1625-0056 (April 2019)
SUPPORTING STATEMENT
FOR
LABELING REQUIRED IN 33 CFR PARTS 181 AND 183 and 46 CFR 25.10-3
OMB Control No.: 1625-0056
Collection Instruments: Application for Manufacturer Identification Code (MIC) Form
JUSTIFICATION
1.
CIRCUMSTANCES
WHICH MAKE COLLECTION OF INFORMATION NECESSARY
In
accordance with Section 4302(a)(3) of Title 46 of the U.S. Code: "the
Secretary may prescribe regulations requiring or permitting the
display of seals, labels, plates, insignia or other devices for
certifying or evidencing compliance with safety regulations and
standards of the United States Government for recreational vessels
and associated equipment."
Parts 181 and 183 of Title
33, Code of Federal Regulations and 46 CFR 25.10-3 contain the
regulations and safety standards authorized by the statutes which
apply to manufacturers of recreational boats, un-inspected commercial
vessels and associated equipment. The regulations and safety
standards contain information collections, which require boat and
associated equipment manufacturers, importers and the boating public
to apply for serial numbers and to display various labels evidencing
compliance: Hull
Identification Numbers; U.S. Coast Guard Maximum Capacities Label;
Gasoline Fuel Tank Label; USCG Type Fuel Hose Label; and Certified
Navigation Light Label.
Hull
Identification Numbers
(33 CFR 181.21 through 181.35): The Hull Identification Number is a
12 character serial number (similar to the VIN on an automobile),
which provides evidence of compliance with regulations and uniquely
identifies each boat manufactured by an individual for his or her own
use or manufactured or imported by a company for the purposes of
sale. The first three characters in each Hull Identification Number
are a three character Manufacturer Identification Code the Coast
Guard assigns to each manufacturer and importer who submits an
application (33 CFR 181.31).
U.S.
Coast Guard Maximum Capacities Label
(33 CFR 183.21 through 183.27): The U.S. Coast Guard Maximum
Capacities label gives consumers a guide in selecting safe loading
and powering capacities for mono hull boats less than 20 feet in
length. The label also evidences compliance with the Safe Loading
and/or Safe Powering Standards in 33 CFR Part 183.
Gasoline
Fuel
Tank Label
(33 CFR 183.514): The label evidences compliance with requirements
for fuel tanks in the Coast Guard Fuel System Standard in 33 CFR Part
183, and provides information to members of the public who purchase
fuel tanks for use in recreational boats and to manufacturers,
dealers and installers of fuel tanks in recreational boats.
USCG
Type
Fuel
Hose Label
(33 CFR 183.540): The label evidences compliance with requirements
for fuel hose in the Coast Guard Fuel System Standard in 33 CFR Part
183, and provides information to members of the public who purchase
fuel hoses for use in recreational boats and to manufacturers,
dealers and installers of fuel hoses in recreational
boats.
Certified
Navigation Light Label
(33
CFR 183.810 & 46 CFR 25.10-3): The label evidences compliance
with requirements for navigation lights in 33 CFR Part 183 and 46 CFR
25, and provides information to members of the public who purchase
navigation lights for use in recreational boats and to manufacturers,
dealers and installers of navigation lights in recreational boats and
un-inspected commercial vessels.
2.
HOW, BY WHOM, HOW FREQUENTLY AND FOR WHAT PURPOSE IS THE INFORMATION
USED?
Hull
Identification Numbers:
All recreational boats manufactured in or imported into the United
States for the purposes of sale must be identified with two Hull
Identification Numbers (HIN). The HIN provides a unique
identification for each boat: (1) a primary HIN affixed to the
transom; and (2) a secondary HIN affixed somewhere on the interior of
the boat or beneath an item of hardware. The secondary HIN required
in the regulations is used in tracing lost stolen or abandoned boats.
The
first three characters
in the HIN are the Manufacturer Identification Code (MIC). The
regulations require each recreational boat manufacturer or U.S.
importer to request a MIC form to receive the manufacturer’s
MIC. Manufacturers of recreational boats for the purposes of sale to
the public must provide the Coast Guard with their company name and
address, and a brief description of the types and lengths of boats
the company will manufacture (33 CFR 181.31(a)). The information is
used to determine which manufacturers are building boats subject to
U.S. Coast Guard safety standards. Importers of foreign-built boats
for the purposes of sale to the public must provide the Coast Guard
with their company name and address, a list of the foreign
manufacturers whose boats they will import and a brief description of
the types and lengths of boats the company will import (33 CFR
181.31(b). Individuals who build or import a boat for their own use
and not for the purposes of sale do not request a MIC from the Coast
Guard. Instead, each "Backyard Boat Builder" requests an
entire Hull Identification Number from the issuing authority in the
State in which the individual resides (33 CFR 181.31(c)). The MIC in
an HIN issued by a State consists of the State abbreviation followed
by the letter, "Z."
Characters
four through eight
are a manufacturer serial number consisting of letters of the English
alphabet (except "I," "O" and "Q") or
Arabic numerals or both. A manufacturer or importer may choose any
serial number sequence as long as each boat has a different
HIN.
Note: For the purposes of calculating the burdens
associated with the requirement for two Hull Identification Numbers,
no burdens are associated with determining a hull serial number.
This is because there are literally thousands of possible sequential
serial number combinations, i.e., 00001, 00002, 00003, etc. or A0000,
B0000, C0000, etc., which do not require any special expertise to
assign. Some manufacturers might incur additional burdens in
determining hull serial numbers indicative of vessel-specific
information of significance to the manufacturer such as factory where
boat was manufactured, boat type, type of propulsion, etc. However,
such burdens involve optional designations available to a
manufacturer, and are not required for compliance with the HIN
regulations.
Characters
nine and 10
indicate the date of certification for boats subject to an applicable
Coast Guard safety standard in 33 CFR Part 183 (mono hull boats less
than 20 feet in length except sailboats, canoes, kayaks and
inflatables and any boat with a permanently installed gasoline
engine). In all other cases characters nine and 10 indicate the date
of manufacture. Characters
11 and 12
indicate the model year of the boat, such as "13" for
2013.
Purpose
of the HIN Requirement:
Boat manufacturers, the Coast Guard and various State and Federal
agencies use the MIC and the HIN to identify boats subject to recall
in accordance with 46 U.S.C. 4310; to identify the date of a boat's
construction and the safety standards in effect when it was built; to
identify boats being registered; to identify boats involved in
accidents; and to trace lost, stolen or abandoned boats. The
information describing the types and sizes of boats manufactured is
used to determine which manufacturers are building boats subject to
U.S. Coast Guard safety standards for the purposes of compliance
inspection (factory visits) and enforcement.
U.S.
Coast Guard Maximum Capacities Label:
Manufacturers and importers of boats subject the Safe Loading and
Safe Powering Standards in Subparts C and D of 33 CFR Part 183 must
affix a U.S. Coast Guard Maximum Capacities label. Required wording
and format are supplied by the Coast Guard; however, the manufacturer
must perform certain tests and calculations to determine the
individual values which apply to each boat model
(Safe Loading and Safe Powering capacities are usually the same for
all additional units of the same model).
The U.S. Coast
Guard Maximum Capacities label displays the maximum person(s)
capacity (in terms of the number of persons and in terms of the
number of pounds), the maximum weight capacity in pounds (persons,
motor and gear for outboard powered boats and persons and gear for
inboards and stern drives) and the maximum horsepower capacity
(outboard powered boats only). The U.S. Coast Guard Maximum
Capacities label gives the consumer a guide in selecting appropriate
loads and an appropriate maximum horsepower for certain outboard
powered boats.
The Display of Capacity Information, Safe
Loading and Safe Powering Standards were developed because statistics
had shown that mono hull boats less than 20 feet in length, except
sailboats, canoes, kayaks and inflatable boats were involved in
significant numbers of accidents due to overloading or overpowering.
A small boat hull can physically accommodate more people and more
weight or a larger motor (outboards only) than many boats can safely
carry.
Gasoline
Fuel
Tank Label:
Manufacturers and importers of boats equipped with a permanently
installed gasoline engine must comply with the Fuel System Standard
in Subpart J of 33 CFR Part 183. Gasoline fuel tanks must be labeled
in accordance with 33 CFR 183.514. Required wording for part of the
label and the format for the label are specified in the regulations;
however, the tank manufacturer must perform tests and calculations to
validate the safety of the tank and determine some information which
is different for various models and is the same for additional units
of the same model. Information concerning month and year of
manufacture changes according to when the fuel tank is
manufactured.
Note: The Fuel System Standard in which the
labeling requirements for fuel tanks appear applies to the boat
manufacturer; however, most boat manufacturers do not build their own
fuel tanks. Therefore, fuel tank manufacturers are actually the
respondents who are subject to the labeling requirements.
Each
fuel tank label must contain:
1. Fuel tank manufacturer's
name (or logo) and address;
2. Month (or lot number) and year
of manufacture;
3. Capacity in U.S. gallons;
4. Material
of construction;
5. The pressure the tank is designed to
withstand without leaking;
6. Model number, if applicable;
7.
The statement, "This tank has been tested under 33 CFR
183.580"; and
8. If the tank is tested in accordance with
183.584 at less than 25g vertical accelerations, the statement, "Must
be installed aft of the boat's half length."
The
requirements for fuel tank labels are necessary
to reducing the number of deaths and injuries and the amount of
property damage caused by fires and explosions of gasoline on boats.
The information required on the fuel tank label and the tests that
must be performed on a fuel tank are consistent with voluntary
industry standards that have been in existence since the 1950's.
Also since the 1950's, marine surveyors inspecting boats for
insurance companies required the information included in the
voluntary standards for their inspection of boats.
USCG
Type
Fuel
hose label:
Manufacturers and importers of boats equipped with a permanently
installed gasoline engine must comply with the Fuel System Standard
in Subpart J of 33 CFR Part 183. Gasoline fuel hoses must be labeled
in accordance with 33 CFR 183.540(e) and (f). Required wording and
the format for the label are specified in the regulations; however,
the manufacturer must perform tests to determine the permeation rates
of four different types of hose. Also, the year of manufacture must
be displayed on the hose.
Note: The Fuel System Standard
in which the labeling requirements for fuel hoses appear applies to
the boat manufacturer; however, most boat manufacturers do not
manufacture their own fuel hoses. Therefore, fuel hose manufacturers
are actually the respondents who are subject to the labeling
requirements.
Each fuel hose must bear a label, which
contains the following information:
1. The statement
"USCG TYPE (insert A1, A2, B1 or B2)";
2. The year in
which the hose was manufactured; and
3. The manufacturer's name
or registered trademark.
The Fuel System Standard requires
different types of hose depending upon where the hose is installed in
a boat and whether or not it will pass a two and one-half minute fire
test.
Fuel
hose labels are necessary
to identify fuel hose which is resistant to permeation due to
alcohol-blended fuels for the purposes of reducing the number of
deaths and injuries and the amount of property damage caused by fires
and explosions of gasoline on boats.
Certified
Navigation Light label:
Manufacturers and importers of recreational boats and un-inspected
commercial vessels equipped with a navigation lights must install
navigation lights, which comply with the Navigation Rules.
Navigation lights must be labeled in accordance with 33 CFR 183.810
and 46 CFR 25.10-3. Required wording and the format for the label are
specified in the regulations; however, the manufacturer must perform
tests to determine whether or not a navigation light model meets the
requirements of the regulations.
Note:
The Navigation Light Standard in which the labeling requirements for
navigation lights appear applies to the boat manufacturer; however,
most boat manufacturers do not manufacture their own navigation
lights. Therefore, navigation light manufacturers are actually the
respondents who are subject to the labeling requirements.
Each
navigation light must bear a label, which contains the following
information:
1. ``USCG Approval 33 CFR 183.810.''
2. ``MEETS
.''
(Insert the identification name or number of the standard under
paragraph 33 CFR 183.810(a)(2) of this section, to which the
laboratory type-tested.)
3. ``TESTED
BY .''
(Insert the name or registered certification-mark of the laboratory
listed by the Coast Guard that tested the fixture to the standard
under paragraph (a)(2) of this
section.)
4. Name of
manufacturer.
5. Number of model.
6. Visibility of the
light in nautical miles.
7. Date on which the light was
type-tested.
8. Identification and specifications of the bulb
used in the compliance test.
Navigation
light labels are necessary
to identify lights, which meet applicable requirements in the
Navigation Rules, thereby reducing the number of deaths and injuries
and the amount of property damage caused by collisions at night
involving recreational boats and un-inspected commercial
vessels.
Frequency
of Labeling Requirements:
Hull
Identification Number:
Twice per boat. A primary HIN on the transom and a secondary HIN
somewhere on the interior of the boat. Application
of Manufacturer Identification Code (MIC):
Once per boat manufacturer, unless manufacturer has multiple plants
or product lines and desires additional MICs. Individuals who build
or import a boat for their own use and not for the purposes of sale
do not request a MIC from the Coast Guard. Instead, each "Backyard
Boat Builder" requests a single, entire Hull Identification
Number from the issuing authority in the State in which the
individual resides.
U.S.
Coast Guard Maximum Capacities Label:
Once per monohull boat less than 20 feet in length, except
sailboats, canoes, kayaks and inflatables.
Gasoline
Fuel
tank label:
Once per permanently installed gasoline fuel tank.
USCG
Type
Fuel
hose label:
On the outside of the hose at intervals of 12 inches or less.
Certified
Navigation Light label:
Once on navigation light so that it is visible without removing or
disassembling the light.
3.
CONSIDERATION GIVEN TO THE USE OF IMPROVED INFORMATION TECHNOLOGY
As
a practical matter, there is no means for applying improved
information technology to the display of labels, beyond improvements
in label manufacture and construction. Some of the labeling
requirements have been amended periodically to increase the
usefulness or prominence of the information displayed. The use of
computer-generated labels, in lieu of conventional molded plastic or
metal labels, has been considered in estimating the burdens and costs
associated with the display of some labels.
Explain how you will provide a fully electronic reporting option by October 2003, or an explanation of why this is not practicable.
The
labeling requirements in 33 CFR Parts 181 and 183 and 46 CFR 25.10-3
do not involve information collected by the Coast Guard. Instead,
the regulations require manufacturers of recreational boats and
un-inspected commercial vessels and associated equipment to perform
certain tests and to display labels on their products as evidence of
compliance with applicable Coast Guard safety standards and
regulations. The labels provide information, which is important to
prospective purchasers, owners, operators and repairers of
recreational boats and un-inspected commercial vessels and associated
equipment. There
is no practical way to collect (provide) the information
electronically.
4.
EFFORTS TO IDENTIFY DUPLICATION
This
information is not collected in any form, and therefore is not
duplicated elsewhere.
5.
IF THE COLLECTION OF INFORMATION INVOLVES SMALL BUSINESSES OR OTHER
SMALL ENTITIES, DESCRIBE METHODS USED TO MINIMIZE BURDENS:
This
information collection does not have any impact on small businesses
or other small entities.
6.
CONSEQUENCE TO COAST GUARD BOATING STANDARDS PROGRAM IF LABELING
REQUIREMENTS ARE WITHDRAWN OR INFORMATION IS COLLECTED LESS
FREQUENTLY.
In
the absence of the Hull
Identification Number
requirements, there is no way to individually identify each boat
built by every manufacturer or importer. This would make it
impossible to identify the date of a boat's construction and the
safety standards in effect when it was built; to identify boats being
registered; to identify boats involved in accidents; and to trace
lost, stolen or abandoned boats. The regulations governing
Manufacturer Identification Codes; require a single application for a
MIC.
In
the absence of a requirement for a U.S.
Coast Guard Maximum Capacities label,
there would be increased accidents involving sinking, capsizing,
swamping and drowning involving small boats.
The absence
of a Gasoline
Fuel Tank Label
would remove information useful to the boat owner who needs a
suitable replacement fuel tank and would make it impossible for the
Coast Guard, marine surveyors and manufacturers to determine whether
tanks installed in recreational boats meet applicable requirements.
This would increase the risk for increased numbers of fires and
explosions on recreational boats because of non-complying fuel
tanks.
The absence of the USCG
Type Fuel Hose Label
would remove information necessary to determine whether a hose
installed meets applicable requirements and finding equivalent
replacement hose. This would increase the risk for increased numbers
of fires and explosions on recreational boats because of
non-complying fuel hoses.
The absence of the Certified
Navigation Light Label
would remove information necessary to determine whether lights being
installed on recreational boats and un-inspected commercial vessels
meet applicable requirements and finding equivalent replacement
lights. This would increase the risk for higher numbers of nighttime
collisions involving recreational boats and un-inspected commercial
vessels because of non-complying lights.
Manufacturers of
boats subject to labeling requirements in 33 CFR Parts 181 and 183 do
not have to furnish the information more than the single time before
the boat is offered for sale to the public.
7.
CIRCUMSTANCES WHICH REQUIRE COLLECTION TO
This information collection is conducted in manner consistent with the guidelines in 5CFR 1320.5(d)(2).
8.
DESCRIBE EFFORTS TO CONSULT WITH PERSONS OUTSIDE THE AGENCY:
A
60-day Notice (See [USCG-2019-0262], August 19, 2019, 84 FR 42938 and
30-day Notice (November 4, 2019, 84 FR 59396 were published in the
Federal Register to obtain public comments on this collection. The
notice elicited one comment that stated, “to check all policy
by the owner/government policy to register to show more penalties
from act of government” which does not provide any suggestions
for improving this collection of information. Accordingly, no
changes have been made to the Collections.
The Coast Guard Office of Boating Safety also conducts two meetings of the National Boating Safety Advisory Council each year. The Council is made up of a total of 21 members; seven members represent the boating industry; seven are State boating authorities; and seven represent the boating public. Issues involving Coast Guard regulations applicable to boat manufacturers, including labeling requirements, are routinely discussed at NBSAC meetings. In addition, every five years the Coast Guard conducts regulatory reviews under the auspices of NBSAC for all of the regulations applicable to manufacturers of recreational boats and associated equipment.
9. EXPLAIN ANY DECISION TO PROVIDE ANY PAYMENT OR GIFT TO RESPONDENTS
USCG does not provide payments or gifts to respondents in exchange for a benefit sought.
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 the Marine Information for Safety and Law Enforcement System of Records Notice (SORN). Links to the aforementioned PIA and SORN are provided below:
https://www.dhs.gov/sites/default/files/publications/privacy_pia_008_uscg_misle_2009.pdf
https://www.govinfo.gov/content/pkg/FR-2009-06-25/html/E9-14906.htm
11. PROVIDE ADDITIONAL JUSTIFICATION FOR ANY QUESTIONS OF A SENSITIVE NATURE
There are no questions of a sensitive language.
12. PROVIDE ESTIMATES OF THE BURDEN OF COLLECTION OF INFORMATION
Summary of existing and new Annual Burden Hours for the Label Regulations
Information Collection (IC) |
Burden (hours) |
Hull Identification Number |
184,802 |
Maximum Capacities Label |
26,617 |
Fuel Tank |
922 |
Fuel Hose |
2,398 |
Navigation Lights |
1,405 |
Total |
216,144 |
|
|
Information Collection (IC) |
Man Hour Costs ($) |
|
(2015) |
New (2018) |
|
A-2. Hull Identification Number |
$4,545,054.54 |
$4,805,368.78 |
B-2. Maximum Capacities Label |
$139,100.00 |
$164,242.00 |
C-2. Fuel Tank |
$23,556.00 |
$24,050.00 |
D-2. Fuel Hose |
$5,668.00 |
$5,772.00 |
E-2. Navigation Lights |
$30,654.00 |
$35,126.00 |
Total |
$4744032.54 |
$5,034,558.78 |
- Man Hours and Labor Costs to Affix Labels:
A-2. Man Hour Costs to Order and Affix HIN:
Overview: Labor costs to affix HIN are determined by: Hours to affix label times $26 (boat builders hourly wage).
Responses: 192 new manufacturers annually (1 per respondent)
Preparation time: 7 min. per response
Estimated hourly cost for secretary: $18.69*
*Source: BLS April 2019 National Occupational Employment and Wage Estimates
192 (respondents) x 7 min = 1,344 min
1,344 /60 (min/hr) = 22 total hours to complete MIC request
22 (hr) x $18.69 (secretary) = $411.18 total cost for secretary
$0.55 (stamp) x 192 (number of respondents) = $105.60 total cost of postage
$411.18 + $105.60 = $516.78 to request MIC
Boat manufacturer hourly wage of $26.00
184,802 man-hours to affix HIN x $26.00 per hour (boat builder) = $4,804,852.00 total cost of boat builder
$516.78 (request for MIC) + $4,804,852.00 = $4,805,368.78 total man-hours for MIC and HIN
B-2. Man-hour Costs to Affix Maximun Capacity Labels:
Overview: Labor costs to affix Maximum Capacity Label are determined by: Hours to affix label times $26 (boat builders hourly wage).
Boat manufacturer hourly wage of $26.00
6,317 (hours to affix Maximum Capacity Label) x $26.00 (boat builder per hour) = $164,242.00
C-2. Man-hour Costs to Affix Fuel Tank Labels:
Overview: Labor costs to affix Fuel Tank Labels are determined by: Hours to affix label times $26 (boat builders hourly wage).
Boat manufacturer hourly wage of $26.00
925 (man-hours) x $26.00 (per hour wage) = $24,050.00 (total hourly wage cost)
D-2. Man-hour Costs to Affix Fuel Hose Labels:
Overview: Labor costs to affix Fuel Hose Labels are determined by: Hours to affix label times $26 (boat builders hourly wage).
Boat manufacturer hourly wage of $26.00
222 (man-hours) x $26 = $5,772.00 total man-hour wages
E-2. Man-Hours Costs to Affix Navigation Light Labels:
Overview: Labor costs to affix Navigation Light Labels are determined by: Hours to affix label times $26 (boat builders hourly wage).
Boat manufacturer hourly wage of $26.00
1,351 (total man-hours) x $26.00 (wage) = $35,126.00 total wages
Information Collection (IC) |
Man Hour Costs ($) |
|
(2015) |
New (2018) |
|
A-2. Hull Identification Number |
$4,545,054.54 |
$4,805,368.78 |
B-2. Maximum Capacities Label |
$139,100.00 |
$164,242.00 |
C-2. Fuel Tank |
$23,556.00 |
$24,050.00 |
D-2. Fuel Hose |
$5,668.00 |
$5,772.00 |
E-2. Navigation Lights |
$30,654.00 |
$35,126.00 |
Total |
$4744032.54 |
$5,034,558.78 |
A. Hull Identification Number (applies to all recreational boats)
Manufacturer Identification Code (MIC): The regulations require each recreational boat manufacturer or U.S. importer to the Coast Guard and request a MIC application that reports the company name and address, and a brief description of the types and lengths of boats the company will manufacture. The following is a summary of the numbers of Manufacturer Identification Codes the Office of Boating Safety has issued for the last 10 years.
YEAR |
# OF MANUFACTURER |
2018 |
196 |
2017 |
220 |
2016 |
202 |
2015 |
200 |
2014 |
190 |
2013 |
204 |
2012 |
177 |
2011 |
197 |
2010 |
212 |
2009 |
124 |
TOTAL |
1,922 |
AVERAGE |
1,922/10 = 192 |
Therefore, the average number of respondents is 192.
Time to complete MIC application: .1 hours [7min*(7/60)hr/min = .1 hours]
Responses: 192
1 Response per respondent
192 x .1 = 19: 19 total hours to request MICs
Recordkeeping: None
Hull Identification Numbers for Individuals building their own boats (BYBBs)
Responses: 17,075* BYBBs annually (1 per respondent)
* Based on 4 State survey in 1989
Preparation time: .1 hours [7 min. per response]
17,075 x .1 = 1,708 hours to request BYBB HINs. Note: States assign HINs to BYBB not the U.S. Coast Guard.
Recordkeeping: None
Display of HIN
Time Required to affix: 10 min. per boat* [(10/60)min/hr = .2 hours]
Estimated Annual Boat Production: 900,000
BYBB HINs = 17,075
Total: 900,000 + 17,075 = 917,075.
917,075 x .2 = 183,415 hours to affix HINs
Summary for HIN:
Hull ID # |
Hours |
MIC |
19 |
BYBBs |
1,708 |
Display of HIN |
183,075 |
TOTAL |
184,802 |
Recordkeeping: None
B. U.S. Coast Guard Maximum Capacities Label (testing for new models; display for all boats subject to the standard; no recordkeeping)
Safe Loading
Estimated 1,200 new boat models introduced annually
Two people one eight hour day to conduct test = 16 hours
16 x 1,200 = 19,200 hours to test safe loading
Safe Powering
Estimated 1,100 new boat models introduced annually
One person one hour to measure boat and make calculations
1,100 x 1 = 1,100 hours to test safe powering
Time Required to Affix U.S. Coast Guard Maximum Capacities Label
Label Boat types on which displayed Units Sold*
2015 2016 2017 3 yr. avg
Maximum Outboard boats, inboard ski/wake
Capacities boats, jetboats, sterndrive boats 178,800 190,600 199,100 189,500
Label
*Source: The 2017 Recreational Boating Abstract is a comprehensive summary of statistics on the recreational boating industry in the United States. It presents data collected by the National Marine Manufacturers Association (NMMA) through a coalition of sources brought together by the NMMA Industry Statistics & Research Department. See http://www.nmma.org/statistics/publications/statisticalabstract.aspx.
Estimated 2 minutes to affix label
2 x 189,500 = 379,000min
379,000/60(min/hr) = 6,317 hours to affix label
19,200
1,100
6,317
26,617 hours (total Annual Burden for Display of Capacity Information)
C. Fuel Tank Label (testing for new models; display for all boats subject to the standard; no recordkeeping)
Testing Gasoline Fuel Tank for Purposes of Label Display:
New Tank Models Manufactured Annually = 50
15 minutes to conduct Static Pressure Test
15 x 50 = 750 min
750/60(min/hr) = 13 hours to Test Fuel Tanks
Display of Label
Time Required to affix: 2 minutes per tank
Label Boat types on which displayed Units Sold*
2015 2016 2017 3 yr. avg
Fuel tank Inboard ski/wake boats
Label jetboats, inboard cruisers 27,000 28,800 28,300 27,767
sterndrive boats
*Source: See footnote above
27,767 x 2 min. = 55,534 min
55,534/60 (min/hr) = 925 total hours to affix label to tanks
Recordkeeping: None
13
925
938 hours (Total annual burden to test fuel tanks and affix labels to Fuel Tank)
D. U.S. Coast Guard Type Fuel Hose Label (testing for all batches; display for all hose used on boats subject to the standard; no recordkeeping)
Label Boat types on which displayed Units Sold*
2015 2016 2017 3 yr. avg
Fuel hose Inboard ski/wake boats
Label jetboats, inboard cruisers 27,000 28,800 28,300 27,767
sterndrive boats
* See footnote above
Fuel hose installed in a boat, approximately 20 feet in length
20 (feet) x 27,767 (boats) = 555,340 total feet of hose
It is estimated 5,000 feet of hose per batch manufactured
555,340 /5000 (total ft/hose batch) = 111 total batches of hose manufactured annually
Estimated 20 hours to test a batch of fuel hose
20 x 111 = 2,220 total hours to test fuel hoses
Labeling Fuel Hose
111 fuel hose batches manufactured annually
Labels are painted on using a roller
It is estimated it takes 2 hours to manufacture and label one batch
2 x 111 = 222 hours to label fuel hose
Recordkeeping: None
2,220
222
2,442 hours (Total annual burden to test and label fuel hoses)
E. Certified Navigation Light Label (testing for new models; display on all lights for boats subject to the standard; no recordkeeping)
Testing Certified Navigation Lights for the purposes of label display:
There are nine manufacturers of navigation lights on the market.
The testing portion of this information collection takes place only when a manufacturer wants to place a new light on the market.
We estimate that it takes one employee a total of one hour to prepare the paperwork to submit a light for performance tests and actual testing would take approximately one hour.
If each of these manufacturers submits three new models of lights for testing each year, the burden for testing is:
9 manufacturers x 2 hours x 3 lights = 54 hours burden for testing
Labeling Navigation Lights:
Much of the verification is printable on an insert with the package, or on a sticker (described in Title 33 CFR 183.810). If the insert and/or sticker are machine inserted or applied, we estimate 5 seconds per Navigation Light for labeling
Label Boat types on which displayed Units Sold*
2015 2016 2017 3 yr. avg
Navigation light All boats operated at night
Label Outboard boats, inboard ski/wake 183,600 196,100 204,000 194,567
boats, jetboats, inboard cruisers
sterndrive boats, sailboats
The typical recreational boat or un-inspected vessel, displays from three to six Navigation Lights (sidelights, masthead light, a stern light and an anchor light)
3 + 4 + 5 + 6 = 18/4 = 5 boats average lights per vessel
194,567 x 5 seconds = 972,835 total seconds
972,835/60 (seconds/hr) = 16,214 total minutes
16,214 total minutes x 5 average lights per boat = 81,070 total minutes
81,070/60 (min/hr) = 1,351 hours (burden for Navigation Light’s paperwork, testing and labeling)
54
1,351
1,405 hours (Total annual burden for Navigation Light Label)
SUMMARY TOTAL ANNUAL BURDEN FOR LABELING REQUIRED IN 33 CFR PARTS 181 AND 183 and 46 CFR 25.10-3
SECTION 12 |
DESCRIPTION |
ANNUAL BURDEN HOURS |
12.A |
HIN |
184,802 |
12.B |
Display Capacity Information |
26,617 |
12.C |
Fuel Tank Label |
938 |
12.D |
Fuel Hose Label |
2,442 |
12.E |
Navigation Light Label |
1,405 |
Total |
|
216,204 |
13. PROVIDE AN ESTIMATE OF THE TOTAL ANNUAL COST BURDEN TO RESPONDENTS OR RECORDKEEPERS RESULTING FROM THE COLLECTION OF INFORMATION:
Summary of existing and new Annual cost to respondents for the Label Regulations
Information Collection (IC) |
Production Costs ($) |
|
(2015) |
New (2018) |
|
A-1. Hull Identification Number |
$580,656.25 |
$723,705.25 |
B-1. Maximum Capacities Label |
$462,871.30 |
$585,625.00 |
C-1. Fuel Tank |
$17,820.88 |
$20,236.90 |
D-1. Fuel Hose |
$40,674.00 |
$40,515.00 |
E-1. Navigation Lights |
$213,082.00 |
$274,860.00 |
Total |
$1,315,104.43 |
$1,644,942.15 |
Production Cost of Labels
A-1. Hull Identification Number Production Costs (applies to all recreational boats)
Overview: Production costs of HINs are determined by: time to request for a MIC; cost of mailing MIC application; cost to produce label (label printing company); and cost of affix label (Manufacturer).
Request for a Manufacturer Identification Code (MIC):
(Manufacturers and Importers)
Responses: 192 new manufacturers annually (1 per respondent)
Preparation time: 7 min per response
Estimated hourly cost for secretary: $18.69*
*Source: BLS April 2019 National Occupational Employment and Wage Estimates
Postage per response = $.55
(No recordkeeping)
192 x 7 min = 1,344 total minutes
1,344/60 (min/hr) = 22 hours (total time to complete paperwork by manufacturer)
22 x $18.69 = $411.18 total cost for secretary to complete form
$0.55 x 192 = $105.60 total cost of mailing, stamps
$411.18 + $105.60 = $516.78 to request MIC (total cost to complete form and stamps for mailing)
Request for Hull Identification Number:
(Backyard Boat Builders [BYBB])
Responses: 17,075* BYBBs annually (1 per respondent)
* Based on estimates from 4 State survey in 1989
Postage per response = $.55
(No recordkeeping)
Cannot estimate cost of time to the public
Cannot estimate cost of recordkeeping to the public
- Note: BYBB HINs are assigned by the State the BYBB is registering the boat in. The U.S. Coast Guard does not have knowledge of the time it requires to fill out State forms.
17,075 x $.55 = $8,336.75 estimated total annual postage cost
Respondents Cost in the Federal Register Notices.
NOTE: In the past, there has been no comments in the Federal Register Notices
Cannot estimate the time to the public.
Cannot estimate the cost of submitting comments to the Federal Register Notice both by mail or electronically.
HIN Label Production Costs:
Estimated annual production of all boat models: 900,000
BYBB HINs = 17,075
900,000 + 17,075 = 917,075
Estimated annual boat production 917,075
Two HIN labels required on each recreational boat (commercial manufacturer and BYBB)
917,075 x 2 = 1,834,150 Total HIN Labels
Estimated cost per label: $0.35
One-time start-up fee for label of $50.00
Estimated total cost of HIN Label: 1,834,150 (total number of labels) x $0.35 (each label) = $641,952.50
Shipping cost: United States Postal Service Priority Flat Rate $7.65 per package (Note: cannot determine the total cost of shipping and handling due to the unknown number of manufacturers of recreational boats that would receive HIN Labels).
Costs to Affix HINs: Manufacturers of all boats must display two Hull Identification Numbers.*
Label Construction: (1) HIN labels on fiberglass boats usually consist of a "male" embossed mirror image label which is stuck to the transom area of the hull mold which results in a "female" embossed HIN in the fiberglass of the hull. Metal labels may also be used, provided they are riveted and epoxied to the transom area of the finished boat hull. (2) HIN labels on aluminum boats usually consist of a metal label riveted and epoxied or welded to the transom area of the finished boat hull. (3) HIN labels on wooden boat hulls may be carved or burned on the finished boat hull. Metal labels may also be used, provided they are riveted and epoxied to the transom area of the finished boat hull.
*The secondary HIN may be handwritten and glassed over on the interior surface of a fiberglass boat.
HINs to be affixed by rivets: 2 rivets per HIN Label for a total of 4 rivets per boat (two HINs per boat). 917,075 x 4 = 3,668,300 total rivets needed
Rivets are $0.02 apiece: 3,668,300 x $.02 = $73,366.00 total cost of rivets
$641,952.50 (HIN label) + $73,366.00 (cost of rivets)+ $50.00 (label start-up fee) = $715,368.50 total manufacture cost for labels.
$8,336.75 + $715,368.50 = $723,705.25 total production costs for MIC and HIN labels, rivets and postage.
B-1. U.S. Coast Guard Maximum Capacities Label Production Costs (testing for new models; display for all boats subject to the standard)
Overview: Production costs of Maximum Capacity Labels are determined by: required testing to determine Maximum Horsepower and Maximum persons/weight; cost to produce label (label printing company); and cost to affix label (boat manufacturer).
Costs to Perform Tests:
Safe Loading Standard for determination of maximum persons capacity and maximum weight capacity:
Average of 1,200 new models introduced annually which are subject to the Safe Loading Standard.
Estimated cost to conduct Safe Loading tests: $310.00
1,200 x $310.00 = $372,000 cost for Safe Loading tests
Safe Powering Standard for determination of maximum horsepower capacity of outboard powered boats:
Average of 1,100 new models introduced annually which are subject to the Safe Powering Standard.
Estimated cost to conduct Safe Powering calculations: $65.00
1,100 x $65.00 = $71,500.00 cost for Safe Powering
$372,000.00 (Cost of Safe Loading test) $71,500.00 (Cost of Safe Power test) = $443,500.00 total testing costs for Safe Power and Safe Loading
Maximum Capacity Label Production Costs:
Estimated annual boat production 189,500 (3 year average)
Label one-time start-up fee: $50.00.
Estimated cost per label: $0.75
Estimated total cost of Maximum Capacity Labels: 189,500 x $0.75 = $142,125.00
$142,125.00 (cost of labels) + $50 (label start-up fee) = $142,175.00 total cost of Maximum Capacity Label
Shipping cost: United States Postal Service Priority Flat Rate $7.65 per package (Note: cannot determine the total cost of shipping and handling due to the unknown number of manufacturers of recreational boats that would receive Maximum Capacity Label packages).
Costs to Affix Maximum Capacities label:
Label Construction: The label must resist the weather and wear encountered in normal use of the boat (material that can withstand exposure to water, oil, salt spray, direct sunlight, heat, cold and wear expected in normal use), and the label must be made so that it shows visible traces of any attempt to alter or remove information on it. Generally, capacity labels are constructed of plastic, printed aluminum plates, or adhesive, mylar-covered computer generated paper labels.
$142,175.00 total production cost of Maximum Capacity Labels. (Note: Capacity Labels affixed with self-sticking adhesive included in the label cost.)
$443,500.00 (cost of Safe Powering and Safe Loading tests) + $142,125.00 (total production cost of capacity label) = $585,625.00 total cost to test for Maximum Capacity and manufacture Maximum Capacity Labels.
C_1. Gasoline Fuel Tank Label (testing for new models; display for all boats subject to the standard)
Overview: Production costs of Fuel Tank Labels are determined by: required testing to determine maximum pressure and leakage ; cost to produce label (label printing company); and cost to affix label (tank manufacturer).
Cost for Static Pressure Test = $15.00
New tank models manufactured annually = 50
$15.00 x 50 = $750.00 cost to test fuel tanks
Fuel Tank Label Production Costs:
Estimated annual boat production 27,767 (3 year average)
Fuel Tank Label’s one-time start-up fee: $50.00
Average cost of label = $.70
$.70 (cost of label) x 27,767 (3 yr. avg. annual production) = $19,436.90 estimated total cost of Fuel Tank Labels
Shipping cost: United States Postal Service Priority Flat Rate $7.65 per package (note: cannot determine the total cost of shipping and handling due to the unknown number of manufacturers of recreational boat fuel tanks who would receive Fuel Tank Label packages).
Cost to affix Fuel Tank Label:
$19,436.90 (cost of labels) + $50.00 (label start-up fee) = $19,486.90 total to produce Fuel Tank Labels. (Note: Fuel Tank Labels affixed with self-sticking adhesive included in the label cost.)
$750.00 (cost to test fuel tanks) + $19,486.90 (total to produce and affix Fuel Tank Label) = $20,236.90 total cost to test fuel tanks and produce Fuel Tank Labels.
D_1. U.S. Coast Guard Type Fuel Hose Label Production Costs (testing for all batches; display for all hose used on boats subject to the standard)
Overview: Production costs of Fuel Hose Labels are determined by: required testing to determine maximum pressure and leakage ; cost to produce stamp label; and cost to stamp label (fuel hose manufacturer).
Estimated $250.00 to test a batch of fuel hose
111 batches manufactured annually
$250.00 (estimated cost to test a batch of fuel hose) x 111 (number of fuel hose batches = $27,750.00 to test fuel hose
Fuel Hose Label Production Costs:
Fuel hose installed in a boat, Approximately 20 feet
20 (ft of fuel hose) x 27,767 (average boat production over three years) = 555,340 total feet of hose
Estimated 5,000 feet of hose per batch manufactured
555,340 /5000 (total hose ft/ft per batch) = 111 total batches of hose manufactured annually
Estimated $115.00 per batch to label fuel hose
$115.00 (batch label cost) x 111 (total number of batches) = $12,765 total cost to produce Fuel Hose Labels
Shipping cost: United States Postal Service Priority Flat Rate $7.65 per package (Note: cannot determine the total cost of shipping and handling due to the unknown number of manufacturers of recreational boats that would receive Fuel Hose Label packages).
Cost to Affix Fuel Hose Label:
$27,750.00 (fuel hose testing) + $12,765 (cost to produce fuel hose labels = $40,515.00 total cost to test fuel hoses and manufacture Fuel Hose Labels.
E-1. Certified Navigation Light Label Production Costs (testing for new models; display on all lights for boats operating at night)
Overview: Production costs of Navigation Light Labels are determined by: required testing to certify light meets Coast Guard Standards ; cost to produce label (label printing company); and cost to affix label (light manufacturer).
Testing Costs: In conversations with Underwriters Laboratories and Imana Laboratory, testing laboratories approved by the Coast Guard, we developed an estimate of $500 for a performance test of each model. Volume discounts for multiple model tests from these laboratories will decrease the cost of each model to $400. We know that the nine manufacturers of navigation lights introduce three new models each year.
9 (navigation light manufactures) x 3 (new model of navigation lights per year) x $400 (Navigation light tests) = $10,800 total testing costs
Labeling Costs: Labeling navigation lights:
Each of 9 manufacturers introduces 3 new models per year.
We first compute the one-time cost of labeling for the 3 models of each type of light. In computing the cost of labeling we must also include a one-time $50 plate charge for each model. Therefore:
9 (number of manufacturers) x 3 (new navigation lights per year) x $50.00 (Start-up fee) = $1,350.00 total cost of start-up fees
3 + 4 + 5 + 6 = 18/4 = 5 lights average per vessel
194,567 (3 yr. avg. annual production) x 5 (avg. lights per vessel) = 972,835 total lights
972,835 (lights)/1,000 (labels) = 973 batches of labels
Using estimates from labeling companies, we have determined that manufacturers will pay about $270 for 1,000 labels.
973 (batches of labels) x $270.00 (per 1000 labels) = $262,710 cost to produce labels
Shipping cost: United States Postal Service Priority Flat Rate $7.65 per package (note: cannot determine the total cost of shipping and handling due to the unknown number of manufacturers of recreational boat navigation lights who would receive Navigation Light Label packages).
Cost to affix Navigation Light Label:
$262,710 (cost to produce labels) + $1,350.00 (start-up fees) = $264,060.00 total to produce Navigation Light Labels. (Note: Navigation Light Labels affixed with self-sticking adhesive included in the label cost.)
$10,800 (total cost to test navigation lights) + $264,060 (total to produce labels) = $274,860.00 total cost to test Navigation Lights and produce Navigation Light labels.
Label Production Cost Summary
Information Collection (IC) |
Production Costs ($) |
|
(2015) |
(2018) |
|
A-1. Hull Identification Number |
$580,656.25 |
$723,705.25 |
B-1. Maximum Capacities Label |
$462,871.30 |
$585,625.00 |
C-1. Fuel Tank |
$17,820.88 |
$20,236.90 |
D-1. Fuel Hose |
$40,674.00 |
$40,515.00 |
E-1. Navigation Lights |
$213,082.00 |
$274,860.00 |
Total |
$1,315,104.43 |
$1,644,942.15 |
14. TOTAL ANNUAL ESTIMATED COST TO GOVERNMENT
The estimated annual cost to the Federal Government is $2,064.00 due to operational expenses (man-hours). For the Manufacturer Identification Codes, the average number of respondents for the last 10 years is 192. The information supplied by boat manufacturers and importers is entered on a computerized database. It takes an estimated 15 minutes to read the manufacturer's correspondence, enter the information into the database and compose and send a reply. 192 x .25 (15 min) = 48 man-hours expended annually. Estimated average cost/hour = $43.00 at 48 (mh) x $43.00 = $2,064.00. There are no costs to the Government associated with requirements for affixing labels.
15. EXPLAIN REASONS FOR PROGRAM CHANGES OR ADJUSTMENTS
This is a program adjustment. There are no new or additional label requirements. The regulations requiring the labels appear in 33 CFR Parts 181 and 183 and 46 CFR 25.10-3. Any change to the required number, wording or format of the labels would require notice and comment in the Federal Register.
In order to estimate the numbers of boats manufactured annually, we use estimates of annual sales figures published by the National Marine Manufacturers Association (NMMA) Statistical & Research Department. Economic changes during the last several years mean significantly smaller numbers of boat manufacturers and numbers of boats sold. For example, compare the numbers of Manufacturer Identification Codes issued in the years 2009-2011 to those issued 2012 – 2014, or the annual sales statistics for the years 2009-2011 to those for 2012 – 2014 (See http://www.nmma.org/statistics/publications/statisticalabstract.aspx).
16. OUTLINE PLANS FOR TABULATION, STATISTICAL ANALYSIS AND PUBLICATION
USCG does not intend to employ the use of statistics or the publication thereof for this information collection.
17. IF SEEKING OMB APPROVAL TO NOT DISPLAY EXPIRATION DATE, EXPLAIN THE REASONS THAT DISPLAY WOULD BE INAPPROPRIATE
USCG will display the expiration date for OMB approval of this information collection.
18. EXPLAIN EACH EXCEPTION TO THE CERTIFICATION STATEMENT IDENTIFIED IN ITEM 19.
The Coast Guard does not request an exception to the certification of this information collection.
ADDENDUM
The statutory authority for Labeling required in 33 CFR Parts 181 and 183 and 46 CFR 25.10-3 is 46 U.S.C. 4302(a)(3):
(a) The Secretary may prescribe regulations—
(1) establishing minimum safety standards for recreational vessels and associated equipment, and establishing procedures and tests required to measure conformance with those standards, with each standard—
(A) meeting the need for recreational vessel safety; and
(B) being stated, insofar as practicable, in terms of performance;
(2) requiring the installation, carrying, or use of associated equipment (including fuel systems, ventilation systems, electrical systems, sound-producing devices, firefighting equipment, lifesaving devices, signaling devices, ground tackle, life- and grab-rails, and navigational equipment) on recreational vessels and classes of recreational vessels subject to this chapter, and prohibiting the installation, carrying, or use of associated equipment that does not conform with safety standards established under this section; and
(3) requiring or permitting the display of seals, labels, plates, insignia, or other devices for certifying or evidencing compliance with safety regulations and standards of the United States Government for recreational vessels and associated equipment.
| File Type | application/vnd.openxmlformats-officedocument.wordprocessingml.document |
| File Title | SUPPORTING STATEMENT |
| Author | USCG |
| File Modified | 0000-00-00 |
| File Created | 2021-02-04 |