1625-0084
Supporting
Statement
for
Audit Reports under the International Safety
Management Code
A. Justification.
1) Circumstances that make the collection of information necessary.
The implementation of the International Safety Management (ISM) Code on U.S. vessels subject to the International Convention for the Safety of Life at Sea, as amended (SOLAS 74/88) is mandated by section 602 of the Coast Guard Authorization Act of 1996 (Pub. L. 104-324; 110 STAT. 3901). The statute requires that U.S. shipping companies and their vessels possess Safety Management Certificates (SMC) and Documents of Compliance (DOC), respectively, as outlined in the ISM Code. Information showing the compliance status of U.S. vessels in international trade must be provided to the Coast Guard by organizations recognized by them. Three classification societies possess this recognition. 33 CFR Part 96 sets the rules for the safe operation of vessels and safety management systems.
This information collection supports the following strategic goals:
Department of Homeland Security
Prevention
Protection
Maritime Safety
Protection of the Natural Resources
Marine Safety, Security and Stewardship Directorate (CG-5)
Safety: Eliminate deaths, injuries, and property damage associated with commercial maritime operations.
Human and Natural Environment: Eliminate environmental damage associated with maritime transportation and operations on and around the nation’s waterways.
2) By whom, how, and for what purpose the information is to be used.
Information describing companies’ and vessels’ compliance with the ISM Code must be verified by the Coast Guard. Information must be collected to determine the compliance status of U.S. vessels, subject to SOLAS 74/88, engaged in international trade. Ongoing audits of vessels’ and companies’ safety management systems which impact the SMC and DOC status are conducted by organizations recognized by the Coast Guard. Collecting the information ensures that vessels will not be delayed or detained while conducting international commerce. When visiting foreign ports, these certificates attest that the vessel meets applicable requirements of Chapter IX of SOLAS 74/88 to the satisfaction of the organization recognized by the Coast Guard to issue ISM certificates. Without compliance, American flag ships could be detained and/or harassed as being “unsafe.” Unless sooner returned or revoked, these certificates are valid for five years. “Interim” SMCs and DOCs are valid for six months and 12 months respectively. Interim certificates may be issued to companies/vessels that are new or newly acquired. Collection is necessary when the status of the certificate changes.
3) Consideration of the use of improved information technology.
At present, the classification societies do not have the ability to send in reports electronically, but they do have a new system that will give surveyors the abilities to do reports on laptops and send them directly to the home office. We estimate that when the system is completely on-line 100% of the reporting and recordkeeping requirements can by done electronically. At this time we estimate that 0% of the responses are collected electronically.
4) Efforts to identify duplication. Why similar information cannot be used.
The Coast Guard established specific criteria for organizations to be recognized to act on its behalf. Presently, only three classification societies are authorized to issue ISM certificates: America Bureau of Shipping, Germanischer Lloyd, and Det Norske Veritas. Close contact and continuous communication with these organizations ensures that no duplication occurs.
5) Methods to minimize the burden to small business if involved.
This information collection does not have an impact on small businesses or other small entities.
6) Consequences to the Federal program if collection were conducted less frequently.
Without current information, the possibility of vessels being delayed or operating under unsafe conditions increases.
7) Explain any special circumstances that would cause the information collection to be conducted in a manner inconsistent with guidelines.
This information collection is conducted in manner consistent with the guidelines in 5 CFR 1320.5(d)(2).
8) Consultation.
A 60 day Notice was published in the Federal Register to obtain public comment on this collection. (See [USCG-2009-0115, March 12, 2009, 74 FR 10752). The USCG has not received any comments on this information collection.
9) Explain any decision to provide any payment or gift to respondents.
There is no offer of monetary or material value for this information collection.
10) Describe any assurance of confidentiality provided to respondents.
There are no assurances of confidentiality provided to the respondents for this information collection.
11) Additional justification for any questions of a sensitive nature.
There are no questions of sensitive language.
12) Estimates of reporting and recordkeeping hour and cost burdens of the collection of information.
The estimated number of annual respondents is 409.
The estimated number of annual responses is 4,621.
The estimated hour burden is 16,873 hours.
The estimated cost burden is $1,271,622.
The reporting and recordkeeping burden will be imposed only on those vessels required to comply with the ISM Code. The specific recordkeeping requirements in the ISM Code are an international standard. The regulations themselves prescribe no additional recordkeeping on the companies or classification societies. The estimated reporting information was obtained from the MISLE database. The frequency of response varies since the requirements are based on parameters established in individual safety management systems. Also, the complexity of the safety management system is based on the type and number of vessels operated. The vessels that currently hold Safety Management Certificates are listed in the following table:
Vessel Type |
Vessels |
Freight Barges |
6 |
Freight Ships |
233 |
Industrial Vessels |
27 |
MODUs |
3 |
OSV |
213 |
Oil Recovery |
7 |
Passenger |
135 |
Recreational |
2 |
Research Vessel |
31 |
School Ship |
1 |
Tank Barge |
16 |
Tank Ship |
94 |
Towing Vessel |
233 |
TOTAL |
1,001 |
There were 1,001 total vessels which are owned by 4061 separate entities.
It is estimated that the companies responsible for the vessels listed above will use classification societies to attain the required ISM certificates. Hence, the number of annual respondents is 409, comprised of the 406 companies that own the vessels subject to the International Convention for the Safety of Life at Sea, as amended (SOLAS 74/88), and the 3 classification societies.
The no. of annual responses is 4,621, which is calculated using the following formula:
4,6212 = 2 x 406 + 2 x 1,001 + 1 x 1,001 + 0.4 x 1,001 + 1 x 406
Vessel ISM audit reports.
# of Audits per year |
Time Requirements |
# of Companies |
Total # of Annual hours |
|||||
|
Time to Complete Audit Reports |
Time to Review Audit Reports |
|
|
||||
2 |
x |
(1 |
+ |
3) |
x |
406 |
= |
3,248 |
+
# of Audits per year |
Time Requirements |
#
of |
Total # of Annual hours |
|||||
|
Time to Complete Audit Reports |
Time to Review Audit Reports |
|
|
||||
2 |
x |
(2 |
+ |
3) |
x |
1,001 |
= |
10,010 |
Total Annual Hour Burden (3,248hrs+ 10,010hrs) = 13,258 hours
Total Annual Cost Burden:
Total Hour Burden X hourly rate (O-3 outside3) = cost
13,258 hr X $84/hr = $1,113,672
12-2. Classification societies process (vessel audit) information.
# of Audits per year |
Time Requirements |
#
of |
Total # of Annual hours |
|||
1 |
x |
2 |
x |
1,001 |
= |
2,002 |
Total Annual Hour Burden = 2,002 hours
Total Annual Cost Burden:
Total annual hour Burden X hourly rate (E-3 outside) = cost
2,002 hours X $37/hr (E-3) = $74,074
12-3. Classification societies complete audits, audit reports and review ISM audit reports to determine compliance with the ISM Code. Consider two vessel-audits in five years and one company-audit yearly.
# of Audits per year |
Time Requirements |
#
of |
Total # of Annual hours |
|||
0.4 |
x |
2 |
x |
1,001 |
= |
801 |
+
# of Audits per year |
Time Requirements |
# of Companies |
Total # of Annual hours |
|||
1 |
x |
2 |
x |
406 |
= |
812 |
Total Annual Hour Burden (801 hrs + 812 hrs) = 1,613 hours
Total Annual Cost Burden:
Total Hour Burden X hourly rate (E-5 outside) = cost
1,613 hours X $52/hr (E-5) = $83,876.
Total Annual Industry Hour Burden (13,258 hrs + 2,002 hrs + 1,613 hrs ) = 16,873 hours
Total Annual Industry Cost Burden ( $1,113,672 + $74,074 + $83,876) = $1,271,622
13) Estimates of annualized capital and start-up costs.
There are no capital, start-up or maintenance costs associated with this information collection.
14) Estimates of annualized Federal Government costs.
Government costs will come from a Coast Guard officer (0-3) who will review vessel ISM audit reports as well as classification society printouts to determine compliance with ISM Code—
14.1 Review of vessel ISM audit reports.
Hour Burden:
# of Audits per year |
Time Requirements |
# of vessels |
|
Total # of Annual hours |
||
0.4 |
x |
2 |
x |
1,001 |
= |
801 |
Total Annual Hour Burden = 801 hours
Total Annual Cost Burden:
Total Hour Burden X hourly rate = cost
801 hours X $67/hr (O-3 inside) = $53,667
14-2. Review of classification society audits.
Hour Burden:
# of Audits per year |
Time Requirements |
# of companies |
|
Total # of Annual hours |
||
1 |
x |
1 |
x |
406 |
= |
406 |
Total Annual Hour Burden = 406Hours
Total Annual Cost Burden:
Total Hour Burden X hourly rate = cost
406 hours X $67 (O-3 inside) = $27,202
Total Annual Government Time Burden (801 hrs + 406 hrs) = 1,207 hours
Total Annual Government Cost ($53,667 + $27,202) = $80,869
15) Explain the reasons for the change in burden.
The change in burden is an ADJUSTMENT due to a change in the vessel and company populations. The methodology for calculating burden remains unchanged.
16) For collections of information whose results are planned to be published for statistical use, outline plans for tabulation, statistical analysis and publication.
This information collection will not be published for statistical purposes.
17) Explain the reasons for seeking not to display the expiration date for OMB approval of the information collection.
The Coast Guard will display the expiration date for OMB approval of this information collection.
18) Explain each exception to the certification statement.
The Coast Guard does not request an exception to the certification of this information collection.
B. Collection of Information Employing Statistical Methods.
This information collection does not employ statistical methods.
1 Figure was obtained from the following MISLE data: US shipping companies that own SOLAS vessels.
2 The number of responses is calculated by adding together the number of audits per year times the number of vessels or companies that are affected by those audits. These numbers can be located in the tables and do not count the time required for each audit.
3 The hourly rates are from COMDTINST 7310.1L. When the cost is borne by the Coast Guard, the “within government” rate was used. When the work was performed by a non-government employee, the “outside government” rate was used.
| File Type | application/msword |
| File Title | PAPERWORK REDUCTION ACT SUBMISSION |
| Author | zzjward1 |
| Last Modified By | Arthur A. Requina |
| File Modified | 2009-06-30 |
| File Created | 2009-02-05 |