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Coast Guard: Enforcement of Egress Requirements for Historic Wood Sailing Vessels

GAO-24-106644 Published: Jan 30, 2024. Publicly Released: Jan 30, 2024.
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Fast Facts

In 2019, a small boat off the California coast caught fire at 3:00am, killing 34 people—partly because both exits from below-deck bunks led into the fire. In 2021, the Coast Guard required certain small boats carrying passengers overnight to comply with stricter egress requirements by December 2023.

Our Q&A report looks at the evolution and enforcement of these requirements for wood sailing boats. Initially, operators of these boats voiced concern about feasibility. Coast Guard personnel were unsure about how much discretion they had in enforcing the requirements. The Coast Guard's October 2023 policy letter helped alleviate these concerns.

This wood sailboat, pictured off the coast of Rockland, ME, is subject to the newer egress requirements.

A sailboat on the water

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What GAO Found

The Coast Guard's enforcement of egress requirements helps ensure that passengers and crew can safely exit vessels in the event of an emergency. Egress requirements for small passenger vessels have become more stringent over time. However, older small passenger vessels were allowed to comply with less stringent egress requirements until the Coast Guard issued its 2021 interim rule, in response to statute. The rule requires small passenger vessels with overnight accommodations for passengers that are not ferries, regardless of when they were built, to comply with newer, more stringent requirements by December 27, 2023.

While no operational vessels meet all the elements of the statutory definition of a "historic wood sailing vessel," GAO identified 27 vessels— referred to in the report as wood sailing vessels—that meet most of the elements of the definition. These 27 vessels account for a small portion of the total number of vessels (308) that are required to comply with egress requirements in the 2021 interim rule.

GAO's review of Coast Guard marine casualty reports found that from January 2013 through July 2023, some of these wood sailing vessels were involved in incidents, none of which resulted in significant damage or fatalities. Additionally, GAO's review of safety inspection data found 42 deficiencies during this same time period that could be related to egress. The largest number of deficiencies (18) were related to properly labeling exits.

At the time of our review, it was unknown how feasible it would be for wood sailing vessels to comply with the 2021 interim rule by December 27, 2023, because each vessel is different. Some maritime stakeholders and Coast Guard field personnel initially told GAO that some wood sailing vessels in their area of responsibility may easily comply with the 2021 interim rule, while others may need to make significant modifications. Modifications to wood sailing vessels may require significant time and resources due to their construction and operational nature, according to maritime stakeholders. However, in October 2023, the Coast Guard issued a policy letter providing clarification on the enforcement of egress requirements, such as the level of discretion provided to authorized field personnel when enforcing requirements. Subsequently, Coast Guard and maritime stakeholders said that the clarification provided by the policy letter would likely result in wood sailing vessels being able to comply with the 2021 interim rule without signification modifications. The policy letter expires with the issuance of the final rule, which is expected in November 2024.

Why GAO Did This Study

In 2019, a vessel named Conception caught fire off the coast of California, resulting in the deaths of 34 people, in part due to exits that all led to where the fire was located. An investigation by the National Transportation Safety Board resulted in recommendations to the Coast Guard to revise fire safety requirements for small passenger vessels. In 2021, the Coast Guard issued an interim rule related to egress requirements that went into effect on December 27, 2023.

The James M. Inhofe National Defense Authorization Act for Fiscal Year 2023 includes a provision for GAO to review the effect of these egress requirements on historic wood sailing vessels, including the feasibility of compliance and associated risk and costs. This report addresses changes to egress requirements, the safety of wood sailing vessels, and the feasibility of vessels complying with the 2021 interim rule. GAO analyzed Coast Guard data, reviewed relevant laws and Coast Guard policies, and interviewed agency officials and maritime stakeholders.

For more information, contact Heather MacLeod at (202) 512-8777 or

Full Report

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