REGULATIONS
New Small Passenger Vessel Risk-Based Inspections
T
he Coast Guard is now using a computer-based risk model to guide its small passenger vessel (SPV) inspection program. The model assesses a vessel’s “potential risk for an undesirable outcome.” SPVs are assigned to three Tiers I, II and III, reflecting varying degrees of risk or hazard. Each Tier sets the scope of an SPV’s inspection requirements, and possibly expanded inspections. The inspection program is part of the larger requirement for a vessel to obtain a five-year Certificate of Inspection (COI), required for commercial operation. The process requires numerous regulatory compliance responsibilities and activities. This new program has been in development for a few years, since at least 2013. This active phase was announced in January 2021. A new, official Guidance document—Small Passenger Vessel Risk Based Inspection Program—was published June 14. Risk assessment and risk management are not new to the Coast Guard, of course. This new “data analytics” tool, however, provides a “modernized approach to the marine inspection program to prioritize marine inspection resources.” Vessels with higher risk characteristics or operations may receive greater Coast Guard oversight than corresponding vessels that pose a lower risk. The model evaluates numerous factors, including compliance history, number of passengers carried, vessel type, vessel age, route, and history of peer vessels. The Tier level then corresponds to an inspection’s required scope and procedures. The tier assignment does not necessarily reflect the
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owner/operator’s performance or condition of the vessel, but instead “reflects the potential outcomes based on an analysis of both the specific vessel and vessels with similar activity,” according to the Guidance.
Here’s how the program will work: Every year, the Office of Commercial Vessel Compliance will evaluate the new model’s results. Next, it will send a vessel list, with associated Tier levels, to internal Coast Guard contacts. The Coast Guard will then notify owners of vessels ranked as Tier 1 because Tier 1 vessels are subject to “a follow-on inspection” that evaluates crew and vessel performance while passengers are on board. Capt. Matt Edwards is chief, Office of Commercial Vessel Compliance. He explained that over the last few weeks the Coast Guard has notified approximately 870 vessel owners that their vessel was assigned “a tier status that required a follow up inspection approximately six months after the annual inspection.” There are 7,400 vessels in the small passenger fleet. Edwards said that previously Coast Guard units could voluntarily use a risk model to assess their inspection program. Now, the new risk program mandates the minimum level of items that must be inspected and the experience of the primary Marine Inspector. Edwards commented that “this promotes a more consistent approach to vessel inspections and helps the Coast Guard manage Marine Inspector time.” The model is based on a “number of undesired outcomes,” Edwards said, including deaths, fire, or flooding. These outcomes, he added, “focus on serious incidents rather than all reportable
marine casualties.” Two other policy issues are critical within the June SPV Guidance document. One is that Officer in Charge, Marine Inspection (OCMI) “shall ensure that the appropriate MI (marine inspector) is assigned to the vessel based upon the tier level and inspection required.” Inspectors have considerable latitude. They can, at their discretion, identify vessels that should “receive an expanded annual inspection.” The OCMI is to be briefed on the results from each Tier I inspection. And the OCMI can expand the scope of the inspection to “verify the vessel does not pose a threat to people, property, or the environment.” A second issue in the Guidance centers on specific types of inspections, briefly summarized here: • COI and Expanded Annual Inspection: All SPVs require inspection for the 5-year COI, whether initial or renewal. An expanded annual inspection will be done on vessels that are Tier 1 or sail an international route. These inspections are to be done by a qualified Advanced Journeyman. If that rank is unavailable, the OCMI will select a lead inspector. • Follow-On Inspections: Required annually for Tier I vessels. The focus is on the performance of crewmembers and operational condition of the vessel with passengers on board. This is not a surprise inspection. The focus includes crewmember knowledge of emergency procedures, watch standing and operation of engineering and safety systems. An inspector may require the crew to conduct a drill or otherwise demonstrate capabilities. Follow-on inspections are required annually for Tier I vessels approximately 5-7 months after receipt of a COI or an annual inspection. • Annual Inspection: This covers basic SPV program demands, but the inspection can be expanded at the inspector’s discretion. For Tier III vessels, this annual inspection is not really “annual,” rather, it occurs on the third year after receipt of the COI. For the other years, Tier III vessels are subject to a final type of inspection: • Focused Annual Inspection: This is related to lifesaving, firefighting and watertight integrity. Again, though, if a “serious deficiency” is noted, “the inspection shall be expanded.”
Photo Credit: Shutterstock/ Shelly Bychowski Shots
By C.F. St. Clair
