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Safety Recommendation Details

Safety Recommendation M-14-004
Details
Synopsis: This report discusses the allision of the high-speed passenger vessel Seastreak Wall Street with Pier 11 in Lower Manhattan, New York City, on January 9, 2013. Four passengers were seriously injured, and 79 passengers and one deck hand sustained minor injuries. The estimated cost to repair the Seastreak Wall Street was approximately $160,200. The total cost of repairs to the pier, which was a dock barge, was $333,349. Safety issues identified in this report include company oversight and procedures, guidance, and training necessary for safe approach and landing of the Seastreak Wall Street and similar vessels; management of passenger access and movement to mitigate injury in case of a vessel incident; the importance of marine safety management systems; and the need for comprehensive vessel operational data, such as the detailed information that is captured by a voyage data recorder, in investigating and analyzing accident causes and identifying remedial actions to help prevent a recurrence. The National Transportation Safety Board (NTSB) issues new recommendations to the United States Coast Guard regarding distribution of information about this accident and the need to control passenger access and to Seastreak LLC, the managing owner and operator of the Seastreak Wall Street, regarding timely safety management system implementation. The NTSB reiterates previous recommendations to the Coast Guard regarding safety management systems and voyage data recorder carriage requirements.
Recommendation: TO THE UNITED STATES COAST GUARD: Require installation of voyage data recorders that meet the International Maritime Organization’s performance standard for simplified voyage data recorders on existing ferry vessels subject to 46 Code of Federal Regulations Subchapters H and K. (Supersedes Safety Recommendations M-10-005 and M-10-006)
Original recommendation transmittal letter: PDF
Overall Status: Open - Unacceptable Response
Mode: Marine
Location: New York (Manhattan), NY, United States
Is Reiterated: No
Is Hazmat: No
Is NPRM: No
Accident #: DCA13MM005
Accident Reports: ​Allision of the Passenger Vessel Seastreak Wall Street
Report #: MAR-14-01
Accident Date: 1/9/2013
Issue Date: 4/29/2014
Date Closed:
Addressee(s) and Addressee Status: USCG (Open - Unacceptable Response)
Keyword(s):

Safety Recommendation History
From: NTSB
To: USCG
Date: 2/17/2017
Response: You state that an economic analysis shows that the benefits of requiring VDRs do not outweigh the costs, and you do not plan to take any further action on this issue. We disagree with your assessment. We have long advocated VDR carriage requirements and point out that you supported an international requirement for this technology and are currently actively involved with the VDR information being gleaned from the investigation into the tragic sinking of the El Faro. We are also investigating the March 2016 Hornblower Adventure allision with a pier in San Diego, California, in which a VDR of any sort would have provided crucial data. In addition, VDRs have proven to be effective safety management tools for vessel managers and a source of training for vessel crews. The lack of a domestic VDR requirement will be addressed in the Hornblower Adventure allision. These recommendations were developed to appropriately target carriage requirements based on the size of the vessel, and it was our hope that you would ensure that the standard applied to domestic ferries would not be inferior to that applied to vessels in international service. We believe that Americans deserve the same level of safety as those traveling on international routes and will continue to address the need for a domestic VDR carriage requirement; therefore, we request that you reconsider your position. Pending your response, Safety Recommendations M-14-3 through -5 are classified OPEN--UNACCEPTABLE RESPONSE.

From: USCG
To: NTSB
Date: 10/18/2016
Response: -From Charles W. Ray, Vice Admiral, U.S. Coast Guard, Deputy Commandant for Operations: The Coast Guard's position on requiring voyage data recorders, described in Vice Admiral Charles Michel’s letter of April 3, 2015, has not changed. An economic analysis shows that the benefits unfortunately do not outweigh the costs. We do not plan to take any further action on this matter and we ask the Board to reconsider and close this recommendation.

From: NTSB
To: USCG
Date: 3/11/2016
Response: 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 correspondence@ntsb.gov 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.

From: NTSB
To: USCG
Date: 6/11/2015
Response: We are disappointed that you do not agree with the merits of these recommendations and have concluded that, although VDRs offer some value to certain accident investigations, their overall benefits are minimal and do not justify the cost of their installation. Although we recognize the costs associated with installing a VDR and the regulatory requirements for justifying those expenses, we must emphasize that the associated safety benefits of this technology quickly outweigh installation costs. These benefits have been proven on larger vessels time and again and, as you are aware, many European countries have adopted similar carriage requirements to that of the International Maritime Organization (IMO) for their domestic fleets. Since 1976, the NTSB has consistently supported the outfitting of recording devices such as VDRs on ferries and other vessels. Initially, the Coast Guard rejected our recommendations for the installation of these technologies, citing excessive equipment cost and suggesting that VDRs were of limited value to investigations. The Coast Guard later concurred with the intent of subsequent new recommendations, yet took little positive action for various reasons, including funding limitations, for studying the VDR issue. In the end, the Coast Guard supported efforts at the IMO for VDR requirements on vessels operating on international voyages. We continue to support the outfitting of such recording devices as VDRs on ferries and other vessels because we have repeatedly found that, when VDR data are available, investigations are more likely to result in well-developed findings and recommendations that, when implemented, enhance safety. Your stated position regarding the domestic fleet conflicts with your position at IMO for the international fleet; ultimately, this conflict creates a double standard. We are very perplexed by the Coast Guard’s assessment that the “cost outweighs the benefit of installing VDRs” for the domestic fleet, because passenger safety is the most important aspect of vessel operations. The benefits to the traveling public warrant the installation of VDRs on passenger ferries. Accordingly, we request that the Coast Guard reconsider its stated position on this issue. Pending your reply to this request, Safety Recommendations M-14-3 through -5 are classified OPEN—UNACCEPTABLE RESPONSE.

From: USCG
To: NTSB
Date: 4/3/2015
Response: -From Charles D. Michel, Vice Admiral, U.S. Coast Guard, Deputy Commandant for Operations: I do not concur with these recommendations. The U.S. Coast Guard has assiduously studied the use and benefits of voyage data recorders (VDRs) on U.S. passenger vessels. Based on these efforts, the Coast Guard has concluded that, while they offer some value to certain accident investigations, the overall benefits of VDRs are minimal and do not justify the cost. The Coast Guard's position is based on the tenet that any rulemaking project requires quantitative analyses of the rule's economic, environmental and small business impacts. Additionally, each proposed regulatory action should maximize the net economic, environmental, public health and safety benefits to society. Research has indicated that the accident history of passenger vessels subject to 46 CFR, Subchapters H, K and T does not support widespread carriage of this expensive equipment. The expense to industry, when compared to any potential safety or societal benefits, does not withstand cost-benefit scrutiny within the regulatory rulemaking process. I consider the U.S. Coast Guard's action on these recommendations complete and request that they be closed.

From: NTSB
To: USCG
Date: 5/13/2014
Response: We have long advocated VDR carriage requirements. Although you have supported an international requirement for this technology, you have rejected a domestic VDR requirement, even for passenger ferries, which carry millions of passengers each year. Accordingly, Safety Recommendations M-14-3 through -5 are classified OPEN—UNACCEPTABLE RESPONSE.