1625-0032
Supporting Statement
for
Vessel Inspection Related Forms and Reporting Requirements
Under Title 46 U.S. Code
A. Justification.
1) Circumstances that make the collection of information necessary.
The reporting/recordkeeping requirements of Notice of Cargo Gear Tests, Notice of Drydocking, Major Alteration or Repair Reporting, Appeal of Decision or Action of the Officer in Charge, Marine Inspection (OCMI), Permits to proceed (CG-948), Certificate of Inspection (CG-841), Temporary Certificate of Inspection (CG-854), Vessel Inspection Record (CG-2832), Application for Excursion Party (CG-950), Permit to Carry an Excursion Party (CG-949), and Request to Carry Persons in Addition to the Crew, Application for Underwater Survey, and Application for Drydock Extension are part of the Coast Guard’s Commercial Vessel Safety (CVS) program in Title 46, Code of Federal Regulations (CFR). They are prescribed or authorized by one or all of the following laws: 46 U.S. Code, (U.S.C.) 2113, 3301, 3304, 3305, 3306, 3307, 3308, 3309, 3310, 3311, 3312, 3313, and 3714. The laws and regulations relating to these reporting or recordkeeping requirements are described below. These reporting and/or recordkeeping requirements are necessary and useful in the proper administration of the Coast Guard CVS program.
a. Notice of Cargo Gear Test: This reporting requirement is authorized by 46 U.S.C. 3306(a)(4) and 3313(a).
b. Notice of Drydocking: This reporting requirement is authorized by 46 U.S.C. 3306(a)(4).
c. Major Alteration or Repair Reporting: This reporting requirement is authorized by 46 U.S.C. 3306(a)(10). No repairs or alterations affecting the safety of the vessel shall be made without the knowledge of the OCMI.
d. Appeal of Decision or Action of the OCMI: Title 46 U.S.C. 3313 (d) grants the owner or master the right to appeal the suspension or revocation of a vessel’s CG-841.
e. Permits to Proceed (CG-948): Title 46 U.S.C. 3313(b)(2) authorizes the issuance of a CG-948.
f. Certificate of Inspection (CG-841) and Temporary Certificate of Inspection (CG-854): These forms are authorized all or in part by 46 U.S.C. 3309, 3310, 3311, 3312, 3313, 3714; and 46 CFR 31.05-10, 91.01-10, 107.211, 115.107, 126.250, 169.201, 176.107, and 189.01-10.
g. Carrying Persons in Addition to Crew: Title 46 U.S.C. 3304 specifically identifies and requires these functions.
h. Permit to Carry an Excursion Party (CG-949), Application for Excursion Party (CG-950), and Application for Special Permit (CG-950A): These forms are specifically identified and required by 46 U.S.C. 2113, 3301, and 3305. CG-950A is called by 46 CFR 26.03-8.
i. Vessel Inspection Record (CG-2832): This recordkeeping requirement is authorized by 46 U.S.C. 3310.
j. Underwater Survey Inspection in Lieu of Drydocking (UWILD) program: This application for a voluntary program is authorized by 46 CFR §§ 71.50-5, 115.615, 126.140, 167.15-33, 169.230 and 176.615.
k. Alternate Hull Exam (AHE) program: This application for a voluntary drydock extension is authorized by 46 CFR §§ 71.50-19, 29, 31; 115.630, 655, 660; and 176.630, 655, 660.
This information collection supports the following strategic goals:
Department of Homeland Security
Protection
Prevention
Coast Guard
Maritime Safety
Maritime Security
Protection of the Natural Resources
Maritime Mobility
National Defense
Marine Safety, Security and Stewardship Directorate (CG-5)
Safety: Eliminate deaths, injuries, and property damage associated with commercial maritime operations.
Security: Eliminate marine transportation and coastal security vulnerability.
Human and Natural Environment: Eliminate environmental damage associated with maritime transportation and operations on and around the nation’s waterways.
Economic Growth and Trade/Mobility: Reduce interruptions and impediments that restrict the economical movement of goods and people, while maximizing safe, effective, and efficient waterways for all users.
2) By whom, how, and for what purpose the information is to be used.
a. The owner, agent, or master of a vessel is required to give the U.S. Coast Guard advance notice when it is desired that the tests and examinations of cargo gear be made by or under the supervision of a marine inspector. A thorough examination of assembled cargo gear shall be made at least once every year. An inspection to determine the condition and suitability of shipboard cargo gear is made by a marine inspector at each inspection for certification. Inspections may be made at such other times as considered necessary by the OCMI. For vessels fitted with cargo gear, an initial test of the assembled units under proof loads is conducted, followed by a complete dismantling or disassembling of such gear and a thorough examination of the parts to ascertain its condition. Subsequent tests of the assembled unit under proof loads, followed by dismantling or disassembling of such gear and a thorough examination is made once every four years or more often if necessary.
b. The master, owner or agent of a vessel is required to notify the OCMI, when the vessel is to be placed on drydock in order that an examination of the underwater portion of the vessel may be made if deemed necessary.
c. Drawings of alterations shall be approved before work is started unless deemed unnecessary by the OCMI. Drawings are not required for repairs in kind. An inspection, either general or partial depending upon the circumstances, is conducted whenever any important repairs or alterations are undertaken.
d. The results of this appeal would be a recordkeeping requirement for the owner or master of the vessel.
e. The OCMI may issue a permit to a vessel to proceed to another port for repairs if in his judgment it can proceed with safety, even if the CG-841 of the vessel has expired or is about to expire. Such permit is issued upon the written application of the master, owner, or agent of the vessel. The permit will state upon its face the conditions under which it is issued and whether or not the vessel is permitted to carry freight or passengers. The permit shall be carried in a manner similar to that described for a CG-841.
f. Every inspected vessel is issued a CG-841. CG-841s are good for five years. If it is necessary to prevent delay of a vessel, a CG-854 can be issued pending the issuance and delivery of the regular CG-841. A CG-854 is carried in the same manner as a regular CG-841 which it represents. When changes in the vessel owner, operator, route, equipment, etc., occur after the issuance of the original CG-841, a revised CG-841 is provided.
g. The purpose of this requirement is to allow some cargo vessels and some vessels engaged in certain fisheries to carry persons in addition to the normal crew without having to meet more stringent material requirements for passenger carrying vessels. In that a separate form does not exist to request this permission to carry persons in addition to the crew, the owner/operator of an affected vessel simply notes it when making the routine application for certification. This reporting requirement is part of the Coast Guard CVS programs of 46 CFR. It enhances these programs by implementing laws designed to reduce the regulatory burden on some vessel owners/operators.
h. These forms are utilized whenever the operator of an inspected vessel desires to temporarily deviate from the limits of his Coast Guard issued CG-841. These temporary deviations may include either operation of the vessel upon a route not previously allowed. In addition, uninspected vessels participating in Maritime Events of National Significance are also required to apply for an excursion permit that would allow them to participate in the event by filing out CG-950A (the permit is temporary and valid only during the duration of the event). The cognizant OCMI examines the vessel and reviews its inspection files and operating history prior to deciding to grant the requested authorization. Usually, as a condition for authorizing the excursion, the vessel will be required by the OCMI to provide additional lifesaving equipment and/or personnel. The vessel’s master must be aware of the new conditions and the best way to accomplish this is to require that the permit be posted along with the vessel’s CG-841. This also ensures that the passengers may observe whether the vessel has been properly certified or the deviation from the posted conditions of the CG-841.
i. The form provides the marine inspector with ready information as to the inspection status of a specific vessel when it is boarded for various inspections. It is prepared by the Coast Guard at annual inspections for certification on large passenger ships (those of at least 100 gross tons) and every five years for certification on cargo ships, including tank ships, of 500 gross tons or more.
j. Passenger vessels under 15 years old (except wooden hull vessels), nautical school ships, sailing school ships, and offshore supply vessels may be considered for an alternate underwater survey instead of drydocking examinations, provided the vessel is fitted with an effective hull protection system. Vessel owners that want to participate in the UWILD program must apply to the Officer in charge, Marine Inspection for approval of underwater surveys instead of alternate drydock examinations for each vessel. This is a voluntary collection of information, which is intended to allow greater flexibility for owners of passenger vessels.
k. The information provided provides the OCMI information necessary to determine eligibility of a vessel for the AHE program. The application includes information such as a Hull Maintenance and condition Assessment program and an Internal Structural Examination.
3) Consideration of the use of improved information technology.
The U.S. Coast Guard’s Marine Information for Safety and Law Enforcement (MISLE) is used for the collection and storage of data relevant to vessel inspections. Any of the Coast Guard offices involved with commercial vessel safety can access this system. Once the initial data capture of a vessel has been made and the information has been entered into the MISLE, it is only necessary to make updates as changes occur to the vessel or its equipment.
We estimate that approximately 35% of the reporting and recordkeeping requirements can by done electronically. At this time, we estimate that 25% of the responses are collected electronically.
4) Efforts to identify duplication. Why similar information cannot be used.
The Coast Guard monitors State and local regulatory activity in the field. To date no equivalent State and local programs have been identified that require equivalent information, and no other Federal agencies have similar or equivalent regulatory requirements.
5) Methods to minimize the burden to small businesses if involved.
Specifically, only very simple and non-technical, general information is required from vessel operators. For the reporting/recordkeeping requirements, consideration has been given to the burden imposed on small business. The burden is the same regardless of the size of the entity. None of the requirements takes more than 30 minutes of the respondent’s time with the majority only taking five or ten minutes.
6) Consequences to the Federal program if collection were conducted less frequently.
The recordkeeping/reporting requirements in paragraphs A.1.a through h. are mandated by law and required by regulation. These requirements are concerned with the safety of personnel, equipment, and the vessels on which they are found. They are designed to coincide with particular events, a number of which the U.S. Coast Guard has no control over. The reporting requirements are considered necessary to ensure the safety of lives and property. Any changes to the requirements would require a change in the law.
Without the reporting arrangement of paragraph A.1.h (Permit to Carry an Excursion Party, etc.), inspected vessels would not be permitted to operate beyond the limits of their COI on special occasions. The existing system allows flexibility for safety, administration and enforcement of these infrequent changes to vessel operations on an “as needed” basis. If a vessel operator wishes to carry the additional passengers on a more frequent basis, he must have the vessel’s COI amended and the additional safety equipment carried on board at all time.
Lengthening the collection period would take the review of the form in paragraph A.1.i. (Vessel Inspection Record) out of a synchronized review of other documents that are all a part of the Coast Guard’s efforts to maintain and promote maritime safety. In addition, changes that occur on vessels must be followed closely, thereby requiring this periodic review to ensure that safety is not compromised.
7) Explain any special circumstances that would cause the information collection to be conducted in a manner inconsistent with guidelines.
Information is collected in manner that is consistent with the guidelines.
8) Consultation.
A 60 day Notice was published in the Federal Register to obtain public comment on this collection. (See [USCG-2008-0178], April 8, 2008, 73 FR 19082). The USCG has not received any comments on this information collection.
9) Explain any decision to provide any payment or gift to respondents.
No payments or gifts of any kind are provided to respondents.
10) Describe any assurance of confidentiality provided to respondents.
No particular assurance of confidentiality is provided to respondents.
11) Additional justification for any questions of a sensitive nature.
There are no issues of a sensitive nature involved in this information collection.
12) Estimates of reporting and recordkeeping hour and cost burdens of the collection of information.
There are currently 14,215 commercial vessels which have the recordkeeping requirements or reporting requirements listed.
The number of burden hours varies considerably due to the respondent size, type of record/report, type of vessel, and the condition of the vessel. For example, the telephone call notification of a cargo gear test from the master of a cargo vessel to the Officer in Charge, Marine Inspection would be “on occasion” and the time involved would be minimal for both parties. On the other hand, a Certificate of Inspection is completed at specific intervals. It requires time and effort to prepare the document and to have it posted on the vessel.
The Coast Guard estimates the affected industries to have a total annual burden of 1,686 hours/year. This includes 1,326 hours for Certificates of Inspection, 10 hours for Excursion Party Permits, 40 hours for Drydock extension applications, 94 hours for Applications for underwater surveys, and 216 hours for all other applications and requirements. See table 1 below for a summary:
Table 1: Annual Respondents, Responses & Burden Hours
|
Respondents
|
Responses |
Burden Hours |
Annual COI certificates |
284 |
284 |
142 |
5-year Cycle COI certificates |
2,368 |
2,368 |
1,184 |
Application
and Permit for |
42 |
42 |
10 |
AHE Program related collections |
20 |
20 |
40 |
Applications for UWILD |
47 |
47 |
94 |
Other applications |
861 |
861 |
216 |
Total
|
3,622 |
3,622 |
1,686 |
Average Annual Hour Burden:
Annual COI Certificates: 142 hours/year
The Coast Guard expects to issue 284 Certificates of Inspection for COI certificates that have a one-year expiration date. The average annual hour burden is therefore 142 hours (284 COI/year affected x .50 hours).
5-year Cycle COI Certificates: 1,184 hours/year
On average and annually, the Coast Guard expects to issue 2,3681 Certificates of Inspection that have a 5-year expiration date. The average annual hour burden is therefore 1,184 hours (2,368 COI/year affected x .50 hours).
Application and Permit for Excursion Party: 10 hours/year
The Coast Guard expects that 25 inspected vessels need the application and posting of an excursion permit annually. In addition, 175 uninspected vessels would also apply for excursion permits once every 10 years for participation in Maritime Events of National Significance. Therefore, we expect 42 vessels to apply for excursion permits annually. 25 would be already inspected vessels and 17 would be uninspected vessels that participate in Maritime Events of National Significance (175 vessels times the annual probability of a Maritime Event of National Significance 1/10).
We expect the application and posting of an excursion permit to take between 14 to 15 minutes (0.245 hrs will be used for calculations). Therefore we expect the 25 inspected vessels to spend 6 hrs on this collection (25 X 0.245).
Also, the expected time for uninspected vessels participating in Maritime Events of National Significance would be 4 hrs on this collection annually (17 X 0.245). The average annual hour burden is therefore 10 hours (6 + 4).
AHE Program related collections: 40 hours/year
The Coast Guard expects 20 extension applications per year. Each application is expected to place a burden of two hours including research and legal review. Therefore, the average annual hour burden is 40 hours (20 applications/year x 2 hours).
Application for participation in UWILD program: 94 hours/year
The Coast Guard expects 47 applications for underwater surveys per year. Each application is expected to place a burden of two hours including research and legal review. Therefore, the average annual hour burden is 94 hours (47 applications/year x 2 hours).
Other Applications and Requirements: 216 hours/year
The Coast Guard expects 861 respondents submit one application or requirement per year (therefore 861 responses occur annually). Each vessel is assumed to take 15 minutes (0.25 hours) in meeting these requirements (5 minutes for reporting burden, and 10 minutes for recordkeeping). The annual hourly burden is therefore 216 (861 applications/year x 0.25 hours/application = 216 hours/year).
Annual Cost Burden:
Note: The hourly rate used above was based on data from the Enclosure (2) to COMDTINST 73101.1K – Hourly Rates for Personnel ($).
13) Estimates of annualized capital and start-up costs.
There are no annualized capital and start-up costs.
14) Estimates of annualized Federal Government costs.
It is expected that LCDRs/LTs (GS-13) would take 24 minutes (0.4 hours) for completing and processing reports per response. The average annual hour burden would be 1,449 hours per year (3,622 responses X 0.4 hour/response). The average annual cost burden would be $95,634 (1,449 hours X $66/hour).
ENSs/LTJGs (GS-09) are expected to spend 12 minutes (0.2 hours) in checking/updating information per response. The average annual hour burden would be 724 hours per year (3,622 responses X 0.2 hour/response). The average annual cost burden would be $29,684 (724 hours X $41/hour).
It is estimated that GS-5 personnel would spend 12 minutes (0.2 hours) typing and filing certificates/applications per response. The average annual hour burden would be 724 hours per year (3,622 responses X 0.2 hour/response). The average annual cost burden would be $20,996 (724 hours X $29/hour).
Annual Federal cost burden: $146,314
Note: The hourly rate used above was based on data from the Enclosure (2) to COMDTINST 73101.1K – Hourly Rates for Personnel ($).
15) Explain the reasons for the change in burden.
The change in burden is an ADJUSTMENT due to a change in the vessel population.
16) For collections of information whose results are planned to be published for statistical use, outline plans for tabulation, statistical analysis and publication.
There is no plan to use statistical analysis or to publish this information.
17) Explain the reasons for seeking not to display the expiration date for OMB approval of the information of collection.
We are not seeking such approval. The OMB Number will appear on appropriate PRA disclosure information.
18) Explain each exception to the certification statement.
There are no exceptions to the certification statement.
B. Collection of Information Employing Statistical Methods.
This information collection does not employ statistical methods.
1 11,840 inspected vessels with 5-year COIs per MISLE query.
| File Type | application/msword |
| File Title | SUPPORTING STATEMENT |
| Author | Ben White |
| Last Modified By | Kenlinishia Ann Tyler |
| File Modified | 2008-06-11 |
| File Created | 2007-11-27 |