Action Plan for Implementing the Observer Safety Program Review Report Recommendations
The Action Plan for implementing the Observer Safety Program Review recommendations provides a road map outlining our timeline to address these recommendations as well as a progress report outlining actions that have been addressed to-date.
The independent review of NOAA Fisheries observer safety policies and protocols was released in May of 2018. The final Observer Safety Program Review report found national and regional observer safety programs in the United States to be robust, mature, and effective. It provided 118 recommendations across seven relevant observer safety categories:
- Safety reporting
- Practices and policies;
- International observers
In May 2019, the NOAA Fisheries National Observer Program released an action plan. It included updates on the implementation status of these recommendations, including those completed in 2018. Since the last update, more than half of the recommendations have been implemented. The remainder are in process of implementation or pending further assessment to incorporate into our regional and national observer safety programs.
Many of the responses to the report equate to the initiation of practices that augment standard safety protocols or ongoing safety training activities. The process of prioritizing the work to address pending recommendations, and integrate these new measures with our current safety practices, policies, and procedures is continuing. Also continuing is the long-term goal of developing standards that address safety matters in all phases of an observer’s career. After considerable review, ten of the report’s recommendations were tabled as these required substantive regulatory, legislative or policy changes.
We have completed Phase 1 of the Action Plan by assessing, categorizing and prioritizing the numerous report recommendations. We have also implemented many of the high-priority recommendations. We will continue to focus on Phase 2 and 3 of the Action Plan with the implementation of more complex recommendations such as:
- Finalizing a national rule for observer employer insurance.
- Streamlining pre-trip vessel safety checklists appropriate to vessel size and trip length.
- Updating medical clearance checklists.
- Expanding the Observer Safety Standards framework to address safety elements throughout an observer’s career.
Current status of the recommendations as of December 16, 2019.
The NOAA Fisheries Office of Science and Technology, National Observer Program Advisory Team and its Safety Advisory Committee have continued their collaboration with the Regional Observer Programs, Office of International Affairs and Seafood Inspections, Office of Law Enforcement, and NOAA General Counsel to assure the agency’s commitment in utilizing the report findings for further enhancement of an already effective and comprehensive safety program.
Over the last year, substantial progress has been made in response to many of the recommendations including:
- Developing a proposed rule to establish national minimum insurance standards that would apply to authorized observer provider employers, or those seeking authorization, in regional regulatory observer programs. The proposed rule establishes these national minimum insurance standards for observer employers and revise regional observer program regulations to reference the newly established national minimum insurance standards.
- Producing safety materials for regional observer programs designed as quick references for safety awareness and protocol on topics such as donning immersion suits, reporting on marine pollution, proper lifting techniques, and bed bug detection and mitigation.
- Providing cross training for observer safety trainers across Regional Observer Programs to develop and maintain teaching skills through exchange of staff with Marine Safety Instructor Training certification. These experienced staff provide observers with marine safety and survival skills training.
- Adoption of a recommendation and a resolution by the International Commission for the Conservation of Atlantic Tunas (ICCAT) related to the health and safety of observers in ICCAT's regional observer programs for transshipment of eastern Atlantic and Mediterranean bluefin tuna. The binding recommendation requires safety training, proper safety equipment including communication devices for observers, and an emergency action plan for each member of ICCAT with vessels participating in the programs. This recommendation will be reviewed in three years, taking into account international standards and guidelines adopted in the future. The non-binding resolution acknowledges other international processes dealing with the health and safety of observers and ensures enhanced dialog between vessel owners, crew, and operators.
The National Observer Program Advisory Team and its Safety Advisory Committee have initiated actions to address many of the regional recommendations since the release of the report. The most recent accomplishments in response to the recommendations are listed below for each region.
North Pacific Observer Program
- Provide additional hands-on training with emergency equipment, such as Bullex Bullseye system for simulated fire training in class setting and dewatering pumps for training purposes.
- Continue weekly, or more frequent, communications with NOAA Office of Law Enforcement, US Coast Guard, and Alaska Fisheries Science Center leadership to ensure that emerging issues are addressed as soon as possible. All incidents have been investigated to the fullest and after action summaries have been prepared and shared when needed.
- All North Pacific observers receive initial and refresher training with hands on practice of a U.S. Coast Guard dewatering pump and experience with a bullex live fire training system on these topics while certified to observe for the North Pacific Observer Program.
- Purchased ten handheld InReach communication devices. These devices will be added to the tools available for observers in the partial coverage sector that deploy in remote areas with limited communication options.
Southeast Fisheries Observer Program
- Record "Missed time due to illness or injury" on observer feedback forms
- Submit monthly equipment test logs.
- Perform mock safety drills on fishing vessel platforms.
- Collect data from “near misses” during deployment are incorporated into observer training.
- Update the Emergency Action Plan to include clear responsibilities for responders, providers and agency staff.
- The contracted observer provider and regional program staff have developed bed bug identification and mitigation protocols which are incorporated into annual observer training.
- Data on the presence or abuse of drugs or alcohol aboard vessels is recorded and reported directly to NOAA Office of Law Enforcement.
- All observers are required to pass the 60-second immersion suit skills tests, while fully clothed and starting with a closed suit bag, as part of the annual safety training.
Northeast Fisheries Observer Program
- Sharing the New England Emergency Action Plans (EAP) with the regional programs, which has shown to be effective in emergency situations, and assisting where applicable with the other programs to update their EAP.
- Purchased a USCG helicopter basket and acquired a USCG dewatering pump for operational purposes during observer safety training. The program is also researching acquiring a damage control training trailer, currently the program borrows or mimics the use of a USCG damage control training trailer.
- Review and update to the pre-trip vessel safety checklist in response to industry feedback while maintaining U.S. Coast Guard vessel safety requirements when deploying with observers.
- Updating and enhancing the observer safety gear checklist. This checklist is used to inspect an observer or at-sea monitor's issued safety gear when they are at a facility with trained personnel. Their personal locator beacon, personal flotation device, and immersion suit, and their associated components, are the primary safety components that are examined to ensure compliance with manufacture requirements.
Northwest Groundfish Observer Program and West Coast Regional Observer Program
- Incorporated rescue basket, dewatering pump, hands-on damage control procedures and practical fishing vessel stability training.
- Utilize the Bullex Bullseye system for simulated fire training in a class setting to reduce environmental impacts of burning diesel fuel and improve safety for staff and observers during training.
- Reviewing and updating current Emergency Action Plan.
- All regional report recommendations have been implemented and integrated into the regional safety policies and procedures. These programs continue to support development of national recommendations with their expert participation.
Pacific Islands Observer Program
- Included the provision of health insurance on the first day of observer deployment through the recently awarded observer provider service contract.
- Added hands on pyrotechnic training with SOLAS hand-flares and smoke canisters as a regular part of all initial and refresher observer trainings. Dewatering pump training is also provided in conjunction with observer safety training.
- Port coordinators receive training to refresh their knowledge base of eligibility requirements and ensure competency when conducting observer placements and safety checks on selected fishing vessels.
- Placement documents are regularly reviewed for the Hawaii and American Samoa observer programs to respond quickly and correct oversights or deficiencies.
- Deployed observer dietary and water needs are accommodated by regulations which reimburse vessels for additional costs and supported through a memorandum of understanding with the Hawaii Longliners Association.
West Coast Regional Observer Program
- Continue to perform mock safety drills.
- Practice pre-deployment checklist on fishing vessel platforms.
- Provide observers with GARMIN In-Reach satellite devices to facilitate real time, at-sea communications, improve data capture and reporting as well as facilitate communication between observer providers and observers.