Marine Link
Tuesday, January 16, 2018

Hudspeth on Passenger Vessel Compliance

Maritime Activity Reports, Inc.

January 24, 2011

Flush mounted watertight hatches and deck drains promote accessibility and can be submitted to the Coast Guard as an alternative to six-inch door coamings. (Image courtesy All American Marine)

Flush mounted watertight hatches and deck drains promote accessibility and can be submitted to the Coast Guard as an alternative to six-inch door coamings. (Image courtesy All American Marine)

By Joe Hudspeth, from the January 2011 edition of MarineNews

One thing we can look forward to in the new year and beyond is the implementation and development of more regulations. Through a series of unfortunate events, the marine industry seems to have become a prime target for scrutiny, which may or may not be warranted. The onus of compliance established its momentum with the potential threat of terrorists on the waterways; thus, we received the requirement for T.W.I.C. cards that somehow create a shield of security. In addition to new security measures, we have lately seen stronger environmental regulations for emissions and vessel discharge. New regulations have just become effective covering operational procedures for accessibility. In 2011, you can expect some call for new safety regulations due to the tragic accidents of the Deepwater Horizon explosion in the Gulf and the collision involving a duck boat and barge on the Delaware River.

Boat builders closely monitor which policies and procedures are suggested and enacted, as it affects how operators use their craft and in many ways how each vessel is built and designed. With the sting of the recent drilling moratorium still being felt and the reality of a slowly recovering economy still present, how feasible will it be for operators to comply with more policies? Compliance always comes with a cost. Some regulations do outline a grandfathering clause, which may allow for certain exemptions, but then the intent of the rule loses impact. Operators will have to ask themselves if they can afford to just get by via grandfathering or if their operations will need to exemplify full compliance.

Requirements for Tier 3 diesel engines will be rolling out starting in 2012. One can expect both a rush to snatch up the remaining inventory of Tier 2 engines as well as a delay in the commencement of re-powering and new construction projects until the newly certified engines are in stock. Some state and federal agencies have programs in place that offer grants and incentives to motivate operators to move beyond the complacency of grandfathering and bring each vessel up to compliance. Engine suppliers are familiar with the available programs and can even offer assistance with the application process. Certain suppliers are offering EPA certified remanufacture kits that can be retrofitted to bring older, grandfathered engines into compliance. 

With this issue’s market focus on passenger vessels, it would be remiss not to mention the current accessibility regulations that just came into effect on January 3, 2011. 49 CFR Part 39, Transportation for Individuals with Disabilities: Passenger Vessels, addresses the policies and practices of passenger vessels and ensures nondiscrimination on the basis of disability. This rule only focuses on policy; standards on physical accessibility requirements are still to come.

Proactive operators who choose to make their boats more accessible may experience conflict with prevailing USCG regulations. Many inspected passenger vessels must have six-inch coamings at each door in order to prevent the possibility of down-flooding. In this scenario, in order to comply with Access Board standards a 72-inch ramp would be required on both sides of the coaming with a landing area in between. The landing and ramp may also need to be protected by railings to avoid the potential of becoming a tripping hazard. Some boats simply cannot offer that much real estate without a major alteration. Boat builders and designers have been working with the USCG to develop an acceptable alternative that offers both safety and accessibility. By keeping the main deck watertight with hatches and drains, the six-inch coaming can go away.

Whether re-purposing, repairing, or constructing new, consider going beyond compliance and become proactive in addressing social responsibility. The latest offerings in construction technology contribute towards eco-friendly operation. Installing precision meters for fuel flow monitoring can be used to guide each helmsman to operate the vessel at the most fuel efficient speed. Marine grade exhaust muffler filters are now offered that can reduce Carbon Monoxide emissions by up to 99 percent, Hydrocarbon emissions by up to 99 percent and particulate matter by over 85 percent.

Designers can also use Computational Fluid Dynamics (CFD) analysis and digital modeling to optimize hull shapes for the least amount of resistance, thus yielding better fuel economy. Hulls can now be made stronger with new developments in alloys such as 5383 aluminum which is 15 percent stronger than welding conventional 5083 aluminum. Boat builders can do their part by utilizing Friction Stir Welding (FSW) for some processes in aluminum construction. The process not only eliminates the health hazards and consumables associated with conventional welding, but also reduces the potential for defects. Keeping the construction crew in mind, many coating suppliers now offer low Volatile Organic Compound (VOC) coatings which are less hazardous.

Passenger vessel operator’s like WETA and Hornblower in San Francisco are staying ahead of the curve for environmental regulation, by acquiring vessels that supersede the requirements set by the currently imposed emissions standards. Other operators like Kitsap Transit in Washington State are being progressive in pioneering an ultra-low-wake vessel design. While no current requirement has been set, flush mount deck hatches, low clearance door sills, and wheelchair accessible heads and passenger areas will go a long way to create a positive perception for passengers.

Compliance means more cost, and it also can potentially mean the loss of revenue. With every 185 pounds added in mitigating features, it has the same performance implication as one potential passenger onboard. Exhaust after-treatment systems are large and heavy. Accessible heads and ramps take up floor space. Bringing a boat up to compliance may necessitate the need for a bigger boat, which will burn more fuel and produce more emissions. This is not a battle to be won, but it is worth a fair evaluation. It is true that “they sure don’t make ‘em like they used to,” but that probably is a good thing.

Joe Hudspeth is the Business Development Manager at All American Marine, Inc. He currently serves as a regional co-chairman for the Passenger Vessel Association and participates regularly on several committees concerned with marine related issues. Joe can be reached at or 360-647-7602.

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