Risk-Based Domestic Vessel Inspections U. S. Coast Guard LTJG Thomas F. Whalen Marine Safety Detachment Belfast

Operational Flexibility: Risk-Based Domestic Vessel Inspections CG-CVC Policy Letter 16-05 Operational Flexibility: Risk-Based Domestic Vessel Inspections In situations where workload demand exceeds resources; the need exists to prioritize resource allocation through the careful consideration of risk Policy Letter Authorized OCMI to utilize a risk-based approach to help prioritize & manage inspection activities (annuals) Provides guidance to OCMIs regarding which criteria to consider: when determining if de-scoping is appropriate, and if so to help determine the proper scope

Rationale for a Risk-Based Approach Limited resources (marine inspectors) Increased demand for inspection services Subchapter M - Towing Vessels More complex vessel systems (e.g., automation) Increasing numbers in fleet & foreign vsl arrivals

Operational Flexibility - Small Pax Vsls Regulation/Policy which Give flexibility Subchapter T regulations: “The scope of the annual inspection is the same as the inspection for certification but in less detail…” MSM Vol II. Sec. B. Ch.2 gives flexibility to Marine Inspector based on vessel condition, record of maintenance and inspectors time constraints. Subchapter T Regulations: 46 CFR 176.500(a)(1)(ii); The scope of the annual inspection is the same as the incpection for cetrification but in less detail unless th cognizant marine inspector finds deficiencies or determines that a major change has occurred since the last inspection. MSM: Reinspection, annual inspections and periodic inspections focus more on the vessel's equipment and operating practices, while inspections required by vessel inspection laws focus on basic hull and machinery conditions. The scope of reinspections, annual inspections, and periodic inspections varies according to the vessel’s condition, its record of maintenance, and, at times, the marine inspector’s time constraints.

T-Boat Risk Matrix for Annual Inspections General safety factor categories: Risk Assessment Methodology Safety Management Culture Marine Casualty History Route Compliance History Vessel’s Age Hull Type Knowledge of the owner or operator reliability, integrity, and Safety Management culture. 2) Vessel’s documented violation history, paying particular attention to lifesaving and firefighting readiness. 3) 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.) 4) Route and service. 5) Vessel’s conditions of carriage. 6) Age and construction of the vessel. 7) Past observations of firefighting and lifesaving techniques. 8) Prior visits for other reasons that give insight into the vessel’s ongoing fitness. 9) Third party involvement in vessel oversight.

Factors in Determining Scope of Exam If answer “yes” to following, then conduct normal scope of inspection: Has the vessels current condition changed since the last inspection? Are there any maintenance issues outstanding? Have there been any modifications or repairs made to the vessel? Has the vessel been involved in Serious Marine Incident or placed under operational control (i.e. No Sail 835) If “no” to above; questions to determine scope of inspection: Vessels documented violation history. Knowledge of the owner or operator reliability, integrity & Safety Management culture 1st, 2nd, or 4th annual, Route and Service, Age & Construction Past observations of firefighting and lifesaving techniques Previous visits that give insight in the vessels ongoing fitness.

Minimum Tasks Per Tier Level

T-Boat Matrix – Ideal Scenario T-Boat: 5 year COI cycle COI COI Tier 1 Tier 2 Tier 3 3rd Annual or periodic inspection 1st Annual 2nd Annual 4th Annual NOTE: This represents a vessel maintained in good shape – very few deficiencies..

Risk Matrix – Beta Test CG-CVC-1 conducted a 90-day beta test of the T-Boat matrix Rcvd feedback input from the following units: Mobile Baltimore Northern New England Toledo San Diego Honolulu Valdez Majority of feedback was positive, prevailing thought was the Matrix could be a useful tool to assist w/ OCMI decision-making

IMPLEMENTATION MOVING FORWARD Make its use discretionary and not mandatory The guidance provides a risk-based approach that OCMIs may use for allocating resources to prioritize inspection activities. This is not blanket authority or discretion to defer/descope automatically and/or indefinitely. This guidance is meant to assist OCMIs in prioritizing their resources against a variety of mission demands, Should it be needed!!!!!

Any Questions?