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General Aviation Safety
The recommendations are derived from the NTSB’s investigation of the January 23, 2010, accident in which the 810-foot-long oil tanker Eagle Otome collided with the 597-foot-long general cargo vessel Gull Arrow at the Port of Port Arthur, Texas. A 297-foot-long barge, the Kirby 30406, which was being pushed by the towboat Dixie Vengeance, subsequently collided with the Eagle Otome. The tanker was inbound in the Sabine-Neches Canal with a load of crude oil en route to an ExxonMobil facility in Beaumont, Texas. Two pilots were on board, as called for by local waterway protocol. When the Eagle Otome approached the Port of Port Arthur, it experienced several unintended heading diversions culminating in the Eagle Otome striking the Gull Arrow, which was berthed at the port unloading cargo. A short distance upriver from the collision site, the Dixie Vengeance was outbound with two barges. The towboat master saw the Eagle Otome move toward his side of the canal, and he put his engines full astern but could not avoid the subsequent collision. The Kirby 30406, which was the forward barge pushed by the Dixie Vengeance, collided with the Eagle Otome and breached the tanker’s starboard ballast tank and the no. 1 center cargo tank a few feet above the waterline. As a result of the breach, 862,344 gallons of oil were released from the cargo tank, and an estimated 462,000 gallons of that amount spilled into the water. The three vessels remained together in the center of the canal while pollution response procedures were initiated. No crewmember on board any of the three vessels was injured.
TO THE UNITED STATES COAST GUARD: Implement fatigue mitigation and prevention programs for pilotage practices in the Great Lakes and St. Lawrence Seaway that (1) regularly inform mariners of the hazards of fatigue and effective strategies to prevent it and (2) promulgate hours-of-service rules that prevent fatigue resulting from extended hours of service, insufficient rest within a 24-hour period, and disruption of circadian rhythms.
Original recommendation transmittal letter:
Closed - Acceptable Action
Port Arthur, TX, United States
Collision of Tankship Eagle Otome with Cargo Vessel
and Subsequent Collision with the
Addressee(s) and Addressee Status:
USCG (Closed - Acceptable Action)
Safety Recommendation History
We are pleased to learn that, on March 7, 2016, you issued a final rule, Great Lakes Pilotage Rates—2016, Annual Review and Changes to Methodology. In addition to updating the methodology used to determine the number of pilots needed to provide safe, efficient, and reliable service, the rule adopts a work standard that incorporates all necessary activities to provide pilotage services and replaces the previous bridge hour standard. Further, the new standard incorporates travel time to and from the assignment, delay, detention, time on task, administrative time, and the mandatory 10 hours of rest between assignments, as well as establishes the goal of providing pilots 10 days of restorative rest per month. Because the final rule satisfies the intent of Safety Recommendation M-15-6, it is classified CLOSED--ACCEPTABLE ACTION.
-From Charles W. Ray, Vice Admiral, U.S. Coast Guard, Deputy Commandant for Operations: On March 7, 2016, the Coast Guard issued a Great Lakes pilotage final rule to update the methodology used to determine the number of pilots needed to provide safe, efficient, and reliable service. The final rule adopts a work standard that incorporates all necessary activities to provide pilotage services and replaces the previous bridge hour standard. The new standard incorporates travel time to and from the assignment, delay, detention, time on task, administrative time, and the mandatory ten hours of rest in between assignments. The final rule also establishes the goal of providing ten days of restorative rest per month for the pilots. We consider our action on this recommendation complete and request that it be closed.
This letter concerns 40 open safety recommendations that the National Transportation Safety Board (NTSB) issued to the US Coast Guard between 2002 and 2015. For several years, the NTSB received an annual update on all open safety recommendations issued to the Coast Guard; however, for 25 of the 40 recommendations listed, we have received no update in over 2 years regarding the status of action either taken or planned to address these important safety issues. We are interested in knowing whether and how our recommendations are implemented, both to ensure that the traveling public is provided the highest level of safety and to identify creative solutions that might be shared with others. Please respond to this letter electronically at firstname.lastname@example.org regarding your progress in addressing these safety recommendations, and do not submit both an electronic and a hard copy of the same response. To assist with your response, enclosure (1) is a list of the 40 recommendations highlighting the recommendation number, current status, source of the recommendation, and date of the last Coast Guard update; enclosure (2) is a print-out from our database with the complete correspondence history of each open recommendation.
We understand that the Coast Guard requires a pilot to refuse an assignment if the pilot believes he or she cannot perform duties and responsibilities of the position because of fatigue. We further understand that you use the 2014 surcharge authority to provide Great Lakes pilot associations training funds for fatigue mitigation and recognition. We note that your pending 2016 rate-making notice of proposed rulemaking will propose to update the methodology used to determine the number of pilots needed to provide safe, efficient, and reliable service. The proposed rule adopts a seasonal work standard that incorporates all the necessary and reasonable activities that replaces the bridge hour standard (travel time to and from the assignment, delay and detention, time on task, administrative time, and the mandatory 10 hours of rest in between assignments). Accordingly, pending issuance of the final rule as described above, Safety Recommendation M 15-6 is classified OPEN—ACCEPTABLE RESPONSE.
Mark E. Butt, Rear Admiral, USCG, Acting Deputy Commandant for Operations: I concur with this recommendation. We are taking several steps to implement fatigue mitigation and prevention for pilotage practices in the Great Lakes and St. Lawrence Seaway: • First, all of the Great Lakes Pilotage office requires a pilot to refuse an assignment if the pilot feels that his or her duties and responsibilities cannot be performed safely due to fatigue. • Second, we used our surcharge authority in the 2014 Appendix A rulemaking to provide the U.S. Great Lakes pilot associations with the funds to conduct training for fatigue mitigation and recognition. • Third, the 2016 Rate-making Notice of Proposed Rulemaking proposes updates to the methodology we use to determine the number of pilots needed to provide safe, efficient, and reliable service. Our proposal adopts a seasonal work standard that incorporates all the necessary and reasonable activities which replaces the bridge hour standard (e.g., travel time to and from the assignment, delay and detention, time on task [historically referred to as "bridge hours"], administrative time, and the mandatory 10 hours of rest in between assignments). This provides a more accurate accounting of the actual time needed to safely and efficiently move traffic. We are also updating our staffing model to address seasonal peaks and allow for 10 days of recuperative rest per month and training time for all of the pilots, and additional administrative time for the association presidents. In addition to this, we are adjusting staffing requirements to address the historic peaks at the opening and closing of the season instead of average demand throughout the season. • Fourth, if the pilot determines that the weather conditions, vessel speed, or ship configuration may introduce an extraordinary hazard, the pilot can request a second pilot for the voyage. We approve these requests on a case-by-case basis. • Finally, we have proposed a mandatory change point at Iroquois Lock. This will break up the nearly 11-hour transit on the St. Lawrence River between Cape Vincent and Snell Lock. We are also preparing to ask the Great Lakes Pilotage Advisory Committee to review the effectiveness of other pilot change points throughout the system and recommend additional change points if necessary. I will keep the Board informed of our progress on this recommendation.
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