The requests for comments and proposals were announced in the Federal Register:
Federal Requirements for Propeller Injury Avoidance Measures: Notice of proposed rulemaking withdrawn. Federal Register 18 Oct 2007.
full text.
- Propeller Accidents Involving Houseboats and Other Displacement Type Recreational Vessels request
for comments by the U.S. Coast Guard published in the 11 May 1995 Federal Register. Pg. 25191. This information was orginally collected in a Docket called CGD 95-041.
The docket was later changed to USCG-2001-10299. They originally received about 100 comments
- The Coast Guard extended the period for comments at request of NASBLA in the Federal
Register on 9 August 1995 Pg.40545. They received 1994 comments including over 1800 form letters.
- On 26 Sept 1995 (60 Federal Register Pgs. 49531-49532 the Coast Guard announced the availability of the 1989
NBSC Propeller Guard Subcommittee Report and that it has been placed in the docket.
- Propeller Injury Prevention Aboard Rental Boats Advance Notice of Proposed Rulemaking. Published
in the 26 March 1996 Federal Register. Pgs. 13,123 - 13,125. This notice requests comment and announces several public meetings for input toward potential future regulations
in this area. Rental houseboats are specifically discussed.
- A series of Public Hearings were held in the Spring of 1996 to solicit comments.
- The Coast Guard Requested Comments on the Effectiveness of Specific Devices in regards
to the Propeller Injury Prevention Aboard Rental Boats Advanced Notice of Rulemaking above. Published in Federal Register 28 April 1997 Pgs 22991-
22992.
- The Coast Guard announced they only received two comments for their request for information on the effectiveness of specific devices above, and are
extending the period for comments. Published in Federal Register 21 August 1997 Pg. 44507.
- Comments to the Docket above can be viewed by entering "10299" in the search box on the Dept. of Transportation web site.
- One comment of particular interest is from the Institute for Injury Reduction (IIR), a group of lawyers that became active against propeller injuries for a few years in the mid 1990's. Their letter includes a copy of the CDC study on propeller injuries, plus near the end, it lists an extensive bibliography the IIR put together.
- Federal Requirements for Proposed Injury Avoidance Measures Notice of Proposed Rulemaking. Published in the 10 Dec 2001 Federal Register. Pg. 63650-63651. This regulation specifically addresses houseboats.
- The Coast Guard extended the comment period with an announcement in the 26 March 2002 Federal Register. Pg. 13,738.
- Comments to the Docket above can be viewed by entering "10163" in the search box on the Dept. of Transportation web site.
- We have additional coveage of this Proposed Regulation.
In addition to the Coast Guard references above, Congress held a boating safety hearing that also covered propeller injury issues in 2001. Congressional Hearing on Boating Safety. Recreational Boating Safety (107-20) Hearing Before the Subcommittee on Coast Guard and Maritime Transportation of the Committee on Transportation and Infrastructure. House of Representatives. One Hundred Seventh Congress. First Session. 15 May 2001.
Proposed Regulation for House Boat Propeller Injury Protection
In 2002 the U.S. Coast Guard collected public comments on a proposal regulating
mandatory propeller protection devices on houseboats. The collection period was extended till May 2002. On
May 22, 2002 the NMMA issued a press release
saying the proposal raises the question of whether the risk justifies the cost of regulation and encourages the industry
to voice their objections. Houseboats have long had special risks in this area. Swimmers are often near them or
climbing on them, they move infrequently, poor visibility of the props from the operating station, their engines
are not as loud in the water as those of smaller craft, few visual indicators to swimmers the boat is about to
get underway and large, slow rotating props may be more likely to draw people into them. The list of remedies
proposed by the Coast Guard, does not include sensor based prop guards.
Industry comments on the houseboat propeller guard proposal are now viewable from the
U.S. Coast Guard web site, including a four page letter from Mercury Marine's General Counsel.
|
|
|
|
Interestingly, Mercury's letter refers solely to shroud type propeller guards and was written
one day prior to issue of their sensor based patent. To view other industry comments, enter
10163 in the Dept. of Transportation Docket Management System (DMS) docket number
search box.
NOTE - Docket 10163 is somewhat of a follow on from the "Propeller Injury Prevention Aboard Rental Boats" request for comments by the U.S. Coast Guard published in the 26 March 1996 Federal Register. Those comments can be viewed by entering "10299" into the search box above. Note - Docket 10299 was itself somewhat of a follow on from "Propeller Accidents Involving Houseboats and Other Displacement Type Recreational Vessels" request for comments by the U.S. Coast Guard published in the 11 May 1995 Federal Register.
We particularly recommend viewing these documents in the 10163 Docket: Note these letters may take a while to download.
- Another Mercury Marine Letter, it includes
a 1996 presentation, some statistics and enumerates many objections. Letter is written by Dick Snyder, a retired engineer. One
interesting point he raised was an increase in emissions due to the increased drag of propeller guards. We had not previously logged that issue.
- Our letter commenting on Virtual Propeller Guards and pointing out how current regulations provide an incentive for drive manufacturers
NOT to develop effective propeller guards.
- Lake Powell Resorts & Marinas letter,
with almost 400 rental houseboats provides some very in-depth comments in their response.
- MariTech Industries letter, they manufacture
some houseboat propeller safety products.
- NMMA letter, National Marine Manufacturers Association (industry trade association).
- Joseph Greenleaf letter the last four pages include a narrative of several pontoon boat propeller accidents.
|
A series of Public Hearings were held in the Spring of 1996 to solicit comments.
Below are direct links to comments from some well known firms and well as other companies with a specific interest in the rulemaking.
Company Comments
Bumper Boats
Although this site focuses on recreational boats, we did notice some discussion of propeller safety regulations
on bumper boats such as at amusement parks.
Historical Proposals
As an example of how long the government has been discussing the propeller issue, we found a California Bill proposed in 1955 being
discussed in the 5 Feb 1955 Long Beach Telegram on Page A3.
A California legislator named Kilpatric proposed "every motor boat operating near swimmers would have to have
a propeller guard." Bill AB3038.
Our Position Statement on Mandating the Use of Propeller Guards on New Boats
Boat manufacturers should be working in conjunction with marine drive manufacturers, boat dealers and providers
of propeller injury avoidance devices to provide new boats with the appropriate combination of propulsion systems,
propeller injury, avoidance devices, propeller guards, boat design features, and additional safety measures as
needed to minimize risk of propeller injuries.
In our opinion, the boating industry is not currently shouldering that responsibility. Therefore, we
encourage the U.S. Coast Guard to establish basic, sensible, mandatory regulations requiring appropriate
combinations of propeller injury avoidance devices and/or propeller guards for all propeller driven
recreational boats.
Additionally, similar regulations, including procedural requirements, should be established for all
propeller driven rental, taxi, party, charter fishing, tour, charter diving, and excursion boats,
based on boat type, length, use, and a risk assessment.
Our position statement was in part inspired by a somewhat similar statement from the Institute for Injury
Reduction in a 6 July 1995 letter to the U.S. Coast Guard that is part of Docket #10299.
"IIR urges the Coast Guard to mandate the use of propeller guards and/or other alternative technologies
on all recreational vessels to prevent propeller lacerations."