG
Chief, International Affairs Division, Office of Public and International Affairs, United States Coast Guard, Washington, D. C.
In almost everytiling the Coast Guard does the key word is "Safety"--safety of life and property at sea, merchant marine safety, safety in recreational boating, safety in our ports and waterways.
Most aspects of our safety mission have an international flavor. For example, search and rescue activities often involve the life and property of foreign nationals. Our aids to navigation guide domestic as well as for eign shipping. Our enforcement of the mari time laws and treaties of the U. S. is felt by both citizens and non-citizens alike.
Historically, the oceans have served man kind as commercial highways. Even though in recent years the exploration of the seas lias been greatly accelerated for purposes of science and exploitation of resources, trans portation is still the primary use of the oceans, rivers, lakes and waterways of tire world.
A large part of marine transportation is essentially an international undertaking. Ships of many nations sail in and out of our ports, and our ships are moving in and out of foreign ports. The safety of this vast mari time commerce cannot be left to what would lie an enormous series of unrelated and uni lateral standards. The need for coordination with others using the same waterways, har bors, and oceans is obvious.
This need led to the birth of IMCO-- Intergovernmental Maritime Safety Consult ative Organization. IMCO was conceived at an international conference in Geneva in 1948. Gestation was 10 years, for it took that long for a sufficient number of nations to ratify the IMCO convention. The Republic of Korea was the 21st nation to do so, and IMCO was bom in 1958. There was thus brought into being an international, repre sentative, responsive, viable, continuing body concerned with the whole field of safety of international sea transportation. Means were now provided for cooperation among gov ernments on technical matters affecting inter national merchant shipping, with special em phasis on the safety of life at sea. Currently, seventy-one nations are now members. Prac
tically all major maritime nations are repre sented. Even land locked countries like Switzerland belong. Some of the smaller countries in the organization are Maldives. Malta, and Kuwait.
One of the first tasks of IMCO was to conduct the lOciii Conference on the Safety of Life at Sea. This conference, which up dated a similar 1943 conference, Iras now been adopted by 81 nations, including the U.S.
IMCO has throe main bodies: the assem bly, the council, and the maritime safety committee. There is also a secretariat of some seventy odd international civil servants who keep the organization functioning on a day to day basis.
The Assembly is the principal body, con sisting of all of the members. It is the ulti mate decision-making unit and meets every second year. However, an emergency session can be called at any time.
Eighteen of the member nations compose the Council, which usually meets twice a year. The council is primarily concerned with other than technical matters and acts as the housekeeping body of the organization. It does, however, review the work of lesser bodies. The council is formed from the fol lowing groups: The first group must consist of six nations from among those with the largest interest in providing international shipping service. Elected in 1969 were The United States, Japan, United Kingdom. Nor way, Greece, and The Soviet Union. The next group of six is from the nations with the largest interest in international seaborne trade. Elected were Canada, France, Italy, Belgium, Germany and The Netherlands The final grouping of six is from those na tions not included in the two former cate gories but with special interest in maritime transport or navigation and 'whose election to the council will ensure the representation of all major geographic areas in the world Elected were Brazil, India, The Malagasy Republic, Australia, Poland, and Ghana.
The Maritime Safety Committee (MSC). meeting twice a year, handles all matters of a technical nature for the organization. There are presently 16 member nations on the MSC.
40
Marine Section
The composition of the maritime safety committee is as follows: eight members are from nations representing the 10 largest shipowning states. Elected in 19o9 were The United Kingdom, U. S., Japan, Norway, The Soviet. Union, France, Greece, and Italy. Liberia and Germany were not elected from this category. Four members each must rep resent one of the following geographical areas: Africa, The Americas, Asia and Oceania, and Europe. Elected in 1969 were: Pakistan, United Arab Republic, Argentina, and Germany. The remaining four members must be from those nations not already otherwise represented on the committee. Elected in 1969 were G.i Or The Nether
lands, Sweden, and Spain.
By the way. Lloyds' Register of Shipping lists the U. S. Merchant ship tonnage as of 1 July 1969 as 19.550.J94, We are in fifth
place; however much of our tonnage is in the laid-up fleet. Liberia is first, with over 29 million gross tons. Nations in between are United Kingdom. Japan, and Norway in that order. As you can see, even though Liberia leads the world in tonnage site was not elected to membership to cither the Coun cil or the Maritime Safety Committee.
Under the MSC are the following 10 technical subcommittees, each meeting once or twice a year: subdivision and stability; fire protection; radiocommuni,cations: marine pollution; cargoes and containers; carriage of dangerous goods; lifesaving appliances; safety of navigation; ship design and equip ment; and fishing vessels.
The ,United States is a member of the Assembly, the Council and the Maritime Safety Committee, as well as each of the subcommittees. In fact, United States citizens chair two of the IMCO subcommittees.
As IMCO is an international body, all contacts between IMCO and the United States are made through the Department of State. To coordinate associated problems, the Department of State has formed and chairs a special group called the shipping coordinat ing committee. This committee, in turn, has standing committees to handle different types of problems. One such group is the Safety of Life At Sea nr SOLAS subcommittee, chaired by the commandant of the Coast Guard. This group handles technical IMCO matters relating to maritime safety. Members of this subcommittee are from various gov ernment agencies and industry groups. The
Lake Carriers" Association, the American Institute of Merchant Shipping, the Ameri can Petroleum Institute, as well as labor and management groups, are represented on the various committees, subcommittees, and worktug group;.
Although the Department of State has the prime responsibility to establish U. S. posi tions on international matters, it looks to the U. S. Coast Guard as the organization hav ing the training, personnel, and technical knowledge in marine safety activities to as sure effective United State; participation in international discussions in this specialized field.
Members of the Coast Girard, therefore, act as alternate delegates and advisors to the IMCO Assembly and to the Council. The Coast Guard furnishes the chief delegate as well as advisors to the Maritime Safety Committee and to the various subcommittees.
I would like to review briefly some of the important areas with which IMCO has dealt and is dealing, to illustrate the scope arid effect of this organization.
For many years, the United States has been advocating a higher degree of struc tural fire protection in international conven tions for passenger vessels. After the loss of the Lakonia and 125 of its passengers in 1963, the loss of the Yarmouth Castle and 90 persons later, the United States proposed that the Maritime Safety committee of IMCO should make a special study of ship board fire protection. A special meeting was held in 1966. The Viking Princess fire, which occurred just before the meeting, served to heighten the urgency of the problem. All of these vessels were of a non-U.S. flag.
Because of its complexity, the matter was separated into two steps, the first directed toward upgrading of existing passenger ships and the second to establishing standards for future construction.
At the conclusion of that meeting, the delegates agreed on various proposed amend ments to the I960 International Convention for the Safety of Life at Sea for existing passenger ships. These -were submitted to an extraordinary session of the IMCO Assembly called for this specific purpose.
In November 1966 the IMCO Assembly unanimously approved the recommended amendments- The result will bring a higher degree of fire safety for existing passenger
41
1970 National Safety Congress
vessels, upgrading many of those ships oper ating in the cruise trade from our ports.
The recommendations for amendments to the 1960 SOLAS convention for future passenger ships that emanated from these meetings were considered and adopted by the Maritime Safety Committee and Assembly meeting in 1967. These amendments will come into effect one year after acceptance by two-thirds of the contracting governments to the 1960 SOLAS convention. The United States has ratified these 1966 and 1967 amendments.
Marine pollution is a matter of intense national and international concern. On March 18, 1967, the Torrey Canyon, again of nonU.S. registry, a supertanker of over 120,000 deadweight tons capacity, foundered on The Seven Stones. These partially submerged rocks are in international waters off the south-west coast of England. The accident resulted in the spilling of thousands of tons of crude oil which was washed up on the beaches and harbors in the resort areas of Southwestern England and, subsequently, across the channel in France.
The incident and the extensive damage that resulted to the coasts and to wildlife focused worldwide attention on the need for measures to prevent future accidents of this nature, and to minimize ill effects if such accidents would re-occur. IMCO took special and immediate action. A whole series of pre ventive measures were recommended to gov ernments. Some of the most significant ones were: the designations of sea lanes and pro hibited areas, requirements for additions! navigational aids, shore guidance for ships near land, testing of navigation equipment, officer and crew training, use of automatic pilots, international cooperation in connec tion with handling significant spillages of oil, and a strengthening of the international convention which seeks to prevent the pollu tion of the sea by oil.
One of the areas currently being investi gated by IMCO is the question of tanker tank size. Roughly, this means wlrat. if any, should be the maximum size tank permitted in an oil tanker, recognizing that if this tank is breached a given amount of pollution will result?
There are legal aspects involving marine pollution. In 1969 IMCO called an inter national conference, held in Brussels, dealing
with such problem?. The result of this con ference was the adoption of two new con ventions. (Of course, these conventions must be ratified by the various governments. Some have already done so.) The first deals with the right of a coastal state to take action to prevent pollution of its waters and shore line in event of a vessel casualty occurring in international waters. The second conven tion deals with civil liability and will, when brought into force, ensure that funds are available for clean up and liability claims in case of casualties.
Future plans of IMCO call for a confer ence on the safety aspects of containers anti a conference on revision of tire international rules for prevention of collision at sea, both in 1972, and a conference on environmental pollution by ships in 1973. Waiting in the wings are international conferences on the revision of the rules governing tire unberthed passenger trade and on fishing vessels.
In my mind, IMCO is playing and will continue to play an important role in the future of the entire shipping world. I believe our participation places us in an excellent position to improve the international posture of our merchant marine. The United States has taken an active jart in this organization, and already we are achieving results which will be to our advantage. The safety of inter national shipping is constantly being im proved.
I would now like to review some of the principal achievements of IMCO in its first decade. The first IMCO Assembly was held in 1959. In 1960 IMCO called an internation al convention to revise the safety of life at sea convention. The rules of the road were also revised at that time. In 1962 IMCO railed a conference to update the Interna tional Convention on the Prevention of Pol lution of the Sea by Oil. This convention was updated by IMCO's Assembly as re cently as October 1969. IMCO produced art Internationa! Convention on Facilitation of Travel and Transport in 1965. Also that year, international agreements were reached on a new code of signals, on an international maritime dangerous goods code, and also a code on safe practices for bulk cargoes. In 1966 IMCO held a conference on leadlines and produced a convention. In 1966 and 1967 IMCO was engaged mainly in working on measures to produce fire protection safety measure* .on passenger ships. !- I960 IMCO
42
etioine Section
produced a convention on tonnage measure ment. In 1969 IMCO hosted a legal confer ence on marine pollution damage.
You can see that IMCO does useful work as far as the U.S. is concerned. Essentially, it comes to this: when we lave an interna tional problem, titers exists an international forum where the matter can be thrashed out and concrete action taken. Most of the ma
rine passenger trade and much of the cargo trade to and from our shores are carried in foreign flag vessels. Therefore, international cooperation in maritime safety is very muc.lt in our best interest.
In my view, If ICO will continue to grow and prosper and will continue to make a vital contribution O inO'nnrinnnt nrtritimK: safety.
PREVENTION OF WATER POLLUTION BY MARINE TRANSPORTATION
Ey CDR. ALBERT G. STIRLING, USCG
Chief, Electrical Engineering Branch, Merchant Marine Technical Division, Office of Merchant Marine Safety, United States Coast Guard, "Washington, D. C.
Although "ecology," "anti-iioHution," and "environment" are the "in" phrases of today, they do not, in my opinion, change the basic fact that safety and anti-pollution measures are inseparable, and that anti-pollution meas ures are only an extension of what we desire to keep safe. The problem of containment of petroleum products or chemicals is the same whether you are concerned that it will es cape and bum or escape and destroy the environment Thus the Coast Guard has been and will continue to be a pollution control agency. The ecological concern of this coun try will only modify the nm-eut rmpbnri* of our safety program.
I believe that the problem of water pollu tion is'much more susceptible to an effective solution when placed in this safety' perspec tive. Whether we like it or not, as safety experts we realize that we mut accept some degree of risk, tome degree of lack of safety in our everyday work, and in our lives. Your job and mine is to minimize this risk, to establish an acceptable level of risk. So, too, must we temper our approach to water pollution. In the words of the First Report of the President's Pane! or, Oil Spills, "Al ternatives available to lessen the frequency and magnitude of oil spills do not include the complete abandonment of oil tankers or the total elimination of offshore oil opera tions."
With a presumption that marine transport of possible pollutants will continue to exist and will expand, what safety strategies exist? I would propose the following:
1. Provide a cnnhiiitinent system which i,-,,ii; .!; Pi be breeched.
2. Eliminate all hazards to the contain ment system which have sufficient potential to breech it.
3. Limit the quantity of pollutant lost in the event of containment failure.
4. Limit the rate of loss of pollutant its the event of containment failure.
5. Provide a system external to the car rier to contain and clean-up any spill.
The above strategics written are con cerned with the product as stored aboard the transport. However, we must modify them and apply them also to the possible discharge of a pollutant as a result of product handling and transfer mid routine vessel maintenance and operating procedures.
What is needed most then, is a method or system to evaluate these strategies, their sub strategies, and the various combinations thereof to determine their impact and effec tiveness on the pollution problem. The re mainder of this presentation will be a dis cussion of these strategies, their application ami value assessment.
I believe we will always need a clean-up capahility. As long as people are involved in marine transport we will have spills. How ever, spill clean-up is attacking a symptom and not the cause. It is unfortunate that our society and particularly <mr research and development efforts are so hardware oriented I suggest that we would be far better off if much of toe efforts and funds of both gov-
47
IV'u National Safety Congress
emment and industry were directed to pre vent pollution rather than cleaning it up or developing better solvents and emulsifiers. This latter approach is akin to spending money on cemeteries rather than medical research because there'll be some tangible evidence of where the money went.
While I'm on the subject of people and spills, let's examine the old cliche that its just "human error." We must attack any accident prevention program (and spills are a form of accident) in a positive manner based upon the knowledge that man is fal lible. In every human error accident there is a chain of events leading to the final act by a human. If any event in the sequence is eliminated, the accident does not occur in spite of the human failure. A foolproof sysstem must be our design philosophy for, I submit, with the right set of events preced ing an accident, anyone of us can be "the fool." With these criteria in mind let's ex amine the proposed strategies in more detail.
Protide a Containment System Which Is Not Likely to Be Breeched
The mere statement of this strategy con cedes compromise is necessary. We cannot with current technology and within reason able bounds maintain containment when two 300,000 ton tankers collide at 16 knots or break their backs upon the rocks. A total containment concept was used for the nuclear reactor on the Savannah; however, that de sign was assisted by a much smaller package to be contained.
A damage criterion is being developed by the Ship Design and Equipment Subcommit tee of the Marine Safety Committee (MSC) of the Intergovernmental Maritime Consulta tive Organization (IMCO). This type of work must be done on an international basis since our waters are exposed to vessels of all nations. This criterion appears reasonable and only time will answer the question of its adequacy.
The joint effort of the Coast Guard and the chemical transportation industry to de velop marine transportation standards for hazardous materials has resulted in a new Subchapter 0 of Title 46, more commonly,
the Coast Guard Regulations. That section concerning unmanned barges has been pub lished and that portion concerning manned vessels is soon to be published.
44
In these regulations are three types of hull design with varying degrees of damage re sistance, Type I vessels being most damage resistant and Type III vessels the least The Type I and II vessels require a double hull or independent tank such that the inner tank is a specified distance inboard of the outer hull. Although the distances presently spec ified approximate the tentative international standards for extent of damage, they do not in all cases meet the new international cri teria. Once the international standard is in final form then our standards will be brought into line.
The present and proposed regulations, then, have in some way related hazard to degree of containment To date only the very toxic (to humans or fish) and the very reactive: have been assigned double hull type protec tion. We are faced with a decision on ac ceptable risk. Past decisions placed a higher risk cm the ecology than present day con sideration might Typical of this are petro leum products which are carried in single skirt barges and ships. To my knowledge no one has ever justified this risk. A compre hensive study has not been done on the life cycle cost of using double hull construction rather than single hull construction. Uncon firmed reports I have received about one oil company, which built some large tankers with double bottom construction, are that many unexpected benefits occurred. With a Slush bottom tank and a well type suction, one such benefit is that tank cleaning is greatly reduced and lost capacity due to sludge and residual cargo is eliminated. One adverse arid unexpected result was the re finery complained to the producer on the l<oor quality of the crude because of the increased sand and dirt content
A major side benefit of double hull con struction is that it provides for clean ballast tanks and the elimination of the major con tribution of slop oil and dirty ballast to water pollution. Although there are other alternatives to a better container, double hull construction is the only one receiving much attention at this time.
Eliminate all Hazards to the Containment System Which Have Sufficient Potential to Breech It
This strategy is, of course, the opposite of the first. In this strategy we propose to eliminate ar.y possibility of collision, strand-
Marine Section
mg, impact, weather damage, falling space ships, overpressurizing or overfilling, fire, dynamic loading, or fatigue. Again we are faced with lack of perfection. We cannot totally eliminate damage to the system, but we can reduce the probability that a damag ing incident will occur. We can provide 1-ztter navigation systems; we can provide better aids to navigation; we can provide vessel routing considering weather, channels, and traffic; we can provide better cargo han dling, overflow, and pressure relief systems; and we can provide better training to the operating personnel. One interesting thought under this strategy is that we should have a tcw large vessels rather than many small unes and thereby reduce the probability of .isi accident
Limit the Quantity of Pollutant Lost in the Event of Containment Failure
This strategy dictates many small vessels, many small tanks, available empty tanks or collapsible containers such that cargo from a leaking tank can be rapidly transferred, and one far out idea is cargo solidification. IMCO lias the problem of tank size under consideration in conjunction with the ex pected damage criteria.
In relation to cargo handling, this strategy requires smaller loading hoses, lower trans fer rates, and rapid response to the handling system to various conditions such s over filling or line rupture.
Limit the Rate of Pollutant Loss
In regard to vessels this may be difficult to achieve. Two possible approaches would
be a self-sealant tv pc tank lor small rup tures and a cargo coagulation process for larger ruptures. In regard to cargo handling, this is very similar to the previous strategy of lower handling rates and small inter-con nections.
It should be apparent and not at all sur prising from the above discussion that we are unable to lire any one strategy to its fullest; rather we will use them all to some extent How does *e asses* the .pollution hazard and make a decision on which strat egy and to what extent it should be em ployed? To auovcr this we must look to the complete pollution problem
This procedure is to evaluate the intrinsic product hazard; consider the technology available to control the product prior to smd after release; considering the quantities in volved, assign an acceptable degree.of risk which specifies the required preventive pro gram; this in turn result* iit spills from which we establish nnr experience factor for re-evaluation. The fly in To ointment is that -ve. haven't figured nut an analytical
scientific way to do thi-=
The first part *.t the problem is specifying the hazard in some fashion so that products can he rated and equated. I would suggest that the hazard II he based upon the prod uct's target or victim V, toxicity T. and persistency P. This might be expressed as:
' II - f(VTF)
Values could be assigned to the parameters and a hazard rating arbitrarily ( but with some scientific basis) assigned from the products score. For example:
F
people -- A fish & aquatic animals -- B birds & plants -- C water supply = D recreation & esthetic = E
T_
none = 0 mild = 3 moderate = 2 bad = 3 extreme = 4
P >wk -- W
<day'! _ v >hr f .-y. = 7
Where A>B>C>D>E and W>X>Y>Z
Thus, for example, any product scoring greater than B3X for any victim or a total score for all victims greater than (A+B+C)2X would be in the highest haz ard rating. The necessary number of ratings and their end points could be established to span the range of pollution.
The control evaluation is a straightforward evaluation of current technology. With this in hand, we must attempt to establish some degree of risk. The risk R as a function of parameters may be expressed as:
R = f(HQEUTMPa) Where; H -- product, hazard, previously established.
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19/0 National Safety Congress
Q -- quantity of product involved.
E = environmental conditions at the time
and location of the spill. This would include temperature, stream flow char acteristics, human population and aquatic life exposure.
ly discharged to the waterways, and which constitute a long term ecological hazard. Recent examples are the Great Lake's area concern over mercury and DDT. The job of designating hazardous materials, i.e, those that are a pollution problem, has been as
U -- water use. The water quality standards signed to the Department of Interior under
are based upon an assigned water us the authority of the 1970 Water Quality age. Improvement Act. The Evaluation of the
T = time to detect or available to detect the Hasard of Bulk Water Trasisfrcvtotion of
product release and to begin some type Industrial Chemicals done by the National
of response.
Academy of Science for the Coast Guard is
M -- mitigation factor, this accounts for any after spill action which ameliorates the pollution.
Pa -- the probability of product release and based upon the preventive measures required.
With a conservative approach E, V, and M can be assumed to maximize the. risk, thus limiting the problem to:
R -- f(HQTPa)
a good beginning. But it is only a beginning.
Our ability to clean-up or neutralize a spill is extremely limited. To date we have attacked only the problem of oil, which U
relatively simple. Note that I said "relatively simple," because oil is easily visible, tends to separate from the water and retain its identity. You will see that oil is still a diffi cult problem, and we have not begun to reach a level where we can neglect preven tion of a clean-up capability.
At this point we have a choice of solutions. We can, based upon the hazard, assign a probability of spill and calculate a risk, or
we can assign a risk and calculate the prob ability of spill. I would propose to use the latter and thus calculate the probability of spill or non-spill. I feel there is sufficient
data available to estimate the probability of failure of the different strategies and thus determine our prevention program. I don't have a system to solve this problem, but I do believe this shows the logic our thinking
Finally, our tolerance or acceptance of pollution must be considered- At present, public indignation is high and political pres sure dictates a very low tolerance level. However, man cannot live without modifica tion of his environment .and I suggest that our tolerance level must he established by a national scientific analysis and assignment of water usage. I ftelieve some progress is be ing made by the government and the aca demic community in this respect. Zero defects is not possible.
should take and perhaps someone can sug gest ways to define the parameters.
I have just recently been involved in an accelerated but extensive study of the gatera! spill problem. To me, the most enlight ening fact I learned was our nearly total ignorance of this problem. There is insuffi cient data available to pinpoint causes of spill pollution and to identify where our cor rective efforts should be used. Perhaps one of the most significant actions to result from the Water Quality Improvement Act of 1970 will lie the mandatory reporting of spills. This will enable us to get some handle on the real causes of their probable rate of occurrence. The consequences of a spill are not in ail cases well established. Particularly, the long term effects of a spill require a great deal of study.
There are many products carried today which are unregulated, ate probably routine
Where, then, do we stand as far as prog ress is concerned in. our efforts to curb pol lution from marine transportation? I believe overall that the problem of pollution from marine cargoes is well in hand. Particularly with chemicals has a rational approach been made, primarily because the requirements either preceded or were developed concur rently with the establishment of the marine transportation mode of the product Oil, however, bar, been shipped for sometime prior to our full awareness or concern for its pollutant properties. We need a formal rational approach to replace our past "seat of the pants" approach to the problem.
I said the pollution problem from cargoes is well in band. Unfortunately, I cannot say the same for our daily marine operations. The Maryland State authorities fee! their single largest routine source of oil on the Chesapeake is the waste oil and dirty bilge
46
Marine Section
pumpings of transient vessels. Tins is in excusable.
The Water Quality Improvement Act of 1970 calls for the President to issue regula tions for the prevention of oil pollution. This act also provides for a ten thousand dollar penalty for deliberate discharge of oil and a five thousand dollar penalty for failure to comply with the regulations. The Depart ment of Interior has defined a harmful quantity of oil as any discharge which vio lates applicable water quality standards or
causes a film or sheen upon or discoloration of the surface or shoreline, or causes a sludge or emulsion beneath the surface. With this definition and the above penalties, it seems assured that we will see some rather radical changes in our present system of handling shipboard waste oils, tank slops, and dirty bilges. The nation is no longer wall ing to provide free waste disposal to the marme industry. Waste disposal is a legiti mate cost of business and the industry must
recognize it as such.
CLEANUP AND CONTROL OF POLLUTING SPILLS IN THE MARITIME ENVIRONMENT
By CDR. DANIEL B. CHARTER, JR,, USCG
Chief, Maritime Pollution Control Branch, Office of Operations, Law Enforcement Division, United States Coast Guard, Washington, D. C.
In U.S. waters there may be as many as 10,000 polluting spills a year--ten of which are major spills. In addition, one spill of disastrous proportions can be expected on the average of every ten years. About half of these are oil spills, some three-quarters of which are estimated to be transportationrelated. While many of these spills are rela tively small, they are frequent and add up to an unacceptable level of pollution in our ports and waterways.
Thus, in addition to our preventive pro gram, we must have a cure for the polluting spills that do occur. We must he able to limit the losses that these spills can cause to human health, natural beauty, wildlife, fisheries resources, recreational areas, private and public property, and other things that we value in the marine environment. To control such damages, quick action must be taken to confine the polluting substance to a small area and then to remove or somehow inac tivate it.
First of all, effective response to pollution, incidents requires careful advance planning. When a spill occurs, responsible officials must be ready to act immediately and de cisively. The Federal government has been active in pollution contingency planning dur ing the last few years. In anticipation of enactment of the Water Quality Improve ment. Act of 1970 and in response to a
Presidential memorandum of June 1968, the Departments of Transportation, Interior, Defense, and Health, Education and Welfare and the Office of Emergency Preparedness signed an interagency agreement known as the National Multi-agency Oil and Hazard ous Materials Pollution Contingency Plan. This agreement provided for a coordinated Federal response to a spill posing a sub stantial threat to public health and welfare. In June 1970 a new plan, based on the previous one, was published in order to meet the requirements of the Water Quality Im provement Act of 1970, which was passed last April. Under the new plan, the Coast Guard was assigned responsibility for fur nishing or providing for on-scene command ers for spills on the high seas, coastal and contiguous zone waters, and coastal and Great Lakes port and harbor areas. This on-scene commander is responsible for the coordination of Federal response efforts at the scene. The plan also requires the Coast Guard to have equipment and trained per sonnel available in the above areas to take the necessary cleanup action when the re sponsible party is either unable or unwilling to respond adequately.
Unfortunately, present technology for cleaning up oil spills and other types of polluting spills is sadly Inadequate. This fact has been most evident at major spills such
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19/0 National Safety Congress
as the offshore oil well blowout at Santa Barbara, California, in January 1969, and the oil well incident off the Louisiana coast last February. It was most distressingly dem onstrated in March 1967 when the super tanker Torrey Canyon ran aground off the southern coast of England, spilling 119,000 tons of crude oil into the sea. The desperate and largely futile efforts of the British and French to cope with this oil captured the attention and sympathy of people all over the world. Even for small oil spills, more over, the cleanup methods that are now used are almost totally ineffective except in verycalm and sheltered waters. Some commonly used methods such as dispersion of spiffed oil with chemical detergents may even do more harm than good to the marine ecology. Finally, we know very little about how to cope with spills of the variety of chemical products which are now being shipped in bulk for the first time.
To provide an effective cal spill cleanup capability in the United States, the Coast Guard is now conducting an intensive $4, 000,000 a year research program to develop new. techniques and equipment. We plan to continue this research on a high priority basis for several years and to explore a wide variety of approaches to the oil spill cleanup problem.
We have placed emphasis initially on pre venting spills from distressed tankers off shore and on preventing spilled oil from spreading out on the sea surface. An airdeliverable system for offloading oil and other potential pollutants from grounded or otherwise damaged tankers is an early prod uct of our research program. The theory be hind this system is that it is much easier to remove a ship's oil cargo before it spills than to try to clean up the same oil after it has spilled into the water. A prototype system has been built, and we are almost finished testing and refining it. The system consists of pumps, transfer hoses, and rubberized nylon bags for temporarily storing the oil. It is designed to be flown on short notice to the scene of an offshore tanker accident, dropped by para chute, and deployed by a specially trained Coast Guard pollution control team. A rapid response is possible because Coast Guard air craft and other resources are kept at a high state of readiness at all times. The pumps and transfer hosing wii! be used to pump the oil from the vessel into the temporary
containers before it spills into the water. The first operational system is scheduled to be ready for use in about one year.
The other problem that the Coast Guard is giving highest priority is that of prevent ing spiffed oil from spreading on the water surface. Once oil has spilled into the water, it must be confined in as small an area as possible if cleanup measures are to be effec tive. If the oil is allowed to spread out over a large area, it is much harder to clean up and causes more damage. Many oil slick containment "booms" of "fences," as they are called, are new being sold commercially to oil companies and other potential users. Another method which is coming into use is the air bubble barrier, whirh creates sur face currents by releasing air bubbles under water. This device has the advantage of al lowing vessels to pass freely through. Also, it can be permanently installed at an oil dock and instantly activated when a spill occurs.
Unfortunately, these products are effective only in very calm, sheltered waters where the water currents are very slow. In open waters, the action of the wind and waves washes the oil over and under these barriers, making them almost totally useless. None of the many commercial products tried at the Gulf of Mexico oil well incident last March were able to hold the oil slick against the forces of the sea. In view of the inadequacy of present technology, the Coast Guard has been conducting research on the problem for several years. We are now ready to begin construction of a prototype high seas oil slick barrier. If this prototype is successful, the Coast Guard hopes to have an operational version within a year. Eventually, the system may be packaged for delivery by Coast Guard aircraft to the scene of an oil spiff. This feature will reduce our response time to a minimum.
After an oil slick has been confined to a limited area--or even if it lias not been confined--there is the problem of recovering the oil or somehow treating it so as to make it less destructive. Many inventive methods of doing this have been proposed. Some of them are quite ingenious; so far, however, no single method has proved to be sufficiently promising to warrant a large investment by the Coast Guard. We are keeping an open mind and are funding re search on many different approaches. Let
48
Marine Section
me briefly mention some of the techniques which are being considered.
Chemical dispersion of oil is perhaps the most commonly used method of making an oil slick disappear from the water surface. Detergents and other chemicals can dissolve an oil slick so that it mixes with water and thus becomes less visible. Unfortunately, the oil can do more harm to fish and other marine life when it mixes with the water than when it remains on the surface. Also, the chemicals themselves are usually toxic to marine life. Chemical compounds which stick to oil and sink it to the bottom have similar disadvantages in that they bring the oil into contact with shellfish and other bot tom life. They also tend to release the oil to the surface after a period of time. Be cause of these harmful side-effects, chemical dispersants and sinking agents often do more harm than good. Consequently, the Federal Water Quality Administration has published guidelines prohibiting use of these methods except under certain specified circumstances, such as when waterfowl or important shore areas are threatened by the oil. Dispersants may also be used if, in the judgment of the on-scene commander, there is a hazard to human life or limb or a substantial fire hazard which could be reduced by dispersing the oil.
Another approach is to absorb spilled off with straw or some other plant fiber. Straw was used extensively at the Santa Barbara, California, oil well incident last year. Buoy ant plastics and foams have also been tried, but straw seems to work best This method has the advantage of not introducing the oil or any chemicals into the water below the surface. Its chief disadvantage is that re covering the absorbing material after it has soaked up the oil can be very costly and slow, especially if the slick has spread out over a large area.
When an oil slick has been confined and is thick enough, some of the oil can be re moved simply by vacuuming the surface of the water. Septic tank cleaning trucks are often used for this purpose. As the slick becomes thinner, this method fails because large quantities of water are picked up
along with the oil. Current oil-water separa tion techniques are not efficient enough to
make this method practical under such cir cumstances.
Burning oil slicks on the water have been given considerable attention as a method of removing them. Special chemical agents have been developed by several companies to fa cilitate tins process. Obviously, this method cannot be used in port areas where the fire might spread. In ripen waters, on the other hand, it can be very difficult to ignite an oil slick unless it is fairly thick and its more volatile components have not evaporated.
Biological degradation of oil slicks by spe cial strains of bacteria or other micro-or ganisms Is another area in which research is underway. As yet the feasibility of this method has not been determined, but it may be possible to accelerate the natural process by which oil decomposes in the water.
The Const Guard is also concerned with the great number of hazardous substances other than oil which arc increasingly being shipped iu bulk quantities and which could cause serious pollution and safety hazards if spilled. Because of the variety of these chemi cals and the scarcity of knowledge about some of them, it is difficult for non-specialists to know what to do when there is an acci dent involving one or more of them. We are now developing a solution to this prob lem. The National Pollution Response Cen ter established by the National Pollution Contingency Plan and located in Coast Guard Headquarters will house a computer ized information system which will be able to provide real-time technical guidance to personnel at the scene of a spill or a poten tial spill of oil or hazardous substance. Some type of rapid communication with a data blank at the center will be provided for Coast Guard units at major ports, Coast Guard district offices, and other users. By providing certain key information about a spill situation, such as the substance involved, the type of area threatened, weather condi tions, and other parameters, an on-scene com mander will be able to get instant informa tion about the dangers involved and advice as to what action he should take. The infor mation system wff! be developed and operated by the Coast Guard but will be available to other users. Developmental work on this sys tem has just begun.
These, then, are some of the approaches to the "cure" for pollution by spills of off
and other substances. As the Coast Guard's
research program progresses, we plan to
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1970 National Safety Congress
purchase the necessary equipment and ma terials and maintain them at locations where polluting spills are most common or could cause the most damage. Specially trained Coast Guard pollution control teams will
stand ready to respond to any major inci dent I am optimistic that with proper man agement and adequate funding American technology can rise to the challenge of con trolling water pollution by oil.
ADDRESS
By ADMIRAL CHESTER R. BENDER Commandant, U. S. Coast Guard, Washington, D. C.
The first year of this decade is rapidly coining to an end, and a report is indicated to bring you up-to-date on current Coast Guard matters and projects which are closely associated with marine safety. In general, we, as the Department of Transportation's marine arm, intend to continue to contribute our special knowledge to the support of a national transportation system, a safer fish ing industry, and a more enjoyable and safer recreational boating fleet.
Our multi-mission capability to render service in marine safety, law inforcement, and marine science, while at the same time maintaining our ability to serve with the Navy in time of national emergency, is truly unique. It is this flexibility which gives the taxpayer great value for his dollar. So it is that our service, which lias been histori cally dedicated to safety at sea, has in recent months acquired closely related duties con cerning protection of the marine environ ment.
The Water Quality Improvement Act of 1970 provides for both prevention of and cure of water pollution problems caused by oil, other hazardous polluting substances, and vessel sewage. As will be emphasized later, our main aim is to prevent the pollution. However, we are prepared to cope with it and to minimize its effect should pollution occur. We also are prepared to proceed against polluters in Federal courts as cir cumstances warrant.
The Coast Guard, in coordination with other federal agencies, has assisted in de velopment of a national contingency plan. This plan provides coordination of all fed eral response to a pollution incident in coastal waters through a Coast Guard on-scene com
mander. As part of the national plan, re gional plans have been developed with re gional response centers set up to respond to and monitor spills. Regional response teams monitor pollution problems and supervise containment and cleanup operations. All oil spill reports funnel into our national pollu tion response center in Washington.
Strike force teams are being organized and trained and air deliverable equipment is be ing developed in order to respond rapidly to a major spill in any location. A large portion of our research and development dollars is being spent in development of containment, recovery' equipment, and special techniques.
Under the act, we are designated to study and to make recommendations for any needed additional legislation imposing liability for cost of removal of hazardous pollutants other than oil. This study is complete and has been submitted to the Secretary of Transporta tion. The Coast Guard is also required to promulgate regulations governing the de sign, construction, installation, and operation of marine sanitation devices. We have an active developmental program at this time.
Probably the marine safety matter of the most immediate concern to the Coast Guard is the enactment of the Administration's Ports and Waterways Safety Act of 1970, introduced in the present Congress and pend ing further action after recess. In his mes sage on oil pollution, the President empha sized the growing danger to our marine en vironment posed by oil pollution from ships. In this connect ion he pointed out the large increase in the seaborne transport of oil and the large number of ship collisions involving tankers. The President outlined a number of
50
Marine Section
legislative and other actions being proposed to reduce the risks of water pollution from oil and other hazardous materials.
One of these proposals was the Ports and Waterways Safety Act of 1970. This Act would allow the Coast Guard to regulate vessel traffic, foreign flag vessel? as well as American vessels, in the inland waters and territorial seas of the United States in order to minimize danger of collision and resultant pollution. It would also allow us to regulate the handling and storage of dangerous car goes on the nation's waterfronts and to set up safety zones or other controlled access areas in or near U.S. harbors.
Most of you arc aware that we can al ready do most of those things, but the pres ent authority under which the Coast Guard carries out its port security program is pur suant to a delegation from the President under the Magnuson Act of WHO. That Act authorizes the President to make rules gov erning the movement, inspection and guard ing of vessels, harbors, ports and waterfront facilities in the United States upon determin ing that our national security is endangered. In 1950 the emphasis was on sabotage pre vention and port security operations were focused on this aspect.
The present need for port security ha shifted from the sabotage aspect to that of port safety, including fire and pollution pre vention.
The authority of the Coast Guard to pre scribe pr enforce regulations covering ac tivities :in U.S. harbors is circumscribed by the penalty procedures in the Magnuson Act For example, the usual practice in enforcing safety' regulations is to assess civil penalties Regulations issued under the Magnuson Act, however, can be enforced only by criminal penalties. As a consequence, the punishment often doesn't fit the offense and enforcement is difficult.
The need for legislation is apparent. If we are to protect our waters and the ecology of our shoreline, a? well as the port facility itself, it is evident that action must be taken to broaden the statutory area of epneern and establish workable procedures. The non-de fense aspects of port safety go far beyond the intended scope of the Magnuson Act and should be based upon permanent statutory authority specifically addressed to current needs.
The language of the Bill is written in broad, general terms. This was intentionally done, as we believe that a totally effective system should promote the safety of our water transportation and environmental qual ity of our ports, harbors and waterways. To accomplish these objectives, the Bill au thorizes specific areas of regulatory action. In pursuing that action, the Coast Guard is. of course, bound to the provisions of the Administrative Procedures Act and will use the advice and recommendations of all in terested parties.
Already, from the testimony of many in terested groups and individuals, suggestions for improving and clarifying the language of the Bill have been noted and will cer tainly be considered. Most witnesses have supported the Bill but there are several who have expressed concern over the broad au thority of the proposed legislation. To them I would emphasize that the Bill basically puts into permanent form our temporary authority exercised under the Magnuson Act. There are other features to the legislation, but none will change the traditional respon siveness of the Coast Guard to the needs of the maritime industry and the transportation community in general.
In his address to Congress in May of this year, the President also commented on the importance of harbor advisory radar sys tems. Such a radar system has been devel oped by the Coast Guard and is now op erating successfully in the San Francisco Bay area. The system is designed to furnish pilots with surveillance data and traffic in formation by radio from a control center that will be manned 24 hours a day by Coast Guard surface traffic advisors.
As funds permit, our plans call for the establishment of the systems in Gulf and East Coast ports. We anticipate that these radar advisory' systems will enable tankers and other vessels to move through congested areas with much less risk of collision and will make busy ports such as New York. Houston, and New Orleans safer than they are at present. At the same time, the threat of pollution from spilled cargoes will be much reduced.
The President also mentioned the increased use of air surveillance in the fight against water pollution. We know- that much of the contamination of our coastal waters is due
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1970 National Safely Congress
to oil spills offshore. Many of these spills result from long standing practices which are nevertheless willful violations of laws which limit the discharge of oil within SO miles of the coast. Such spills can be re duced by a cooperative industry combined with more stringent surveillance procedures.
Subject to budgetary restrictions, we plan to procure, as rapidly as possible, additional airplanes for offshore surveillance missions. To avoid the limitations of visual detection. .nr research and development program is con centrating on development of airborne all weather sensors that can be used to detect spillage day or night. We hope to have these sensors operational and installed on surveil lance aircraft within the next several years. We envision that within a few years there will be continuous air surveillance from Portland, Maine, to Miami on the Atlantic Coast, Seattle to San Diego on the Pacific Coast, the Gulf Coast, and the Great Lakes.
Another Coast Guard sponsored bill which we are watching with interest is the bill that would require the use of bridge-to-bridge radiotelephones on all vessels navigating in U.S. waters. This bill passed the House on 16 December 1969 and is presently awaiting Senate action subsequent to recess.
We believe this legislation will he a sig nificant step toward the reduction of col lisions. Many of our records of significant collision disasters have spoken to this need. Some of the more noteworthy marine casu alties in which it was concluded that bridgeto-bridge radiotelephone communications might have prevented the collisions are the Stockhohn-Andrea Daria collision in 1956, which cost 50 lives; the Massackusetls-Alva Cafe collision in 1966, which cost 33 lives; the African Star-Midwest Cities collision in 19t8, which took 21 lives; and the Union Faiih-Warrent J. Doucet collision in 1969. which took 25 lives.
President Nixon further commented on the
importance to safe navigation of this legis
lation in his address to Congress and urged prompt enactment. As those of you from the
Great Lakes are well aware, bridge-to-bridge
radio has been used in your area since 1934.
The large ore carriers have demonstrated its
effectiveness by maintaining one of the safest
navigation records in the world. We hope
that very soon the harbors of the United
States will have a safety record equal to that of the Great Lakes through the pro visions of this bill.
Because of the significant trend toward vessels of much greater tonnage, and in the light of continued collision incidents, the maritime nations of the world have agreed that the International Rules of the Road must be updated. An international conference has been called in 1972 for this purpose.
The Coast Guard, in close consultation with the U.S. maritime community, has been working for two years to develop the U.S. position for that conference. A questionnaire based on the preliminary work we have done so far is now being circulated to U.S. mas ters and deck officers. The tabulated infor mation expected from this questionnaire will be used in firming up the U.S. position.
Although it is a little premature to proph esy what the final results of the international conference will be, the consensus is that there will be a strong push to modify the concept of "moderate speed" in fog to a term more relevant to present day ships. Much greater emphasis will be placed on the use of radar in all conditions of visi bility and recognition will be given to the fact that deep draft ships are restricted in maneuvering ability outside the channel in many international waterways.
I would be remiss if I did not mention the status of the unification of U.S. Rules of the Road. As you know, for ten years the Coast Guard has sought to update and combine the inland, Great Lakes, and western rivers into a single set closely associated with present international rules. Although we can expect some further changes in this package, due to present work to amend the interna tional rules, the Coast Guard is still very much interested in accomplishing more uni fication. We consider greater unification es sential to optimum marine safety on Ameri can waterways and are eager to reconcile
any parochial differences that arise. Although it may take another year or two, we feel
the unified rules can crime into force before
the new international rules.
Another Coast Guard project had its be
ginning on the Great Lakes. For many years,
vessels transiting the Great Lakes have used
recommended course lines with marked suc
cess. It is only recently, however, that added
52
Marine Section
sea lanes have been established at the en trances to our major coastal ports. During the past decade, over 50 sea lane systems have been established on the oceans of the world and have been approved by the. Inter national Maritime Consultative Organization. In U.S. waters we now have six traffic sep aration systems. We hope to see the next traffic separation system established for the approaches to Los Angeles/Long Beach
Harbor later this year.
In dosing, I would like to note that in all of these Coast Guard endeavors the prog ress that has been made was. possible only because of the close cooperation and assist ance of the members of this group in the
maritime community. The continual endeavor to improve marine
safety must always be a joint effort of the Federal government and private industry. It goes without saying that the National Safety Council epitomizes this relationship.
OFFICERS OF THE
MARINE SECTION
NATIONAL SAFETY COUNCIL 1970-71
General Chairman--John L. Horton, Asst. Manager, Marine Dept, The Cleveland Cliffs Iron Co., Cleveland Ohio
Vice General Chairman--Fred R. Smith. President & General Manager, Seattle Stevedore Co., Seattle, Wash.
Price General Chairman--Cavi. E. P. Walker, Manager, U. S. Fleet, Texaco. Inc., Port Arthur, Texas
Secretary John R. Blackest, Secretary, American Bureau of Shipping, New York,
Assistant Secretary--Hubert F.. Carr, Secretary and Counsel, Mn-ore-McCormack Lines,
Inc., New York, N.Y.
'
Advisory Committee--Caw. Arthur M. Knight (Past General Chairman), Vice Presi dent, Mystic Steamship Corps., Boston, Mass.; J. Andkeae (Retired), New York, N.Y.; David L. Buchanan, Supt., Personnel Services, Great Lakes Fleet, United States Steel Corp., Cleveland, Ohio; Caw. G. H. E. Buxton (Ret.), Brooklyn, N.Y.; Richard W,, Berry, Senior Vice Pres,, United Fruit Co., Boston. Mass.
Nominating Committee--(Division Chairman & Advisory Committee) Capt. Arthur M. Knight (Chairman), J. Andrbae, David L. Buchanan, Caw. G. H. E. Buxton, Bruno J. Atjgrnti. President, Marine Index Bureau, Inc., New York, N.Y.
Cameron Committees
Technical Publications Committee--Caw. M. J. Sullivan (Chairman), Asst. Vice Pres,, Marsh & McLennan, Inc., New York, N.Y.; Caw. Gordon F. Beal (Vice Chairman), Manager, Marine Operations, United Fruit Co,, Boston, Mass,
Program Committee--Robert E. Kkatzert (Chairman), Manager Vessel Personnel & Serv ice, Columbia Transportation Div., Oglebav Norton Co., Cleveland, Ohio; Sidney G. Vass (Vice Chairman), Safety Director, Marine Transport Lines, Inc., New York, N.Y.
Membership Committee--A. B. Randall, Jr. (Chairman). Safety Officer, Marine Dept, Humble Oil & Refining Co., Houston, Texas
Newsletter Editor-Comdr. John A. Packard, USCG. (Ret.), Director, Public Relations, Lake Carriers Assn., Cleveland, Ohio
Research Committee--Caw. S. Fraser Sammis (Chairman), Chief Surveyor, Technical National Cargo Bureau, Inc., New York, N.Y.
54
Visual Aids and Foster Committee--Hugh M. Stephens (Chairman), President, Ships' Operational Safety, Inc.. Port Washington, N.Y.; R. Snow (Vice Chairman), Safety Engineer, Sea-Land Service, Inc., Elizabeth, N. J.
Training Committee--Caw. George D. Barlow (Chairman), Director, Safety Bureau, New York Shipping Assn., Inc., New York, N.Y.; Caw. Robert H. Smith (Vice Chairman J, Head, Ship Safety Division, Hull & Cargo Surveyors. Inc.. New York, N.Y.
Off-the-Job-Safety Committee--Karl F. Eismeier (Chairman), Vice Pres., Johnson & Higgins, New York, N.Y.; Capt. R. J. Murray (Vice Chairman), Manager, Vessel Operations, Sea-Land Service. Inc., Elizabeth, N. J.
Associations--Carl E. McDowell (Chairman), Executive Vice President, American Insti tute of Marine Underwriters, New York, N.Y.; C. J. Bourke, Coast Directors, Accident Prevention Dept., Pacific Maritime Assn., San Francisco, Calif; Braxton B. Carr, Pres., The American Waterways Operators, Inc., Washington, D C ; E. M. Hood, Pres., Ship builders Council of America, Washington, D.C.; James J. Reynolds, President, Ameri can Institute of Merchant Shipping, Washington, D.C.; *A. L. Chopin, Chairman of the Board, New York Shipping Assn,, New York, N.Y.; V. Adm. Paul E. Trimble, USCG, (Ret), Pres, Lake. Carriers Assn,, Cleveland, Ohio
Special Activities Best Paper Awards Committee--Bruno J. Aucenti (Chairman), Pres., Marine Index
Bureau, Inc., New York, N.Y.; Rear Adm. William F. Rea, III, (Vice ChairmanPresentation), Chief, Office Merchant Marine Safety', USCG, Washington, D.C.
Public Relations Committee--Capt. Robert E. Hart, USN. (Ret.) (Chairman), Executive Vice President, Marine Index Bureau, Inc, New York, N.Y.; Meredith S. Bbel (Vice Chairman), Public Relations Director, American Institute of Merchant Shipping, Wash ington, D.C.
Historian--C. Bradford Mitchell, Maritime Consultant, Brooklyn, N.Y.
Safety of Life at Sea Committee--Amt. Chester R. Bender (Chairman), Commandant, USCG, Washington, D.C; Rear Adm. William F. Rea, III, Chief, Office Merchant Marine Safety, USCG, Washington, D.C.; Rear Adm. Roderick Y. Edwards, Chief, Office of Public & International Affairs, USCG, Washington, D.C; Rear Adm. Halert C. Shephearp. USCG (Ret.), Washington, D. C.
Ship Safety Achievement Awards--Caw. Jones F. Devlin, Jr. (Chairman), Maritime Consultant, New York. N.Y.; Caw. Thomas A. Kino (Vice Chairman), Eastern Re gion Director, U.S. Dept, of Commerce, Maritime Administration, New York, N.Y.
Special Representatives--Caw. Thomas A. King (Chairman), Eastern Region Director, U. S. Dept, of Commerce, Maritime Administration, New York, N.Y.; Henry A. Moran (Vice Chairman), Safety Director, Military Sealift Command, Washington, D.C.
Statistics and Contests Committee--Lars N. Pederson (Chairman), Safety Co-ordinator. Terminal Operations, United Fruit Co., New Orleans, La.
Government Representatives Committee--V. Adm. A. R. Gralla, US Navy Commander. Military Sealift Command, Washington, D.C.; Lt. Gen. F. J. Clarke, US Army, Chief of Engineers, Dept, of the Army, Washington, D.C.; Rear Apm Don A. Jones. USESSA, Director, Coast & Geodetic Survey, Rockville, Md_ 55
Dwisioits
Barge & Towing Vessel--Ralph A. Guffey (Chairman), Safety Director, A. L. Mechling Barge Lines, Inc., Joliet, 111.; Lee D. Tracy (Vice Chairman), Director of Loss Con trol, Ingram Corp., Mew Orleans, La.; Robert L. Gray (Membership), Manager, River Operations, Ashland Oil & Refining Co., Ashland, Ky.; McVey F. Ward (Program), Southern Regional Representative, The American Waterways Operators, Inc., New Orleans, La.
Great Lakes--John W. Manning (Chairman), Supt. of Operations, Steamship Div., The Hanna Mining Co., Cleveland, Ohio; Robert E. Kkatzeet (Vice Chairman), Manager, Vessel Personnel & Service, Columbia Transportation Div., Oglebay Norton Co., Cleveland, Ohio; F. Warren Seesaw (Membership), Supervisor Safety, Great Lakes Fleet, U.S. Steel Corp, Cleveland, Ohio; Matthew C O'Hearn (Program), Vice President, Wilcox, Peck & Hughes. Inc., Cleveland, Ohio
Passenger & Dry Cargo--Capt. R. N. LePage (Chairman), Mgr., Insurance, Farrell Lines. Inc., New York, N.Y.; Capt R. J. Anderson (Vice Chairman), Asst to Vice Pres., Operations, Prudential Lines, Inc., New York, N.Y.; Caft. C. H. Waring, USCG (Ret), (Membership), Accident Prevention Div., Lykes Bros. Steamship Co., Inc., New Orleans, La.; Capt. H. R. Rosenoren (Program), Technical Assistant, National Cargo Bureau, New York, N.Y.
Shipbuilding & Repair--Lloyd J. Piccxn (Chairman), Manager of Safety, Sun Shipbuild ing & Dry Dock Co., Chester, Pa.; James R. O'Donnell (Vice Chairman), Maritime Safety Consultant, New Orleans, La.; Lloyd A. Beers (Membership), Bath Iron Works Corp., Bath, Maine; Austin Srean (Program Co-Chairman), Director of Safety & Comp., Todd Shipyards Corp., New York, N.Y.; H. H. Howard (Program Co Chairman), Asst, to Vice President, Bethlehem Steel Corp., New York, N. Y.
Stevedoring--Theodore R. Alep (Chairman), Director of Safety, Nacirema Operating Co., Inc., New York, N.Y.5 Albert W. Cash (Vice Chairman), Safety Director, Interna tional Terminal Operating Co., New York, N.Y.; Edward McIntyre (Membership), Safety Director, Pittston Stevedoring Corp.. New York, NY. Samuel A, Clauss (Program), Safety Director, Steamship Trade Association of Bal timore, Inc.. Baltimore, Md.
Tankship--Phillip Neal (Chairman), Marine Safety Advisor, Mobil Oil Corp., New York, N.Y.; Donald G. Brown (Vice Chairman), Manager--U.S. Fleet, Gulf Oil Co., Trans portation, New York, N.Y.; Harold Harvey (Membership), Safety Director, Chevron Shipping Co., San Francisco, Calif.; Sidney G. Vass (Program), Safety Director, Marine Transport Lines, Inc., New York, N.Y.
Discussion Groups
Atlantic Area--Nicholas DiArcangel (Chairman), Acting District Supervisor, Work Place Standards Admin., U. S. Dept, of Labor, New York, N. Y.; Austin Shean (Vice Chairman), Director Safety & Comp., Todd Shipyards Corp., New York, N.Y.
Great Lakes Area--Ian Carswell (Chairman), Safety Director, Wilson Marine Transit Co., 2100 Illuminating Bldg., Cleveland, Ohio; Michael J. Murphy (Vice Chairman), Fleet Safety Director, Pickands Mather & Co., Cleveland, Ohio
Gulf Area (Cargo)--Capt. Ollie Davis (Chairman), Operations Manager, Gulf & South American Steamship Co., New Orleans, La.
56
Gulf Area (1 anker)---Open
Inland Waterways Area--H. S. Strassner (Chairman), Safety Director, National Mari time Services, Inc., Hartford, III; Charles H. Chapin (Vice Chairman), Marine Supt., Material Service Corp., Subsidiary of General Dynamics, Lockport, 111.
Pacific Area--Capt. Theodore W. Anderson (Chairman), President, Joshua Handy Corp., Los Angeles, Calif; Vern Newton (Vice Chairman), Asst. Coast Director, Pacific Maritime Assn,, San Francisco, Calif.
National Safety Council Staff Representative--Ralph M. Coe, Staff Representative, Na tional Safety Council, 425 N. Michigan Ave,, Chicago. 111. 60631
PLAN
NOW TO ATTEND
THE
1971 NATIONAL SAFETY CONGRESS OCTOBER 25-28, 1971 / CONRAD HILTON HOTEL, CHICAGO
1972 The Congress is always a big week, a worthwhile week for the 13,000 safety people who attend.
At the "71 Congress you can meet other safety peopie, with the same problems and responsibilities asyourself.
1973 You can exchange views and ideas on accident preven tion, health, hygiene, and fire prevention ... on safety in industry, traffic, school, at home and on the farhn.
You can see the largest of all safety equipment exhibits at the Congress... an opportunity for you to make well-
1974 informed buying decisions for vdur company. This four-day educational program, planned and pre sented by the National Safety Council, can be your most thought-provoking, most'worthwhile safety expe rience in 1971.
Make plans early to attend the 1971 Congress and bring the other people in your organization who have safetyresponsibilities. '
FUTURE CONGRESS DATES
1971 1972 1973 1974
October 25-28 Oct. 30 - Nov. 2 Oct. 29 - Nov 1 Sept. 30 - Oct. 3
NATIONAL SAFETY COUNCIL
425 NORTH MICHIGAN AVENUE . CHICAGO. ILLINOIS 60611
The attached photocopied material is an authentic reproduction o f an original file copy o f :
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