1625-0039
Supporting Statement
for
Declaration of Inspection Before Transfer of Liquid Cargo in Bulk
OMB No.: 1625-0039
COLLECTION INSTRUMENTS: Instruction
A. Justification
1. Circumstances that make the collection of information necessary.
Title 46 U.S. Code (U.S.C.) 3703 and 70011 authorized the Coast Guard to establish procedures, methods, and equipment requirements to prevent damage to vessels and facilities resulting from an unauthorized discharge of oil or hazardous substances into the environment. The Declaration of Inspection (DOI) is required to ensure safety during transfer of liquid cargo in 33 Code of Federal Regulations (CFR) 156.150 and 46 CFR 35.35-30. A Person-in-Charge (PIC) designated under 33 CFR 154.710 and 155.700 completes the DOI for each bulk transfer conducted. A copy of the DOI must be kept on board the vessel and facility for one month from the date of signature.
Coast Guard personnel, under the direct supervision of the Captain of the Port (COTP), conduct regulatory compliance inspections of vessels and facilities that transfer oil and hazardous materials in bulk. The DOI is checked to ensure compliance and to determine culpability in spill and accident investigations.
The statutory authority is 46 U.S.C. 3703 and 70011.
2. Purpose of the information collection.
As part of the Coast Guard’s Port Safety and Security Program, this information is used in order to identify potential or actual violations of the regulations. The DOI must be completed for the U.S. to ensure compliance with specific procedures to prevent pollution of U.S. waters or damage to vessels and facilities. If no records were kept, a PIC may not know their responsibilities (in case of foreign nationals working on foreign ships that transfer oil or hazardous materials in bulk in U.S. ports) or they may not follow all of the proper procedures. The result would be a significant increase in the risk of pollution or damage. Also, it would be more difficult to ascertain culpability for accidents and spills.
3. Consideration of the use of improved technology.
The DOI may be in written or electronic form.1 The information is not submitted to the Coast Guard; rather the DOI must be available for inspection during the transfer and retained for at least 1 month thereafter. We estimate that 5% of DOI activities are done electronically.
4. Efforts to identify duplication.
The Coast Guard monitors State and local regulatory activity in this field. No State, local, or other Federal agencies have been identified that require equivalent information. No similar information is available.
5. Methods to minimize the burden to small businesses 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.
Presently, a DOI is completed each time a bulk transfer is conducted and is kept for one month following each transfer operation. Reducing the use of DOIs could be detrimental in determining the causal factor for accidents and spills. Also, there is the possibility of increased pollution if proper prevention procedures are not followed.
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 was published in the Federal Register to obtain public comment on this collection (See [USCG-2022-0048]; February 8, 2022, 87 FR 7197) and 30-Day Notice (May 18, 2022, 87 FR 30244) were published in the Federal Register to obtain public comment on this collection. The Coast Guard has not received any comments on this information collection.
9. Provide 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:
https://www.dhs.gov/sites/default/files/publications/privacy_pia_uscg_misle.pdf
https://www.gpo.gov/fdsys/pkg/FR-2009-06-25/html/E9-14906.htm
11. Additional justification for any questions of a sensitive nature.
There are no questions of sensitive language.
12. Estimates of annual hour and cost burdens to respondents.
The annual number of respondents is 15,360.
The annual number of responses is 266,835.
The estimated annual hour burden is 80,051.
The estimated annual cost burden is $3,356,894.
The burden to respondents is provided in Appendix A. Each time a vessel conducts a transfer of oil or other hazardous materials, a DOI must be completed and kept. Completing a DOI constitutes a response. This requirement covers all U.S. vessels and all non-U.S. flagged ships that carry oil and hazardous materials in bulk. We estimate the annual frequency of responses varies by vessel type. We estimate that it will take vessel personnel about 0.3 hours (18 minutes)2 to verify that the required procedures have been followed and to sign the DOI. For U.S. Tank Ships, U.S. Nontank Vessels and Non-U.S. Vessels, we estimate that a Chief Engineer will complete the DOI. For U.S. Tank Barges, we estimate that a tankerman will complete the DOI. For the Chief Engineer wage rate, we used the Bureau of Labor Statistics (BLS) wage rate for Ship Engineers (53-5031) [May 2020, mean hourly wage, loaded 50%, and rounded].3 For the tankerman wage rate, we used the BLS wage rate for Sailors and Marine Oilers (53-5011) [May 2020, mean hourly wage, loaded 50%, and rounded].4
13. Estimates of 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 $86,508 (see Appendix B). Coast Guard personnel review DOIs during cargo transfer monitorings, periodic inspections, random boardings, and post-casualty investigations. The number of reviews is about 20% of all annual DOIs. We estimate that it will take a CG petty officer (E-5) about 0.03 hours (i.e., 1.5 minutes) per review. The wage rate shown is in accordance with the current edition of COMDTINST 7310.1(series) for “In-Government” personnel.
15. Explain the reasons for the change in burden.
There is no change in the burden. There is no proposed change to the recordkeeping requirements of this collection. The 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 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 The use of any electronic DOI system is at the discretion of an owner/operator of the waterfront facility or vessel that engages in oil or hazardous materials transfers.
2 The time estimate (i.e., 18 minutes) to complete a DOI reflects both the vessel and facility time.
| File Type | application/vnd.openxmlformats-officedocument.wordprocessingml.document |
| File Title | Supporting Statement |
| Author | USCG |
| File Modified | 0000-00-00 |
| File Created | 2022-09-04 |