I offer to you and the USCG MBI my perspective of the investigation for the loss of the S S El Faro. I do not have any maritime experience; however, my experience as described from the attached e-mails below qualifies me to make an educated statement pertaining to the deficiencies which I was reading in the most current memorandum from the Coast Guard - Vintage Vessel NCOE Marine Inspection Notice. The information/guidance sheet for Marine Inspection Notices identifies deficiencies of specific inspections. It identifies the need for changes, updates, rewrites and continuity between the USCG Vintage Vessel NCOE, The American Bureau of Shipping, 46 CFR, ASME and CG-840 MI Book.
I have reviewed several of the Notices and I will point out the need for improvement individually. The first title presented to you is “Overspeed Testing of Steam Driven Feedwater Pumps”. The guidance states that an update to MSM Vol II is currently being updated. This Notice was printed in 2013; yet, Chief Engineers were given these guidelines at the end of 2015.
Regarding the Notice pertaining to “Speed Limiting Governors and Overspeed/Low Oil Shutdown”; although they are routinely checked during inspections; both the MSM and CFR’s are not clear on the overspeed inspection requirements. The Notice also states that their inconsistency in the inspection guidance concerning overspeed protection devices.
Finally, the “Setting of Safety Valves” – The ABS rules are not consistent with the USCG Regulation regarding safety values. The standards that I observed which need updating were not necessarily the reason for the sinking of the S S El Faro. However, the need for proper inspections is critical for maritime safety. I request that the MBI expeditiously make the necessary changes to the Marine Inspection Notices. They are now over three years old, and need to be changed.
On a personal level, I was driven to write to the MBI after the testimony of TOTE executive, Mr. Keller. Having 51 years in transportation, benchmarking a corporation’s safety record by the delivery of goods and services to their customers is archaic by safety standards, much of the responsibility for the safety of the vessel fall on the shoulders of the Captain. The Captain is responsible for accident investigations, near misses, safety meetings and ensuring job briefings are performed. I find it difficult that a major corporation places and deflects all the responsibility of safety to the Captain. Yet, after the sinking of the S S El Faro, Mr. Keller acknowledged that it was a tragic loss. Mr. Keller was only waiting for the USCG MBI and the NTSB for answers. This, to me and most likely many people who are truly consumed with safety, will review policies and procedures within the company, then make recommendations to improve their safety culture without following an internal safety investigation. A company fails to change instinctive and habitual at-risk behavior in the workplace.
“The true test of a man’s character is what he does when no one is watching”, American Basketball Coach John Wooden said. Companies face this every day. Companies cannot monitor the employees around the clock. Even if they could, supervision is not as good as driver of safety. Changing habitual and instinctive behavior from the outset is. Safety in Progressive Corporations in America will always look at fixing the problem, not fixing the blame.
The Safety of America’s Mariners are depending on the recommendations from this USCG MBI. Designated Safety Administrators/Directors are needed with every corporation. Our son, Richard Pusatere, always told his mother and me that he respected the licenses of the Deckies. In turn, the Deckies respected the Engineer’s Licenses. This begs the question – Who can the crew depend on?
I thought that writing to the board was a bad idea; however, I recently read a quote from Mark Twain that inspired me to write this letter, “You’re never wrong to do the right thing”.