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From:
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TOTE Services, Inc.
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To:
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NTSB
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Date:
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5/7/2018
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Response:
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-From Philip H. Greene, Jr., President, TOTE Services, Inc. and Timothy Nolan, President, TOTE Maritime Puerto Rico: This letter acknowledges the e-mail of February 7, 2018, in which the Executive Secretariat, Office of the Managing Director, National Transportation Safety Board (“NTSB”) formally issued certain safety recommendations to TOTE Services, Inc. (“TOTE”). We have organized our responses below to correspond with the numbered safety recommendations to TOTE contained in the final report.
Please note that all of the NTSB’s safety recommendations involve changes to vessel operations or capital improvements that exceed existing minimum standards set by law. Accordingly, as discussed further below, some recommendations, if adopted, may require capital improvements or other changes to vessels that are within the exclusive purview of the vessel owner, not the vessel operator. Accordingly, for vessels we manage that are not owned by one of our affiliated companies, we are contacting these external customers by letter to make them aware of these recommendations, so that they may consider these issues and initiate whatever changes they deem appropriate. Therefore, in many cases below, the response we provide only applies to the vessels that are owned by our affiliated companies. We try to make that distinction clear with respect to each recommendation.
Additionally, please note that in our Supplemental Party Submission, submitted to the NTSB on January 11, 2018, we identified a number of factual errors that were stated on the record by certain staff at the NTSB’s Public Meeting. Our intent was for the public record to be clear, but many of the errors we raised were not corrected or otherwise addressed when the final NTSB report was published. In some cases below, we point out these errors, not to be argumentative, but to ensure implementation of the changes we are making to our safety procedures are put in their proper factual and operational context.
TOTE Response: TOTE concurs with the intent of this recommendation.
Traditionally, operators looked to vessel designers and equipment manufactures to provide general information in the associated operating manuals in regard to oil operating levels. Therefore, TOTE, or any other vessel operator, would rely on the manufacturer’s guidance and expertise to define the precise operational limitations and the optimum oil levels needed to maintain operations of critical machinery for sustained conditions, i.e., heavy weather, that create significant vessel pitch, roll, or list.
To address this recommendation, we anticipate adding engineering-focused heavy weather guidance in our Safety Management System (“SMS”), specifically checklists, to reflect operational limitations of engineering machinery, and precautions to be taken in heavy weather. To the extent the manufacturers of machinery have provided recommended operational limitations and oil levels for critical machinery that best ensure their continued operation under adverse circumstances, we will incorporate such manufacturers’ recommendations into our procedures. However, we do not believe it is safe or feasible to institute, for example, a blanket policy to raise oil levels above the normal operating limits in anticipation of heavy weather. (Examples of potential negative outcomes are overfilling, resulting in leakage/spillage; and, in the case of certain equipment configurations, such as the bull gear in main propulsion systems, high oil levels an result in churning and frothing/foaming of the oil.) Accordingly, at a minimum, we will specify in heavy weather guidance that relevant oil levels are to be raised to the high end of normal operating range (or other manufacturers’ recommended operational limits), in order to improve potential reliability during heavy weather.
We will keep you apprised of our progress in completing this effort.
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