b'SAFETYMATTERSAlso suitable for use in Recreationalworking order is critical to egressaboard, a watchman is required by Vehicles. from a compartment used by pas- law and regulation.Many operators Emergencysengers or crew. have had Certificate of Inspection Lack of emergency lighting and/or inef- Not enough suitable watchmen con- amended to reflect the verbiage ficient emergency lighting.Emergencyducting patrols.When operating,in the statute, 46 U.S. Code 8102 lighting is not only required inand that means underway, at theThe owner, charterer, or managing certain spaces, but its properdock, or anchored, with passengersoperator of a vessel carrying pas-sengers during the nighttime shall keep a suitable number of watchmen in the vicinity of the cabins or state-rooms and on each deck to guard against and give alarm in case of a fire or other danger.While that specific language is not the same as 46 CFR 122.410 or 185.410 in Subchapters K and T, respec-tively, there remains a duty to post watchmen, who will make rounds of the vessel in the overnight hours.Emergency instructions not posted. Crewmembers are drilled using the emergency instructions required to be posted.They serve as a reminder and cannot be used in that capacity if they are not posted.Fire drills not conducted and/or logged properly.Not logging drills takes away any objective evidence the owner/operator has that drills are being conducted. As owners and operators, you know your vessels best.It is incumbent on all of us to take a fresh look at our vessels and identify any areas of concern.It is better to be proactive rather than reactive in this day and age.Additional Coast Guard ActionsAs a result of the loss the M/V Conception and 34 people, the Assistant Commandant for Prevention Policy chartered the Small Passenger Vessel Inspection Reform Team to inves-tigate the way domestic passenger vessels are inspected and certificated. This approach is similar to how the Coast Guard looks at their oversight of the deep draft fleet after the loss of the M/V El Faro. PVA is committed to working with the Coast Guard in iden-tifying areas of improvement.n32NOVEMBER 2019FOGHORN'