ALCOAST 243/21 - JUL 2021 GUIDANCE ON SERVICING FIXED ATON STRUCTURES

R 021422Z JUL 21
FM COMDT COGARD WASHINGTON DC
TO ALCOAST
BT
UNCLAS
ALCOAST 243/21
SSIC 5100
SUBJ:  GUIDANCE ON SERVICING FIXED ATON STRUCTURES
A. Aids to Navigation Manual - Structures, COMDTINST 16500.25
(series)
B. Petzl I’D L User Manual
C. 3M DBI SALA Fisk User Manual
D. CMC Clutch by Harken Industrial User Manual
1. The National Aids to Navigation School (NATON) recently discovered
that the techniques and procedures employed during 2-person rescue
may exceed the working load limits (WLL) or manufacturer’s intended
use of descent devices as prescribed in REFs (B) and (C),
specifically when using the Petzl pre-2019 I’D L, Petzl 2019 I’D L,
and 3M DBI SALA Fisk Descenders.
2. Petzl pre-2019 I’D L Descender. Based on conversation between the
NATON staff, Petzl technical representatives, and information in REF
(B), the following are the maximum WLL’s for the pre-2019 I’D L:
    a. Single Person Descent: 150 kg, 330 lbs.
    b. Assisted Rescue: 150 kg, 330 lbs. when connected to an anchor
point with an additional friction device (carabineer) in accordance
with revised rigging identified in REF (B).
    c. Suspended Rescue: 200 kg, 440 lbs., when used in conjunction
with an additional friction device in accordance with revised rigging
identified in REF (B).
3. Petzl 2019 Descender. As per REF (B), the following are the
maximum WLL’s for the 2019 I’D L:
    a. Single Person Descent: 120 kg, 264.5 lbs.
    b. Single Person Descent with manufacturer’s friction device
add-on (sold separately): 150 kg, 330 lbs.
    c. Assisted Rescue: 120kg, 264.5 lbs., when used in conjunction
with an additional friction device (carabineer) in accordance with
revised rigging identified in REF (B). When used with an additional
friction device, the additional manufacturer’s attachment
(sold separately), in accordance with revised rigging per REF (B),
the maximum allowable weight is increased to 150 kg, 330 lbs.
    d. Suspended Rescue: 200 kg, 440 lbs., when used in conjunction
with an additional friction device in accordance with revised rigging
identified in REF (B).
4. 3M DBI-SALA Fisk Descender. Based on REF (C), the following are
maximum WLL’s for the DBI-SALA Fisk Descender:
    a. Single Person Descent: 200 kg, 440 lbs.
    b. 3M DBI-SALA technical representatives and REF (C) 1.2.D state
that this device is intended for single-person descent only, except
in emergency rescue cases. Units must stop using the Fisk as a
planned rescue device and switch to a self-locking descent device
for all rescues and rescue training.
    c. NATON will continue to teach the Fisk as a single person
descent device, but stopped teaching the use of the Fisk as a
rescue descender. As such, units must no longer use the Fisk
for rescue climber currency maintenance or recertification.
Rescue climbers must instead conduct all future currency and
recertification using a self-locking device. Units may continue
to use and train on the Fisk for single person use only. COMDT
(CG-NAV) will be phasing out the Fisk from service on 31 May 2022.
By that date, all Fisk descenders must be replaced with an approved
self-locking device. Units should immediately stop procuring the
Fisk and instead purchase self-locking type descenders.
5. COMDT (CG-NAV) and NATON are continuing to research other brands
of self-locking descent devices with higher WLLs more suitable for
rescue work as it applies to ATON structures. NATON identified two
descenders with a higher WLL and COMDT (CG-NAV) provided funds to
each dpw to procure at least one of these approved self-locking
descenders and associated recommended friction devices (if required)
for each unit with a climbing mission. Due to the limited supplies
of these new devices, dpws/units should only procure one device
per rescue kit at this time. As supply catches up with demand,
units are encouraged to procure additional devices and separate
their descent devices used for operations, training, recertification,
and currency maintenance from devices included in the unit rescue
kit. While the below descent devices are now authorized both for
use as a rescue and a personal descent device, the Petzl I’D L
remains a less expensive option for a self-locking personal
descent device. The newly approved higher WLL devices are:
    a. 3M DBI-SALA No Worries descent device (MFC: 8700387), WLL 661
lbs. Approved for use; however, 3M DBI-SALA stopped manufacturing
this device, so procurement may be difficult. Pricing will vary
depending on the vendor.
    b. Harken Industrial CMC Clutch, 13 MM, (CMC 335013), WLL 600 lbs.
(272 KG). GSA Advantage, GSA Contract GS-07F-5668P. $554.15 each.
    c. Units that discover additional descent devices with WLLs higher
than the Petzl I’D L are asked to share this information with NATON
for possible inclusion as a COMDT (CG-NAV) approved descent device.
6. Given the limitations of our current descenders, commands, working
with their designated unit competent authority, must verify combined
climber weight (2-person) and associated gear does not exceed 200 kg
or 440 lbs., or the maximum WLL’s of their descent devices specified
in paragraphs 2 – 5. This requirement must be added and completed as
part of the pre-climb risk assessment.
    a. These maximum WLLs include the weight of the approved climbing
outfits as prescribed in REF (A) and any ATON servicing equipment
carried by the climber. If the combined weight exceeds 200 kg or 440
lbs. and a Petzl I’D L is the rescue descent device, the climb must
be cancelled until such time as the unit can provide a climber and/or
rescue climber pairing, including equipment, which does not exceed
the 200 kg or 440 lbs. maximum. In the case of units with the higher
rated descent devices, the rescue climber pairing plus equipment
must not exceed the WLL of their rescue descent device.
    b. Commands must verify that all unit climbers are aware of these
limitations, are familiar with the applicable procedures covered in
REFs (A), (B), (C) and (D), and that these limitations be included
in all Basic and Advanced level PQS training.
7. To date there are no reported MISHAPs or HIPOs during actual or
training rescues. NATON did have a situation where two students using
a Petzl pre-2019 I’D L during a two-person suspended rescue rapidly
descended 10 feet before the safety devices engaged to stop both
climbers. This was thought to be an issue with worn equipment, and as
a precaution that individual pre-2019 I’D L was permanently taken out
of service. Inspections must continue to be conducted in accordance
with manufacturer’s specifications.
8. User Manuals:
    a. REF (B), Petzl I’D L User Manual can be found at:
(Copy and Paste Below URL into Browser)

https://www.Petzl.com/US/en/Professional/I-D-L-uses-and-
specifications?ProductName=I-D-L

    b. REF (C) 3M DBI SALA Fisk Descender User Manual can be
found at:
(Copy and Paste Below URL into Browser)
  
https://multimedia.3m.com/mws/media/1413199O/ifu-5902142-fisk-
descender.pdf
  
    c. REF (D) CMC Clutch by Harken Industrial User Manual can be
found at:
(Copy and Paste Below URL into Browser)

https://www.cmcpro.com/wp-content/uploads/wd/user_manuals/335013ML01.
pdf

9. All ATNSCR certified members must view NATON’s instructional
video displayed on the NATON portal page:
(Copy and Paste Below URL into Browser)

https://cg.portal.uscg.mil/units/tracenyorktown/TrainingDivision/
SiteFiles/NATON/SitePages/NATON%20Resources.aspx

The NATON portal page will also include the ordering information
for the additional Petzl friction devices discussed in paragraphs
2 and 3 as well as links to GSA contracted CMC Clutch self-locking
descenders.
10. NATON is conducting OT&E for a long-term training solution,
working with commercial climbing schools to identify potential
revised rescue procedures that coincide with leading industry
training techniques, and researching additional descent equipment
that may provide higher WLLs. Revised policy will be disseminated
by COMDT (CG-NAV) via SEPCOR.
11. Questions or concerns should be directed to BMCM William Pierce
or BMC Dillon Smith, NATON ASC, at (757) 856-2505 or
William.C.Pierce@uscg.mil or Dillon.J.Smith@uscg.mil. Mr. David
Merrill is the POC for COMDT (CG-NAV) and can be reached at
(757) 376-9092 or David.Merrill@uscg.mil.
12. Mr. Michael Emerson, Director, Marine Transportation Directorate
(CG-5PW), sends.
13. Internet release is authorized.