USCG Office of Commercial Vessel Compliance issued guidance focused on high risk small passenger vessel (SPV) inspection, in an effort to assist Officers in Charge, Marine Inspection (OCMI).
Namely, Officers in Charge, Marine Inspection (OCMI) shall actively employ risk management when managing SPV inspections within their Fleet of Responsibility (FOR).
The new Policy Letter 20-02: “Inspection Guidance For High Risk Small Passenger Vessels” will expire January 1, 2024.
It is known that risk assessment and risk management are daily activities for Coast Guard personnel involved in vessel compliance activities.
While, OCMIs use formal and informal assessments to balance workforce constraints with the need to facilitate a safe and efficient maritime industry.
To remind, the types of SPVs and nature of operations vary greatly from small water taxis within a harbor to large, overnight ocean going vessels.
The associated probability of a marine casualty and the subsequent consequence to people, property and the environment likewise varies greatly across the SPV fleet.
Vessels that pose greater risk may receive greater Coast Guard oversight than corresponding vessels that pose a lower risk.
Beginning January 1, 2021, the results from the SPV risk model shall be used to prioritize SPV inspections. It is important to note that vessels determined to be high risk are not presumed to be non-compliant. Rather, these vessels were selected based on the specific vessel history and performance of similar vessels.
In light of the situation, Office of Commercial Vessel Compliance (CG-CVC) will:
- Develop a list of high risk vessels based on updated information in MISLE and ensure OCMIs have access to the vessel names.
- Routinely review MISLE casework to ensure consistent program implementation across OCMI zones.
- The list of high risk vessels will not be made accessible to the public, CGCVC shall notify the owner or operator of a vessel, as noted on the Certificate for Inspection (COI), when the vessel has been added to or removed from the high risk vessel list.
At the same time, concerning the OCMIs, the guidance stated:
- OCMI should assign an Advanced Journeyman Marine Inspector (AJMI) to perform the initial, renewal, and annual COI inspections on high risk vessels. If an AJMI is not available, the designated OCMI shall select the most experienced qualified Marine Inspector (MI) to conduct the inspection and document the waiver in MISLE.
- For high risk vessels, the cognizant OCMI should adhere more closely to the format for subsequent COI inspections as outlined in subsections 46 CFR 115 Subpart H or 176 Subpart H, as applicable, including the completion of satisfactory drills as required in that subsection.
- OCMI shall be briefed on the annual inspection results on each high risk vessel. Initial and reissuance COIs issued to high risk vessels under Subpart D of reference (a) and (b) shall be signed by the designated OCMI.
- The OCMI should not be limited by the CG-CVC high risk vessel list. The OCMI may continue to use their discretion to identify additional vessels that are high risk and inspect them accordingly.
- The OCMI may recommend to CG-CVC, via a memo through the District and Area, that a vessel be removed from the high risk list maintained by CG-CVC.
- Since passengers are not typically present during the inspection described in paragraph (4)(b)(2), MIs shall conduct a follow-on inspection on high risk vessels when passengers are on board. The focus of this inspection is on the performance of crewmembers and operational condition of the vessel with passengers on board.
- A follow-on inspection for high risk vessels shall be conducted at least once a year, preferably 5 to 7 months after the annual inspection.
