On Monday, September 2, 2019, approximately 3:14 a.m. Pacific daylight time, U.S. Coast Guard Sector Los Angeles/Long Beach received a distress call from the 75-foot wood and fiberglass constructed commercial diving vessel, Conception, with 39 persons on board, 6 of which were crew. The Conception was owned and operated by Truth Aquatics, Inc., based in Santa Barbara, California. The Conception was classified by the Coast Guard as a small passenger vessel offering passengers dive excursions in the waters around the Channel Islands off the coast of Santa Barbara. The accident voyage was a three-day diving trip to the Channel Islands. On the last night of the voyage, the vessel was anchored in Platts Harbor off Santa Cruz Island, 21.5 nautical miles SSW of Santa Barbara, when it caught fire. Weather conditions were reported as light and variable winds, patchy fog, 2- to 3-foot seas and air and water temperature about 65°F.
Thirty-three passengers and one crewmember died.
The National Transportation Safety Board, NTSB, has authority to investigate and establish the probable cause of any major marine casualty or any marine casualty involving both public and nonpublic vessels under CFR49 section 1131. The NTSB does not assign fault or blame for a marine casualty; rather, as specified by NTSB regulation, investigations are fact-finding proceedings with no formal issues and no adverse parties and are not conducted for the purpose of determining the rights or liabilities of any person. Reading CFR49 Section 831.4. Assignment of fault or legal liability is not relevant to the NTSB’s statutory mission to improve transportation safety by conducting investigations and issuing safety recommendations. In addition, statutory language prohibits the admission into evidence or use of any part of an NTSB report related to an accident in a civil action for damages resulting from a matter mentioned in the report.
The United States Coast Guard, USCG Marine investigators carry out investigation of commercial vessel causalities and reports of violations per CFR46 chapter 61, 63, and 77. The primary purpose of the USCG investigation is to ascertain the cause or causes of the accident, causality or personal behaviors, or if any violation of federal law has occurred and to determine if remedial measures should be taken. The USCG is authorized to enforce incidents involving vessel personnel, boating accidents, waterfront facility causalities, deepwater port causalities, marine pollution incidents, accidents involving Aids to Navigation and accidents involving structures on the Outer Continental Shelf.
The results of their investigations play a major role in changing current law, developing new law and regulations and implementing new technologies. During the course of the USCG Marine Board of Investigation, MBI, the panel must decide the factors that contributed to the accident, whether there is evidence that any act of misconduct, inattention to duty, negligence or any willful violation of law on the part of any involved person contributed to the causality.
In some instances, the MBI will identify pressing safety issues and will issue safety alerts that are available to the public through the Coast Guard Office of Investigations and Causality Analysis website. In parallel, criminal investigations by the Coast Guard Investigative Service, CGIS, Federal Bureau of Investigation, FBI, Bureau of Alcohol, Tobacco, Firearms, and Explosives, ATF, and the Department of Justice, DOJ are working in coordination with the US Attorney’s office.
On September 10, 2019, the United States Coast Guard issued a marine safety bulletin based on their preliminary investigations. On September 12, 2019 the National Transportation Safety Board, NTSB, released a preliminary report. The preliminary investigations indicate a strong possibility that a charging station for cameras, cell phones and other devices with lithium-ion batteries could have been the source of the ignition. The USCG Marine Safety Information Bulletin, MSIB 008-19 identifies regulations related to firefighting, lifesaving, preparations for emergencies and means of escape and among other items suggests that owners and operators immediately reduce potential fire hazards and consider limiting the unsupervised charging of lithium-ion batteries and the extensive use of power strips and extension cords.
Interestingly, in April of 2013, the USCG issued MSIB 003-13 after a marine causality investigation of two separate stateroom fires onboard U.S. flagged container ships revealed the source of the fires were attributed to the use of surge protector power strips that had been plugged into the ships lighting circuit. At that time the USCG recommended owners and operators examine the risks associated with the use of power strips aboard their vessels, and if necessary, ensure their organizations have policies and procedures relating to their use. Vessels should have defined procedures for checking the condition and grounding capabilities of personal/portable electrical equipment and trained shipboard personnel should be assigned to check and approve all power strips in use or those brought on board for compatibility with the vessel’s electrical distribution system prior to use. Routine checks of switchboard and distribution system 120 VAC ground detection systems are necessary to detect the presence of grounds that may cause similar circumstances with non-marine type power strips. These recommendations were not mandated rather simply an advisory based on lessons learned from the casualty. Owners and operators may wish to purchase equipment meeting MIL Performance Specification MIL-PZRF-32167A which incorporates ASTM F1507 (Standard Specifications for Surge Suppressors for Shipboard Use) and UL 1449 (Safety Standards for Surge Protective Devices).
A fire on board a vessel is one of the worst incidents that can occur and suppressing the fire takes precedence over all other emergencies on board. Every commercial and recreational vessel has a minimum number of handheld fire extinguishers based on the length of the vessel. Do you know where yours are located? Are they operational? Do you know how to use them? I cannot answer the first two questions but I can answer the last one. Remember the mnemonic PASS; Pull (pull the pin), Aim (at the base of the fire), Squeeze (the trigger), Sweep (at the fire). You will empty a small B-1 extinguisher in a matter of seconds but will effectively suppress a small fire.
The USCG requirements for fire suppression equipment on board recreational vessels is laid out in the Code of Federal Regulations, Title 46 CFR Chapter I Subchapter C Part 25 Subpart 25.30, USCG approved marine type fire extinguishers are required on boats where a fire hazard could be expected from the engines or fuel system. Fire extinguishers are classified by a letter and roman number symbol where the letter indicates the type of fire the unit is designed to extinguish and the number indicates the amount of the extinguishing agent contained in the extinguisher; the higher the number, the greater the amount of agent in the extinguisher. The USCG approved extinguishers required for boats are hand held portable, have either B-I or B-II classification, and must be provided with a mounting bracket, although it is not required that the extinguishers be mounted or be in a readily accessible location. Vessels 8- to 12-meters in length (26- to 39-feet) are required to have two B-I extinguishers and vessels 12- to 20-meters (39- to 65-feet) are required to have three. If the vessel is fitted with a fixed engine room fire suppression system then we can reduce the number of hand held extinguishers by one.
Most of you probably remember the three classes of common fires. Class A is ordinary combustibles such as wood and paper and the burned material leaves an ash, Class B is flammable liquids such as gasoline, alcohol, and diesel, and class C is electrical. However, you may have missed two classes; Class D and Class K. A class D fire is combustible metals such as Magnesium, Titanium or Lithium. A Class K fire is cooking oils and fats. These last two categories require different fire suppression systems than we are required to keep on board but many of us do have cooking oils and lithium (modern laptop or cell phone batteries for example) on board our boats. A good example of using the wrong extinguishing agent on a fire is putting water on a class D fire. Water will accelerate the reaction, the fire will burn hotter, and the source may even explode.
Looking at the chart on page 51, you can quickly see that the USCG required B-I with its 2 pounds of dry powder is relatively small and not suitable for many possible sources of fire. A B-II extinguisher with 10 pounds of suppression has 5 times the extinguishing agent and is still easily portable. Hand held portable extinguishers will be either a Size I or II; sizes III, IV, and V are considered semi portable systems and are fitted with hoses and nozzles.
It is also important to consider locations where the extinguisher can be easily reached. For example, at or near the steering station or in the galley or engine room, but away from locations where a fire may likely start. Extinguisher markings can be confusing because one extinguisher can be approved for several different types of fires (A, B, or C). For example, an extinguisher marked Type A, Size II; Type B; C, Size I is acceptable however a Type B-I extinguisher is a much better choice to have on board. In order to meet the USCG requirements, the extinguisher must state “Marine Type USCG, Type A, Size II; Type B; C Size I.” and will have a USCG approval number. In any case, make certain that Type B is indicated.
A fire requires three things for maintaining combustion, oxygen, fuel and heat. Remove any one of the three and the fire will not burn, the triangle illustrates these three elements. For example, using water on a class A fire will cool the fuel and extinguish the fire. Cover a fire with a blanket and you remove the oxygen.
For many years the concept of fire was symbolized by the triangle of combustion and represented fuel, heat, and oxygen. Further fire research determined that a fourth element, a chemical chain reaction, was a necessary component of fire. The fire triangle was changed to a fire tetrahedron to reflect this fourth element and represents the addition of the chemical chain reaction. Once a fire has started the chain reaction sustains the fire and will continue until one of the elements is removed. Halon, or a clean air alternative, is a common engine room fire suppression agent and creates a barrier of inert gas that blocks the chemical chain reaction.
The National Fire Protection Association has also developed fire suppression standards for the marine industry. Standard 302 provides fire and life safety requirements for boats (less than 300 gross tons) that are used for pleasure and commercial purposes. Provisions apply to (1) elimination of ignition sources, (2) ventilation of accommodation spaces, fuel tank compartments, and machinery spaces, (3) use of combustible materials, (4) fire-extinguishing equipment and fire exits, (5) control of fire-extinguishing agents in machinery spaces, and (6) mitigation of carbon monoxide hazards. Specific criteria cover hull, engines and engine exhaust systems, cooking and heating appliances, electrical systems, lightning and fire protection and carbon monoxide detection.
ABYC Standard A4
The American Boat Yacht Council standard A4 outlines firefighting equipment guidelines. For vessels under 20-meters in length the ABYC compares with the USCG requirements but adds one additional extinguisher and suggests locations for each of the four. The ABYC standard also requires either an engine room fixed fire suppression system or provision for discharging a portable fire extinguisher directly into the engine room without having to open a hatch.
For vessels between 12- and 20-meters the ABYC suggests 4 ABC extinguishers with one outside the engine room, one at the helm, one in the galley and one in the crew quarters. For boats between 8- and 12-meters that number is reduced by one eliminating the crew quarter extinguisher.
Boats contain materials that are mainly included in Classes A, B and C. For this reason, ABYC and NFPA recommend type ABC extinguishers except when the extinguisher is specifically intended for machinery space protection where they specify type BC. The USCG only requires type B aboard your boat.
I would bet that most boaters do not think much about fire safety or fire suppression on board their vessels. Most boats that I conduct a Vessel Safety Check, have the minimum required handheld extinguishers on board however I usually find they may or may not be serviceable and are usually stuffed in a locker or drawer. And even if they are serviceable, there is no requirement that they be easily accessible in proper locations. Fire safety, at its most basic, is based upon the principle of keeping fuel sources and ignition sources separate and keeping sufficient fire suppression equipment readily available.
At this time the USCG does not have any guidance on the suppression of lithium-ion battery fires so we can look to other sources that have to deal with this new hazard. The Federal Aviation Administration, FAA, has issued a written advisory on dealing with in flight battery fires. Apparently any given flight may contain hundreds of lithium-ion cells in phones and laptops and that many rechargeable devices involved in these fires such as wireless headphones and especially e-cigarettes which were not even on the market a few years ago. On average the FAA reports that there is one lithium-ion battery fire on board an aircraft every 11 days. Battery fires are particularly dangerous because they burn very hot, they can emit toxic by-products. They tend to flare up even after it seems like they’ve been extinguished. The FAA guidance indicates the best way to cool a runaway battery is, believe it or not, with plain old water. After extinguishing the fire, douse the device with water or other nonalcoholic liquids to cool the device and prevent additional battery cells from reaching thermal runaway. So, what kind of fire extinguisher should you use in this scenario, lithium-ion batteries are considered a Class B fire, so a standard ABC or BC dry chemical fire extinguisher should be used. lithium-ion batteries contain liquid electrolytes that provide a conductive pathway, so the batteries receive a B fire classification.
It will be many months before we see the final report from the NTSB and generally the USCG findings are even more delayed. As I was preparing this article it was announced that the hull of the sunken vessel has been raised, placed on a barge and moved to a location where the investigators will try to determine the root cause of the fire. I personally have made many dive trips aboard the Conception and as I recall, she was a well-designed vessel and was professionally run. Of course, back then we did not have the plethora of electronic devices all needing to be recharged.
Winter boating can be much fun, but it is also a time when we tend to find creative ways to keep warm. Be careful with portable electric heat sources and make certain they are safe for use aboard the boat. If you have a propane heater, check the CO detector for proper operation and do not use the heater in any enclosed space.
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