PILOTAGE ISSUES THE WAIVER SYSTEM Pacific Pilotage Authority

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PILOTAGE ISSUES – THE WAIVER SYSTEM Pacific Pilotage Authority “Your partner in marine safety”

PILOTAGE ISSUES – THE WAIVER SYSTEM Pacific Pilotage Authority “Your partner in marine safety” Tugboat Industry Conference June 2 nd 2017

Focus today Who is the Pacific Pilotage Authority? Our Area of Jurisdiction History Changing

Focus today Who is the Pacific Pilotage Authority? Our Area of Jurisdiction History Changing time Pacific Pilotage Authority Navigational Safety on B. C. Coast

Who is the Pacific Pilotage Authority? Our Mandate ◦ To operate an efficient pilotage

Who is the Pacific Pilotage Authority? Our Mandate ◦ To operate an efficient pilotage service in the interest of safety within the region on a basis of financial self-sufficiency Our Mission ◦ The Pacific Pilotage Authority is dedicated to providing safe, efficient pilotage by working in partnership with pilots and the shipping industry to protect and advance the interests of Canada Pacific Pilotage Authority Navigational Safety on B. C. Coast

History Prior to 1972 local traffic both Canadian and US not part of the

History Prior to 1972 local traffic both Canadian and US not part of the pilotage system Current version is the Pilotage Act of 1972 ◦ Initially Canadian manned vessels exempt ◦ US vessels placed into a waiver system 2003 ◦ Canadian manning exemption declared ultra vires by Standing Committee of Parliament ◦ All Canadian vessels over 350 GRT and under 10, 000 placed into the waiver system Pacific Pilotage Authority Navigational Safety on B. C. Coast

Challenges Time Personnel Anti energy issues NIMBY Attitude

Challenges Time Personnel Anti energy issues NIMBY Attitude

The Waiver System (pre NES) Light handed approach Based purely on regional sea-time (Sec

The Waiver System (pre NES) Light handed approach Based purely on regional sea-time (Sec 10) Assumed companies were in compliance No audits No oversight of vessel movement Pacific Pilotage Authority Navigational Safety on B. C. Coast

Nathan E. Stewart Grounding 13 October 2016 • • • 30. 48 m x

Nathan E. Stewart Grounding 13 October 2016 • • • 30. 48 m x 9. 75 m x 4. 9 m 302 GT Built 2001 3400 HP 340 cum diesel fuel DB-55 capacity ~8400 cum (but empty at the time) u ~100 cum fuel spilt u One month to raise tug u Environmental, cultural impacts

Fallout Bella diesel spill response ‘a joke’, say critics B. C. First Nation slams

Fallout Bella diesel spill response ‘a joke’, say critics B. C. First Nation slams response to tug sinking au e n ar G arc ite M s r l e l t i s p ini uel s m rt. C. f o p ns its B a r T vis Fe in dera fo rm l go at ve io rn n m di on en es im t w el sp pac ithh ill t o ol f B ds. C.

Immediate Action Random audits to ensure compliance Two people on the bridge Master to

Immediate Action Random audits to ensure compliance Two people on the bridge Master to be on the bridge at certain locations Fuel barges bound to Alaska to avoid inside passage from Gordon Channel north Risk Assessment to be conducted Pacific Pilotage Authority Navigational Safety on B. C. Coast

Risk Assessment A study to answer the question: Subsequent to the recent grounding off

Risk Assessment A study to answer the question: Subsequent to the recent grounding off Bella, a. What mitigation of risk has been achieved by changes in (the Pilotage Waivers Regulation interpretation), and b. What residual risks require further mitigation? Pacific Pilotage Authority Navigational Safety on B. C. Coast

Pilotage Risk Management Methodology (PRMM) • A deliberate process for examining risks and intended

Pilotage Risk Management Methodology (PRMM) • A deliberate process for examining risks and intended regulatory changes • Broad engagement/consultation with stakeholders • Examination of objective evidence • Consideration of risks • Ranking of various mitigations • ü Survey & Interview of all waiver holders ü Fully representative Risk Management Team ü Marine Occurrence Record from TSB ü Traffic patterns ü Causes, outcomes - probability and consequence ü What is the issue to be solved? u What is possible/feasible? u What is reasonable? u What is effective? Recommendations for implementation Pacific Pilotage Authority Navigational Safety on B. C. Coast

PPA Waiver Holders Survey/Interviews • • Addressed to 61 companies 36 survey respondents online

PPA Waiver Holders Survey/Interviews • • Addressed to 61 companies 36 survey respondents online (59% representing 73% of vessels) 59 companies interviewed by phone (96. 7% representing 93. 7% of the waivered vessels) Key concerns of respondents: Ø Extra manning costs Ø Accommodation limitations on small tugs Ø Hours of rest requirements (master on the bridge) Ø Consistent definitions (confined waters, oil cargoes) Ø Unintended increase in risk: adverse weather in Hecate Strait Ø Level playing field with regard to waiver rules Ø Companies “flying under the radar” Pacific Pilotage Authority Navigational Safety on B. C. Coast

Canadian waiver fleet transits

Canadian waiver fleet transits

US waiver fleet transits

US waiver fleet transits

“Heat Maps” of Cdn and US Vessels Cdn US

“Heat Maps” of Cdn and US Vessels Cdn US

Waiver Holders’ Appreciation of Risk Factors • WK vigilance and competence almost on par

Waiver Holders’ Appreciation of Risk Factors • WK vigilance and competence almost on par • Remainder @ 30 -40% level • “Others” include: judgment, complacency, comms, unregulated vsls, currents, weather, lack of AIS, manning levels, fatigue, distraction • Areas of risk included: (PPA areas) + Fern Pass, Masset Inlet, Skidegate Narrows Pacific Pilotage Authority Navigational Safety on B. C. Coast

Unintended effect of PPA Oil-routing Restrictions? Kirby Tracks for 2016 Tracks since 14 Nov

Unintended effect of PPA Oil-routing Restrictions? Kirby Tracks for 2016 Tracks since 14 Nov 16

What does the TSB Marine Occurrence record show? Navigational Occurrences on the BC Coast

What does the TSB Marine Occurrence record show? Navigational Occurrences on the BC Coast 1997 -2017 • 2658 “Occurrences” in the area • 794 “Navigation” Occurrences among vessels <10, 000 GT • Filtered to Primary Vsl/Primary Incident • General decline …anomalous trend in last 3 years • Groundings predominant • Strikes (largely berthing incidents) next most numerous

Groundings & Near. Groundings North & Central Coast 1997 -2017

Groundings & Near. Groundings North & Central Coast 1997 -2017

Groundings & Near. Groundings North & Central Coast 1997 -2017 (less FV < 350

Groundings & Near. Groundings North & Central Coast 1997 -2017 (less FV < 350 GT)

Groundings & Near. Groundings Central Coast 1997 -2017 (with FV < 350 GT)

Groundings & Near. Groundings Central Coast 1997 -2017 (with FV < 350 GT)

Hazard Identification and Risk Analysis (HIRA) Causes B r id g e W a

Hazard Identification and Risk Analysis (HIRA) Causes B r id g e W a t c h k e e p e r ill/ a s le e p / in c a p a c it a t e d B r id g e W a t c h k e e p e r in a t t e n t iv e / c o m p la c e n t B r id g e W a t c h k e e p e r in e x p e r ie n c e d / la c k s lo c a l k n o w le d g e B r id g e W a tc h k e e p e r u n a b le t o m a n a g e e v e n t s / in fo o v e r lo a d M a s t e r e x e r c is e s p o o r ju d g e m e n t / / o v e r - c o n fid e n c e M a s t e r f a t ig u e d ( b y a d d it o n a l P P A r e q t s ? ) N a v ig a t io n - o v e r - r e lia n c e o n e le c t r o n ic a id s N a v ig a t io n d if f ic u lt y - h ig h c u r r e n t s in c o n f in e d w a t e r s N a v ig a t io n e q u ip m e n t f a i lu r e P ilo t u n f a m ilia r w it h v e s s e l t y p e R e d u c e d v is ib ility T r a f fic d e n s it y V e s s e l e x p o s e d t o c o n d it io n s b e y o n d c a p a b ilit y (b y P P A R e g s ) V e s s e l im p r o p e r ly m a in t a in e d V e s s e l im p r o p e r ly m a n n e d V e s s e l m e c h a n i c a l/ c o n t r o l f a ilu r e V e s s e l o p e r a t in g w it h o u t p il o t o r r e q u i r e d w a iv e r W e a t h e r c o n d it io n s e x c e s s iv e ( n o t p r o p e r ly f o r e c a s t / r o u t e d ) Outcomes

Hazard Identification and Risk Assessment (HIRA) Ø A deliberate and structured approach to ranking

Hazard Identification and Risk Assessment (HIRA) Ø A deliberate and structured approach to ranking problems and solutions

HIRA … most effective mitigations

HIRA … most effective mitigations

PPA Waivers Study Conclusions Ø Risk Factors: no “smoking gun” Ø But … vigilance/watch-keeper

PPA Waivers Study Conclusions Ø Risk Factors: no “smoking gun” Ø But … vigilance/watch-keeper attentiveness? Ø Waiver Holders: an exceptionally diverse community, even among tug & tow operators Ø Waiver Holders: want a rigorously level playing field Ø FN Communities: pushback on requirement for US vessels transits u Constant effort to keep discussion focused on PPA’s role… Ø PPA Waivers process: generally effective …but relatively low on experiential requirements Ø PPA Implementation Guidelines: need additional clarification Ø PPA Waivers changes: best to incentivize rather than regulate compliance Pacific Pilotage Authority Navigational Safety on B. C. Coast

Risk Assessment Recommendations General outline by item: 1. “Standard of Care” 2. Tonnage 3.

Risk Assessment Recommendations General outline by item: 1. “Standard of Care” 2. Tonnage 3. Areas 4. Basic Experience 5. Specific Experience 6. Vessels 7. “Confined waters” 8. “Two man rule” 9. Master on the bridge 10. “Oil cargoes” 11. Reporting 12. Safety Management Practices 13. Incentives 14. Manning Regs 15. Implementation Pacific Pilotage Authority Navigational Safety on B. C. Coast

Standard of Care Proposal Intent: • Establish “Standard of Care” as non-regulatory summation of

Standard of Care Proposal Intent: • Establish “Standard of Care” as non-regulatory summation of conditions under which granting of waivers will be considered Effect: • Improve overall navigation safety practices Pacific Pilotage Authority Navigational Safety on B. C. Coast

Standard of Care Proposal #3 - Zones Intent: • Require specific experience in waiver

Standard of Care Proposal #3 - Zones Intent: • Require specific experience in waiver “zones” Effect: • Improve experience level of (new) waiver holders Impact: • Greater requirement for documentation, deliberate preparation of candidates Undertaking: • Allow combination of experience, training, simulation to substitute Pacific Pilotage Authority Navigational Safety on B. C. Coast

Standard of Care Proposal #4 - Vessels When vessels are operating under waiver, the

Standard of Care Proposal #4 - Vessels When vessels are operating under waiver, the following Standard of Care is required: a. All vessels operating under a Waiver must be operating a Bridge Navigation Watch Alarms System (BNWAS) set to (at most) 10 -minute intervals; and b. All vessels operating under a Waiver shall be fitted with and transmitting on Class A AIS. This requirement shall not apply to 12 -hour shift boats (day boats) operating with two men constantly present in the wheelhouse Pacific Pilotage Authority Navigational Safety on B. C. Coast

Standard of Care Proposal #5 – Confined waters Def: track within 1 mile of

Standard of Care Proposal #5 – Confined waters Def: track within 1 mile of grounding Two persons on the bridge with no more than 10 min absence unless BNWAS installed Master to be on the bridge at certain locations unless mate meets predetermined criteria Does not apply to vessels operating solely within a port or vessels towing logs Pacific Pilotage Authority Navigational Safety on B. C. Coast

Standard of Care Proposal #6 – Cargoes/routes For vessels carrying or pushing/towing oil cargoes,

Standard of Care Proposal #6 – Cargoes/routes For vessels carrying or pushing/towing oil cargoes, the inside passage is a NO-GO area Laredo Sound and Principe Channel with permission in adverse weather Oil cargoes def: ◦ Any quantity of petroleum products, excluding ship’s fuel, exceeding 10% of cargo volume Does not apply to vessels delivering supplies to remote communities or camps Pacific Pilotage Authority Navigational Safety on B. C. Coast

Standard of Care Proposal #7 – Safety Management Practices Companies encouraged to adopt Safety

Standard of Care Proposal #7 – Safety Management Practices Companies encouraged to adopt Safety Management Systems (SMS) Standing Orders to clarify a deliberate approach to risk management This establishes the company’s expectations of safety culture

Standard of Care Proposal #8 - Renewal Annual renewal may be extended to two

Standard of Care Proposal #8 - Renewal Annual renewal may be extended to two years provided two or more of the following are met: ◦ An SMS is in place within the company ◦ The company maintains Standing Orders regarding navigational safety practices on the BC coast and an established training/mentorship programme ◦ A clean waiver record over the preceding five years ◦ A clean navigational safety record over the preceding five years Implementation Timeline ◦ This Standard of Care document shall become effective immediately following approval by the PPA Board on 8 June 2017 ◦ Requirements for the fitment of equipment and changes to qualifying experience for waivers shall take effect with applications for renewal of waivers for January 2019 ◦ Approved waiver holders before that date shall be grandfathered Pacific Pilotage Authority Navigational Safety on B. C. Coast

Kevin Obermeyer, CEO Pacific Pilotage Authority E-mail: oberkev@ppa. gc. ca Website: www. ppa. gc.

Kevin Obermeyer, CEO Pacific Pilotage Authority E-mail: oberkev@ppa. gc. ca Website: www. ppa. gc. ca