PLA risk assessment response form

PLA Consultation on the Regulation of Rowing on the Upper Reaches of the Tidal Thames

16^th May 2005

A full Council meeting was held at TRC and all club representatives were invited. Additional observer guest attendees were also welcomed. Alan Hawes and Pauline Rayner attended in this capacity and can also report what they saw and heard to the committee.

The meeting was reasonably well attended with, I suspect 50 to 80 persons present including a considerable number of non-Tideway clubs.

The meeting was to explain the nature of the 92 page report from the Salvage Association and to look at one particular aspect of it – the Recommendations to the ARA and the TRRC, the preliminary reaction of the RWSA and to seek comments from the Council and guest attendees on both the SA report and the preliminary comments of the RWSA. The comments from the meeting were noted electronically and contemporaneously by the Hon Sec and PR officer.

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A Response to the Risk Assessment – TRRC by the Regional Water Safety Adviser and an invitation to all other readers to respond with agreements, disagreements and suggestions.

Recommendations

A total of 75 recommendations are included in the S.A. Report, which have been subdivided into the following:

• Control of Rowers & Safety of Navigation
• Promulgation
• Improve Cross-User Communication
• Recommendations for ARA/TRRC
• Physical Mitigation of Risks

Summary of Recommendations for ARA/TRRC

Following to be put to ARA/TRRC

• Certification of coach boat drivers and coxes/steersmen
• Improve publications/Water Safety Code
• Increase effectiveness of education & training
• More effective enforcement by Clubs & Region
• Develop personal buoyancy aids
• Incident reporting/statistics – actions
• Standardised lights & mounting brackets
• Buoyancy compliance with ARA standards
• Boat identification
• Lookout – better guidance & focus on safety

ARA/TRRC recommendations

There are 26 recommendations

We will look at each in turn with the RWSA’s initial comments and you are invited to provide your views.

Recommendation 1

“15.4 Recommendations to be put to the ARA/TRRC:

1. Identification of novice crew / cox / steers person; day-glo vests worn by cox & bow/steers person for a probationary period (particularly if tied in with certification);

RWSA’s initial Response;

Agreed – but we need to agree a colour code for novice scullers to differentiate with experienced ones who wish to use day glow

Suggest Red with Green for “passed test but not yet confident”

Subsequent comment- perhaps we can put markers on the boat bow and stern canvases like Empacher slots at right angles and literally put “L” plates and “R” plates on obtained from Car Accessory shops This avoids confusion with the issue of vests for visibility

Agree with S A recommendation?		yes	no
Comments

Recommendation 2

2. Alternately using differing colours all coxes / bow / steer persons to have day glo vests – seen used to good effect on the river. Improves visibility and conspicuousness;

RWSA’s initial Response;

Not agreed – too prescriptive. This means every single sculler would have to wear one. Suggest that, as with lights, day-glow vests are ‘required’ only at night, dawn and dusk. Light colours, preferably [reflective] white, should be mandatory at night for all bow steersmen and are to be encouraged for the rest of the crew by means of culture, example and exhortation

Agree with S A recommendation?		yes	no
Comments

Recommendation 3

3. Certification of cox / steersperson should be compulsory: syllabus recommended to include a minimum time on the water in a training capacity;

RWSA’s initial Response;

Completely agreed. Not before time. The present modus operandi is subject to the whim of coach and captain and is so variable as to be dangerous.

Proposal. Set up a working group from Div 16 to 19, plus any ARA help from the Coach educator team, to write a syllabus and approve/modify the test on the site

http://thamesrc.atics.co.uk/cms/safety/mandatory-tideway/steering/steering-test.html

Agree with S A recommendation?		yes	no
Comments

Recommendation 4

4. Certification of coach boat drivers should become compulsory e.g. RYA Level II with ARA specific modules;

RWSA’s initial Response;

Completely agreed. Not before time. The present level of launch driving courtesy is appalling and is dangerous in some cases.

Fact: There is already a working group on this.

Proposal: it[the working group] needs to have a timetable set for performance of its objective, which should be twofold:

The normal/modified RYA level 2 (suitable for continental training camps, etc.)

Specialised, inexpensive, Regional-based, non-RYA Tideway-only syllabus for clubs

Agree with S A recommendation?		yes	no
Comments

Recommendation 5

5. Increased education and effective training amongst the rowing community – noted as Attachment H (ARA initiatives)

RWSA’s initial Response;

Agreed. This needs to cover:

Coaches – both old (experienced!) and new to Tideway

Steerspersons

Rowers in rest of crew

Proposal.

In addition to that in App H, the TRRC website is being developed to increase education. TRRC has done very successful seminars. Also, it is planned to issued DVDs, videos and the steering syllabus/test can be disseminated widely…

Any other ideas?

Agree with S A recommendation?		yes	no
Comments

Recommendation 6

6. Personal Buoyancy Aids – ARA to continue investigation/research/design for a suitable aid for rowers;

RWSA’s initial Response;

An ARA matter. The ARA provides national guidance – e.g. the Remploy sculling lifejacket and W.S.Code. (This will help non- rowers with smaller, better fitting lifejackets and allow non-rowers and the physically disabled / non-swimmers to row)

Agree with S A recommendation?		yes	no
Comments

Recommendation 7

7. Increased internal enforcement by ARA/TRRC/Clubs. At least for a period of introduction of any new Rules or Code of Practice. To be tied in with promulgation, enforce the rules with regards positioning, overtaking and manoeuvring;

RWSA’s initial Response;

Completely agreed.

The TRRC to provide the input for the PLA liaison and production of the new Rules and Clubs to become part of this process rather than seeing coming from “above”. Absolutely essential to develop the philosophy that club officers be the ‘policemen’ for club members rather than the regional or ARA advisers.

Agree with S A recommendation?		yes	no
Comments

Recommendation 8

8. To improve internal enforcement consider appointment by TRRC of ‘duty marshals’ to monitor activities at busy periods such as weekends. Divisional Representatives should play a significant role in this respect. Improve reporting and enforcement procedures within Clubs and Divisions.

RWSA’s initial Response;

Completely agreed. Clubs to agree a duty roster of “duty marshal” with launch and agreed colour “bib”. TRRC to provide funds for petrol and launch expenses. All clubs with launches to be involved on a proportional basis to club members/ number of launches. Syllabus for what advice to offer and how to offer it to be provided in guidance document. Heavy reliance of video data in case of argument on grounds of fact - v common! (“I was on the right line”…when nearly on the Fulham flats on the Ebb!)

Agree with S A recommendation?		yes	no
Comments

Recommendation 9

9. Review of accident statistics and action on trends to be visibly improved. Include in discussions with PLA at periodic meetings. e.g. the ARA statistics contain several comments querying the use of 4’s on the tideway, particularly for inexperienced crews. Incidents with rowers caught out by stream on bridges and fixed marks continue, including 2005 during Ladies Heads meetings;

RWSA’s initial Response;

Agreed. This has already been started. I have agreed with the Harbour Master to have all non-impact near miss reports sent electronically to me on a no-blame basis and am happy to have no names - if that is wanted. See http://safety.thames-rrc.org/information/incident-reporting.html

I am to meet quarterly with the Harbour Master to review the “near miss” reports.

Agree with S A recommendation?		yes	no
Comments

Recommendation 10

10. Provide guidance and take up as a theme the fact that user risk assessments should include better assessment of interaction with other craft – i.e. is it assessed sensible to row set pieces without deviation in a dynamic environment seen on the river;

RWSA’s initial Response;

Agreed. This is a matter of coach and club education and a reduction of the “I will not stop for anything” attitude and a substitution of “I will just have to do this piece again – and just think of the training benefit I will get!”

Agree with S A recommendation?		yes	no
Comments

Recommendation 11

11. The Water Safety Code provides little direct input relating to navigation. And in particular does not touch on navigation or collision avoidance. Produce a local Code or promulgate any Code decided after this study, to include local hazards and rules and the COLREGS. Emphasise role of COLREGS and in particular in collision avoidance;

RWSA’s initial Response;

Agreed. ARA/Regional (Tideway – initially) work on new section of the code applicable to the Tideway as appendix proposed by Region. Others to follow if desired.

Proposal: PLA TRRC working party to do.

Agree with S A recommendation?		yes	no
Comments

Recommendation 12

12. If a system of rowing routes outside the main channel is chosen by the PLA, emphasise within training and publications that rowers proceeding against the stream are to remain adjacent to the bank. There must be greater awareness of other users;

RWSA’s initial Response;

Absolutely Agreed.

See the steering test. Too many crews steer so far out that several – let alone one – crews could “undertake them”. The criterion should be that no one can even think of getting inside the gap between you and the bank. See video clip![link to be put in]

Proposal: TRRC working party to do.

Agree with S A recommendation?		yes	no
Comments

Recommendation 13

13. Lookout – decide upon standardised guidance on frequency and operation and promulgate this widely;

RWSA’s initial Response;

Agreed!

Proposal: TRRC working party to do this on a SCIENTIFIC BASIS. Look at the report – look at his calculations of speed of boat and distance covered per stroke and work out optimum number of strokes taken between looks for each of the many situations likely to be found. Take film of this process for research purposes. This “look out” is a key process. Investigate panoramic mirrors and web cams with low cost small computers, etc

Agree with S A recommendation?		yes	no
Comments

Recommendation 14

14. Lookout – make this the focus of a safety campaign within rowing community. Monitor accident and incident statistics; take action against those where poor lookout is a feature;

RWSA’s initial Response; Agreed

Proposal: TRRC PR committee to take on board and devise means of doing this with stick and carrot. Action must be determined as being more training and testing – perhaps by a group of dedicated “educators” before such a person is allowed out on his or her own again? Like being force to take the driving test again?

Agree with S A recommendation?		yes	no
Comments

Recommendation 15

15. Lookout – other options include lead by powered craft and verbal control; rear view mirrors (no formal assessment seen). The current situation must be improved and if not by better application of standardised guidance then other means must be introduced for safety;

RWSA’s initial Response; lead by powered craft- not agreed as practical

rear view mirrors; agreed -needs research

Proposal: TRRC technical / coaches committee to do this on a proper scientific basis as previously indicated.

Agree with S A recommendation?		yes	no
Comments

Recommendation 16

16. Review enforcement actions open to rowing authorities:

RWSA’s initial Response;

Propose a committee of all Tideway Div Reps be convened with President Chairman and Safety adviser to agree coordinated action so enforcement is standardised and provide “guidance” to Club Captains to enforce. Region only steps in as last resort. Suggest records of enforcement action kept by region of individuals and clubs.

Agree with S A recommendation?		yes	no
Comments

Recommendation 16a

16. a. Greater publicity of offenders;

RWSA’s initial reponse http://www.twrc.rowing.org.uk/slug?

Seriously… this should not be personal but club-orientated, i.e. the stats published should be about safe clubs not individuals. The launch driver poll but based of fact rather than opinion could be one way forward here.

Agree with S A recommendation?		yes	no
Comments

Recommendation 16b

16. b. Restrictions on competitive rowing, including removal of ARA membership;

RWSA’s initial response;

A disciplinary procedure already exists for clubs.

The idea of banning an individual by removing personal membership of the ARA for a regional disciplinary matter is not one with which I agree. Discipline and sanctions must reside with club and club captains. It has been suggested already to provide guidance for consistency. Lets leave it at that.

Recommendation 16c

16. c. Sanctions against Club for members and hosted rowers;

A disciplinary procedure already exists for clubs. I have covered members.

RWSA’s initial response;

Hosted rowers are a problem only if they come from another region. The only solution here is for the events to cooperate with the clubs and use the threat of a ban for offenders from events and clubs if the club in question does not take appropriate disciplinary action for individuals and if it is complete club that needs action taken then this would be a matter for Regional Council on the advice of the RWSA.

Agree with S A recommendation?		yes	no
Comments

Recommendation 17

l7. Buoyancy – it is imperative that all boats are sufficiently buoyant. Ensure adoption and compliance with international / national standards;

RWSA’s initial response; A British code exists for this. The international one is for FISA regattas.

Proposal

Every club is asked to conduct a self-audit of boats with respect to buoyancy and retain it on file. Each club should propose its own time scale to suit its budget whereby it can complete a programme of buoyancy provision. The audit document should be kept up to date to reflect the progress toward 100% buoyant fleets and the percentage achieved should be reported back to the RWSA on the annual audit.

.

Agree with S A recommendation?		yes	no
Comments

Recommendation 18

18. Navigation Lights - Standardised design of lights for fitting forward and aft with lights also visible from side;

RWSA’s initial response; Agreed up to a point. It is too prescriptive to insist on a standard light but what is required is a standard performance.

Proposal

A technical panel appointed to determine luminescence and penetrative distance requirements together with a suggested list of suppliers of such suitable products.

Agree with S A recommendation?		yes	no
Comments

Recommendation 19

19. Lights - Boats to be fitted with light mounting brackets forward and aft standardised for lights in No 17[sic 18];

RWSA’s initial response;

Agreed up to a point. It is too prescriptive to insist on a standard light fitting but absolutely correct that the fitting (to suit the light) should be part of the boat

Proposal

The technical panel appointed to work with boat builders to design a universal fitting base.

Agree with S A recommendation?		yes	no
Comments

Recommendation 20

l20. Lights - consider forward light having characteristics of a combined fixed and flashing/pulsating light (with fixed light aft)– discuss with PLA;

RWSA’s initial response;

Agreed. This is Sean Collins’s idea and a good one at that.

What views does the Council have? (I am meeting PLA tomorrow.)

Agree with S A recommendation?		yes	no
Comments

Recommendation 21

21. Lights – coach boats accompanying rowers at night are recommended to have a white light plus red/ green sidelights;

RWSA’s initial response;

Agreed. This is plain common sense.

My personal view is that we ought to make the white light a mandatory mounting on a single vertical pole. Comments?

Recommendation 22

22. Locate or design a standard fitting for lights and for light characteristics and recommend these within the safety Code or other guidance;

RWSA’s initial response;

Not Agreed. This is too prescriptive. The luminescence and other characteristics should mirror normal light requirements under the Col Regs Section25.

Agree with S A recommendation?		yes	no
Comments

Recommendation 23

23. Coach boats must actually be coaching to enjoy the concession of exceeding 8 knots and must be approved and certificated by the PLA as acceptable for wash;

RWSA’s initial response;

Not Agreed. Provided that the wash is low when planing it is far far better to be at speed than at below 8 knots.

This recommendation does not cater for the possibility of a coach having stopped for a flotilla of scullers in order not to wash them down and lost ‘contact’ with the crew.

Acceptable for wash

Not Agreed. The TRRC should decide this not the PLA. It is far better that rowers determine amongst themselves what is and is not acceptable and clubs will have to bite the bullet and accept that some lauches will have to be sold

Agree with S A recommendation?		yes	no
Comments

Recommendation 23 (continued)

23. Coach boats …must be approved and certificated by the PLA as acceptable for wash;

RWSA’s initial response;

Not Agreed. The TRRC or better still Divs16 to 19 should decide this not the PLA. It is far better that rowers determine amongst themselves what is and is not acceptable and clubs will have to bite the bullet and accept that some launches will just have to be sold! [We all know which clubs we have in mind!]

Proposals: 1) A technical panel be appointed to look at low wash launches for the Tideway. 2) No tin fish-type launch has more than two coaches at any time.3) Wash characteristics are determined with stated total capacity of persons.

Agree with S A recommendation?		yes	no
Comments

Recommendation 24

24. Coach boats or safety boat should accompany all rowers at night / poor visibility; particularly single scull as potentially most vulnerable;

RWSA’s initial response;

Not Agreed. Totally impracticable and restrictive of the freedom of the individual lone sculler. Shows lack of understanding of way sculling squads are run or rights of the individual and appreciation of costs.

Comments?

Agree with S A recommendation?		yes	no
Comments

Recommendation 25

25. Continue with noted work towards boat identification against a standard system for identification, including the use of a code sequence such as “LRC 27”;

Response;

ARA council and WSC were well ahead of the plan here (and this goes back to Peter Coni’s recommendation in 1992 – which was never followed.)

It will put an end to deliberately obstructive, cantankerous individuals, such as one from my club who insisted his boat was labelled with a minus sign on the basis that this was the Chinese symbol for “one”. He has been the incentive behind this latest move, which is nothing more than to compliance with the existing law. {On advice from the PLA, I understand his boat would only be legal here if it was registered in China}

Agree with S A recommendation?		yes	no
Comments

Recommendation 26

26. Use of day-glo and reflective strips on the vests or tops of single scullers, and at least the bowman and coxswain in larger boats and / or designate novice coxes and steerspersons;

RWSA’s initial response;

This has been covered in Paragraphs 1 and 2

Overview

We have covered the 26 individual recommendations to the TRRC

What about the other aspects that affect us directly?

Recommendations - Promulgation

• Presentations/meeting Rowing Clubs re new procedures

Agree with S A recommendation?		yes	no
Comments

• Revise PLA website – user friendly/transparent

Agree with S A recommendation?		yes	no
Comments

• Single publication with navigation rules

Agree with S A recommendation?		yes	no
Comments

• Publish Thames User Guide jointly with EA – schematic

Agree with S A recommendation?		yes	no
Comments

• Raise wider awareness of new procedures

Agree with S A recommendation?		yes	no
Comments

• Leaflets at entry points for upper Tideway

Agree with S A recommendation?		yes	no
Comments

• Safety signage on bridges and beside river

Agree with S A recommendation?		yes	no
Comments

Recommendations -

Improve Cross-User Communication

• PLA to initiate an upper tidal river user safety group

Agree with S A recommendation?		yes	no
Comments

• Increase informal contact with river users, particularly Clubs

Agree with S A recommendation?		yes	no
Comments

• Information transfer with ARA/TRRC – incident reports/data

Comments

• Cameras & speed guns/boards on bridges – enforcement & review

Agree with S A recommendation?		yes	no
Comments

• Monitor wash levels

Agree with S A recommendation?		yes	no
Comments

Recommendations –

Physical Mitigation of Risks

Consideration to be given to the following:

• Marking of banks/flats using piles/withies or buoys

Agree with S A recommendation?		yes	no
Comments

• Removal of debris/obstructions/overhanging trees

Agree with S A recommendation?		yes	no
Comments

• Define channel on bridges

Agree with S A recommendation?		yes	no
Comments

• Visible depth gauges on bridges

Agree with S A recommendation?		yes	no
Comments

• Restrict overtaking at blind bends & bridge

Agree with S A recommendation?		yes	no
Comments

Recommendations –

Physical Mitigation of Risks

Consideration to be given to the following:

• Marking of banks/flats using piles/withies or buoys

Agree with S A recommendation?		yes	no
Comments

• Removal of debris/obstructions/overhanging trees

Agree with S A recommendation?		yes	no
Comments

• Define channel on bridges

Agree with S A recommendation?		yes	no
Comments

• Visible depth gauges on bridges

Agree with S A recommendation?		yes	no
Comments

• Restrict overtaking at blind bends & bridges

Agree with S A recommendation?		yes	no
Comments

Recommendations –

Control of Rowers & Safety of Navigation

• Replace Notice to Mariners U6 with a Code of Practice

Agree with S A recommendation?		yes	no
Comments

• Simplify Regulations & improve promulgation

Agree with S A recommendation?		yes	no
Comments

• Define Fairway or Channel

Agree with S A recommendation?		yes	no
Comments

• Clarify relationship between rowing and COLREGS

Agree with S A recommendation?		yes	no
Comments

• Enforce boat identification through Clubs and leisure craft at entry points

Agree with S A recommendation?		yes	no
Comments

• Consider registration/license scheme for river users between Teddington & Wandsworth

Agree with S A recommendation?		yes	no
Comments

• Increased enforcement during introductory period

Agree with S A recommendation?		yes	no
Comments

• Log of transgressors

Agree with S A recommendation?		yes	no
Comments