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.
NOAA Fisheries initiated an independent review of current observer-related policies and protocols as part of NOAA Fisheries' voluntary Observer Safety Program Review (OSPR) to examine existing factors facing observers and at-sea monitors. While the review found national and regional observer safety programs in the United States to be robust, mature, and effective, the report also provided recommendations in seven areas: safety reporting; communications; practices and policies; training; regulations; equipment; and international observers. The Observer Safety Program Review Report was released in May 2018 and can be found here.
The processes of assessing the 118 recommendations, implementing responsive actions and the current status of each recommendation are summarized herein. A team of agency staff is now focused on implementing OSPR report recommendations. The NOAA Fisheries Office of Science and Technology (OST), the National Observer Program (NOP) and Regional Observer Programs (ROP), the National Observer Program Advisory Team (NOPAT) and its Safety Advisory Committee (SAC), Office of International Affairs and Seafood Inspections (IASI), Office of Law Enforcement (OLE), and NOAA General Counsel are working collaboratively to prioritize our response to the OSPR recommendations. They will work with observers, observer providers, international delegations and many other constituents and stakeholders during the coming year to finalize the implementation plan and continue to initiate actions in response to the report. Our intent is to assure that NOAA Fisheries continues to work diligently to address the OSPR report recommendations. However, not every recommendation is currently viable and some may not be appropriate for NOAA Fisheries to address within the scope of current resources, regulations and legislation. The following implementation plan and specific recommendation responses will be addressed in the interest of our observers’ health and safety.
Phase 1 - Immediate: May 2018 – February 2019
National and Regional Observer Programs: The first phase of response to the OSPR report was initiated in May 2018, immediately after the review was released. NOAA Fisheries publicly posted and distributed the review to NOAA Fisheries programs engaged in observer safety-related responsibilities. Personnel have been actively engaged in the report review, assessment of the recommendations, and implementation planning since that time. Some recommendations have already been implemented. As part of the immediate response phase, the ROPs and other NOAA Fisheries program offices have been working through the report. The NOP has been working in collaboration with the NOPAT and its SAC to facilitate responses to the recommendations at the national and regional level. The process of assessing, categorizing and prioritizing the numerous recommendations has been completed. Employees are now implementing initial changes in response to a number of recommendations that are of high priority. These include, but are not limited to, the actions currently listed in the following OSPR Progress Update. The current status report follows, and updates will posted on the NOP website approximately every six months.
Phase 2 - Intermediate: March 2019 –December 2019
The next phase of implementing the action plan requires specialized expertise and guidance. A small working group is developing proposed and final rulemaking to revise observer provider insurance coverage requirements. Similar working groups to address communications, Emergency Action Plans (EAP), technical equipment specifications, contract issues, regulatory provisions and legislative “fixes” will be formed. The SAC will meet in person in early 2019 to focus on challenges stemming from the recommendations.
Engaging with our stakeholders may overlap with the specialized work groups, but it is clear that many of the recommendations require the engagement of stakeholders to assure a meaningful outcome. Meetings and collaboration to address government contract/observer provider improvements will be held with approved observer employers, current observers and other stakeholders.
While the OSPR has laid the groundwork of identifying improvements to the operational and management phases of observer safety, NOAA Fisheries leadership has expressed support for creating an overall framework of “observer safety standards” to be incorporated throughout the duration of an observer’s career. The NOP has initiated the process of using current observer safety policies and procedures along with the OSPR recommendations to establish a comprehensive list of observer safety standards that will address safety matters in all phases of an observer’s career.
Phase 3 - Long Term: January 2020 forward
The “long term” portion of this action plan is to institutionalize Observer Safety Standards that were developed in phase two as part of the ROPs’ best practices, and to continually work to improve and enhance these standards. These standards will be utilized to deliver advice, expertise and training to other regional, state, or international observer program that may be receptive to using this resource.
Since the release of the OSPR, NOAA Fisheries and the NOP have implemented a number of immediate actions to address the OSPR recommendations by working with the SAC. Actions include:
- develop an implementation action plan with short and long term goals to incorporate many of the recommendations into the current national and regional observer safety programs;
- adding representation from the Office of International Affairs and Seafood Inspections on the NOPAT;
- published a Request for Information in the Federal Register to revise regulatory requirements of observer provider insurance for work-related incidents;
- support regional observer program safety trainers with marine safety instructor training certification and refresher courses through a multi-year service contract;
- enhance cross-training safety programs between regional observer programs to share best practices; and
- Implement a standardized approach for incident reporting and comprehensive after action reporting (AAR) for more serious incidents.
In addition to the reports made pursuant to current AAR protocols, observer programs now are reporting all safety-related incidents to the NOP every six months to identify and address these incidents more rapidly.
The NOPAT and SAC have initiated actions to address many of the regional recommendations since the release of the OSPR. These 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.
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.
- Updating the Emergency Action Plan to include clear responsibilities for responders, providers and agency staff.
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.
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.
Northwest Groundfish 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.
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.