[PSUBS-MAILIST] USCG Marine Investigation Report and Ramifications

Tue Aug 12 19:21:50 EDT 2025

Boating regs state that along with life jackets onboard, we must have a
bailer too. In my case, rather than bailing water out of the boat, I have
to bail air into it.
Tim

On Tue, Aug 12, 2025 at 11:00 AM David Colombo via Personal_Submersibles <
personal_submersibles at psubs.org> wrote:

> Alan, hmm, I always wear my life preserver when diving inside the sub.
> Best Regards,
> David Colombo
>
> 804 College Ave
> Santa Rosa, CA. 95404
> (707) 328-1224
> www.SeaQuestor.com
>
>
>
> On Mon, Aug 11, 2025 at 12:06 PM Alan James via Personal_Submersibles <
> personal_submersibles at psubs.org> wrote:
>
>> To put it in perspective, in 2024 there were 556
>> deaths in the USA attributed to recreational boating accidents, and
>> 300,000 drowning deaths World wide.
>> Most of those deaths could have been prevented if everyone wore life
>> jackets while
>> swimming & boating. But no one is going to
>> agree to that.
>> Alan
>>
>> Yahoo Mail: Search, organise, conquer
>> <https://mail.onelink.me/107872968?pid=nativeplacement&c=US_Acquisition_YMktg_315_SearchOrgConquer_EmailSignature&af_sub1=Acquisition&af_sub2=US_YMktg&af_sub3=&af_sub4=100002039&af_sub5=C01_Email_Static_&af_ios_store_cpp=0c38e4b0-a27e-40f9-a211-f4e2de32ab91&af_android_url=https://play.google.com/store/apps/details?id=com.yahoo.mobile.client.android.mail&listing=search_organize_conquer>
>>
>> On Tue, 12 Aug 2025 at 1:21 am, via Personal_Submersibles
>> <personal_submersibles at psubs.org> wrote:
>> Thanks Jon, Will read it for sure!
>>
>> Br, Emilegoing
>>
>> -----Oorspronkelijk bericht-----
>> Van: Personal_Submersibles <personal_submersibles-bounces at psubs.org>
>> Namens Jon Wallace via Personal_Submersibles
>> Verzonden: woensdag 6 augustus 2025 18:48
>> Aan: Personal Submersibles Generalre   Discussion <
>> personal_submersibles at psubs.org>
>> Onderwerp: [PSUBS-MAILIST] USCG Marine Investigation Report and
>> Ramifications
>>
>> Psubbers,
>>
>> This is a long message, but please read.
>>
>> The US Coast Guard has released their Marine Investigation report of the
>> Titan submersible implosion at
>> https://media.defense.gov/2025/Aug/05/2003773004/-1/-1/0/SUBMERSIBLE%20TITAN%20MBI%20REPORT%20(04AUG2025).PDF
>>
>> Since this report is going to generate chatter throughout the submersible
>> industry I thought it appropriate to make a statement and start an official
>> discussion relative to our own organization.
>>
>> Now that the Marine Boards report is public we are sure to see an uptick
>> in attention to the operation of our vessels and potentially some movement
>> to save ourselves, from ourselves, and need to be proactive in addressing
>> this issue rather than allowing some other agency or organization to define
>> our future.  While we are not the largest organization in the world, we ARE
>> the largest organization in the world associated with private submersible
>> fabrication, operation, and ownership and therefore have standing to be
>> recognized and heard regarding any government regulation that might affect
>> us.
>>
>> From PSUBS beginning it has always been my position, and still is, that
>> private recreational use of our vessels is difficult for the government to
>> regulate due to the “pursuit of happiness” founding principles of the USA.
>> It is my opinion, for example, that this was one reason recreational
>> submersibles had a specific section carved out for them in USCG NVIC 5-93
>> (see Chapter 1, B, 4) and were equated to pleasure surface boats.
>> To wit:
>>
>> USCG NVIC 5-93, Chapter 1, B, 4
>> “Recreational vessels, as defined in 46 U.S.C. 2101(25), are vessels
>> manufactured or operated primarily for pleasure, or leased, rented, or
>> chartered to another for the latter's pleasure. Submersibles within this
>> category are subject to the requirements of 33 CFR Subchapter S - Boating
>> Safety, Parts 173-183. The guidelines in this circular generally do not
>> apply; however, depending on the area of operation, COTP operating
>> restrictions may be appropriate. This will be evaluated on a case-by-case
>> basis. These guidelines may be of assistance to a manufacturer or owner of
>> a recreational submersible.”
>>
>> As optimistic as I am regarding our rights as private submersible owners,
>> the Titan disaster does represent a potential impact to us and we should
>> have a message ready to deliver to the US Coast Guard to protect our
>> interests.  Specifically, I have concerns related to carrying passengers
>> (not for hire) and impacts to private submersibles participating in
>> research and/or acting as a non-passenger commercial operator.  We enjoy
>> quite a bit of latitude given the language of NVIC 5-93, 1, B, 4 and it
>> should be our goal to preserve it as currently written.
>>
>>
>>
>> The USCG Marine Investigation Board made 14 safety recommendations to the
>> USCG Commandant.  While the majority of these recommendations target
>> vessels conducting commercial and oceanographic research operations, the
>> following draw my concern as potential serious impacts to our PSUBS related
>> pursuits.
>>
>> 8.1.1. Recommendation #1: The USCG should establish an industry working
>> group to review and update NVIC 5-93. During the investigation, submersible
>> industry leaders indicated to the MBI that current USCG limitations on
>> operating parameters, including the maximum depth of 150-feet for Coast
>> Guard inspected passenger submersibles, was stifling submersible owners
>> from exploring new passenger operations in U.S. navigable waters and also
>> potentially incentivizing operators like OceanGate to conduct non compliant
>> operations. An update to the NVIC would also provide an opportunity to
>> clearly outline the process for certifying submersibles of novel design.
>>
>> PSUBS POSITION
>> PSUBS *must* be included in any working group the government creates to
>> update NVIC 5-93 and/or create regulations that may impact us.  We cannot
>> afford to sit idly by and allow “industry leaders” and/or the government
>> itself to revise this document without our input.  It is notable that the
>> USCG regularly attends the MTS Underwater Intervention and participates in
>> discussions with MUV commercial attendees; however the USCG has never
>> accepted an invitation to a PSUBS convention.  Regrettably, we own some
>> responsibility for lack of communication with the USCG since we have often
>> taken the philosophy of “let sleeping dogs lie” and “out of sight, out of
>> mind” when considering our interaction with them; however I think we can no
>> longer afford to take this approach.  This month I will be writing the USCG
>> Commandant seeking inclusion of a PSUBS representative in any working group
>> organized to review NVIC 5-93 and/or any other regulatory act that may
>> impact our organization.  Additionally, I will be requesting the USCG send
>> a representative to PC2026 to conduct discussions with PSUBS members
>> regarding issues and concerns relative to our segment of the submersible
>> industry and to start fostering communication between us.
>>
>>
>>
>> 8.1.6. Recommendation #6: The USCG should pursue a new regulation which
>> requires all submersibles manufactured, owned, or operated by a U.S. entity
>> or any submersible operating in U.S. navigable waters carrying any occupant
>> other than the owner to be built to the standards of a USCG RO and
>> maintained under those standards.
>>
>> PSUBS POSITION
>> Any language requiring certification for privately owned submersibles is
>> a serious detriment to our pursuits since from a financial perspective it
>> essentially is a show stopper.  This recommendation goes well beyond the
>> current wording in NVIC 5-93 which clearly demarcates commercial, passenger
>> carrying, and recreational submersibles.  If implemented as suggested it
>> would prevent us from carrying our own spouses, families, and friends as an
>> occupant unless the vessel was certified.  It is PSUBS position that this
>> unreasonably restricts our right to pursue sharing our hobby with voluntary
>> passengers who are not for hire.
>>
>>
>>
>> 8.1.7. Recommendation #7: The USCG should pursue an update to the vessel
>> documentation requirements in 46 CFR § 67.7, to require all U.S.
>> submersibles that conduct commercial or scientific operations to obtain a
>> USCG Certificate of Documentation (COD) with an Official Number assigned
>> and recorded in the MISLE database.
>>
>> PSUBS POSITION
>> We currently have a number of privately owned submersibles that are used
>> to conduct various types of research, free of charge, for universities and
>> science organizations whom have a need for a deep diving vessel beyond the
>> range of SCUBA.  This recommendation by the Marine Investigative board
>> could have severe impact on those missions and it is PSUBS position that
>> this recommendation unreasonably restricts a private submersible owner from
>> providing a donated service targeted for the advance of science.
>>
>>
>>
>> WHAT YOU NEED TO DO (right now)
>> Minimally all PSUBS members should read the “Recommendations” section of
>> the USCG Marine Investigation Board starting on page 324 and consider how
>> this impacts you personally or our organization and raise it as a concern
>> if it has not been addressed already.
>>
>> Additionally, start thinking now about issues and concerns we should
>> address with the USCG at PC2026 in February.  The more that we can speak
>> with one consistent message in terms of specific issues that we feel need
>> to be preserved or modified to our benefit, the better we will present
>> ourselves.
>>
>> Jon
>>
>>
>>
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>>
>>
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