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In the first phase of the study, the committee was asked to review the U.S. Coast Guard (USCG) policy documents to ensure they are clear, accurate, and usable; consistent with one another; and aligned with the requirements in Subchapter S. Examples of policy documents are Navigation and Vessel Inspections Circulars (NVICs), Marine Safety Center Technical Notes (MTNs), Marine Vessels Investigation Letters, and USCG correspondence in response to requests for regulatory interpretations. Of concern is that the information and guidance contained in these various documents is widely dispersed and accompanied by guidance pertaining to other vessel safety regulatory requirements, which makes the stability requirements both hard to find and difficult to keep consistent and current. While the committee did not have the time or resources to undertake a detailed review of all policy documents related to stability, it does recommend that the USCG consolidate all such policy decisions and guidance into a single, searchable, online database. It further suggests that as part of this consolidation, the USCG examine each stability-related document with an eye to whether it could be modified (e.g., updated or rescinded) and in some cases promoted to higher-level guidance, including elevation to a regulation. In requesting this second phase of the study, the USCG asked the com- mittee to suggest an approach for undertaking such a policy document review and rationalization, recognizing that the implementation of such a review must be left to the USCG. In this chapter, therefore, the committee does the following: 6 Review of U.S. Coast Guard Policy and Guidance Documents 71
72 USCG VESSEL STABILITY REGULATIONS AND GUIDANCE â¢ Considers the public availability of a range of policy documents that have stability relevance; â¢ Demonstrates how to undertake a review by examining several types of policy documents and offering ideas on how to improve them, as appropriate; â¢ Provides examples of organizations that have put in place a struc- tured and transparent approach for maintaining regulatory-like documents; and â¢ Offers additional advice on how to consolidate the information and guidance in the policy documents into a searchable database. PUBLICLY AVAILABLE STABILITY-RELATED POLICY DOCUMENTS Policy documents are intended for users of stability regulations. Therefore, the first step in the committeeâs review of these documents was to locate as many as possible that are publicly available over the Internet using search engines and procedures that one would expect a naval architect to use when attempting to find relevant policy documents to ensure compliance with stability regulations in the Code of Federal Regulations (CFR). These consist of the following five types of documents. Marine Safety Manual The Marine Safety Manual (MSM) is the primary policy and procedural statement for the USCGâs marine safety program, intended to be used by marine safety personnel in the USCG and industry. Stability considerations are addressed in MSM Volume IV, Technical and were prepared by USCGâs Naval Architecture Division (CG-ENG-2). Although the MSM is available online, it can be difficult to find stability-related guidance in it because of its size and breadth of topics. The downloadable version1 consists of 452 pages, including chapters for â¢ USCGâs Commercial Vessel Safety Technical Organization â¢ Technical Computer Support â¢ Engineering Systems â¢ Considerations for Survival Systems â¢ Technical Considerations for Vessel Design â¢ Ship Stability, Subdivision, Structures, Welding, Load Lines, and Maneuverability â¢ Tonnage Measurement Program 1 See https://media.defense.gov/2017/Mar/29/2001723819/-1/-1/0/CIM_16000_9.PDF.
REVIEW OF USCG POLICY AND GUIDANCE DOCUMENTS 73 The Ship Stability, Subdivision, Structures, Welding, Load Lines, and Maneuverability chapter (see Chapter 6) contains approximately 125 pages of technical and background information.2 The MSM Volume IV that is available online is listed as being last updated on September 29, 2004, in Change 3 (CH-3). Navigation and Vessel Inspection Circulars NVICs are issued by the Assistant Commandant for Prevention Policy to provide detailed guidance on enforcement of federal marine safety regula- tions and policies. USCG personnel use them to ensure that inspections and other regulatory actions are âadequate, complete, and consistent.â The marine industry can also use them to understand how marine safety regulations are enforced. Because NVICs do not have the force of law, non- compliance is not necessarily a violation of the marine safety regulations. NVICs cover a wide range of subjects, including vessel construction, stability, inspection methods, manning requirements, and special hazards. NVICs are posted on a dedicated web page and can be easily searched by date of issue and general subject matter (of which there are 17). NVICs related to a vesselâs stability are published by the Naval Architecture Divi- sion (CG-ENG-2). Policy Letters Policy letters provide detailed guidance based on the USCGâs understand- ing and interpretations of various subject areas covered in regulation and marine safety policy documents. They are typically issued in response to specific requests from industry about the applicability of a regulation. Issued by the Commandant, they usually originate from one of two offices: the Office of Design and Engineering Standards (CG-ENG) or the Office of Commercial Vessel Compliance (CG-CVC). Both offices post policy letters on their web pages; however, the postings are not accompanied by a key word search function to assist the user in locating a relevant document. CG-CVC Policy Letters do have relatively descriptive titles that will help in locating any relevant documents. It merits noting, however, that some older policy letters relevant to the marine community are not available on USCG websites. They include Policy File Memorandums (PFMs) and Merchant Marine Technical Center 2 An electronic copy of this chapter is available on the Assistant Commandant for C4 and ITâs (CG-6) CG-612 Directives and Publications Division Commandant Instruction Manuals index of documents web page. C4 and IT are Command, Control, Communications, Com- puters and Information Technology, respectively.
74 USCG VESSEL STABILITY REGULATIONS AND GUIDANCE (MMT) individual letters. MMTs were the precursor to MTNs (described in the following section), and PFMs were used to disseminate policy deci- sions by individual MMTs to the other MMTs for consistent application of the regulations. Marine Safety Center Technical Notes MTNs are issued to inform the marine industry of policy decisions related to plan review, tonnage admeasurement, and technical requirements involv- ing vessel design and approval relevant to commercial vessels. They usually explain USCG technical policy for vessel construction topics such as fire pro- tection, machinery and systems, tonnage, and stability. MTNs are posted on a dedicated Marine Safety Center (MSC) web page, where they are listed by title and identification number. Although the listed MTNs cannot be searched by keyword or subject manner, their titles are descriptive of content. Plan Review Guidelines and Design Verification Guides The MSC issues Plan Review Guidelines (PRGs) and Design Verification Guides (DVGs) to submitters of plans and calculations for MSC review. They convey the USCGâs current thinking on a topic and can be used by the maritime community to assist in applying statutory and regulatory require- ments when submitting plans and calculations for MSC review. The USCG circulates PRGs and DVGs internally to ensure that the review of plans is carried out in a consistent manner and that all critical areas are addressed. PRGs and DVGs are accessible on a dedicated MSC web page. The web page lists all of the currently available PRGs and DVGs by title, ID number, and the current revision date. The list of PRGs and DVGs cannot be searched by keywords or subject matter, but the individual PRG and DVG titles are descriptive of their contents. METHOD FOR REVIEWING STABILITY POLICY DOCUMENTS The committee was able to locate many of the stability-related policy documents previously described by conducting a web search, which turned up 12 relevant PRGs and DVGs, 8 MTNs, 8 NVICs, 3 policy letters, and 5 PFMs, as well as MSM Volume IV, Chapter 6. These documents cover a wide range of intact and damaged stability policy decisions for inspected vessels of all types and sizes. The following selection of these documents is helpful in illustrating how the USCG can review policy documents to deter mine whether the guidance and information remains valid and current, could be modified, or could be upgraded to a higher-level document (e.g., incorporated into an MTN, NVIC, or regulation).
REVIEW OF USCG POLICY AND GUIDANCE DOCUMENTS 75 That review, in the committeeâs judgment, could consist of asking the following kinds of question (depending on the level of the policy document): â¢ Has any part of the guidance been incorporated into a regulation? â¢ Should any part of the guidance be incorporated into a regulation? â¢ Is any part of the guidance inconsistent with other USCG policy documents or regulations? â¢ Is any part of the guidance outdated or not reflective of current best practice? Example Document 1: NVIC 3-73, Intact Stability Criteria for Passenger and Cargo Ships Under 100 m in Length NVIC 3-73 (dated April 18, 1973) provides recommended intact stability criteria (Section 5.1) applicable to both sea-going passenger vessels and decked cargo vessels less than 100 m (328 ft) in length and recommended criteria for maximum heeling angle for passenger vessels when subjected to a passenger crowding moment (Section 5.2(a)) or turning moment (Section 5.2(b)). It also gives a detailed set of requirements for applying the stability criteria, including superstructure volumes to be included in calculations, openings in the superstructure to be considered as downflooding points, and how to account for slack tank liquid free surface effects. NVIC 3-73 is considered a current document. Has Any Part of the NVIC Been Incorporated into a Regulation? The recommended intact stability criteria in Section 5.1 of the NVIC have been directly incorporated into 46 CFR 170.173(b). The passenger crowd- ing maximum heeling angle criterion in Section 5.2(a) of the NVIC has not been directly incorporated; rather, passenger vessel heeling criteria were incorporated into 46 CFR 171.050 in a different format. Should Any Part of the NVIC Be Incorporated into a Regulation? The recommended maximum turning heeling angle criterion for passenger vessels (Section 5.2(b) of the NVIC) has not been incorporated into USCG regulation. The criterion has been incorporated into the International Mari- time Organizationâs (IMOâs) recommended passenger vessel stability criteria via the Intact Stability Code. Based on the international acceptance of this criterion, the maximum turning heel angle could be investigated by the USCG for inclusion in the regulations.
76 USCG VESSEL STABILITY REGULATIONS AND GUIDANCE Is Any Part of the NVIC Inconsistent with Other USCG Policy Documents or Regulations? Paragraph (9) of Appendix I in NVIC 3-73 allows the volume of super- structures and deckhouses that are not considered as enclosed to be used in the stability calculations up to the angle at which their openings are submerged. After the openings have been submerged, the volumes of these spaces previously included in the stability calculations are now to be con- sidered ânon-existent,â which would result in a stepped stability curve. MSM Volume 4, Section 6.B.1(a), however, only permits the inclusion of superstructures and deckhouses if 1. The structure meets applicable classification society standards. 2. Exterior doors are steel or equivalent with 15 in coamings. 3. There is an internal escape path to a higher deck level. 4. All openings in the sides of the structure are at least weathertight. Is Any Part of the NVIC Outdated or Not Reflective of Current Best Practice? Paragraph (6) in Section 2 of Appendix II of NVIC 3-73 gives the weight to be used for each passenger in the stability calculations of 75 kg (165 lbs), which can be reduced to not less than 60 kg (132 lbs) âwhere this can be justified.â These values are out of date with current USCG practice as de- fined in 46 CFR 170.090(d)(1), which sets an Assumed Average Passenger Weight of 84 kg (185 lbs). Based on the review of NVIC 3-73 using the committeeâs suggested review process, the USCG could cancel NVIC 3-73 in its entirety for the following reasons: â¢ The primary intact stability criteria in the NVIC have been incor- porated in the CFR. â¢ Parts of the NVIC conflict with other stability policies. â¢ Some requirements found in the NVIC have been superseded by current USCG practices. The passenger heeling, crowding, and turning moment criteria in the NVIC have not been updated and are currently not applicable to the U.S. domestic passenger fleet. If the USCG believes these are applicable to pas- senger vessels, then the criteria could be moved to the CFR as a requirement for new passenger vessels.
REVIEW OF USCG POLICY AND GUIDANCE DOCUMENTS 77 Example Document 2: PFM 2-89, Location of Watertight Bulkheads on Passenger Vessels PFM 2-89 sets the USCGâs policy on the location of the aftermost effective main transverse watertight bulkhead (MTWB) for vessels that are subject to the subdivision requirements in 46 CFR 171. Per the PFM, the aftermost effective MTWB shall be at least 5% of the length between perpendiculars forward of the aftermost point on the bulkhead deck. In addition, the after- most effective MTWB need not be located at the standard minimum sepa- ration for MTWBs forward of the aftermost point on the bulkhead deck. Has Any Part of the PFM Been Incorporated into a Regulation? The policies stated in the PFM have not been incorporated into the CFR. Should Any Part of the PFM Be Incorporated into a Regulation? Section 4.b of PFM 2-89 states that the intention of the USCG is to incor- porate the PFMâs policy into the CFRs as part of âupcoming regulatory projects,â but the PFM 2-89âs policy has not yet been incorporated into the CFR. The alternative requirements in the PFM are significantly differ- ent than those in the CFR, yet the PFM wording indicates that the spacing required in the CFR âdoes not always promote safety.â Furthermore, be- cause PFM 2-89 is not available on the Internet, the USCG might consider incorporating these requirements into the CFR. Is Any Part of the PFM Inconsistent with Other USCG Policy Documents or Regulations? 46 CFR 171.065(j)(2), Subdivision RequirementsâType 1, and 46 CFR 171.070(e)(1)(iii) and (e)(2)(iii), Subdivision RequirementsâType 2, require that the minimum spacing between the aftermost point on the bulkhead deck and the aftermost effective MTWB shall be at least the minimum required bulkhead spacing. The PFM provides alternative requirements for the location of the aftermost MTWB as opposed to those mandated in the CFR. Example Document 3: G-MTH Letter 16703/46 CFR 171.080, Dated August 4, 1993 This letter contains guidance on when weathertight openings should be considered downflooding points in the application of damage stability re- quirements on passenger vessels in all waters. The letter states:
78 USCG VESSEL STABILITY REGULATIONS AND GUIDANCE â¢ Watertight closures are required for all openings up to the point of equilibrium. â¢ There must be no openings through which progressive flooding can occur within 15 degrees of equilibrium. â¢ Openings with effective weathertight covers are not considered downflooding points. Has Any Part of the Letter Been Incorporated into a Regulation? The letterâs policy concerning the minimum 15-degree range after equi- librium for no downflooding has not been added to the Subchapter S regulations. Has Any Part of the Letter Been Incorporated into an NVIC, DVG, or MTN? The letterâs policy requiring that all openings up to the angle of equilibrium must be watertight and that effective weathertight covers are not considered downflooding points have been incorporated in other USCG policy docu- ments including PRG H1-01, MSC Guidelines for Review of Stability for Monohull Power Passenger Vessels (T). Is Any Part of the Letter Inconsistent with Other USCG Policy Documents or Regulations? The policy provided in the letter is inconsistent with the requirements in 46 CFR 171.080(f)(2), Damaged Stability Standards for Vessels with Type I or Type II Subdivision. The policy letter requires that there must be no open- ings through which progressive flooding can occur within 15 degrees of equilibrium for all waters. In 46 CFR 171.080(f)(2) though, the minimum range for which no downflooding can occur is dependent on the classifi- cation of the waters on which the vessel operates. For vessels on exposed waters, the minimum range is 15 degrees, with 10 degrees for partially protected waters and 5 degrees for protected waters. Is Any Part of the Letter Outdated or Not Reflective of Current Best Practices? The letter is outdated as it provides policy changes to a superseded section of 46 CFR 171.080. The CFR section referenced by the letter, 46 CFR 171.080(e)(2), is no longer in existence as applicable to the letterâs policies. In addition, the policy provided in the letter concerning a minimum range of 15 degrees after equilibrium with no downflooding for all waters does
REVIEW OF USCG POLICY AND GUIDANCE DOCUMENTS 79 not reflect current best practices, as the policy does not take into account the nature of the waters on which the vessel operates. Should Any Part of the NVIC Be Incorporated into a Regulation? Answers to the preceding questions suggest that the letter could be with- drawn, as the principal policy decisions in the letter have been superseded by subsequent changes to the CFR. Example Document 4: MSC Memorandum 9079/10, Dated November 26, 2003 This memorandum contains intact stability policy for tank barges of 5,000 deadweight tons and above that operate on oceans or the Great Lakes. The policy stated in the memorandum provides an alternative to the Interna- tional Convention for the Prevention of Pollution from Ships (MARPOL) 73/78 Annex 1 Regulation 25A intact stability criteria as required by 46 CFR 172.070. Has Any Part of the Letter Been Incorporated into a Regulation? Given the time available, the committee was not able to determine if the policy in the memorandum has been incorporated into the CFR. There have been several revisions to 46 CFR Part 172 since the memorandum was issued, including to 172.170, which is directly referenced by the memorandum. These include 172.170 now referencing IMO Resolution MEPC.117(52), as opposed to MARPOL 73/78 as listed in the memoran- dum. Part 172 also contains specific sections applicable only to tank barges that contain intact and damaged stability criteria different than that in the memorandum. Should Any Part of the NVIC Be Incorporated into a Regulation? The answers to the preceding questions suggest that the USCG consider reviewing the memorandum to determine if the policy has been superseded by subsequent revisions to the CFR. If it has been superseded, it may be appropriate to cancel the memorandum by sending a notice to the mari- time community. If it has not been superseded and remains valid, it may be desirable to reissue the memorandum in revised form to reflect the current CFR. Another option is to commence a rulemaking process to incorporate the policy in the CFR.
80 USCG VESSEL STABILITY REGULATIONS AND GUIDANCE EXAMPLE DOCUMENT REVIEW OF PROTOCOLS FROM OTHER ORGANIZATIONS The Phase 1 report calls on the USCG to establish a sustainable, repeatable, ongoing, and transparent process to publish, review, and update stability policy documents. In this second phase of the study, the committee looked for examples of organizations that have institutionalized such a process for their collection of policy documents and found two good examples: the International Association of Classification Societies (IACS) and MSC. IACS is a technically based nongovernmental organization that consists of 12-member marine classification societies. More than 90% of the worldâs cargo-carrying shipsâ tonnage is covered by the classification standards set by the member societies of IACS. The central feature of its classification system is the rule set that describes the requirements and associated proce- dures to ensure consistent application, a system analogous to the USCGâs regulatory system in both scope and effect. Volume IV of IACS Procedures (Procedures for the Maintenance of the Common Structural Rules) specifies work processes and procedures pertaining to the maintenance and further development of the IACS Common Structure Rules for Bulk Carriers and Oil Tankers. The committee reviewed this document to gain an understand- ing of the process, which revealed the following important ways that the IACS ensures rule maintenance: â¢ All comments, questions, and rule change requests shall be re- corded and maintained within an Internet-based database. This ensures transparency with all of the IACS members and affected ship owners. â¢ Editorial corrections and question-and-answer documents are not to result in any change to the required rule scantlings. For USCG pur- poses, this is analogous to stating that policy documents and interpre- tations should not change the fundamental regulatory requirement. â¢ All rule changes are to result in an improvement or enhancement of the requirements from a genuine advancement of knowledge, a reflec- tion of operating experience, new technology and advances in design technology, or harmonization with other statutory requirements. â¢ All rule changes are to be fully evaluated to determine the conse- quences on a range of ship types and sizes as per this section of the report. â¢ When errors are detected in the published rules, corrections are to be developed and implemented as quickly as possible, but only after these proposed changes have been fully evaluated and tested to ensure that the errors have been effectively corrected. â¢ Effective dates are to be indicated for all corrections.
REVIEW OF USCG POLICY AND GUIDANCE DOCUMENTS 81 The committee also reviewed the process employed by the MSC to manage the policy documents under its purview. The MSC is an indepen- dent Headquarters command that was established in 1986 by consolidating the Coast Guard Merchant Marine Technical offices located in Cleveland, Ohio; New Orleans, Louisiana; New York, New York; and San Francisco, California. The MSCâs primary mission is to review and approve plans for the design, construction, alteration, and repair of U.S.- and foreign-flag commercial vessels subject to U.S. laws and regulations and international standards. As previously noted, the MSC publishes MTNs and PRGs to communicate policy determinations and plan review expectations to indus- try stakeholders. A quick review of the MSCâs Homeport3 shows 31 MTNs and 148 PRGs. Key points for the USCG include the policy document maintenance process is documented with an established review schedule, assigned re- sponsibilities, and internal metrics for monitoring compliance. Addition- ally, the MSC has posted all of the documents to a single location on their Homeport site. In short, a key feature in both of these organization examples is that the policy document maintenance process is adequately documented with an established schedule, assigned responsibilities, and transparent outputs. OPTIONS FOR CONSOLIDATING POLICY DOCUMENTS IN A SEARCHABLE WEBSITE The USCG stability policy documents reviewed in the previous section were located on four websites, and in some cases could only be obtained through a direct request to the USCG. For example, the NVICs were obtained from their own USCG website; PRGs, DVGs, and MTNs were accessed from links on the MSCâs home web page; the CG-ENG policy letters were accessed from a link on the CG-ENG home web page; and the MSM, Volume 4 was accessed from a link on the Assistant Commandant for C4 and ITâs (CG-6âs) home web page. In some cases, these policy documents refer to other USCG policy documents that could not be located on a USCG website or through a web search. One example, PRG H1-01, MSC Guidelines for Review of Stability of Small Passenger Vessels (T), references the USCG Naval Archi- tecture Division (CG-5212) Memorandum, âIntact Stability Freeboard and Downflooding Angle Determination,â dated September 5, 2008. Another example is MTN 01-93 CH-1, Intact Stability Considerations for Glass Panels/Windows Located above the Bulkhead Deck on Subchapter H, K, and T Vessels, which references Commandant (G-MTH-3) letter 9079/39, 9625, 16710/O.N. 927011, dated April 6, 1990. By the titles of these documents, 3 See https://www.dco.uscg.mil/msc/mtn.
82 USCG VESSEL STABILITY REGULATIONS AND GUIDANCE it appears they could be useful to the marine community and deserve to be made available on the Internet. This multitude of document website locations, each having different degrees of searchability, complicated the committeeâs effort to find the stability policy guidance, which could be similarly problematic to the marine community and USCG personnel. As USCG inspectors, plan reviewers, and technical personnel retire or are posted to other jobs, institutional knowl- edge of these policy decisions and their locations may be lost. Consolidating all of the USCGâs stability policy decisions into a search- able website was recommended in the Phase 1 report, which called for a consolidation with the following features: â¢ Be accessible from one web link page, preferably located on the MSCâs home web page. The MSC web page is the most likely USCG website to be frequented by the vessel design community. â¢ Include all USCG policy decisions of potential interest to the ma- rine community. This would include both technical policy decisions and inspection policy decisions, such as those from CG-CVC. â¢ Be readily searchable by keywords. The keywords include the fol- lowing four groups to ensure all relevant documents are found by the end user. o General topic keywords, such as stability, structures, electrical, etc. o Specific topic keywords, such as downflooding, coamings, water- tight bulkhead, etc. o Vessel type keywords, such as passenger vessel, tank barge, cargo ship, etc. o Regulatory section major titles, such as 46 CFR 170.170 Weather Criteria, etc. â¢ Include USCG policy decisions that are currently not available on a USCG website. Inasmuch as the stability regulations are consolidated into a single CFR Subchapter S, one would expect that policy documents would be similarly consolidated. Indeed, the USCG has done something very similar in other cases, such as unified websites or online hubs, similar to the Towing Vessel National Center of Expertise, the Liquefied Gas Carrier National Center of Expertise, or the Cruise Ship National Center of Expertise. The Phase 1 report recommended certain features that could be in- cluded in an online policy database. Based on the preceding review of the IACS and MSC processes, in the committeeâs view, the following additional features could offer additional value:
REVIEW OF USCG POLICY AND GUIDANCE DOCUMENTS 83 â¢ Include mandatory expiration and review dates on policies. â¢ Host information on a publicly accessible website. â¢ Include searchable keywords. â¢ Associate all policy documents with the regulations they affect and make this feature searchable. â¢ Provide a mechanism for industry alerts when policies are updated or changed. â¢ Include a feature to allow requests from industry for change or clarification that provides status on the request as it is processed. Such a consolidation would have many benefits to both users and the USCG. The additions, deletion, or changes to existing policy could be made in only one document, which will help maintain consistency in the USCG policy decisions and avoid potentially conflicting stability policy, as well as prevent the potential loss of institutional history on the policy decisions. The changes can be readily broadcast to the marine community by a notice on the USCGâs MSC website, as well as press releases in maritime news websites similar to how safety alerts are disseminated. The committee has no recommendations on whether such a consolidated document should be in the form of an NVIC, MTN, PRG, condensed version of the MSM, Volume 4, or some other document type. That decision is best made by the USCG to suit the practicalities of its organizational structure and any regulatory requirements. Such a consolidation of stability policy guidance does not need to be limited to Subchapter S vessels. Other classes of vessels that are regulated by separate Subchapters, such as small passenger vessels, towboats and tugs, fishing vessels, and cargo ships, could potentially benefit both their respective marine communities and the USCG by having a consolidated stability policy document. Because this Phase 2 report has also examined stability requirements in Subchapter T that apply to small passenger vessels, the committee observed some of the same challenges for obtaining policy documents related to these regulations. Indeed, the committee found the following policy decisions to be informative for understanding the stability requirements for Subchapter T passenger vessels: â¢ H1-01âMSC Guidelines for Review of Stability of Small Passenger Vessels (T) â¢ MTN 01-93 CH-1, Intact Stability Considerations for Glass Panels/ Windows Located Above the Bulkhead Deck on Subchapter H, K, and T Vessels â¢ MTN 01-95 CH-2, Permissible Locations of Class 1 Watertight Doors
84 USCG VESSEL STABILITY REGULATIONS AND GUIDANCE â¢ MTN 04-94 CH-2, Damage Stability Considerations Regarding the Extent and character of Damage for Ferry Vessels and Vessels Not Subject to SOLAS Which Operate Only on Inland Waters; 46 CFR Table 171.080(A), Footnote 3 â¢ PFM 2-89, Location of Watertight Bulkheads on Passenger Vessels â¢ PFM 10-85, Watertight and Weathertight Closure Devices â¢ USCG Letter to John Gilbert dated August 04, 1993âCommandant Policy on Downflooding Points for Damaged Stability Require- ments on Passenger Vessels in All Waters â¢ USCG Letter to Harry Warticovshi dated November 04, 1993â Commandant Policy on Downflooding Points for Intact and Dam- aged Stability Requirements â¢ Coast Guard Marine Safety Manual, Volume IV, Chapter 6â Ship Stability, Subdivision, Structures, Welding, Load Lines, and Maneuverability One is required to refer to nine separate policy documents to design a small passenger vessel that meets the applicable USCG regulations. Here again, the committee found that only some of the documents are located online and that the others are located on three different websites. The com- mittee observed that several of these policy decisions contain requirements that run counter to normal stability calculation methods, such as â¢ H1-01âMSC Guidelines for Review of Stability of Small Passenger Vessels (T). o Variable ballast for Subchapter T vessels is not normally permitted. o Subdivision and damage stability calculations shall not incor- porate the emptying of tank contents (run-off) for any dam- aged tanks. USCG policy is to âdouble countâ tank loading for damage stability calculations. âThis policy provides the most conservative means to account for any deviations from the cargo loading restrictions and will not be waived by our office.â As with the consolidation of documents pertaining to Subchapter S, consolidating documents relevant to Subchapter T would be advantageous to the USCG by keeping the guidance current and easy to find. It would also benefit the small passenger vessel marine community, whose members would only need to occasionally check one location to determine if there have been any changes in relevant USCG guidance.
REVIEW OF USCG POLICY AND GUIDANCE DOCUMENTS 85 SUMMARY As part of the committeeâs Phase 2 work, the USCG requested a review of USCG policy documents using the criteria recommended by the committee in its Phase 1 report. In that report, the committee recommended that the USCG establish a sustainable, repeatable, ongoing, and transparent process to publish, review, and update its policy documents. A detailed review of all relevant policy documents would have exceeded the time and resources available for the study. After a limited review of these documents, however, the committee believes the USCG could consider the following: Reviewing and Updating Specific USCG Stability Policy Documents A review of four types of policy documents pertaining to Subchapter S stability regulationsâNVICs, PFMs, policy letters, and policy memorandaâ suggests that some of the information and guidance needs to be revisited and potentially modified or withdrawn. It would be desirable to undertake such a review and update prior to any consolidation of documents and then to repeat this process on a regular basis. A limited examination of the document maintenance practices of other organizations suggests that such a review and update process could be undertaken on an established schedule, with well-assigned responsibilities and transparent outputs. Consolidating All USCG Stability Policy Documents in One Searchable Website Location The USCG stability policy documents located and reviewed by the com- mittee that pertain to Subchapter S were located on multiple websites; some were not available online at all. These multiple site locations, each having different degrees of searchability (from none to functional), can make it difficult for both the marine community and USCG personnel to find and use the guidance effectively. Consolidating all of the USCG stability policy decisions promises to help the USCG meet its stated goals for these policy documents to ensure that inspections, plan approvals, and other regulatory actions by the USCG are âadequate, complete, and consistent.â Consolidating USCG Stability Policy Decisions for a Particular Vessel Type or Class to a Single Document An inspection of USCG stability policy decisions that pertain to small Subchapter T passenger vessels revealed at least nine separate policy docu- ments that provide valuable guidance. They too have various degrees of
86 USCG VESSEL STABILITY REGULATIONS AND GUIDANCE searchability. This observation suggests that a single document by vessel type such as Subchapters T and K passenger vessels, towboats and tugs, fishing vessels, or cargo ships would be desirable for both users and USCG personnel.