Post Office Box 1229 / Sitka, Alaska 99835 907.747.3400 / FAX 907.747.

3462
North Pacific Fishery Management Council
605 West 4
th
Avenue Ste 306
Anchorage, AK 99501
Sept 15, 2014
Re: C-1 Observer program
Dear Members of the Council,
During the past two fishing seasons, several small boat operators have commented that NMFS observers
assigned to their vessels were very concerned about their safety on a vessel that is drifting. More than one
skipper reported the observers were told that up to 80% of accidents on small boats occur when the boats are
drifting for the night. This anxiety increased tensions in an already challenging work environment.
In June, the Alaska Longline Fishermens Association (ALFA) reported this problem to the NMFS Fisheries
Monitoring and Analysis division (FMA) and asked that the FMA review the observer training program to
determine the basis of this accident statistic. ALFA also noticed FMA that we had requested NIOSH (the National
Institute of Occupational Safety and Health) review casualty data for the small boat fixed gear fleet to determine
the correct information.
In July, NIOSH reported: During 2000-2013, there were 52 vessel disasters (defined as a vessel emergency in
which the crew abandoned ship) in the Gulf of Alaska fixed gear groundfish fleets. These fleets were defined in
this data query as vessels using longline and pot gear to harvest halibut, sablefish and pacific cod in the Gulf of
Alaska (NMFS regulatory areas 610, 620, 630, 640, 649, 650, 659).
These are vessel emergencies that involve damage to the vessel that force the crews to abandon ship. In the data
I sent you, I did not include MOB or other types of incidents to individual workers..Below [see table] are the
initiating events for the 52 vessel disasters. The initiating event is the first problem that occurred in the sequence
of events leading to the disaster.
The exact circumstance of a vessel drifting while the crew is asleep is not directly measured in the available data.
However, there is information about the contribution of fatigue and sleeping at the helm to vessel disasters. Out
of the 52 vessel disasters described above, seven (15%) were documented by USCG investigators as having been
related to crewmember fatigue or sleeping while on watchAll 7 had the same initiating event: Struck
rocks/bottom.
The table below shows that collision, the likely problem to occur while drifting, accounted for only 4% of
incidents in this fleet. The number one problem was vessel grounding of which seven (over 50%) were
attributed to crew fatigue. Many skippers report that when the observer takes one bunk and the crew is forced
to keep watch all night, the crew members get less than 5 hours of sleep each night, and one crew will get a split
night consisting of short two hour naps. The effect on crew fatigue is significant and, based on NIOSH data, the
effect on vessel safety of that fatigue is also significant.
ALFA pursued this data request to ensure the observer training program has accurate data to share with
observers about the most common cause of vessel disasters in the small boat fleet and the effect of crew fatigue
on vessel safety. We continue to support development of an electronic monitoring (EM) alternative that allows
at-sea data to be collected from vessels where carrying an observer is impractical and compromises safety.
Sincerely,
Dan Falvey




GOA Longline & Pot Vessel Disasters
Initiating Event Number
Struck Rocks/Bottom 13
Flooding 11
Instability 8
Fire/Explosion 6
Struck by Large Wave 5
Prop Entanglement 2
Engine Failure 2
Collision 2
Struck by Wind Gust 1
Steering Failure 1
Unknown Events 1