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Maritime Safety Strategy – Public Consultation Document

Sea Change – Building a New Maritime Safety Culture June 2014 1

Sea Change – Building a new Maritime Safety Culture

Maritime Safety Strategy Consultation Document

Contents Section 1. Why is a new Maritime Safety Strategy needed? (page 2) Section 2. What areas will the new Strategy cover? (page 3) Section 3. What factors contribute to maritime fatalities? (page 4) Section 4. What can be done to tackle the key causes of maritime fatalities? (page 11) Section 5. Next steps – how to have your say (page 22)

Irish Maritime Administration

Department of Transport, Tourism and Sport

June 2014.



Section 1. Why is a new Maritime Safety Strategy needed? 1. We are fortunate in Ireland to have an abundance of beautiful coastal and inland waters.

None of us lives very far from this wonderful resource, and we are familiar with its beauty, riches and potential. Even in the harshest weather, the sea can be enticing to look at. However, despite its attractions, it can be a very hostile and dangerous environment and consequently demands the utmost respect from its users. As a maritime nation, we need to take a fresh look at how we interact with the waters in and around our island in order to build a new culture of maritime safety in our communities and in society generally.

2. I want to bring a new impetus to improving the safety of all who use water-based craft in

Ireland – whether for work, leisure or transport purposes. We have to learn from past tragedies, both in memory of those who have lost their lives and to safeguard current and future generations. There is a lot of goodwill towards improving safety at sea. Now we need to harness that goodwill and build on it by focusing on the causes of fatalities and by identifying actions to address them.

3. When maritime casualties arise, the Marine Casualty Investigation Board (MCIB) investigates

what occurred and makes safety-related recommendations to me (as Minister), as appropriate. The MCIB reports make distressing reading because the majority of these maritime casualties seem to be avoidable. Most of the fatalities arise in the recreational and fishing sectors. It is all too clear that similar incidents keep occurring and that the same issues arise time and time again. We need a dramatic change in attitudes and practices in order to address this problem. While records show that fewer fatalities arise in the passenger and cargo sectors, we cannot be complacent in that regard as the potential consequences of a major incident could be severe. The MCIB has expressed its support for our renewed efforts as part of this initiative, which I welcome.

4. I believe that we should aim for zero fatalities in the maritime sector by reducing the risks

and therefore reducing the number of incidents. This will be the key goal of the new Maritime Safety Strategy, which will set out targets for improving the safety of recreational craft, fishing vessels, passenger vessels and cargo vessels. The core of the new Strategy will be the creation of a new culture of safety in the maritime sector. Although safety is a fundamental responsibility of the owner, master or skipper of a vessel, this Strategy means that anyone who takes to the water in any type of vessel or craft should take personal responsibility for thinking safety first and act accordingly.

5. This Consultation Document represents our renewed efforts to address safety awareness

and compliance by setting out some key issues and asking some questions to help to shape the new Maritime Safety Strategy. I invite you to engage with this consultation process and to send your views to the Irish Maritime Administration in my Department. As we strive to improve maritime safety together, my hope is that a wide range of responses will be received – and that positive and creative ideas will emerge which will enable us to take further practical actions to save lives in the maritime sector.

Leo Varadkar T.D.

Minister for Transport, Tourism and Sport June 2014.



Section 2. What areas will the new Strategy cover?

1. The Irish Maritime Administration (IMA) of the Department of Transport, Tourism and Sport

is preparing a new Maritime Safety Strategy with the overall aim of achieving zero fatalities and reducing the incidents occurring in the maritime sector. The Strategy will focus primarily on creating a culture of safety in the sector, encompassing all types of craft and vessels used for any purpose on Irish coastal or inland waterways, be it work, leisure or transportation.

2. The core objectives of the Strategy will be to ensure:

- Actions are targeted at the main causes of casualties in the maritime sector, as identified by Marine Casualty Investigation Board reports and Irish Coast Guard incident management experience;

- All who use fishing, passenger or cargo vessels In Ireland, or who take to the water in recreational craft, take personal responsibility for their own safety.

3. Of its nature, maritime safety is a wide-ranging issue, which impacts on a variety of government departments, agencies, bodies, fishers, seafarers, passengers, recreational users, representative groups, industries, volunteer responders and individuals. Efforts are continuing in a number of organisations to improve maritime safety. The IMA’s new Maritime Safety Strategy will not aim to re-state or duplicate these efforts, but will take account of them in pursuit of a common goal.

4. Therefore, it is proposed that the new Maritime Safety Strategy will focus on all of the

maritime transport activities within the remit of the Department of Transport, Tourism and Sport. It will include initiatives relating to recreational craft, fishing vessels, passenger vessels and cargo vessels.

5. As part of the preparation of the Strategy, we are undertaking a consultation process that is

designed to engage a wide range of interested parties. Following the consultation phase, the new Strategy will be drawn up, with a view to publication later this year. The implementation of the Strategy will be monitored, and it is intended that it should be reviewed and updated within a five year period.



Section 3. What factors contribute to maritime fatalities? 1. The main drivers for the new Strategy will be based on the information available about the

number of fatalities, accidents and incidents that occur in the various maritime sectors, and the reasons those events occurred. The chief sources of that information are Marine Casualty Investigation Board (MCIB) reports and recommendations, and Irish Coast Guard (IRCG) incident reports. Although unforeseen events can be a factor in any tragic incident, the aim will be to try to minimise such events and to focus on the key causes of maritime fatalities, insofar as they are identified. No two tragic incidents are identical as there may be multiple causes and interconnected factors, but the new Strategy will re-focus our efforts on the recurring themes. As the Strategy evolves, and as it is reviewed periodically, there will be opportunities to target different areas. This new Strategy will be an important starting point for our renewed efforts to improve maritime safety.

2. The number of maritime fatalities in Ireland, at an average of 12 per year, might appear at

face value to be low. While it is difficult to make cross-jurisdictional comparisons due to the differences in how statistics are collated, it would appear that Ireland’s overall maritime safety record compares favourably on an international basis. However, the impact of individual incidents can be high, and where fatalities arise, these are often multiple. Each life lost is devastating for families and communities, and a major cause for concern is the extent to which fatalities might be avoidable. It is important therefore that all of us aim for a target of zero fatalities in relation to recreational craft, fishing vessels, passenger vessels and cargo vessels. Lowering the risk of fatalities occurring is key and, through focusing on preventative measures, the aim is to reduce the level of maritime-related accidents and incidents. The IMA’s work1 is focused on addressing maritime safety in those areas which are within the remit of the Department of Transport, Tourism and Sport2 and it is a testament to this work that the number of deaths is low.

3. The key objective of the Irish Coast Guard (IRCG) is the reduction in the loss of life on

Ireland’s seas and rivers, coastal and remote areas, lakes and waterways. To deliver this, the IRCG has in place best-practice rescue regimes to minimise deaths and incidents in the sector. It also ensures that, where incidents do occur, there is a high level of emergency preparedness and response to rescues and to saving lives. The IRCG manages an excellent marine emergency response service. It saves the lives of many people who were in imminent danger and who would have died but for its intervention.

1 The Irish Maritime Administration is comprised of the following divisions within the Department of Transport, Tourism

and Sport: Maritime Safety and Policy Division; Maritime Transport Division; Maritime Services Division; the Irish Coast Guard; and the Marine Survey Office. Further details are available at www.dttas.ie 2 Note that persons such as swimmers and those engaged in shoreline activities (e.g., angling, sea-cliff climbing) are outside

the scope of the new Strategy; they are covered by other safety initiatives. Further information is available at www.safetyonthewater.ie



4. During the period 2003-2013, the IRCG saved almost 2,000 lives through Search and Rescue

operations, with an average of 178 lives being saved annually3. Figure 1 sets out maritime safety investment in this period. In the past five years (2009-2013), an average annual investment of over €48 million has been made in IRCG activities, and in 2014 over €71 million will be invested4. The number of recreational craft and maritime transport-related distress/urgency callouts to the IRCG increased from 850 in 2003 to 954 in 2013. This increase of over 12% in callouts can be attributed to greater leisure activity on our waters (particularly in relation to the use of recreational craft), increased activity on inland waters, good summer weather in recent years, and a resultant increase in reports being made by members of the public.

Figure 1: Maritime safety investment 2003-2014

Source: IMA data 2003-2014

5. The Marine Survey Office’s (MSO) work is largely focused on preventing casualties and

incidents on maritime vessels. The MSO fulfils the role of the maritime transport safety regulator and carries out a comprehensive regime of inspections, covering issues such as safety, security, living and working conditions and accessibility. MSO activities cover recreational craft, fishing vessels, passenger vessels and cargo vessels on the Irish flag (whether operating internationally or domestically); certification of Irish seafarers including fishers and recreational craft users; and security in Irish ports. It also carries out risk-based inspections on foreign-flagged ships calling to Irish ports, using the methodology of the Paris Memorandum of Understanding (PMoU) on Port State Control. The MSO carries out an average of 1,300 inspections every year.

3 The number of lives saved were those lives saved in the context of incidents coordinated by the IRCG; the IRCG routinely

tasks a range of Search and Rescue Organisations and declared resources when handling incidents. 4 Over €62 million of the 2014 investment figure relates to the helicopter contract. Although best known for its marine

rescue activities, the helicopter contract also provides the Helicopter Medical Emergency Service (e.g., patient transport to hospitals, scene of accident medevac, paediatric transfer and organ transportation) in conjunction with the Health Service Executive and the Air Corps, the scope of which is outside of this report. The investment covers activities such as the training and equipping of volunteers involved in search and rescue, the design and construction of new IRCG volunteer stations and the installation and maintenance of a national integrated telecommunications network. Pay and administration are excluded. The increase in investment between 2012 and 2013 relates to a significant upgrade of the helicopter fleet and enhancement of search and rescue capability.



6. Following a maritime incident, the Marine Casualty Investigation Board (MCIB) makes a

decision on whether or not to investigate. The MCIB is an independent body established under the Merchant Shipping (Investigation of Marine Casualties) Act 2000. Its role is to investigate marine casualties that take place in Irish waters and/or marine casualties that involve Irish-registered vessels. The types of incidents investigated by the MCIB include the death of, or serious injury to, a person; the loss of a person overboard; and significant loss of, or damage to, or collision with, a vessel or property. On completion of each investigation, the MCIB makes recommendations, as appropriate, to the Minister for Transport, Tourism and Sport,. The IMA then takes any necessary actions on foot of those recommendations.

7. In the 11-year period from 2002 to 2012, a total of 134 fatalities occurred in incidents

involving recreational craft, fishing vessels, passenger vessels and cargo vessels. Details are set out in Figures 2 and 3. The vessel categories most at risk in relation to fatalities are recreational craft and fishing vessels, followed by passenger vessels and cargo vessels.

Figure 2: Fatalities in the Maritime Sector 2002-2012 (inclusive)

Recreational craft – 66 fatalities • 43 due to vessel capsizing, resulting in drowning/hypothermia • 1 due to collision with another vessel, resulting in drowning • 2 due to engine cutting out and persons on board attempting to swim to safety, resulting in

drowning • 20 due to persons falling overboard/drowning

Fishing vessels – 51 fatalities • 39 due to vessel running aground, sinking or capsizing, resulting in drowning/hypothermia • 4 due to accidents on board • 8 due to crew members falling overboard/drowning

Passenger vessels – 11 fatalities • 5 due to vessel running aground, sinking or capsizing, resulting in drowning/hypothermia

3 due to accidents on board

3 due to passengers falling overboard/drowning

Cargo vessels – 6 fatalities • 4 due to accidents on board • 2 due to crew members falling overboard/drowning

Total number of fatalities: 134 Source: Based on MCIB reports 2002-2012 and IRCG annual statistics combined



Figure 3: Percentages of Maritime Fatalities arising by Vessel Type

Source: Based on MCIB reports 2002-2012 and IRCG annual statistics combined

8. It is of interest to consider the age profile of maritime fatalities, as this may assist in identifying measures to improve safety in the sector. Figure 4 sets out some data relating to the age profile of maritime fatalities, based on MCIB reports from 2002-2012. Of the total number of fatalities in the period, the youngest was aged 14 and died in an incident involving a passenger vessel. The youngest fatality in the recreational craft sector was aged 15. The youngest fatalities in the cargo and fishing sectors were aged 20 and 21 respectively. The oldest fatality overall was aged 73, in an incident involving a passenger vessel. The average age of all maritime fatalities in the period was 42. Overall, the majority of fatalities (132 or 99%) were male, with only two female fatalities (both of which occurred in the recreational craft sector).

Figure 4: Age Profile of Maritime Fatalities by Vessel Type 2002-2012

Recreational Fishing Passenger Cargo

Youngest age male 15 21 14 20

Oldest age male 71 70 73 55

Average age male 44 43 40 39

Youngest age female 21 0 0 0

Oldest age female 61 0 0 0

Average age female 41 0 0 0 Source: Based on MCIB reports 2002-2012

Passenger vessels

8% Cargo vessels 5%

Fishing vessels 38%

Recreational craft 49%



9. In the 11-year period from 2003 to 2013, the IRCG handled a total of 9,716 distress/urgency

calls involving fishing vessels, recreational craft and merchant vessels – which is an average of 883 such incidents per year. Figure 5 sets out the callouts by vessel type, and Figure 6 shows the yearly trends. The data shows that a significant majority of IRCG callouts are to assist recreational craft, with a total of 6,420 incidents in the period – which is an average of 584 such incidents per year. The underlying trend shows that the number of incidents involving recreational craft has been increasing. There are also significant numbers of incidents involving fishing vessels, with a total of 2,606 incidents in the period – which is an average of 237 incidents per year. Incidents involving fishing vessels have declined since 2003, although that decline has levelled off in recent years. The number of incidents involving merchant vessels (which comprise cargo vessels and passenger vessels) has remained fairly constant, with a total of 690 incidents in the period – which is an average of 63 incidents per year. Figure 5: IRCG Distress/Urgency Calls by Vessel Type 2003-2013

Source: IRCG statistics 2003-2013 Note: Both passenger and cargo vessels are included under the merchant vessels category.

Merchant vessels

7%

Fishing vessels 27%

Recreational craft 66%



Figure 6: IRCG Distress/Urgency Calls by Vessel Type 2003-2013

Source: IRCG statistics 2003-2013

Note: Both passenger and cargo vessels are included under the merchant vessels category.

10. The MCIB reports highlight that there are similarities in the incidents which contribute

toward the loss of life in the maritime sector. MCIB reports do not provide specific statistics in relation to the recurring factors5. However, based on an analysis of the MCIB reports on fatalities arising since 2002 combined with information from IRCG incident reports in a number of instances6, the IMA has identified 10 factors which appear to arise most frequently, as set out in Figure 7. Taking the maritime sector as a whole, they are ranked according to their prevalence. For example, ‘Unsuitable or inadequately maintained safety equipment on board, or lack thereof’ was the factor cited most often in the MCIB reports and recommendations as contributing to an incident where there was at least one fatality. Contributory factors by sector are considered in Section 4 of this document. The prevalence of these factors is borne out by the practical experience of the IRCG in its management of emergency response in the maritime sector. Each of the factors listed is important and it is noteworthy that there are often multiple factors identified in relation to each tragic incident. A common underlying factor, revealed by examining the MCIB reports over the years, is the lack of an adequate culture of safety in the maritime sector. This factor is therefore listed first. It must be emphasised that this list is not exhaustive and work is continuing in the IMA on all maritime safety issues. However, highlighting these factors will allow us to focus on recurring issues and to make renewed efforts in these areas, with the aim of building a better maritime safety culture in our society.

5 MCIB Annual Reports include statistics on the types of craft/vessels involved in maritime casualties.

6 IRCG incident reports were considered in relation to fatalities involving divers, sailboarders and surfers, as incidents

involving these fatalities were not investigated by the MCIB.



Figure 7:

Top Ten Factors Contributing to Loss of Life at Sea in Ireland (all maritime craft and vessels)

Lack of an adequate maritime safety culture

Unsuitable or inadequately maintained safety equipment on board, or lack thereof

Lack of crew training

Failure to plan journeys safely, including failure to take sea/weather conditions into account

Non-wearing of personal flotation device (lifejacket)

Vessel unseaworthy, unstable and/or overloaded

Inadequate enforcement of regulations

Impairment due to fatigue or the influence of alcohol and/or drugs

Inadequate crewing levels/solo operation

Unsuitable clothing being worn on board


11. Given that the largest number of casualties and incidents arises in the recreational and

fishing sectors, it would seem logical to target these high-risk sectors in particular. Although fewer fatalities arise in the passenger and cargo sectors, there is no room for complacency in those low-risk sectors as the potential consequences of a major incident could be severe. The MCIB reports highlight that the safety message is not getting through and that more enforcement is needed. Although enforcement can be improved and additional deterrents can be put in place, these actions alone will not be enough. A dramatic change in attitudes and practices across the maritime sector is needed in order to improve maritime safety.



Section 4. What can be done to tackle the key causes of maritime fatalities?

1. Over many years, and particularly in response to the recommendations made by the MCIB, the maritime safety authorities (in their various incarnations in a number of government departments; currently the Irish Maritime Administration of the Department of Transport, Tourism and Sport) have made significant efforts to address the recurring issues relating to the causes of maritime fatalities. In addition, improvements have been made in terms of increased regulation (driven by EU and international standards) and more rigorous inspections. The actions taken by the IMA are complemented by activities undertaken by a range of government departments, agencies, bodies, representative groups, industries, volunteers and individuals.

2. This section outlines, sector by sector, the main factors contributing to fatalities in relation

to recreational craft, fishing vessels, passenger vessels and cargo vessels7. Although the focus is on fatalities, it should be noted that the factors contributing to incidents where there has been no loss of life are similar. Therefore, tackling the factors highlighted can reduce both fatalities and incidents overall. Four questions are posed in relation to each sector, and your views are sought in relation to the issues raised. You may choose to answer all or just some of the questions.

Recreational craft 3. The recreational craft sector accounts for almost half (49%) of all maritime fatalities and the

majority (66%) of all IRCG callouts in the sectors concerned. The sector includes sailing craft, motorboats, ski boats, craft with outboard engines, personal watercraft (jet skis), canoes, kayaks and non-powered craft. The regulation of recreational craft in Ireland is focused on the safe operation of craft, the provision of certain items of safety equipment, the carriage and use of personal flotation devices (lifejackets), and the manufacture and sale of safe recreational craft under the EU Recreational Craft Directive. The IMA’s Code of Practice for the Safe Operation of Recreational Craft (available at www.dttas.ie) provides information on the legislative requirements and gives safety advice on best practice for operators and owners of recreational craft.

4. There were 66 fatalities in the recreational sector in the period 2002-2012. Of these fatalities: 25 involved an open boat, 14 fatalities involved a powered pleasure craft, nine fatalities involved a dive boat, eight fatalities involved a canoe or kayak, five fatalities involved yachts or sail craft, three fatalities involved personal watercraft (jet skis), and two fatalities involved a sailboard/surfer. Figure 8 shows the percentages of the types of craft involved.

7 Where IMA activities in relation to maritime safety are outlined, it should be noted that those listed are not exhaustive.

For more detailed information on the IMA’s wide range of maritime safety activities, visit the maritime section of the Department of Transport, Tourism and Sport’s website at www.dttas.ie. Marine Notices, which are issued by the IMA to communicate with the maritime sector on issues that include important safety updates, are also available on this website.

http://www.dttas.ie/



Figure 8: Recreational Craft Fatalities by Vessel Type


5. The IRCG received 6,420 distress/urgency calls involving the recreational craft sector in the

period 2003-2013, which is an average of 521 per year. Of these calls: 2,399 involved yachts or sail craft, 2,244 involved powered pleasure craft, 351 involved angling boats, 316 involved a canoe or kayak, 261 involved sailboarders/kite surfers, 226 involved dive boats, 222 involved personal watercraft (jet skis), 202 involved surfers, and 199 involved row boats. Figure 9 shows the percentages of the types of craft involved.

Figure 9: Recreational Craft Distress/Urgency Calls by Vessel Type

Source: IRCG annual statistics 2003-2013

Open boat 38%

Powered pleasure craft

21%

Canoe/Kayak 12%

Yacht/Sail craft 8%

Jet ski 4%

Sailboard/Surfer 3%

Dive boat 14%

Yacht/Sail craft 37%

Powered pleasure craft

35%

Angling boat 6%

Canoe/Kayak 5%

Sailboarder / Kite surfer

4%

Dive boat 4%

Jet ski 3%

Surfer 3%

Row boat 3%



6. Based on an analysis of the MCIB reports and recommendations, combined with information

from IRCG incident reports in a number of instances8, the most common factor contributing to loss of life in the recreational sector is the failure to plan journeys safely. This is followed by other significant factors, such as non-wearing of a personal flotation device (lifejacket), lack of crew training, and deficiencies in safety equipment on board. The need for an embedded maritime safety culture in the sector is a key underlying issue. A ranking of the prevelance of the factors is set out in Figure 10.

Figure 10: Recreational Craft – Prevalance of Recurring Factors Contributing to Loss of Life

R1 Failure to plan journeys safely, including failure to take sea/weather conditions into account

R2 Non-wearing of personal flotation device (lifejacket)

R3 Lack of crew training

R4 Unsuitable or inadequately maintained safety equipment on board, or lack thereof

R5 Inadequate crewing levels/solo operation

R6 Vessel unseaworthy, unstable and/or overloaded

R7 Impairment due to fatigue or the influence of alcohol and/or drugs

R8 Inadequate enforcement of regulations

R9 Unsuitable clothing being worn on board


7. To assist the IMA with developing the new Maritime Safety Strategy, please answer the

following questions, and provide any relevant additional information and/or comments, should you wish to do so. Contact details are provided in Section 5 of this Document – ‘How to have your say’.

Q.1 Referring to Figure 10 above, what can be done to tackle each of the key causes of fatalities in the recreational craft sector?

Q.2 How can a safety culture be embedded in the recreational craft sector?

Q.3 Do you have any other suggestions to improve safety in the recreational craft sector?

Q.4 What are you/your organisation doing or planning to do to improve safety in the recreational craft sector?

8 IRCG incident reports were considered in relation to fatalities involving divers, sailboarders and surfers, as incidents

involving these fatalities were not investigated by the MCIB.



Fishing vessels

8. The fishing vessel sector accounts for a significant proportion (38%) of all maritime fatalities

and over a quarter (27%) of all IRCG callouts in the sectors9 concerned. The Irish fishing fleet consists of over 2,200 vessels. It is divided into three length categories, i.e. fishing vessels less than 15m in length (90% of the fleet), fishing vessels between 15-24m in length (5% of the fleet) and fishing vessels greater than 24m in length (5% of the fleet). Ireland’s regulatory regime reflects best international practice and follows international and EU regulations. Regulation covers vessel construction, equipment and operation, as well as training, manning and hours of work and rest.

9. The publication by the IMA of the Revised Safety Code of Practice for Small Fishing Vessels

(less than 15 metres in length) in March 2014 requires all small fishing vessels to carry automatic, float-free EPIRBs10 and requires everyone on board such vessels to wear Personal Locator Beacons (PLBs). The revised Code also includes details on existing requirements for the regular carrying out of musters and drills to ensure that skippers and crews are familiar with safety procedures should an incident occur.

10. There were 51 fatalities in the fishing vessel sector in the period from 2002-2012. A total of

19 of the fatalities involved fishing vessels less than 15m in length, 24 fatalities involved fishing vessels between 15-24m in length, and eight fatalities involved fishing vessels greater than 24m in length. The IRCG handled 2,606 callouts involving fishing vessels in the period 2003-2013 – which is an average of 237 per year11. Figure 11 shows the percentages of the types of craft involved.

Figure 11: Fishing Vessel Fatalities by Vessel Type

Source: Based on MCIB reports 2002-2012

9 Sectors concerned: recreational, fishing, passenger and cargo

10 EPIRB: Emergency Position Indicating Radio Beacon.

11 The IRCG does not categorise statistics according to the type of fishing vessel.

Fishing vessels < 15 metres

37% Fishing vessels 15-24 metres

47%

Fishing vessels > 24

metres 16%



11. Fishing vessel safety, particularly in relation to small/medium fishing vessels, is of particular

concern, as it accounts for a high proportion of the fatalities at sea and often results in more than one fatality in a single incident. These incidents occur despite adequate regulation and a regular and comprehensive inspection regime. Since 2010, it is noteworthy that there have been six fatalities in the 15-24m category and nine in the less than 15m category.

12. Based on an analysis of the MCIB reports and recommendations, a range of key factors

contributing to loss of life in the fishing sector has been identified. The most prevalent factor is a lack of crew training, followed by deficiencies in safety equipment on board, unseaworthy/unstable/overloaded vessel, inadequate enforcement of regulations and failure to plan journeys safely. The need for an embedded maritime safety culture in the sector is a key underlying issue. A ranking of the prevalence of the factors is set out in Figure 12. Figure 12: Fishing Vessels – Prevalence of Recurring Factors Contributing to Loss of Life

F1 Lack of crew training

F2 Unsuitable or inadequately maintained safety equipment on board, or lack thereof12

F3 Vessel unseaworthy, unstable and/or overloaded

F4 Inadequate enforcement of regulations

F5 Failure to plan journeys safely, including failure to take sea/weather conditions into account

F6 Non-wearing of personal flotation device (lifejacket)

F7 Impairment due to fatigue or the influence of alcohol and/or drugs

F8 Unsuitable clothing being worn on board

F9 Inadequate crewing levels/solo operation


12

The first two factors listed occur equally.



13. To assist the IMA with developing the new Maritime Safety Strategy, please answer the following questions, and provide any relevant additional information and/or comments should you wish to do so. Contact details are provided in Section 5 of this Document – ‘How to have your say’.

Q.5 Referring to Figure 12 above, what can be done to tackle each of the key causes of fatalities in the fishing vessel sector?

Q.6 How can a safety culture be embedded in the fishing vessel sector?

Q.7 Do you have any other suggestions to improve safety in the fishing vessel sector?

Q.8 What are you/your organisation doing or planning to do to improve safety in the fishing vessel sector?

Passenger vessels

14. There have been very few fatalities on board passenger vessels in Ireland. However, given

the significant loss of life that could occur if there was a major incident, it is important that these historically low numbers do not lead to complacency. Passenger vessels are sub-divided into three categories, as set out below.

15. A passenger ship is any vessel which carries more than 12 passengers, either paying or not paying. Passenger ships are classified as International or Domestic.

16. International passenger ships consist of cruise liners and the passenger roll-on/roll-off ferries

which operate between Ireland and the UK/France. There are no international passenger ships currently on the Irish ship register and the ships operating in Irish waters are regulated by their flag state. Between 2002 and 2012, there were two fatalities on international passenger ships in Ireland. One fatality was as a result of an accident on board and the other was as a result of a person falling overboard.

17. The number of cruise liners calling to Irish ports has increased by 200% in the past decade,

and this trend is expected to continue. Almost 90 cruise liners are expected to visit Dublin between May and December 2014 alone, and approximately 50 cruise liners are due to visit Cork between May and October 2014. As this sector grows, it is important to be aware of the safety measures required, including in relation to these ships’ increasing size.



18. The safety regulations governing international passenger ships have been improved over the

years, but there are still some significant issues outstanding internationally, as highlighted by recent tragedies abroad. Some of these issues relate to the changes in the stability standards applied to such ships, and work is underway at EU and international level to improve stability standards for roll-on/roll-off ships. As international passenger ships are primarily regulated by their flag state, Ireland continues to work with the EU and the International Maritime Organisation (IMO) to improve the safety of international passenger ships.

19. Domestic passenger ships are passenger ships which do not go on voyages to ports outside

the State. The regulatory environment for domestic passenger ships is comprised of both EU legislation and domestic legislation and it is applied according to the size, construction and type of journeys undertaken. There are approximately 80 domestic Irish-flagged passenger ships. These include ferries to offshore islands and many tourist vessels operating throughout the State. In the last 10 years, there have been nine fatalities on board or in relation to, Irish domestic passenger ships. Two fatalities were as a result of persons falling overboard; two fatalities occurred as a result of accidents on board vessels; and five fatalities occurred as a result of a vessel running aground, sinking or capsizing, and resulting in drowning/hypothermia.

20. Ireland continues to work within the framework of the EU to improve the regulatory regime

for domestic passenger ships. This requires regular and significant analysis and research, along with a significant updating of legislation.

21. Passenger boats are defined as vessels carrying 12 or fewer passengers for hire or reward or

for taking people to or from their place of work. They must be built and operated in accordance with the requirements of the Merchant Shipping Act 1992. There are approximately 800 passenger boats in Ireland, ranging from small ferries to sea-thrill boats and workboats.These are Irish vessels and are regulated in Ireland. The safety record in this category has improved since the Merchant Shipping (Passenger Boat) Regulations were introduced in June 2002. These regulations require passenger boats to comply with the safety requirements applicable to their class of vessel.

22. There were 11 fatalities in the passenger vessel sector in the period 2002-2012. Nine of the

fatalities involved domestic passenger ships and two fatalities involved foreign-flagged international passenger roll-on/roll-off ferries. IRCG statistics do not differentiate between passenger and cargo vessels; they are listed in combination as merchant vessels. In the period 2003-2013, there were a total of 690 distress/urgency calls received by the IRCG involving merchant vessels – which is an average of 63 per year. Figure 13 shows the types of craft involved.



Figure 13: Passenger Vessel Fatalities by Vessel Type


23. It is less meaningful to extract the main causes of fatalities from the low numbers that occur

in the passenger vessel sector than in sectors where the numbers are higher. The IRCG experience suggests that the causes for the incidents appear to be similar. However, an analysis of the MCIB reports and recommendations shows that in relation to the fatalities that occurred, there were a number of key factors contributing to loss of life in the passenger vessel sector. The most prevalent factor was deficiencies in safety equipment on board, followed by inadequate enforcement of regulations and unseaworthy/unstable/overloaded vessels. The need for an enhanced maritime safety culture in the sector is also an underlying issue. A ranking of the prevalence of the factors is set out in Figure 14. Figure 14: Passenger Vessels – Prevalence of Recurring Factors Contributing to Loss of Life

P1 Unsuitable or inadequately maintained safety equipment on board, or lack thereof

P2 Inadequate enforcement of regulations

P3 Vessel unseaworthy, unstable and/or overloaded

P4 Impairment due to fatigue or the influence of alcohol and/or drugs

P5 Lack of crew training


Domestic 82%

International 18%



24. To assist the IMA with developing the new Maritime Safety Strategy, please answer the

following questions, and provide any relevant additional information and/or comments should you wish to do so. Contact details are provided in Section 5 of this Document – ‘How to have your say’.

Q.9 Referring to Figure 14 above, what can be done to tackle each of the key causes of fatalities in the passenger vessel sector?

Q.10 How can safety culture in the passenger vessel sector be enhanced?

Q.11 Do you have any other suggestions to improve safety in the passenger vessel sector?

Q.12 What are you/your organisation doing or planning to do to improve safety in the passenger vessel sector?

Cargo vessels

25. There have been very few fatalities on board cargo vessels regulated by Ireland. A cargo ship

is defined as a commercially operating ship, other than a fishing vessel which is not a passenger ship. The types of cargo vessels can be sub-divided into three categories as set out below.

26. The Irish flagged fleet of internationally trading cargo ships greater than 500 GT consists of 32 general cargo ships mainly trading in north-west Europe. The fleet is very new, with a low average age. The average size of the ships is relatively small (5,220 GT)but there have been some recent additions of larger vessels to the fleet. The fleet also consists of a number of other ships, such as research vessels and lighthouse tenders.

27. Over 90% of mercantile trade in Ireland is carried by cargo ships. This includes oil, cars, durable goods and consumer goods, amongst others. The vast majority of cargo ships calling to Irish ports are not registered in the State. Such ships are regulated by their flag state and they are also subject to Port State Control inspections by Ireland in accordance with international requirements. Deficiencies are noted and ships which pose a safety concern are detained. In 2012, Ireland inspected 285 ships under the Port State Control regime, 187 of which had deficiencies, and 21 ships were detained. Ireland works within the framework of the EU, the PMoU and the IMO in seeking to enhance the safety of internationally-trading cargo ships.

28. There is a fleet of 43 Irish-flagged internationally trading cargo ships greater than 100 GT but less than 500 GT. This fleet is increasingly travelling abroad, seeking contracts on offshore renewable energy projects. This exposes the ships to a wider source of risks. At present, the regulatory framework in place for such ships is limited. However, as the ships seek to trade internationally, the regulatory framework needs development due to the increased level of risk.



29. There is a fleet in Ireland of domestically operating cargo ships. These ships are generally

less than 500 GT and are involved in a very diverse range of activities, including cargo transportation, workboats and tugs. There are significant differences between the ships in this sector. At present, Ireland does not have an adequate regulatory framework for the regulation of domestic cargo ships. Currently, there are no design and construction regulations for cargo ships less than 500 GT operating domestically.

30. There were six fatalities in the cargo vessel sector during the period 2002-2012, all of which occurred on internationally trading cargo ships greater than 500 GT. One of the fatalities occurred on board an Irish-registered vessel outside of Irish waters; the rest occurred on foreign flagged ships in Irish waters. Two of the fatalities involved tankers, two fatalities involved general cargo ships, one fatality involved a container ship, and one involved a roll-on/roll-off cargo ship. IRCG statistics do not differentiate between passenger and cargo vessels; they are listed in combination as merchant vessels. In the period 2003-2013, there were a total of 690 distress/urgency calls received by the IRCG involving merchant vessels – which is an average of 63 per year. Figure 15 shows the types of craft involved. Figure 15: Cargo Vessel Fatalities by Vessel Type


31. It is less meaningful to extract the main causes of fatalities from the low number that occur

in the cargo vessel sector than in sectors where the numbers are higher. The IRCG experience suggests that the causes for the incidents appear to be similar. However, an analysis of the MCIB reports and recommendations shows that in relation to the fatalities that occurred, there were a number of contributing factors of almost equal significance. These are: deficiencies in safety equipment on board, unseaworthy/unstable/overloaded vessels, inadequate enforcement of regulations, and lack of crew training. The need for an enhanced maritime safety culture in the sector is also an underlying issue. A ranking of the prevalence of the factors is set out in Figure 16.

Tanker 33%

General cargo 33%

Container ship 17%

Ro-Ro cargo 17%



Figure 16: Cargo Vessels – Prevalence of Recurring Factors Contributing to Loss of Life

C1 Unsuitable or inadequately maintained safety equipment on board, or lack thereof

C2 Vessel unseaworthy, unstable and/or overloaded

C3 Inadequate enforcement of regulations

C4 Lack of crew training

C5 Impairment due to fatigue or the influence of alcohol and/or drugs

C6 Unsuitable clothing being worn on board


32. To assist the IMA with developing the new Maritime Safety Strategy, please answer the following questions, and provide any relevant additional information and/or comments should you wish to do so. Contact details are provided in Section 5 of this Document – ‘How to have your say’.

Q.13 Referring to Figure 16 above, what can be done to tackle each of the key causes of fatalities in the cargo vessel sector?

Q.14 How can safety culture in the cargo vessel sector be enhanced?

Q.15 Do you have any other suggestions to improve safety in the cargo vessel sector?

Q.16 What are you/your organisation doing or planning to do to improve safety in the cargo vessel sector?



Section 5. Next steps – how to have your say

1. The material presented in this consultation document is a starting point in a new drive to improve maritime safety. Therefore, you are invited to respond to the issues raised and to submit any ideas you may have on the subject. If you wish to respond, please do so in writing (preferably by email) to:

Email address: [email protected]

Postal address: Maritime Safety Strategy Consultation Maritime Services Division Irish Maritime Administration (IMA) Department of Transport, Tourism and Sport Leeson Lane Dublin 2.

Responses may be submitted in writing to the IMA at any time during the consultation period, which ends on Friday, 29 August, 2014. Please note that submissions received will not be responded to on an individual basis, but they will be taken into consideration by the IMA in the preparation of the new Maritime Safety Strategy. Copies of all submissions will be published in full on the website of the Department of Transport, Tourism and Sport. It would be of assistance if you would number the questions to which you are replying, where relevant. Questions are set out on pages 13, 16, 19 and 21 of this document.

2. Important note regarding Freedom of Information

The Department of Transport, Tourism and Sport is subject to Freedom of Information legislation. If you wish that any of the information supplied by you in any submission should not be disclosed because of its sensitivity, you should, when providing the information, clearly identify this and specify the reasons for its sensitivity. The Department will consult with you about this sensitive information before making a decision on any Freedom of Information request received.

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