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pdf1625-0037
Supporting Statement
for
Certificates of Compliance, Boiler/Pressure Vessel Repairs,
Cargo Gear Records, and Shipping Papers
A. Justification
1. Circumstances that make the collection necessary.
The requirement for reporting Boiler and Pressure Vessel Repairs, and the requirements
for maintaining Cargo Gear Records, Shipping Papers, and the Certificate of Compliance (CG3585), are a part of the Coast Guard’s Marine Safety Program of Title 46, Code of Federal
Regulations. They are prescribed or authorized by one or all of the following laws: 46 USC
3301, 3305, 3306, 3702, 3703, 3711 and 3714.
These requirements provide the marine inspector with information regarding the
condition of a vessel and its equipment, a list of the type and amount of cargo that has been or is
being carried on a vessel, plus information about the owner of the vessel. Each of these
requirements relate to the promotion of safety of life at sea and protection of the marine
environment.
This information collection supports the following strategic goals:
Department of Homeland Security
• Prevention
• Protection
Coast Guard
• 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.
Cargo Gear Records (46 CFR 31.10-16, 71.25-25, & 91.25-25). Cargo gear records are a
recordkeeping requirement and are maintained to ensure the availability of unique vessel
information that is needed by Coast Guard boarding personnel. Cargo gear records must
be maintained by tank vessels carrying combustible or liquid cargo in bulk (Subchapter D),
passenger vessels greater than 100 gross tons (Subchapter H), and cargo and miscellaneous
vessels (Subchapter I). The owners of these vessels must provide all registers of cargo gear
upon request to the Officer in Charge, Marine Inspection.
Shipping Papers (46 CFR 35.01-10). Shipping Papers are a recordkeeping requirement
and are maintained by tank vessels to ensure the availability of unique vessel information
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that is needed by Coast Guard boarding personnel. Each loaded tank vessel shall have on
board a bill of lading, manifest, or shipping document giving the name of the consignee
and the location of the delivery point, the kind, grades, and approximate quantity of each
kind and grade of cargo, and for whose account the cargo is being handled. In the case of
unmanned barges where shipping papers are not available, an entry in the logbook of the
towing vessel is sufficient.
Certificate of Compliance (46 CFR 30-40, 153 & 154). Certificates of Compliance (CG3585) are a recordkeeping requirement, as the certificates are issued by the Coast Guard
and maintained by foreign vessel owners to ensure the availability of unique vessel
information that is needed by Coast Guard boarding personnel. A foreign vessel owner
may apply for a Certificate by submitting information to the Commanding Officer at the
Marine Safety Center (§154.22(a)). A Certificate of Compliance is issued by the Coast
Guard to document a foreign flag vessel has been examined and found to comply with the
regulations. Certificates of Compliance must be renewed every 2 years.
Boiler/Pressure Vessel Repairs (46 CFR 35.25-5, 78.33-1, & 97.30-1). The purpose of
the reporting requirement regarding boiler and pressure vessel repairs is to ensure that
work completed on these Coast Guard certified devices has been properly accomplished
without compromising safety. Before making any repairs to boilers or unfired pressure
vessels, the chief engineer shall notify the Officer in Charge, Marine Inspection, at the
nearest port where the repairs are to be made. Repair records must be maintained by tank
vessels carrying combustible or liquid cargo in bulk (subchapter D), passenger vessels
greater than 100 gross tons (subchapter H), and cargo and miscellaneous vessels
(subchapter I).
If these above requirements were no longer permitted, many items critical to the safety of
personnel, their vessels, our ports, and the marine environment would be jeopardized.
3. Consideration of the use of improved information technology.
Information is submitted in writing or electronically via e-mail or phone. Information
may be submitted to the CG Officer in Charge, Marine Inspection (OCMI) at the local Sector
Office, or the CG MSC. Contact info for CG OCMIs can be found at—
http://www.uscg.mil/top/units/. For information on submitting information to the CG MSC, go
to— https://homeport.uscg.mil/msc > CONTACT US > MAIL ADDRESS, TELEPHONE
CONTACTS, AND E-COMMERCE INFO.
Cargo Gear Records and Shipping Papers are recordkeeping requirements, and are not
restricted to written form. Electronic files are allowed and would reduce the physical volume of
records on the vessel. We estimate that many vessels employ an electronic database for their
records.
Certificates of Compliance (COC) are maintained on board the vessel for use by the
vessel operators and enforcement personnel. A COC is issued by the CG to document a foreign
flag vessel has been examined and found to comply with the regulations. The COC—in hard
copy format—must be available for CG boarding personnel to annotate—using pen and ink—
following completion of subsequent examinations. The form provides instructions to CG Port
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State Control Officers on how/when the COC should be annotated. The issuance of a COC to a
foreign tank vessel is required by 46 U.S.C. 3711.
Before making any repairs to boilers or unfired pressure vessels, the vessel must notify
the local OCMI at the nearest port. A phone call will suffice for notification. The repair records
are not restricted to written form. Electronic files are allowed and would reduce the physical
volume of records on the vessel.
We estimate that over 90% of the reporting and recordkeeping requirements can be done
electronically.
4. Efforts to identify duplication.
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 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.
The availability of the information required for cargo gear testing, shipping papers, and
Certificates of Compliance, along with reporting requirements for boiler and pressure and vessel
repairs are all elements of the Coast Guard’s marine safety program. The protection of life and
property, our ports and the marine environment would be seriously hindered by the loss of these
requirements.
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-2011-0843]; September 12, 2011; 76 FR 56208). Additionally, a 30-day
Notice was published in the Federal Register to obtain public comment on this collection
(November 18, 2011; 76 FR 71581). The Coast Guard 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.
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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 annual number of respondents is 14,224
The estimated annual number of responses is 37,805
The estimated annual hour burden is 14,725
The estimated annual cost burden is $736,250
The estimated burden varies with the reporting or recordkeeping requirement. The total
respondents, responses, and burden hours are detailed in the attached tables:
A. Boiler and Pressure Vessel Repairs (see Appendix, Table 1). This requirement dictates that
the vessel owners report and record any repairs. The numbers represent the number of boiler and
pressure vessel repair deficiencies resolved during the corresponding year by ship type. The
average time spent per response was assumed to not have changed from the previous analysis,
and therefore was used in this updated analysis. The data was available for years 2009 and 2010
in SANS.1 The number of respondents and the number of responses are the same in the
“Average Number of Respondents per Year Column” and “Average Number of Responses per
Year Column.” This is due to the query being done on an annual basis, which is more accurate
than having an aggregate estimate over a given number of years then estimating a yearly rate.
Actual annual data is available and was used in this analysis.
B. Cargo Gear Records (see Appendix, Table 2). Cargo gear records are a recordkeeping
requirement and are maintained to ensure the availability of unique vessel information that is
needed by Coast Guard boarding personnel. The number of cargo gear records for this analysis
was estimated using SANS and the corresponding query for this estimate used distinct vessel
arrivals into the United States. We assume that all these distinct arrivals keep the required
records. The average time spent per response was assumed to be the same as the last COI
analysis. The analysis was estimated using years 2008-2010 in MISLE.2 The number of
respondents and the number of responses are the same in the “Average Number of Respondents
per Year Column” and “Average Number of Responses per Year Column.” This is due to the
query being done on an annual basis, which is more accurate than having an aggregate estimate
over a given number of years then estimating a yearly rate. Actual annual data is available and
was used in this analysis.
1
2
SANS – Ship Arrival Notification System.
MISLE – Marine Information for Safety and Law Enforcement.
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C. Shipping Papers (see Appendix, Table 3). Shipping papers represent a recordkeeping
requirement and the below figures were calculated based on distinct arrivals and bounces.
Distinct arrivals were used to determine the number of respondents and bounces to determine the
number of responses. Distinct US arrivals, both foreign and United States ships, and bounces for
U.S and Foreign were used for these calculations. We assume that all arrivals processed the
appropriate shipping paper recordkeeping requirement.
D. Certificates of Compliance (see Appendix, Table 4). Certificates of Compliance are issued
once every two years. The number of foreign vessels issued Certificates of Compliance was
estimated using SANS and the corresponding query for this estimate used “Compliance” as the
search word for the query. The average time spent per response was assumed to be the same as
the last COI analysis. The analysis was estimated using years 2008-2010 in SANS. The number
of respondents and the number of responses are the same in the “Average Number of
Respondents per Year Column” and “Average Number of Responses per Year Column.” This is
due to the query being done on an annual basis, which is more accurate than having an aggregate
estimate over a given number of years then estimating a yearly rate. Actual annual data is
available and was used in this analysis.
The total burden to the public is depicted in Appendix, Table 5. Assuming an average salary of
$50/hour3, the annual cost of the reporting and recordkeeping requirements would be $736,250.
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 (see Appendix, Table 6).
Cargo Gear Records and Shipping Papers are vessel recordkeeping requirements.
Therefore, there is no review or collection required of the Coast Guard unless it is necessary to
board the vessel. Certificates of Compliance are the forms that require Coast Guard review.
Using a salary estimate of $72/hour4, the annualized cost to the Federal Government would be
$31,120.
15. Explain the reasons for the change in burden.
The change in hour burden is an ADJUSTMENT due to a change in vessel
population/activity levels. There is no proposed change to the reporting or recordkeeping
requirements of this collection. The reporting and recordkeeping requirements, and the
methodology for calculating burden, remain unchanged.
• In this ICR, we estimate an annual increase in respondents is due to an increase in the
number of vessels that carry out Cargo Gear recordkeeping. This change may be due to
the use of a different data base to collect the vessel population (i.e., a shift from MISLE
to SANS).
3
4
Equivalent to a GS-09 “out-of-gov’t” rate, per COMDTINST 7310.1M.
Equivalent to an O-3 “in-gov’t” rate, per COMDTINST 7310.1M.
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•
•
•
•
In this ICR, we estimate an annual decrease in responses and burden due to a decrease in
the number of vessels that carry out Shipping Papers recordkeeping. This change may be
due to the use of a different data base to collect the vessel population (i.e., a shift from
MISLE to SANS).
Updates are provided for cost burden associated with this collection of information.
Form CG-3585 was revised to better distinguish between tank vessels and FPSOs and
FPSs. The change to the form is burden neutral as this is a CG-issued form that is
maintained by the vessel operator.
The CG has created printable instructions for this collection of information.
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 display the expiration date for OMB approval of the
information of collection.
The certificate associated with this collection is prescribed by U.S. Code. This certificate
has a specific two year expiration date. The addition of a second expiration date to this
certificate—that for OMB approval—may cause problems. It may cause foreign-flag vessel
owner/operators to interact with the Coast Guard more frequently than required to reconcile the
existence of 2 expirations dates on their ships’ certificate. It is for this reason that expiration date
for OMB approval is not displayed on the certificate. However, the OMB expiration date will be
displayed on the Instruction sheet related to the information collection request.
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.
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1625‐0037_SS_Appendix_r2.xls
Tbl 1 Boiler & Pressure Vessel
2009 Number
Responses
2010 Number
Responses
Tank Ships
Passenger Ships
Cargo Ships
Research Ships
School Ships
0
0
0
0
0
0
0
1
0
0
Total
0
1
Respondents
Average Number of
Respondents Per
Avg. Time Spent 2009 Total Annual
Year
per Response (Hrs.)
Time (Hrs.)
0
2010 Total Annual Average Number of
Time (Hrs.)
Responses Per Year
Average Annual
Time Per Year
(Hrs.)
0
0
0
0
0
0
0
1
0
0
0
0
0
1
0
0
0.16
0.16
0.16
0.16
0.16
0
1
0
0
1
0
0
1
0.16
0
1
1
1
1625‐0037_SS_Appendix_r2.xls
Tbl 2 Cargo Gear Records
Respondents
Tank Ships (United
States)
Tank Ships (Foreign)
2008 Number
Responses
2009 Number
Responses
2010 Number
Responses
Average Number of
Respondents Per Year
Avg. Time Spent per
Response (Hrs.)
2008 Total Annual
Time (Hrs.)
2009 Total Annual
Time (Hrs.)
2010 Total Annual
Time (Hrs.)
Average Number of
Responses Per Year
Average Annual Time
Per Year
86
80
69
78
0.16
14
13
11
78
12
2,483
2,477
2,655
2538
0.16
397
396
425
2,538
406
Passenger Ships
(United States)
437
422
447
435
0.16
70
68
72
435
70
Passenger Ships
(Foreign)
294
278
284
285
0.16
47
44
45
285
46
Cargo Ships (United
States)
256
229
207
231
0.16
41
37
33
231
37
5,802
5,604
5,838
5748
0.16
928
897
934
5,748
920
Research Ships
(United States)
Cargo Ships (Foreign)
35
27
25
29
0.16
6
4
4
29
5
Research Ships
(Foreign)
54
58
65
59
0.16
9
9
10
59
9
School Ships (United
States)
10
12
9
10
0.16
1
2
1
10
2
School Ships
(Foreign)
11
9
10
10
0.16
2
1
2
10
2
824
770
757
783
0.16
132
124
121
783
125
Total Foreign
8,644
8,426
8,852
8,640
0.16
1,383
1,347
1,416
8,640
1382
Grand Total
9,468
9,196
9,609
9,423
0.16
1,515
1,471
1,537
9,423
1,509
Total United States
1625‐0037_SS_Appendix_r2.xls
Tbl 3 Shipping Papers
Respondents
Tank Ships
(United States)
Tank Barges
(US)
Tank Ships
(Foreign)
Tank Barges
(Foreign)
Total United
States
Total Foreign
Grand Total
Total
Respondents for
2008,2009,
2010
2008 Number
Responses
2009 Number
Responses
2010 Number
Responses
225
3,875
3,398
2,960
75
29
34
26
23
5,521
23,391
20,949
3
0
8
Average Annual
Avg. Time
Respondents Per
Spent per
Year
Response (Hrs.)
Average
Number of
Responses Per Average Annual
Year
Time Per Year
2008 Total
Annual Time
(Hrs.)
2009 Total
Annual Time
(Hrs.)
2010 Total
Annual Time
(Hrs.)
0.5
1,938
1,699
1,480
3,411
1,706
10
0.5
17
13
12
28
14
21,848
1840
0.5
11,696
10,475
10,924
22,063
11,032
7
1
0.5
0
4
4
5
3
1,135
5,401
5,993
5,669
378
0.5
2,701
2,997
2,835
3,439
1,720
5,537
5,778
23,533
27,300
26,331
24,381
27,599
24,838
1,846
1,926
0.5
0.5
11,767
13,651
13,166
12,191
13,800
12,420
22,068
25,507
11,034
12,755
1625‐0037_SS_Appendix_r2.xls
Tbl 4 Certificate of Compliance
2008 Number of
Responses
2009 Number of
Responses
2010 Number of
Responses
Average Number
of Respondents
Per Year
Avg Time Spent
per response
Towing Vessel
2
3
1
2
0.16
1
1
1
2
0
Passenger >6
83
84
131
99
0.16
8
13
18
99
16
Unclassified
2
5
14
7
0.16
1
1
1
7
1
Commercial
Fishing Vessel
0
0
0
0
0.16
0
0
0
0
0
Industrial Vessel
1
4
1
2
0.16
1
1
1
2
0
Tank Barge
11
13
12
12
0.16
1
1
1
12
2
Research Vessel
5
3
4
4
0.16
1
1
1
4
1
Mobile Offshore
Drilling Unit
62
57
59
59
0.16
7
8
9
59
9
Offshore Supply
Vessel
7
7
3
6
0.16
1
1
2
6
1
1966
2,038
2,176
2,060
0.16
135
209
201
2,060
330
Passenger < 6
4
3
5
4
0.16
1
1
1
4
1
Recreational
0
1
3
1
0.16
1
1
1
1
0
Freight Ship
827
594
432
618
0.16
126
121
112
618
99
Total
2,970
2,812
2,841
2,874
0.16
284
359
349
2,874
460
Respondents
Tank Ship
2008 Time Spent 2009 Time Spent 2010 Time Spent Average Number
per Response
per Response
per Response
of Responses Per
(Hrs.)
(Hrs.)
(Hrs.)
Year
Average Annual
Time Per Year
1625‐0037_SS_Appendix_r2.xls
Tbl 5 Total Burden to Public
Respondents
Boiler & Pressure
Vessel Repairs
Cargo Gear Records
Shipping Papers
Certificate of
Compliance
Total
Average
Number of
Respondents
Per Year
Average
Number of
Responses Per Yearly Average
Year
Annual Time (Hrs.)
1
1
1
9,423
1,926
9,423
25,507
1,509
12,755
2,874
2,874
460
14,224
37,805
14,725
Tbl 6 Total Fed Gov't Burden
Respondents
Certificates of
Compliance
Total Annual Burden
Average
Number of
Responses Per
Year
Avg. Time
Spent per
Response
(Hrs.)
Average Annual
Time Per Year
(Hrs.)
2,874
0.16
460
2,874
0.16
460
| File Type | application/pdf |
| File Title | Microsoft Word - 1625-0037_SS_r2a_2011.doc |
| Author | DADuPont |
| File Modified | 2011-11-18 |
| File Created | 2011-11-18 |