The US Coast Guard Office of Commercial Vessel Compliance announced the release of two policy letters addressing issues associated with testing of machinery alarms on small passenger vessels.
The ‘Policy Letter 17-08: Inspection of Machinery Alarms on Small Passenger Vessels‘ provides guidance to assist owners and operators of small passenger vessels, and Coast Guard field units with the inspection of machinery on small passenger vessels.
Specifically, this policy interprets “test of machinery alarms” in 46 CFR 176.804(i) and 115.804(i) and clarifies the discretionary language for “additional testing or inspections deemed reasonable and necessary” under 46 CFR 176.840 and 115.840. Owners and operators of vessels with microprocessor based propulsion controls or vessels of unusual design with Design Verification Test Procedures should follow existing procedures.
The ‘Policy Letter 17-07: Required Plan Review And Design Verification Testing On Small Passenger Vessels‘ aims to assist vessel owners and operators of small passenger vessels and Officer(s) in Charge, Marine Inspection with the plan review and testing of propulsion control systems that use microprocessors.
The regulations do not clearly address the appropriate level of review required for the broad array of propulsion control systems found on small passenger vessels, nor is there established guidance identifying which plans are required for the initial design review and subsequent testing under 46 CFR 115.804 or 46 CFR 176.804. The lack of guidance has resulted in OCMIs applying inspection criteria inconsistently between zones and raising concern within the industry.
