El Faro Stablity

Were all conversions, as far as you know, reflected in the Cargomax software?

The fructose tanks were not reflected in the Cargomax software but the crew entered the weight as RO/RO cargo. Other than that both the NTSB and CG found that the numbers from Cargomax were accurate.

Thanks for the info.

The damage control module in the CargoMax software on El Faro could have provided timely vessel stability information to the officers for the damage conditions the vessel experienced, but it seems that neither the crew nor Tote nor the crews of the other ships were aware that such a Damage Control module was available in the Cargomax program! For the same reason there was also no damage control plan and booklet available.

Futhermore the stability book didnot identify:

  • Downflooding points.
  • Angle of downflooding.
  • Unintentional flooding due to list.
  • Windheel criteria information.

Regarding the latter I understand that there there is no windheel module in the Cargomax program. If this is the case, it is hard to believe, then this is a serious omission, in my view. It is always handy on a ship with high container stacks to have information about the wind moment. The angle of heel under action of steady beam wind should not exceed 16° or 80% of the angle of deck edge immersion, whichever is less. On top of that the ship is subjected to a gust wind pressure which results in a gust wind heeling lever. In case of the El Faro under the prevailing hurricane winds there would have been extreme wind moment forces present.

A couple of the key conclusions of the preliminary USCG report were:

  • Operated with minimal stability margin, with limited ballast capacity and available freeboard, leaving little flexibility.

  • If built in 2016: As operated would not meet current intact and damage stability standards.



The NTSB pointed out the lack of crew training:

The CargoMax program contained a damage stability module. Although the damage
stability module was not approved by the classification society, investigators found it a fairly quickand useful tool for determining the amount of flooding needed for El Faro to lose positive stability.

Using the program, crewmembers could have simulated different damage conditions (or the effect of various types of damage to the vessel), which would have allowed them to calculate the effects of different stages of flooding and would have provided them with conditions of particular vulnerability. None of the former El Faro officers who were interviewed understood how the damage stability module in CargoMax operated.

Training by the CargoMax developers or by instructors certified by the developers would> have allowed El Faro personnel to be conversant with the full capabilities of the software. They could have experimented in advance with different conditions of damage that would seriously affect the stability of the vessel, quickly determined the status of the vessel during the storm, and recognized the dangerous state El Faro was in.

Understanding shipboard stability, particularly in severe conditions, is a critical skill
requiring specialized training and experience. That skill allows officers to make competent
decisions when faced with complex stability hazards such as list and windheel. The officers on El Faro had no training, and the shipboard guidance was not suitable for thecircumstances.

Thus,the NTSB concludes that the company did not have an effective training program for the use of the CargoMax stability instrument, including its damage stability module.

Of course once the ship began to heel from flooding and wind it was too late to consult CargoMax. NTSB is saying better to have had training in use of the software in advance.

I never received any training on the stability program either, it’s all done on the fly. That would be tough to do given that run’s quick turn-around and fast pace with minimum shore-side assistance.

This is what NTSB report says about wind heel calculations:

El Faro’s onboard CargoMax software included a function that calculated both the wind
profile of the vessel, based on container loading, and the required GM. The vessel’s stability
booklet, which did not have such an “auto windheel” function, calculated limited GM curves for one, two, three, four, or five tiers of containers, using the full wind profile (maximum container load per tier). Compared with the stability booklet, CargoMax with the auto windheel function would more accurately compute windheel for various container-loading arrangements and their associated wind profiles. For a loading case with less than a full-tier container load, the requiredGM output from CargoMax would be less than the GM calculated according to the stability booklet with a full container loading for the same tier.

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The “steady beam wind” criteria is 26 meters/sec, by rule of thumb m/s to kts is double or about 52 kts, by calculator 50.54 kts.

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again…we are over complicating a simple situation here and there are no questions today after the tragedy

EL FARO after it’s last conversion DID NOT HAVE ADEQUATE RIGHTING ARM TO SURVIVE in the event of flooding in ANY weather state other than flat calm…PERIOD! Just like the lifeboats which were useless in anything but the same conditions.

and because ships and their crews are expected to be able to survive damage in other than dead flat calm, the EL FARO was manifestly UNSEAWORTHY on her face! and again, the evidence shows that the USCG simply DOES NOT CARE for the crews on US ships and is more interested in assisting the owners to make MORE MONEY…PERIOD!

end of discussion


The ruling that the lenghting and the loss of two feet of freeboard was not a major conversion was a CG ruling. On the regulatory side however the ABS evidently is able to cash the checks from the owners without a problem but other than that they don’t come out looking too good.


I have been reading the NTSB and the Coast Guard reports for the last couple of weeks, so that I could write a summary for my website. The 1993 lengthening was actually a major modification, but no upgrades to the ship were required because it was not engaged in international trade. The 2005/6 changes had originally been designated as a major modification, but the company had appealed and the Coast Guard changed their minds. Had they stuck with it the ship would have had to be upgraded because it was engaged in the Alternative Compliance Program, the ACP. I have a job to believe that once the ship joined the ACP the 1993 requirement would not be applied, and how in 2005/6 the freeboard could, pretty arbitrarily, be reduced by 2 feet.

I’ve only made a couple quick passes through the reports wrt stablity so I’ve not been able to sort it all out. Where does the information about differing requirements for International Trade come from?

From the CG MBI report:

When EL FARO underwent its major conversion in 1992-1993, it was required to meet the
probabilistic damage stability standard of SOLAS 1990. During the 1992-1993 conversion, ABS completed, reviewed, and approved a SOLAS probabilistic damage stability analyses, 81 and it was confirmed that the limiting stability criteria for EL FARO was the intact GM criteria (46CFR § 170.170) for all loading conditions.

The text as shown can be found here. The mysterious permanent 2° list is also mentioned.

The calculation of the wind heel levers have changed quite a bit since somewhere in the eighties. Before that the wind heel lever was calculated in two parts. From sea level to 5 m 75 kg/m2 and from 5 m to the top of the highest point 125 kg/m2. Now 50.4 kg/m2 or 504 Pa is used with a different definition for height, quite a difference.

The standard measure for figuring out a ship’s GM, which is the stability of the ship, is based on factors including the cargo loading plan, ship size and center of gravity. Due to El Faro’s size, a wind pressure of about 50 to 55 knots, or 58 to 63 mph, was taken into account. So as long as El Faro didn’t lean more than 14 degrees with a wind speed of 58 to 63 mph, it would have met the Coast Guard’s minimum standard for stability in high winds.

But when the Coast Guard asked if Herbert takes into hurricane force winds into account, like a Category 3 with 125 mile per hour winds for example, the company confirmed there were no calculations done to determine how far the El Faro would lean to the side. The Coast Guard does not require calculations for that wind speed.

“a wind pressure of about 50 to 55 knots” What is meant here?

In the NTSB report Page 196 there is the statement “The vessel was not required to comply with SOLAS requirements before or after it was lengthened in 1993 because it was in domestic service”, and I feel sure that I saw a similar statement elsewhere. But there are a lot of words, and i made notes as I was going along, without precisely identifying the sources.

The NTSB on page 196 is confusing, but in any case this is also from the NTSB report, page 63

Under Coast Guard regulations at 33 CFR 96.210, US vessels on international voyages, including cargo ships, are required to operate under a safety management system (SMS). El Faro was required to meet the requirements because it was enrolled in the Coast Guard’s ACP.

Page 45 of the CG MBI report:

EL FARO was enrolled into the ACP on February 27, 2006. 33 Based on its enrollment date,
EL FARO was required to comply with applicable SOLAS conventions, ABS Steel Vessel
Rules, and the June 2003 U.S. Supplement to ABS Rules for Steel Vessels Certificated for
International Voyages.

I believe wrt the El Faro that for any SOLAS requirement there should be a U.S. regulation equivalent.

In any case IIRC I passed the then Northern Lights, it might have been one of the sister ships, a couple times while I was foreign.

I believe that for purposes of SOLAS the El Faro would have to meet 1992 regs, at least as far as stability is concerned.

CG report p 136

The Marine Safety Center determined that the lengthening and spar deck addition
completed in 1993 was a major conversion. That designation required the vessel and its systems be brought up to the applicable 1992 federal regulations (as opposed to those from 1975). Modifications to the vessel were also required to comply with applicable SOLAS regulations at the time of modification because the vessel was certificated for international voyages.

Correspondence from the Marine Safety Center at the time showed that the determination was the basis for the vessel to meet the new probabilistic damage stability requirements at the time of conversion (rather than the owner’s initial intent to meet deterministic damage stability found in a design letter issued by the US Maritime Administration [MARAD] in 1965). 16

According to the testimony at the MBI, the assigned freeboard prior to the 2005/6 conversion was an increased freeboard. This means for whatever reason, the vessel was operated at a draft that was 2 feet less than allowed by the Loadine regulations. The draft increase wasn’t allowed because of anything related to the conversion. At any time from delivery to 2005/6, the owners could have requested to increase the draft by up to 2 feet. The owners took advantage of the permissible 2 foot draft increase in conjunction with the 2005/6 conversion.

You can’t say a vessel isn’t safe because it operates at the draft allowed by the International Load Line Convention. That would mean that every vessel that sails on the marks according to it’s deepest permitted draft is unsafe.

Item 8 of Enclosure 1 to the USCG Final Action Memo confirmed the actual enrollment date of the EL FARO into the ACP program was December 21, 2010, not 2006 are previously claimed.

Which witness, hearing and day?

Give me a bit to go through the reports and get it. It was an ABS witness that testified in MBI 2 and 3.

This is from the CG report p-55

After the 2006 conversion, EL FARO’s total cargo loading capacity changed and the vessel’s maximum allowable draft was increased by over 2-feet. The change also reduced the vessel’s freeboard which lowered hull openings by the same distance. The MSC’s decision to not classify the conversion as a major modification meant EL FARO was not required to conform to applicable 2006 U.S. and international standards (e.g., CFR, ABS SVR, and SOLAS) in conjunction with the conversion work

From p-57

At the time of the accident voyage, EL FARO had a valid International Load Line Certificate
(ILLC) issued by ABS on January 29, 2011, which assigned a summer load line molded draft of 30’-1-5/16” (30’-2-3/8” keel draft) corresponding to a 1966 Type “B” vessel freeboard of
12’-0-15/16” from the 2 nd deck. 69 Prior to EL FARO’s 2005-2006 conversion to LO/LO service, the assigned summer load line molded draft was 28’-0” (28’-1-1/8” keel draft) corresponding to a freeboard of 14’-1-3/8” from the deck.

so less reserve buoyancy and lower downflooding points but no increase in minimum intact or damaged case righting arm? sounds like the USCG giving a nice gift to TOTE Jacksonville…

nice gift to TOTE but what about the 33 who perished? a gift to them? I don’t think so

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A decrease in freeboard of over 2 feet had some detrimental effects on the El Faro’s parameters. Due to this the ship had a limited available freeboard which is bad,

A decrease in freeboard has no effect on the stability of the vessel up to the angle of heel at which the original deck edge became immersed, but beyond this angle of heel all of the righting levers will be decreased. The maximum GZ and the angle at which it occurs will be decreased as also will be the range of stability.

With decreased Freeboard:

  • GM(t) and GZ decreases.
  • Range of stability decreases.
  • Deck edge immerses earlier at smaller θ.
  • KB increases.
  • Decreased distance to ventilation holes.