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31 3. OPTIONS FOR UPDATING U.S. STABILITY REGULATIONS To address deficiencies discussed in this report, several steps are identified that USCG could take to update associated policy documentation and stability regulations as it moves toward its goal of improving clarity, consistency, organization, and alignment. The committee recognizes that USCG faces challenges in initiating any comprehensive regulatory project and realizes a ârewriteâ of the stability regulations may be difficult. The options provided in the following section would allow USCG to pursue both nonregulatory and regulatory actions to meet its goal. U.S. Federal Regulatory Process To make changes to Subchapter S regulations published in Title 46 of the CFR would require a lengthy and deliberative rulemaking process. This process starts with USCG proposing changes to the regulations in a Notice of Proposed Rulemaking (NPRM) for comment from the public. The rulemaking process is described in detail in Box 2. Historically it has taken anywhere from 4 years to more than 10 years to make changes to a regulation. Even regulations desired by industry can take more than a decade to implementâthe adoption of the 46 CFR Subchapter M Towing Vessel regulations is a good example.9 Appendix E provides additional background on past efforts to update 46 CFR Subchapter S. If USCG decides to initiate a regulatory project, the committee has provided a candidate outline of such a complete rewrite for reference (see Appendix F). As an alternative, USCG could prioritize potential changes to the stability regulations, conduct outreach with affected stakeholders, and implement regulatory changes when possible (e.g., to cover a critical safety issue or to make housekeeping amendments within that section of the regulations). 9 See https://www.gpo.gov/fdsys/pkg/CFR-2016-title46-vol5/pdf/CFR-2016-title46-vol5-chapI-subchapM.pdf.
32 Box 2 Overview of U.S. Federal Regulatory Process In issuing regulations, U.S. federal agencies are required to follow a public rulemaking process. The Administrative Procedure Act (APA) generally requires agencies to provide notice of a proposed rule, solicit public comments on the proposal, and explain how comments were considered before issuing the final rule. An agencyâs decision to propose a new rule or modify an existing one may be influenced by statutory requirements; studies and recommendations from agency staff; concerns arising from accidents or problems affecting society; recommendations from congressional committees or federal advisory committees; presidential directives or requests from other agencies; lawsuits; and petitions by citizens, businesses, governments, and interest groups. In following the APA process, an agency in the early stages of rulemaking may publish an âadvance notice of proposed rulemakingâ in the Federal Register even before it issues a notice of proposed rulemaking, to solicit early feedback and information from the public. a In developing a proposed rule, most agenciesâwith the exception of independent agencies such as the Nuclear Regulatory Commissionâare required by executive order to analyze the benefits and costs of proposed rules likely to have an annual national economic impact of more than $100 million and to have their analysis reviewed by the Office of Information and Regulatory Affairs (OIRA). Federal regulators must also make allowances for the requirements of other statutes such as the Regulatory Flexibility Act, which effectively requires regulators to take into account how their requirements will affect businesses of different types; the National Environmental Policy Act, which requires environmental impact assessments; and the National Technology Transfer and Advancement Act, which requires that the voluntary technical standards of consensus bodies be used whenever practicable. When an agency issues a ânotice of proposed rulemakingâ in the Federal Register, it formally announces its proposed rule and provides the public with an opportunity to comment. b During the comment period, the agency may hold public hearings to improve understanding of the proposed ruleâs coverage and requirements and to provide additional opportunity for interested parties to make statements and submit data. When it drafts the final rule, the agency must explain its reasoning and demonstrate that it has taken into account the comments, scientific data, expert opinions, and other feedback obtained during the rulemaking process. For economically significant rules issued by executive (nonindependent) agencies, the draft final rule must be forwarded again to OIRA for a review that can request additional analysis and lead to further changes to the rule before publication in the Federal Register as a final rule. Once a final rule is published in the Federal Register and takes effect, it can be added to the Code of Federal Regulations. After publication of the final rule, the agencyâs attention turns to the practical demands of ensuring compliance. Consideration will likely have been given to compliance during a ruleâs development. For example, a regulation that prescribes specific actions by the regulated entity, such as an occupational safety rule requiring shop workers to wear protective eyewear, is certain to create compliance and enforcement demands on the regulator different from those of a rule calling for the manufacturer to institute safety management procedures aimed at the more generalized goal of providing a workplace free of hazards. a Some agencies develop proposed rules through a negotiated rulemaking. Under this process, the agency invites representatives of affected interests to meetings, where they attempt to reach a consensus on the terms of the proposed rule. If the participants reach agreement, the agency may endorse their ideas and use them as the basis for the proposed rule.
33 b Agencies place each rulemaking and supporting document (e.g., proposed and final rule, economic or environmental analyses and information collection materials) and all public comments received, sometimes including any ex parte communications and late-filed comments, in a public docket. SOURCE: Special Report 324: Designing Safety Regulations for High-Hazard Industries. TRB, Washington, DC, 2017, p. 115. Clean Up Existing Policy Documents and Policies As part of a nonregulatory process, a good place for USCG to begin is to review all stability- related policy documents to determine if each element: ï· Is valid. ï· Is consistent with other policy documentation. ï· Would require modification (e.g., update, deletion). ï· Could be promoted to a higher-level document (e.g., a one-time PFM incorporated into an MTN, NVIC, or regulation). After the review is complete, USCG could assemble the relevant policy documents and take necessary action. Such a process could ensure that policy documents are up to date, eliminate any duplication, and further identify items for inclusion in the regulations. Unified Database of Stability Policy Decisions Curating all relevant stability policy decisions in an online database is an important objective. It will be vital for such a database to have the following characteristics: 1. Hosted in a single location (e.g., MSC Homeport site). 2. Easily searchable, to the extent practical, allowing users to find all needed policies. 3. Cross-referenced to the relevant sections of Subchapter S, which are also searchable. 4. Linked to the parent documents, allowing easy access to review documents. 5. Paper-based policy documents available in PDF or other suitable electronic form that allows access from the Web and is searchable. These include the following: ï· PFMs.
34 ï· One-time policy decisions (e.g., letters, emails). ï· MTNs. ï· MSC Plan Review Guides. ï· Marine Safety Manual, Volume IV. Pursuing these options is important for two reasons. First, creating an accessible and comprehensive record of all USCG stability policy decisions will improve transparency and consistency in applying the regulations for all stakeholders. Second, a consolidated database provides a firm basis for updating and maintaining the regulations over time. Strategy for Subchapter S Reorganization A longer-term option for achieving its goal of improving clarity, consistency, and organization of stability regulations is for USCG to undertake a regulatory project that would include a rewrite of Subchapter S to change the approach, format, and content. Tactics to Execute Regulatory Project As a first step, the committee advises a process that critically evaluates the current stability regulations; compares the requirements with relevant industry standards, IMO requirements, or other national standards; and proposes regulatory changes when the alternative regulations are more appropriate and will enhance the level of safety. The committee has initiated such a process, but USCG could continue it in more detail. Specifically, the review and update process could include: ï· Articulation of the basis for change to help assess and prioritize subsequent work. This could include the reason the section requires an update (e.g., documented casualty or near miss shortcoming, application errors, or a hazard that is not being controlled); a proposed alternate standard; and how the revised or updated standard
35 addresses the section deficiency. Simply stating âout of dateâ may not be enough of a reason. ï· Prioritization of the changes based on a risk ranking (e.g., number of vessels, service risk factor, assessment factors previously listed). ï· Engagement with the potentially affected stakeholders in a nonregulatory forum (e.g., an advisory committee, Society of Naval Architects and Marine Engineers [SNAME]). With the prioritized list in hand, outreach to stakeholders prior to initiating a regulatory project is the preferred goal. By engaging stakeholders, USCG can seek recommendations for maintaining the current requirements or for revising the regulations when international requirements or other standards are more up to date. Stakeholder outreach can include: ï· Validation of the prioritized list when a change might be warranted. ï· Assessment of impacts on the affected fleet from any of the proposed changes. For example, three key U.S. domestic fleets include small passenger vessels, inland and coastal barge owners, and offshore support vessel communities. Each constituency participates with USCG through its respective advisory committee and through industry associations and partnerships, such as the Passenger Vessel Association (PVA), Offshore Marine Service Association (OMSA), and American Waterways Operators (AWO). Engaging these stakeholders early in the process is key to the success of any proposed changes. Other subchapters in 46 CFR and 33 CFR reference parts of Subchapter S, so caution is needed when amending Subchapter S to ensure there are no unintended consequences. For example, other parts of the CFR cite specific sections in Parts 170 and 171 of Subchapter S, so
36 any changes to Subchapter S would require corresponding changes to other parts of the CFR. Table F-1 in Appendix F lists other parts of the CFR that cite Subchapter S. Concept for Revising Subchapter S USCG could pursue a long-term approach for updating Subchapter S that includes the following: 1. Continue the process that allows U.S. vessels carrying a SOLAS certificate to meet the appropriate IMO requirements. 2. For U.S. vessels that operate seaward of the boundary line (International Regulations for Preventing Collisions at Sea Demarcation Lines),10 but do not carry a SOLAS certificate, USCG can consider updating Subchapter S with a view toward harmonization with IMO requirements. Since these vessels could face ocean-like conditions during their time outside the boundary line, harmonization might be appropriate. 3. For U.S. vessels that operate inward of the boundary line (i.e. domestic service only), USCG could systematically review Subchapter S and update requirements, as appropriate, to ensure that they reflect current or best practice. Proposed changes could be supported by a safety or technical basis (e.g., documented casualty or near miss shortcoming, application errors, uncontrolled hazard) to ensure success during the regulatory process. Such an approach could help USCG to achieve its goal of improving the clarity, harmony, and accuracy of its stability regulations. To assist USCG with appropriate updates, the next section identifies areas where USCG could make potential changes to Subchapter S. 10 See Federal Navigation Regulations (https://www.navcen.uscg.gov/?pageName=regContent).
37 Because of the complexities of the Administrative Procedure Act (APA), many of the candidate changes are not feasible in the near term. Potential Format for Reorganizing Subchapter S In addition to consolidating relevant policy decisions related to Subchapter S, USCG could make Subchapter S more organized and functional for the end users. To achieve such functionality, the following format might be considered: Part AâGeneral Applicability This section could contain the general information, as required in any regulation. Part BâGeneral Definitions Applicable Across All Vessels This section could contain definitions and regulations applicable to all vessels. This would include definitions such as free surface, permeabilities, downflooding, tank run-off, margin lines, watertight and weathertight, and other similar items to ensure a uniform application for all classes of vessels in the intact and damaged stability calculations. Part C to Part X (as needed)âIntact and Damaged Stability Requirements There could be one part for each of the vessel classes covered by the regulations, such as one for powered passenger vessels, one for sailing passenger vessels, one for towing vessels, one for tank barges, etc. Each of these parts could be subdivided into four subparts covering the following areas: Subpart Section 1âApplicability to the Specific Vessel Class Subpart Section 2âWatertight and Weathertight Requirements Subpart Section 3âIntact Stability Criteria Subpart Section 4âDamaged Stability Criteria A more detailed outline of a candidate reorganization of Subchapter S is in Appendix F.
38 Any reorganization would allow various parts of the stability criteria to be grouped into logical locations. All of the general definitions concerning stability calculations that are applicable to all vessels, such as point of downflooding, treatment of free surface, or permeabilities of spaces, would be contained in one location at the start of the subchapter, ensuring common definitions for all vessels. Common watertight and weathertight requirements for hull and superstructure envelopes and subdivision bulkheads would also be grouped together. Similarly, grouping all specific intact and damage stability requirements for each class of vessel in their own part of Subchapter S would allow users to more easily locate that portion of Subchapter S that is applicable to their vessel. In addition, the reorganization of Subchapter S would allow for past USCG policy decisions, if appropriate, to be codified into the regulations. The review and update of the existing stability definitions and criteria in the current Subchapter S regulations could be performed in conjunction with this incorporation of past policy decisions. Potential Options for Updating Subchapter S by Indicated Part Number In addition to considering a reorganization of Subchapter S, the committee conducted a preliminary assessment of each part and subpart of Subchapter S. The assessment includes a discussion of the current state of the individual regulatory citation and provides candidate updates or changes USCG could review. Table 3 summarizes the comments on specific parts of Subchapter S and provides potential options for that part of the regulation. Appendix G discusses these options in more detail. Table 3 is based on the committeeâs best judgment and is provided as a quick reference for USCG and other interested parties.
39 Table 3 Potential Options for Updating Subchapter S, by Part Number Cite Topic Comment Candidate Change Part 170âStability Requirements for All Inspected Vessels Part 170, Subpart EâIntact Stability Criteria 170.165 Ocean-Going Ships with International Certificates Vessels with international certificates, such as SOLAS or Load Line, are required to meet the IMO Intact Stability Code (IS Code). No change to this approach, and it could be applied to other parts of Subchapter S. 170.170 Weather Criteria Requirement for each vessel to have initial GM based on a wind heel moment. Very traditional method of stability assessment that does not work with vessels with nontraditional shape and freeboard and does not consider positive stability range of the vessel as it heels. 1. Retain 170.170 as an available stability standard, but not as the sole standard, except in special cases. 2. Apply the more modern IS Code Section 2.3 Severe Wind and Rolling Criteria for ocean-going vessels and larger Great Lakes vessels. 3. For existing vessels where this is the sole criteria, consider requiring the vessel to update stability documentation to include other criteria that would be applied to that vessel type. 170.173 Vessels with Unusual Proportion and Form Range of stability righting lever arm requirement that is very similar to IS Code Section 2.2 Criteria Regarding Righting Lever Curve Properties. Also contains reduced requirements in Part (e) for vessels in partially and protected routes. Limitations included on which ships it applies to, such as less than 100 m. 1. Remove the restriction on length less than 100 m, as this restriction is not applied in the IS Code and there is no technical basis for it. 2. Expand application to all self- propelled vessels, except for special types and small boats to which IS Code would not apply.
40 Cite Topic Comment Candidate Change Part 170, Subpart FâDetermination of Lightship Weight Displacement and Centers of Gravity Subpart F Determination of Lightship Weight and Centers of Gravity Lists requirements for methods of determining lightship weight and centers. Duplicates much of what is in the IS Code, Part B, Annex 1, Detailed Guidance for the Conduct of an Inclining Test. Replace much of Subpart F, where appropriate, with IS Code, Part B, Annex 1, to harmonize U.S. regulations with those of other nations and incorporate latest standards. 170.200 Estimated Lightship Weight and Center of Gravity 1. For tank vessels that use estimated Vertical Center of Gravity (VCG): When changes to outfitting are made that exceed 2% of lightweight, stability documentation has to be updated. Since basic dimensions of these vessels are not changed, however, VCG remains the same and if max displacement is not changed, stability at max draft remains the same. Accordingly, the results of the stability calculation appear to remain the same. 2. For some types of vessels, such as barges, placing a pendulum during the incline test is difficult to do in a manner that is not subject to interference from wind. Current USCG and IMO guidance is to use at least one pendulum. As electronic inclinometers have become more reliable and accurate, it may be acceptable to eliminate the need for one pendulum and to use only inclinometers where vessel arrangement makes pendulum use difficult. 1. For tank vessels with estimated VCG and no change in max displacement, allow a higher threshold for changes in lightweight that trigger need for updated stability documentation. A joint industry committee could study this issue to develop a recommendation, which could be issued as a policy letter. 2. Consider allowing use of only inclinometers in situations where installation of a pendulum in a location out of the weather is not practical considering the vesselâs arrangement. This could be limited to vessels that are not generally stability-limited and could be issued as a policy letter. Part 170 Subpart H Watertight Bulkhead Doors Contains some archaic requirements, such as for coal bunker doors, and refers only to an ASTM standard for watertight doors. Watertight doors are available on a worldwide basis, built to international and class standards. There is also no requirement to keep 1. Align this section better with SOLAS requirements for better harmonization. 2. Expand list of permitted watertight doors to include those constructed to
41 Cite Topic Comment Candidate Change watertight doors closed (USCG has advised on this issue). recognized international and class standards. 3. Add requirement for keeping watertight doors closed. SOLAS provides guidance on this. Part 170 Subpart I Free Surface For passive roll stabilization tanks, the text appears confusing and dependent on legacy graphical methods. 1. Replace the graphical method for reduction factor for free surface of roll stabilization tanks with a method based on the capabilities of computers, which are now used to make these calculations. Part 171âSpecial Rules Pertaining to Vessels Carrying Passengers Part 171 Subpart B Intact Stability This subpart contains passenger ship intact stability requirements. Contains traditional formula based on passenger weight familiar to U.S. designers, but does allow compliance with IS Code as an alternative. Allow continued use of the existing requirement, which is still valid, but allow use of the international standard as an alternative. This approach would provide additional flexibility to designers and operators and allow use of international designs. Part 171 Subpart C Subdivision and Damage Stability This subpart is based on traditional deterministic damage stability requirements that are not harmonized with international standards, which for larger vessels are probabilistic. Passenger ships with SOLAS certificates built after 2009 are required to comply with the SOLAS requirements. Subdivision requirements are divided between Type 1 (larger passenger ships, which would likely have a SOLAS certificate) and Type II (smaller, domestic passenger vessels). 1. Probabilistic damage stability analysis is complex and is not well developed for smaller passenger vessels, so USCG should continue with the deterministic requirements, but update them as needed. Other nations apply similar requirements for smaller, domestic passenger ships. 2. Virtually all Type 1 passenger ships under U.S. Flag (of which there are very few) have SOLAS certificates, so Type I requirements could be deleted and this Subpart reorganized
42 Cite Topic Comment Candidate Change to apply SOLAS rules to ships that meet the definition of Type I and apply CFR requirements to Type II vessels. Part 172âSpecial Rules Pertaining to Bulk Cargoes Part 172, Subpart B Grain In 170.030(b)(5), the definitions of required metacentric height (GMR) and metacentric height, increment (GMI) are difficult to understand, and the ârequired valuesâ are not clear. In addition, the formulas in (i) and (ii) are missing the division sign â/â. Clarify the definitions and ârequired valuesâ of GMR and GMI and correct the formulas by adding the missing â/â. Part 172, Subparts C and D Barges and Vessels with Polluting Cargo Subpart C applies to barges. Subpart D applies to self-propelled vessels. The applied stability requirements are derived from MARPOL requirements for the same type of vessels. 1. Retain Subpart C as separate requirements, but consider updating the requirements to be more in line with those of Subpart D. 2. In Subpart D, permit vessels to comply directly with MARPOL as an alternative to the similar requirements in this subpart. This will permit vessels to comply with latest MARPOL requirements and not have to wait for rulemaking process to update the MARPOL-derived requirements contained in the Subpart. The CFR could keep its own version of the MARPOL requirements, since they can be applied to vessels for which MARPOL would not apply; this also would maintain version control of the regulation.
43 Cite Topic Comment Candidate Change Part 172, Subparts E and F Barges and Vessels with Hazardous Cargo Subpart E applies to barges. Subpart F applies to self-propelled vessels. The applied stability requirements are derived from the IMO IBC (Bulk Chemical Code) requirements for the same type of vessels. 1. Subpart E is similar to Subpart C; retain this as a separate Subpart, since this also applies to barges. 2. For Subpart F, as with Subpart D, permit vessels to comply directly with the IMO IBC. Part 172 Subpart G Liquid Gas Carriers Another specialized vessel for which the CFR stability requirements are derived from the applicable IMO Code, the IGC (Liquified Gases in Bulk Code), Chapter 2. For Subpart G, similar to Subpart D, permit vessels to comply directly with the IMO IGC. Part 173âSpecial Rules Pertaining to Vessel Use Part 173, Subpart B Lifting Lifting stability requirements were recently updated in IS Code, Part B, Section 2.9, with USCG as a key participant in the process. For vessels in domestic service only, the current regulations seem appropriate. For vessels in international service or to which the IS Code applies, meeting the IS Code seems appropriate. It could be rewritten into the CFR to make it suitable as a regulation. Part 173, Subpart C School Ships IMO Special Purpose Ship (SPS) Code is directly applicable to training and school ships, and stability requirements from the SPS Code are a good reference for harmonization of the CFR with world standards. Incorporate the SPS Code, where applicable, since it directly applies to nautical training ships. Part 173, Subpart D Oceanographic Research Vessels As with school ships, much of the SPS Code would apply to oceanographic research vessels. The code offers a way to harmonize the CFR with world standards, expedite use of U.S. designs internationally, and enable international designs to be built in the United States. Incorporate the SPS Code, where applicable, into the CFR and allow compliance with the SPS Code as an alternative method of compliance. Part 173, Subpart E Towing The requirements in this Subpart have been superseded by new requirements in the IS Code (Part B, Section 2.8); USCG was actively involved in this For new tugs in rigorous towing service, such as escort tugs, the requirements of the new IS Code, Part B, Section 2.8,
44 Cite Topic Comment Candidate Change update. For tugs in rigorous service, such as escort tugs and those with Voith Schneider propulsors, the existing CFR appears inadequate. However, for the large domestic towing industry with conventional tugs, the existing requirements seem adequate. appear more appropriate. For conventional tugs and towboats, review the existing CFR requirements to see where the IS Code could provide updates. Part 174âSpecial Rules Pertaining to Specific Vessel Types Part 174, Subpart B Deck Cargo Barges Deck cargo barges are a traditional form of waterborne transport in the United States. Depending on the service (inland, Great Lakes, oceans, or bays and sounds), there are different requirements in this Subpart. The IS Code for barges (or pontoons in the IMO) applies to ocean-going barges and was recently updated with USCG and industry input. Review and update Subpart B for consistency of terminology and consider the latest requirements contained in the IS Code, Part B, Section 2.2. Part 174, Subpart C MODU Stability The IMO-issued mobile offshore drilling unit (MODU) Code, 2009 was recently updated with active participation of USCG and industry. Although much of what is in the IMO MODU Code overlaps with what is in Subpart C, the IMO MODU Code is a more updated version and contains more details. Permit MODUs to comply with Subpart C with the applicable parts of the IMO MODU Code, especially Section 3.1, which contains more detailed requirements than the CFR. This could help to enhance safety. Part 174, Subpart E Tugboats and Towboats Although this Subpart E appears to overlap with Part 173, Subpart EâTowing (see previous information in table), it is necessarily separate because it applies to boats built as tugboats and towboats, and not just vessels that may carry out towing. Tugboats and towboats have distinct shapes and low freeboard, so these stability regulations may seem appropriate. Update these requirements based on IS Code, Part A, where appropriate, to improve harmonization with latest standards. Part 174, Subpart G OSV Stability OSV-type vessels are a U.S. development, but are now in use worldwide. Much of the U.S. fleet is under 100 m and in domestic service; however, the IS Code, Part B, Section 2.4, which is applicable to Review these requirements and update based on the IS Code, Part A and Part B, Section 2.4.5, which is applicable to OSVs, to improve harmonization with latest standards.
45 Cite Topic Comment Candidate Change these vessels, was updated with USCG and industry input. Part 174, Subpart J Dry Cargo Ships This Subpart specifies that all new cargo ships of 500 gross tons and above with a contract date of February 1, 1992, or later comply with subdivision and damage stability requirements in IMO Resolution MSC.216 (82), the 2006 Amendments to SOLAS. SOLAS has been updated since then and the contract date of Feb. 1992 does not align with the 2006 Amendments contract date of January 2009. Align the contract dates in the CFR with SOLAS contract dates, so the requirements are aligned (older ships are not required to meet later SOLAS dates). Permit direct compliance with SOLAS as means of compliance with this Subpart, to reduce the need of frequently updating this Subpart as SOLAS is amended. Polar Code The international Polar Code entered into force in January 2017. It contains additional stability requirements in Chapters 4 and 5 that are applicable to vessels operating in polar waters. Reference the Polar Code in the CFR for the stability of U.S. vessels operating where the Polar Code would apply.
46 Process to Update and Maintain Stability Regulations Previous sections of this report identified options to modernize and improve the content of Subchapter S and associated policy documents. Concurrent with these update efforts, implementation of an ongoing process that keeps the regulations up to date and modern will be essential. A comprehensive and transparent process would need to periodically evaluate the stability-related regulatory documents that fall under the purview of CG-ENG-2, including, but not limited to: ï· International instruments (e.g., SOLAS, MARPOL, Intact Stability Code). ï· CFR (e.g., 46 CFR Subchapter S, 46 CFR Subchapter T). ï· NVICs. ï· The Marine Safety Manual, COMDTINST M16000.9, Volume IV, Technical. ï· PFMs. ï· One-time policy decisions (e.g., letters, emails). ï· Known issues, gaps, or opportunities for improvement in the regulatory construct. In addition, a parallel and coordinated review of those documents falling under the purview of the MSC would be an important part of the process: ï· MTNs. ï· MSC Plan Review Guides. The review process would need to include the following elements: 1. The establishment and continual update of a unified database as previously described. 2. Periodic review of the stability-related regulatory documents to determine if each element: ï· Is valid.
47 ï· Reflects current practice. ï· Reflects best practice. ï· Should be promoted to a higher-level document (e.g., a one-time PFM incorporated into an MTN, NVIC, or regulation). 3. Engagement with key stakeholders (e.g., PVA, AWO, and OMSA) to assist with the review, identify potential solutions, and prioritize actions. 4. Prioritize the findings from the review. 5. With this stakeholder interaction and prioritized list at hand, USCG could take advantage of an open regulatory docket for Subchapter S or other subchapters to amend Subchapter S and associated subchapters within that open regulation project. 6. Update the database to reflect the action taken.