a e” c * F « r t a . ot v We : . Commander A.D. Utara Page Two = - * . ‘ . ~ . , : % . October 29, 1979 hospital ship, specializing in outpatient care, although we have had to deliver one child to a passenger on a trip between Uterikand Kwajalein. This would be classified as inpatient care by most medical facilities. The problem then becomes your classification of this vessel. I would like to quote directly from your letter of 17 April, 1979 to Mr. C. Otterman concerning the mission of this vessel. "With reference to your letter of 13 April, 1979, J. find the Liktanur IT, ON 572028, an oceanographic research vessel as defined in Section 441 of Title 46 U.S. Code. An oceanographic research vessel is snot considered a “passenger vessel", a "vessel carrying passengers", or a "passenger-carrying vessel" under the provisions of the U.S. Merchant Vessel Inspection and Manning Laws. Additionally, an oceanographic _ research vessel shall not be deemed to be engaged in trade or commerce. However, all other regulations remain applicable...you are reminded that my determination is predicated upon the assurance that the ' Liktanur II is being employed exclusively in instruction in oceanography or limnology or both, or exclusively in oceanographic research." . If you will study the log of this vessel, you will see that a very small percentage of its time is devoted to oceanography (by the most liberal definition), and none to limnology. The clarification of the classification of this vessel has become a very serious problem since the Holo Holo event and recent loss of another seaman (Enclosure 2). Brookhaven National Laboxatoxy has established its own “marine safety" guide (Enclosure 3) abstracted from applicable OSHA and Coast Guard directives. As principal investigator and leader of the scientific party, their safety is my primary concern. I am enclosing a copy of my first trip report of the medical survey of January and February 1979 with a detailed report of the marine safety deficiencies discovered aboard Liktanur II (Enclosure 4). Ship safety has been a lifelong interest of mine. I retired from the U.S. Navy in 1973, after 30 years of service. The first two years I served as an enlisted man, working with damage control. I then served nine years as a line officer and, subsequently, nineteen years as a medical officer. Much of that time, both as a line officer and as a medical officer, was spent aboard a number of ships, both large and small. As senior medical officer, I was an active member of the ship's safety committee. In addition, I served on a number of operational readiness safety inspection teams for the Atlantic Fleet. I understand fully your problems with the very nonspecific directives covering a vessel of this size. However, as the Holo Holo tragedy so clearly demonstrates, the regulations need tightening. The Liktanur II is undoubtedly a passenger-—carrying vessel and requires the added protection granted to such a - vessel by rigid safety and crew qualifications.