Vessels should individually be evaluated prior to each annual inspection to determine if reducing the scope is appropriate. OCMIs should considered several factors when managing vessel activities and in general, inspection priorities can be based on numerous factors, including - but not limited to - vessel type, vessel characteristics, route, maintenance and compliance history.
USCG informs that OCMIs are already scoping inspection activities based on risk, primarily due to workload outpacing the workforce's capacity. The Office of Commercial Vessel Compliance (CG-CVC) acknowledges that OCMIs have the final decision on how best to manage the risks associated with vessels in their fleets and for this reason, they are allowing discretionary use of a RBDM Matrix for SPVs (the matrix is included in the policy letter below)
A regular annual inspection is appropriate if answer is “yes” to any question below:
a. Has the vessel’s current condition changed since that observed at the last inspection?
b. Are there any maintenance issues outstanding?
c. Have there been any modifications or significant repairs to the vessel since the last inspection?
d. Has the vessel been involved in a serious marine incident that impacted the vessel’s material condition since the last inspection?
e. Have there been any changes in the vessel’s conditions of carriage since the last inspection?
f. Have there been changes in manning since the last inspection?
g. Has the vessel been placed under operational controls since the last inspection?
The below factors should be considered when planning the scope of a vessel inspection:
a. Knowledge of the owner or operator reliability, integrity, and Safety Management culture.
b. Vessel’s documented violation history, paying particular attention to lifesaving and firefighting readiness.
c. Entries in the vessel’s history that indicate actions on the vessel by another OCMI that were not disclosed (If this is the case, it may be appropriate to engage with the previous OCMI.).
d. Route, service, and any special operating considerations.
e. Vessel’s conditions of carriage.
f. Age and construction of the vessel.
g. Past observations of firefighting and lifesaving techniques.
h. Prior visits for other reasons that give insight into the vessel’s ongoing fitness.
i. Third party involvement in vessel oversight.
OCMIs should periodically report trends and areas of emphasis to District Prevention staffs resulting from the utilization of RBDM for SPV annual inspection activity to include:
- The number of vessels in your fleet of responsibility and the percentage (or number) of vessels that received a reduced scope inspection during the reporting period;
- Information regarding deficiency trends found in each MISLE deficiency category (system, subsystem, and/or component) that prompted the OCMI to place emphasis on certain areas of the vessel during an inspection. The OCMI should also provide the average number of overall deficiencies issued for all reduced scoped inspections;
- The estimated amount (or percentage) of time saved when conducting a reduced scope inspection as opposed to when conducting an annual inspection ; and
- Any recommendations, along with supporting documentation, for improvements to the RBDM Matrix for SPV annual inspection activity.
Further details may be found by reading USCG policy letter herebelow