Monday, May 26, 2008

EPIRB failures, where's the beef?

Well looks like we drew some fire from PANBO Marine Electronics
on our EPIRB story. Why am I not surprised?

I have to admit after reading Ellison's hatchet job of an article I was pretty hot. Neither John Konrad, nor I, are writing about these events for our own gain. We are not ringing alarm bells and we are not blowing smoke.

The issues we've raised are real and important to close the gap on an alert system that has saved many mariners over the years.

Before we went to print on the EPIRB we talked with the USCG, NOAA and even the NTSB as well as survivors of marine accidents. We all believe in the importance of having the EPIRBs and as we said their success rate speaks volumes for the device and the COSPAS-SARSAT System.

However there is an appearance presently of some important gaps that need to be addressed. One of these issues is a post-mortem examination and investigation when a EPIRB has been reported failed and has been recovered. This post-mortem examination and investigation needs to be performed by an independent regulatory agency, namely the United States Coast Guard, since by law it is the entity required to conduct a failure analysis of all USCG certified and inspected life safety equipment.

Mr. Ellison is under the belief that there are not enough marine electronics on the market to accertain a failure rate. Well, that is just smoke .... According to NOAA there are some 70,000 + EPIRBS in the registry. Ok, let's say 20,000 are in reality no longer used/operational, yet they remain on a current registry. They need to be purged. That still leaves 50,000 registered and that is plenty to establish any failure rates and/or false alarm rates. Do we believe that the manufacturer should be allowed to review the post-mortem examination? Of course we want them as parties, but unlike Mr. Ellison, we do not believe that the regulatory agency should be looking over the manufacturer's shoulder while the manufacturer performs the post-mortem examinations. That scenario needs to be reversed.

There are all kinds of statistics that are gathered about accidents involving on-land vehicles.. They include statistics on life-saving devices, i.e. air bags, brakes.. Why should marine vehicles be less important when this life-saving equipment is made mandatory on some vessels (and as a safety-line to others who buy them for times of possible peril)? Once bought and installed, our lives are entrusted to how well they work..!! We may have life-vests aboard that will keep us afloat, but if there's no one that will ever find us because of EPIRB failure, why not just take the vests off and end it quicker?

We also find it interesting that the writer Ben Ellison took the liberty to write his article so quickly that he was not remotely thorough in his research. He wrote with absolutely no reference to any facts that either John Konrad or I might have... His only "source" seems to have been ACR, the EPIRB manufacturer. NASA has zero info on this topic, so that hardly counts as a source. An article written from one viewpoint is hardly unbiased. If he didn't want to put any REAL research into his article why write it? You have to wonder if he created an article out of thin air.. just to have something to write about that day?

But, Ellison asks "where's the meat"?

STATEMENT: With regards to the Sean Seamour II, Mr. Ellison posts, "ACR tells me that they offered to test the unit which was mistakenly attributed to an Alabama registration, but the Seamour's owner declined."

EXPLANATION: Well Ellison, that is not true. Mr. deLutz never told ACR that he declined their offer. What Mr. deLutz has done is to keep his options open. He never told ACR yes or no. Ellison would have learned this if he had, as a boating journalist, done the responsible thing and checked with Mr. deLutz to ascertain the truth. However, he did not do that. He simply took the word of ACR and ran with the story he thought he had. It seems that was part of Ellison's game to discredit our report. Ellison goes on in an attempt to explain away some of the other reports of EPIRB failures, but ends up answering his own question.

The fact is neither we, nor Ellison, know the true cause of any of these failures!! Although HE missed it entirely, THAT is the entire point of our investigation. Yes, some have conducted limited testing, However, that is not what we are asking for.

Ellison asks "where's the meat?" Lets take a look.

STATEMENT: Ellison states "F/V Papa George: The assumption here is that the automatic hydrostatic activation found on Class A EPIRBs failed to work. But isn't it possible that the unit failed to float free of the vessel? It's really hard to mount an EPIRB where it will float free regardless of what the boat does, especially on fishing boats with lots of rigging. It strikes me that it's always better to manually activate an EPIRB if possible."

EXPLANATION: Well, first of all, if the positioning of the automatic hydrostatic cradle is a problem on most fishing boats, then THAT is something that needs to be reviewed! How else does one review something like this unless post-mortem examinations are done? Lets not mention the simple fact that locating the automatic hydrostatic cradle and release of theEPIRB is one of the manufacturers recommended modes of release and prescribed by code. Yes, manual release would be nice, but in many cases when all hell is breaking out, or a crew has limited time to abandoned ship, or the crew has no experience with releasing an EPIRB, the auto-release may be the best (or only) mode of deployment. Having a redundant EPIRB to manually release attached to a raft would be an even better option.

But once again without a post-mortem examination of a failure report, we will not know how to improve the system.

STATEMENT: '* F/V Illusion: An initial USCG press release: "The Rescue Coordination Center, (RCC) in Juneau was notified that the crew was in trouble when the fishing vessel's registered electronic position indicating radio beacon, (EPIRB) was picked up by satellite shortly after the Illusion's crew abandoned ship. The EPIRB did not initially give a fix on the crew's location, and the RCC was able to ascertain that the Illusion had been fishing in Makushin Bay through further investigation." There's no evidence of failure here at all; this is how EPIRBS without the GPS option work. First, a geostationary satellite gets the distress message, and then LEO sats use Doppler shifting to get a location, which generally takes about an hour".

EXPLANTION: "Here is the key phrase to consider "The EPIRB did not initially give a fix on the crew's location, and the RCC was able to ascertain that the Illusion had been fishing in Makushin Bay through further investigation." The question is WHY did the EPIRB
emit a signal? The EPIRB once launched should transmit a signal within a quarter of a second and then transmit every 50 seconds and then shut down to conserve battery power for twenty minutes and then reactivates to repeat the cycle. The USCG should not have had to do further investigation to find out that the Illusion was fishing in Makushin Bay, because the initial signal should have enabled the calculation for the general geographical location, enough to at least launch the Alert C-130 or alert aircraft to obtain a fix. In the case of a GPRIB the extra positioning data accelerates the localization....

STATEMENT: " F/V Ellie B: Robin may have made a mistaken link here—I see no Ellie B.—but he uses this BoatUS page elsewhere in his report. It's about issues with the GPS option on some EPIRBs and PLBs that were discovered back in 2003. Extensive research was done on this, especially by Doug Ritter, and some gear was updated as a result. But throughout that process, no one found any problems with the basic EPIRB functionality. The GPS option can definitely speed up a rescue, but it is not necessary to one. "

With regards to the * F/V ELLIE B"
, first there was no process, since there was no investigation because there was no loss of life. But as you can read the EPIRB is reported not to have launched because of a faulty trigger mechanism. Again there is no post mortem report. Mr. Ellison wouldn't you think that something like this should and needs to be noted in an official casualty report?

While yes much research was done by Doug Ritter and some changes were made. But once again the post-mortem examination needs to be undertaken by the United States Coast Guard, the governing body, not just an advocate for boaters safety.

We applaud Doug Ritter's endeavors, because he proved that if post-mortem examinations are done, they can effect some much-needed change. His actions need to become standard practice when a failure report is indicated. Of course Ellison needs to read "The Sea's Bitter Harvest" to understand what the Coast Guard Investigators recommended as changes to the program.. and what was actually changed/not changed. Once again we support having all parties involved in a failure analysis. What we do not support is having the examination performed by the manufacturer in its own laboratory, as the only unquestioned, post-mortem testing of an EPIRB, until after tests are conducted by the lab of the governing body. Otherwise, where is the objectivity? Having the manufacturer playing watchdog for it's own devices, places the United Coast Guard in a very awkward and uncomfortable position.

STATEMENT: Lastly Ellison writes, "F/V Sav-A-Buck
: This is an initial newspaper report suggesting that an EPIRB that 'should have signaled the Coast Guard that a lobster boat was sinking off the Isles of Shoals Sunday failed to send a distress signal when it hit the water…'Another hydrostatic activation failure? A more recent article suggests that the boat capsized—which would certainly make floating free difficult. But later the EPIRB floated up on a beach with other debris, so perhaps we'll learn more."

EXPLANATION: Are you aware you've answered your own query, Mr. Ellison..? Yet you say this is nothing more than hubbub.. hmmmm. Read what YOU wrote, never mind what I've written.

The point is... that if there was another hydrostatic activation failure, then a post-mortem examination needs to be done by an unbiased lab... and THAT is the "MEAT" we are seeking.

E x a c t l y.