CONCEPTION AFTERMATH - COAST GUARD ISSUES NEW RULES/REGULATIONS

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It would be interesting see how Ted Cummings will deal with this. He runs the Spectre out of Ventura. It’s an 85’ steel boat that was a retired oil rig tender. It has two exits out of the sleeping quarters, but he never does overnight trips though it’s only a day boat. They used to let people sleep on the boat the night before a trip so it was really convenient for out of towners like myself. That’s long gone now.
I’m just wondering if that boat might be bought by someone or maybe he might consider doing overnight trips since that boat is all steel and most of the way there as far as the new compliance rules.
 
As the comment period for the rule making is coming to a close (27 June 2022) I would encourage folks to submit comments. Overall I found the interim rules, while a step forward to be wholly inadequate when it comes to the accommodation area.

Nutshell: The interim rule is for the whole of the vessel (up to 49 passengers). Two exits is wholly inadequate to evacuate a vessel (up to 49 passengers) in a timely fashion due to fire if one of the exits, the primary exit, is blocked. There are other issues with the interim rules as written.

The number of exits must be base on the number passenger on per accommodation area with a maximum time for evacuation with at least one exit blocked.

I have attached my comments that will be sent in this coming week. Suggestions comments are welcome. I will entertain adding other names to my letter but folks should send in their own comments.

You can read the Submitted Comments.
 

Attachments

  • USCG.pdf
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Just came back from a great trip on the Horizon. I had the cabin bunk with the new hatch above it leading directly to the starboard deck. It was hard enough to climb into my bunk. It would probably take quite a long time for the bunk room to be evacuated through it in case of emergency (and in case it were the only accessible exit).
On the other hand, in addition to a similar set of galley exits as in the original Vision layout (two forward staircases leading inside the galley, one aft center bunk trap leading close to the galley exit), there is an additional forward hatch leading to the bow deck in the crew quarters, accessible from the main bunk room.
Regardless, the captain himself was skeptical about the chances to evacuate the bunk room in case of emergency.
The key difference: a large and well trained crew with a 24 h rowing watch.
It still won't prevent accidents such as a night time collision with a floating container in the fog, capsizing because of a rogue wave, or whatever other unpredictable accident at sea.
But it will prevent preventable ones.
 
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