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nificant degree of protection from oil pollution in the event of grounding and/ or collision accidents.” In sum, the Coast Guard, based on legislative and technical considerations, should mandate either double bottoms or double hulls on new U.S. tankers in the domestic trade.

Previously, the Coast Guard has argued against mandating double bottoms because historical tanker accident data shows no clear-cut expectation of side vis-a-vis bottom damage, therefore no particular segregated ballast configuration should be mandated. But this effort seems more like a mathematical exercise than a practical assessment of hazard potential, especially since double hulls are required on liquified natural gas vessels and vessels carrying certain hazardous substances in bulk. Accident data on such vesels is practically nonexistent, yet defensive space configurations are mandated.

I have also been informed that the defensive space formula contained in the proposed rule (1) seems to weight collision events more heavily than groundings (.65 to .45), and (2) assumes that a double side has greater cargo outflow preventing qualities than a double bottom. Is this correct? If so, on what basis were these assumptions made?

In closing, I urge the Coast Guard to once again reappraise its 'defensive space'concept. Error should be on the side of pollution prevention in this instance. Nothing less than the public's confidence in your rulemaking activities is at stake. Sincerely,

WARREN G. MAGNUSON,

Chairman.

TANKER ADVISORY CENTER, New York., N.Y., February 18, 1976.

WORLDWIDE TANKER CASUALTY RETURNS, 1975 Tanker total losses rose to record heights in 1975. There were 22 tankers of 815,000 deadweight tons reported as actual or constructive total loss. The corresponding loss ratios are 0.25% of deadweight tons and 0.51% of number of tankers. Strandings, fires and explosions were the cause of 14 of the 22 losses. Tankers constructed during the period 1951–1955 suffered loss ratios significantly higher than tankers built in earlier and later periods, continuing a ten year trend of high loss ratios for this class of tankers.

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Number of losses

Partial
and total 1

13
30
41

19
15
32

21
22

52
61
61

Weather damage:

1975.
1974.

1973.
Strandings:

1975.
1974.

1973.
Collisions:

1975.
1974.

1973.
Contact:

1975
1974.

1973.
Fires and explosions:

1975.
1974.

1973.
Damage to machinery, shafts, propellers,
etc.:

1975.
1974.

1973.
Other casualties:

1975.
1974.

1973
Totals:

1975.
1974.
1973.

45
87
101

37
32
58

188
267
340

1 Includes actual and constructive total losses.

The number of reported tanker casualties is declining. This is probably due to the practice of including deductibles ranging from $10,000 to $60,000 in tanker hull & machinery insurance policies becoming more wide spread. The slow-down of nearly all tankers and tie-up of over 500 surplus tankers are also contributing factors.

All the casualty data was obtained fom Lloyd's List published by Lloyd's of London. Tankers, ore/oil carriers and bulk/oil vessels of 6,000 deadweight tons and over were included in the statistics. And liquid gas carriers of 6,000 deadweight tons and over were included if their liquid gas capacities were less than 80% of their total cargo capacity.

Copies of their report in Lloyd's List on any casualty can be obtained from the Tanker Advisory Center. There is a charge for this service.

The following table shows the growth of the worldwide tanker fleet and the total losses suffered during the past 12 years. The loss ratios as a percent of deadweight tons and of number of tankers are shown graphically, with a breakdown between actual and constructive total loss ratios.

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The next table compares the loss ratios for tankers constructed during different periods of time. Tankers built during the years 1951 to 1955 have the highest loss ratios. There were 830 of these tankers constructed and about 450 are still in service.

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The statistics on total number and tonnage of tankers for the various years shown in the tables was obtained from The Tanker Register published by H. Clarkson & Company of London.

INTERNATIONAL BROTHERHOOD OF TEAMSTERS,
CHAUFFEURS, WAREHOUSEMEN, & HELPERS, OF AMERICA.

Washington, D.O., March 23, 1976.
Hon. WARREN G. MAGNUSON,
Chairman, Committee on Commerce,
U.S. Senate, Washington, D.O.

DEAR CHAIRMAN MAGNUSON: Our organization, through its Marine Division, represents many workers affected by the Boats and Waterways Safety Act of 1972. Because these workers have had difficulty with the U.S. Coast Guard in connection with the administration of this law, we appreciate the opportunity to submit comments to your Committee.

Initially, it is our understanding that when assuming control of rulemaking and regulation of inland waterways, including rivers, the U.S. Coast Guard pledged to the Congress to secure administrative personnel from among experienced boat officers. This has not been followed. The result has been an evergrowing force of enforcement officers with little or no practical knowledge of the industry which they control.

Another concern is this : essentially all input by labor and industry is rejected at the rule-making level and only those rules and regulations desired by the U.S. Coast Guard are finally adopted.

For example, the Coast Guard's Vessel Traffic Service, recently put computer equipment into effect in the New Orleans-Baton Rouge area. We understand this equipment was actually contracted for without seeking comment from labor or management regarding rule-making.

The effect of this and similar proceedings becomes one of the U.S. Coast Guard making the rules and setting about to enforce these rules, with little or no concern for the expertise of those who are regulated by the Agency.

We believe the manner in which the U.S. Coast Guard has exercised powers has been harmful not only to our members but the industry as a whole; and we would suggest your Committee, as part of the oversight function, clearly stress the need for a higher degree of consideration for our view by the Coast Guard in the rulemaking process. Thank you for your consideration in this matter. Sincerely,

FRANK E. FITZSIMMONS,

General President.

(From the Seattle Times, Sept. 22, 1975)

TANKER SAFETY—Is THE COAST GUARD LEADING OR TRAILING ALONG?

Washington-Within the next few days, the Coast Guard will publish regulations governing the construction and operation of oil tankers that navigate in domestic waters. These will be final regulations, of particular importance to all those who live by the sea. The rules ought to be the best and wisest that can be drafted-and there is much concern that they are not.

The tanker regulations have serious meaning for all mankind. The world consumes some 2.7 billion tons of petroleum annually; of this amount, roughly 1.7 billion tons must be transported by tanker. On any given day, 30 to 35 million barrels of petroleum products are on the seas.

The world tanker fleet consists of 5,300 vessels. Of these, only 623 are "supertankers," those in excess of 100,000 tons; but the supertankers have greater deadweight than all the others put together. About 700 more supertankers are under construction or under contract.

They are enormous vessels-as large as aircraft carriers, drawing 60 to 90 feet of water-and they are enormously efficient. Highly automated, manned by crews of only 25 to 35 men, the supers ply the sea lanes of the world. And they are a source of world concern.

According to a recent study by the Office of Technology Assessment, the tanker fleet as a whole pollutes the seas with more than half a billion gallons of oil every year. Two thirds of this pollution results from standard operations, chiefly the washing of tanks; another part results from drydock operations; the remainder results from 600 to 700 accidents each year that leak 200,000 tons of oil into the oceans.

The worst damage from spillage occurs close to shore, where the oil suffocates marine life, kills birds, and does vast harm to the whole ecosystem on which fish, crabs, oysters, shrimp and other marine creatures depend. Less is known of the harm done far at sea, but common sense would suggest that cumulative oil pollution is cause for apprehension.

Most of the world's tankers are under foreign registry-Liberian, Panamanian, Greek, Norwegian, Japanese and British. The United States fleet is only the seventh largest. The United States is thus not able to control international standards, but our position as the largest importer gives us significant edge. The Coast Guard could lay down stiff regulations for the protection of our waters and make the regulations stick.

Are the forthcoming regulations stiff enough? Experts disagree. The Coast Guard could have required double bottoms. Two years ago, it was strongly in favor of such a requirement. Now it has retreated. These will not be required.

Rear Adm. Sidney A. Wallace says the feeling now is that the original assumptions were not valid ; double bottoms may present safety hazards (because of trapped vapors), and may create navigational hazards also. A double-bottomed vessel, having run aground, is difficult to salvage. There are arguments both ways.

Neither will the Coast Guard regulations require double hulls. Requirements as to segregated ballast reportedly are mild. Little will be demanded in terms of braking and stopping devices. One of these behemoths, traveling at 16 knots, needs three miles to stop; at 6 knots, approaching port, a supertanker has to have three-fourths of a mile.

Senator Lee Metcalf of Montana says the regulations amount to a sweetheart deal between the Coast Guard and the petroleum companies. The Coast Guard's rules plainly are derived directly from rules proposed by an industry committee created by the American Petroleum Institute.

allace denies that this technical study committee was a formal "advisory committee,” subjected to federal procedural rules, but the distinction is not critical. It appears evident that so far as these regulations are concerned, what the industry wanted, the industry got.

Double bottoms, double hulls, braking devices, segregated ballast, added radar, tough requirements for the training and licensing of tanker crews—all these would cost money. The retrofitting of old vessels to comply with new regulations would be especially expensive and time-consuming.

But if the world is going to have to live with supertankers, the world has a right to demand that, whatever the cost, their operations be subject to strict rules that will promote safety and deter pollution. The United States, through

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