1625-0094_SS_r0_2018

1625-0094_SS_r0_2018.doc

Ships Carrying Bulk Hazardous Liquids

OMB: 1625-0094

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1625-0094

Supporting Statement

for

Ships Carrying Bulk Hazardous Liquids


OMB No.: 1625-0094

COLLECTION INSTRUMENTS: CG-4602B, CG-5148,
CG-5148A, CG-5148B, CG-5461 & Instruction


A. Justification


1) Circumstances that make the collection of information necessary.


Many of the information and collection requirements in 46 CFR 153 are required by Annex II to the MARPOL Convention which is implemented in 46 CFR 153 under the authority of 33 USC 1903.


The remaining information collection and recordkeeping requirements are necessary to ensure that the requirements for the safe transport by vessel of bulk liquid hazardous materials mandated by 46 USC 3703 are met.


This information collection supports the following strategic goals:

Department of Homeland Security

  • Prevention

  • Recovery

  • Response

Coast Guard

  • Marine Safety

  • Protection of the Natural Resources

Prevention Policy & Response Policy Directorates (CG-5P & CG-5R)

  • 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) Purposes of the information collection.


The information is used by the Coast Guard to evaluate vessel design, to ensure compliance with the regulations and as a means to implement MARPOL Annex II. The information is used by vessel crewmembers in operations related to the cargoes and to avoid potential dangers presented by the cargo. Subject description and affected population for the collection of information are shown in Table 1.


Table 1

Collection of Information for Ships Carrying Bulk Hazardous Liquids:

CFR, Subject description, Affected Population, and Associated Supporting Documents/Forms


Item

CFR

Subject Description

Affected Vessels

a.

46 CFR 153.9(c)

If required by the MSC, vessels applying for a COC may have to submit additional information. We estimate that 4% of vessels will need to submit additional information annually.

Foreign Vessels

b.

46 CFR 153.483

A vessel owner may request a waiver to carry category B & C NLS between ports of one or more MARPOL countries without meeting the 481 & 482 stripping requirements. We estimate that 2% of vessels will request a waiver annually.

Foreign and U.S. Vessels

c.

46 CFR 153.809

If an owner of a foreign vessel wishes to have the Coast Guard conduct a COC inspection, they must make a request to an Officer in Charge, Marine Inspection of the port where the vessel is to be inspected. We estimate that 50% of vessels will request an inspection annually.

Foreign Vessels

d.

46 CFR 153.902

If a COC becomes invalid or expires, the vessel owner must submit a copy of the COC and IMO Certificate of Fitness to the MSC to become valid again. We estimate that 50% of vessels will need to submit a Certificate of Fitness annually.

Foreign Vessels

e.

46 CFR 153.1119

A tank required to be prewashed may be prewashed in a port other than the loading port if (1) Coast Guard (CG-ENG) permission is granted; (2) there is a written agreement that the other port will accept the tank washing; (3) there is a written pledge from the person in charge. We estimate that 0% of vessels will prewash in another port annually.

Foreign and U.S. Vessels

f.


In addition to the above requirements there are several supporting documents/forms associated with this collection. These are—

  • International Certificate of Fitness for the Carriage of Liquefied Gases in Bulk (form CG-5148) (per 153.12)

  • Certificate of Fitness for the Carriage of Dangerous Chemicals in Bulk (form CG-5148A) (per 153.12)

  • International Certificate of Fitness for the Carriage of Dangerous Chemicals in Bulk (form CG-5148B) (per 153.12)

  • International Pollution Prevention Certificate for the Carriage of Noxious Liquid Substances in Bulk (form CG-5461) (per 153.12)

  • Cargo Record Book (form CG-4620B) (per 153.490 & 909)

U.S. Vessels


3) Consideration of the use of improved information technology.


Information is submitted in writing or electronically via e-mail. Information is submitted to the CG Officer in Charge, Marine Inspection (OCMI) at the local Sector Office, or the CG Marine Safety Center (MSC). Contact info for CG OCMIs can be found at— https://www.uscg.mil/Units/Organization/. For information on submitting information to the CG MSC, go to— http://www.dco.uscg.mil/msc. Electronic submission is voluntary, and we estimate that 90% of respondents submit their plans electronically for this collection.


4) Efforts to identify duplication.


Each submission is unique. The Coast Guard does not know of any similar information being collected.


5) Methods to minimize the burden to small businesses if involved.


For reasons of safety, the carriage of hazardous materials must be in accordance with the type and degree of hazards they represent. The burden imposed on small businesses cannot be lessened relative to the burden on larger entities.


6) Consequences to the Federal program if collection were conducted less frequently.


The vessel safety laws would be extremely difficult and costly to enforce without these recordkeeping and reporting requirements. The pollution-related requirements are predominantly intended to ensure vessel crews have sufficient information to operate without violating MARPOL Annex II and to aid the Coast Guard in enforcing Annex II of MARPOL.


In many cases, the information on each vessel is collected on a case-to-case basis as needed. Less frequent collection would make enforcement mechanisms ineffective. In addition, for most cargoes covered by Part 153, much of the information collected is necessary to comply with the requirements of MARPOL Annex II. Less frequent collection would require repudiation of MARPOL Annex II and impair the ability of U.S. vessels to trade internationally.


7) Special collection circumstances.


This information collection is conducted in manner consistent with the guidelines in 5 CFR 1320.5(d)(2).


8) Consultation.


A 60-day Notice (see [USCG-2018-0281], May 24, 2018, 83 FR 24133) and 30-Day Notice (August 10, 2018, 83 FR 39767) were published in the Federal Register to obtain public comment on this collection. The Coast Guard received one comment. The comment was unrelated to this Information Collection request. Accordingly, no changes have been made to the 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. This information collection request is covered by the Marine Information for Safety and Law Enforcement (MISLE) Privacy Impact Assessment (PIA) and System of Records Notice (SORN). Links to the MISLE PIA and SORN are provided below:


11) Additional justification for any questions of a sensitive nature.


There are no questions of sensitive language.


12) Estimate of annual hour and cost burdens to respondents.


  • The estimated annual number of respondents is 1,538.

  • The estimated annual number of responses is 1,619.

  • The estimated annual hour burden is 7,611 hours.

  • The estimated annual cost burden is $882,876,056.


The burden to respondents is provided in Appendix A. We estimate that it will take from 1 to 8 hours to perform various tasks as detailed in the appendix. We expect that a shore-side technical specialist would be responsible to perform these tasks. The position of shore-side technical specialist is analogous to a Lieutenant (O-3). The wage rate used is in accordance with the current edition of COMDTINST 7310.1(series) for “Out-Government” personnel.


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.


The estimated annual Federal Government cost is $66,825 (see Appendix B). It takes the Coast Guard an average of 1 to 2 hours to perform various reviews, a task typically performed by a Lieutenant (O-3). The wage rate used is in accordance with the current edition of COMDTINST 7310.1(series) for “In-Government” personnel.


15) Reason for the change in burden.


The change in burden hours is an ADJUSTMENT due to an increase in the estimated annual number of respondents. 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.


16) Plans for tabulation, statistical analysis, and publication.


This information collection will not be published for statistical purposes.


17) Approval for not explaining the expiration date for OMB approval.


The certificates associated with this collection are prescribed by an international treaty (MARPOL or SOLAS) that the U.S. Government is signatory to. These certificates all have specific five year expiration dates related to requirements set out in the treaty. The addition of a second expiration date to these certificates—that for OMB approval—may cause several problems. First, it may cause U.S.-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’ certificates. Second, it may cause confusion with foreign Port Sate Control boarding officers, resulting in U.S.-flag ships being delayed or detained in foreign ports due to 2 differing expiration dates. It is for these reasons that expiration dates for OMB approval are not displayed on the certificates associated with this collection. However, the OMB expiration date is 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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