What happens during recreational boat builder visits By Mr. John Hannon and Mr. Alston Colihan Introduction There are approximately 4,000 manufacturers in the United States who produce an estimated 500,000 recreational boats every year. About 2,250 companies build boats which are subject to Coast Guard safety standards. The Factory Visit Program is a major part of recreational boating standards compliance monitoring in the field. Under this program, the Coast Guard visits manufacturers and importers of recreational boats for educational and enforcement purposes. The Recreational Boating Product Assurance Branch of the Auxiliary, Boating and Consumer Affairs Division, Office of Navigation Safety and Waterway Services, is the primary program manager for the administration of boating standards. Local Marine Safety and Marine Inspection Offices throughout the country conduct factory visits under the supervision of the Compliance and Enforcement Branch of the Merchant Vessel Inspection and Documentation Division. Background In August 1971, Congress passed the Federal Boat Safety Act. Among other things, this act authorized the Coast Guard to establish national construction and performance standards for manufacturers of recreational boats, and to develop enforcement mechanisms. The first safety standards became effective in November 1972. These included the display of capacity information, safe loading, safe powering and flotation standards, which apply to manufacturers of monohull boats of less than 20 feet in length, except sailboats, canoes, kayaks and inflatables. Between 1977 and 1980, the Coast Guard published additional standards covering electrical systems, fuel systems and ventilation applicable to all boats with permanently installed gasoline engines for electrical generation, mechanical power or propulsion. From the early 1970s to the mid-1980s, field enforcement, including factory visits, was handled by boating standards offices in the 12 Coast Guard districts: Boston, Massachusetts; St. Louis, Missouri; New York City, New York; Norfolk, Virginia; Miami, Florida; New Orleans, Louisiana; Cleveland, Ohio; Long Beach, and San Francisco, California; Seattle, Washington; Anchorage, Alaska and Honolulu, Hawaii. In 1986, the Coast Guard proposed the establishment of three regional boating standards units as part of a general reorganization designed to improve operations without additional funding. The principal gains realized by regionalization were closer headquarters supervision and a slight increase in the average visits per year, per person. Many boat manufacturers have plants throughout the country, and most of them distribute their product nationally. Therefore, interpretations of the regulations must be uniform and consistent year after year. In the summer of 1987, regional boating standards units were established in Long Beach, Miami and St. Louis. The following year, however, the Coast Guard had a $100 million budget shortfall and had to slow down operations, reduce personnel and close some field units, including the three regional boating standard units. The responsibility for factory visits was then transferred to the Marine Safety Offices and Marine Inspection Offices, which conduct commercial vessel inspections. The officers in charge, marine inspection (OCMIs) are now directly responsible for conducting visits to recreational boat manufacturers in their zones. Factory visits There are three types of factory visits: informal, investigative audit and technical. Informal factory visit Not intended to be an inspection, the informal visit is a basic educational effort to introduce the Coast Guard and present the regulations to the manufacturer. It generally takes no more than two hours. Factory investigative audit This is a thorough investigation of a particular problem. A factory investigative audit should produce enough documentation for valid analysis and evaluation since it either follows an order for a defect notification and recall campaign, or determines the imposition of a civil administrative penalty on the manufacturer. Technical factory visit The technical factory visit is the first step in checking a manufacturer's compliance with regulations and standards. The inspectors help manufacturers identify noncompliances. A typical technical factory visit is a comprehensive effort toward educating boat manufacturers in federal safety standards. Typical technical visit First, the local OCMI writes the president of a manufacturing company in his or her area, requesting and explaining the purpose of a visit. During the visit, the Coast Guard inspector asks to see the plant, the construction process and Continued on page 26 Continued from page 25 current boat production. During an examination of current production, the inspector looks for: (a) noncompliance with federal regulations involving safety standards applicable to the boat manufacturer, (b) incorrect installation of equipment, such as navigation lights, according to federal regulations, and (c) construction practices which differ from recognized voluntary industry safety standards. Once the inspection is completed, violations or potential violations of federal regulations are identified. Potential noncompliance items that cannot be confirmed by inspection, such as safe loading figures that appear too large or amounts of flotation material that seem insufficient, are discussed, and management's calculations and test procedures reviewed. When possible, a list of dealers selling the company's boats is obtained. This is helpful when a test lab contracted by the Coast Guard buys boats on the open market to physically test them for compliance with certain standards. Violations of federal regulations are pointed out to the manufacturer, and voluntary compliance is encouraged to increase boating safety, as well as to help create good customer relations. Practices related to voluntary industry standards are also discussed. The manufacturer will receive a written report of all noted violations. Training Formal training in recreational boating standards of inspectors from all 46 Coast Guard Marine Safety Inspection Offices started in October 1990 at the Reserve Training Center, Yorktown, Virginia. Candidates are trained in Coast Guard policy and procedures for factory visits, including recreational boating standard inspection; budget and administrative functions; laws and regulations for the construction of recreational boats; manufacturer responsibilities; application of regulations to different boat types and sizes; manufacturer calculations for ventilation, flotation and horsepower; and elements of recreational boating standards violations. After completion of training, final certification for qualification as a recreational boating standard inspector is made in writing by the appropriate OCMI. To date, 80 individuals have completed training. Achievements Between 1989 and 1991, Coast Guard Marine Safety/Inspection Offices conducted more than 4,300 factory visits at recreational boat manufacturing plants all over the country. Most of these visits focussed on manufacturers of boats which are subject to federal safety standards. Manufacturers of boats not subject to federal safety standards, e.g., sailboats, canoes, kayaks and inflatables, were visited less frequently. Conclusion The Coast Guard performs a wide variety of functions designed to enhance the safety of the maritime community, the port and the environment. Traditionally, the Marine Inspection Program focus has been on the commercial maritime community. With the added responsibility for visiting recreational boat manufacturers, OCMIS have greatly increased the numbers of vessel owners and passengers who benefit from the vessel inspection program. From outboard runabouts to super tankers, the Marine Inspection Program focuses its efforts and dedication toward the safety of both the commercial and recreational user of America's waterways. Photographs accompanying this article are courtesy of Mr. E. Charles Game, director of product reliability at Hatteras Yachts Inc., High Point, North Carolina. Mr. John Hannon is a staff member of the Compliance and Enforcement Branch of the Merchant Vessel Inspection and Documentation Division. Telephone: (202) 267-1464. Mr. Alston Colihan is a technical writer in the Recreational Boating Product Assurance Branch of the Office of Navigation Safety and Waterway Services. Telephone: (202) 267-0981. The original TAPS study determined that hull cracks were usually caused by: (1) imperfect design of structural details, (3) the use of high tensile steel in (5) harsh environment in the Gulf of A follow-up report confirmed the above determinations and discussed in detail the experiences of the Atigun Pass and American Sun classes, which had undergone the greatest number of structural failures. TAPS tanker hull is carefully inspected for cracks. The primary responsibility for preparing CAIPS lies with the vessel owner or operator. The CAIP requirement is the cornerstone of the TAPS monitoring program to maintain vessel safety and to protect the environment. The most essential element in furthering those ends, however, is the quality of management exercised by the vessel owner/operator. The only vessels to date required to have CAIPS are TAPS trade tankers. Since this requirement was put in place, the need for specific policy guidance for the implementation of CAIPS on the tankers has surfaced in meetings of operators, ABS and Coast Guard representatives. Continued on page 28 Continued from page 27 Specific guidance for CAIPs' implementation is contained in Navigation and Vessel Inspection Circular (NVIC) No. 15-91 and in Commandant G-MVI Policy Letter No. 17-91. NVIC 15-91 NVIC 15-91 provides guidance for the development, use and implementation of CAIPs. A performance standard is provided, which outlines the essential elements for CAIPs. Any vessel service or class can be required by the Coast Guard to have CAIPS inspection plans. The decision to require a CAIP on a specific vessel or on an entire class may be based on its history, service or the climate and conditions of the trade route. Such a requirement is in keeping with the intent of Title 46 U.S.C. 3703 and 3714, and Title 46 CFR, which give the Coast Guard authority to require the inspections and documents necessary to ensure vessel and environmental safety. Policy letter 17-91 Policy letter 17-91 provides guidance for the institution of CAIPS as a management tool and for its implementation on TAPS tankers. The letter is not intended to dilute the authority of the Officer in Charge, Marine Inspection (OCMI), but to establish a framework for the OCMI and the vessel operator to complete consistent, acceptable repairs. The letter is intended to amplify guidance found in NVIC 15-91. TAPS vessels TAPS vessel operators were notified in late 1990 of the requirement for CAIPS. They must submit the CAIPS for review by their classification society as outlined in NVIC 15-91. To allow sufficient time for review, CAIPS already on the vessels were acceptable until June 30, 1992. The Merchant Vessel Inspection and Documentation Division maintains an up-todate status list of CAIPS, including a copy of the plans reviewed by the classification society. All OCMIs have been encouraged to attend critical area surveys required on TAPS tankers to help the Coast Guard properly monitor the structural fitness of the vessels. Credit towards a vessel's internal exam requirements may also be granted for critical area surveys completed with an OCMI present. TAPS vessel operators and/or owners are responsible for finding a solution to the chronic fracturing of their tankers. The CAIP program serves as a tool to assist in this process. Good communication between OCMIS, districts, traveling inspectors and appropriate Coast Guard headquarters offices is essential to maintain an adequate monitoring program of the TAPS fleet. Conclusion All vessels can use CAIPS inspection plans for tracking and recording structural history. All owners and operators should consider incorporating the principles of CAIPS into their management practices, even though they are not required to do so. LCDR Stan Deno is a project officer in the Compliance and Enforcement Branch of the Merchant Vessel Inspection and Documentation Division. Telephone: (202) 267-1464. |