downflooding point

— The El Faro stability booklet did not identify the cargo hold ventilation trunk openings as potential downflooding points, nor did it indicate that they should be closed to prevent downflooding. None of the former officers or crew of El Faro remembered the dampers being closed at sea (even for expected heavy weather), except when they were periodically tested. When asked what a captain should have done if faced with the risk of fire or flooding, an ABS representative stated that the captain would have to "trade off one risk against another risk and maintain certain weathertight integrity while not compromising or not reintroducing some other risk."