Review and Update of U.S. Coast Guard Vessel Stability Regulations and Guidance (2019) / Chapter Skim
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Pages 71-86
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In the first phase of the study, the committee was asked to review the U.S. Coast Guard (USCG)
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72 USCG VESSEL STABILITY REGULATIONS AND GUIDANCE • Considers the public availability of a range of policy documents that have stability relevance; • Demonstrates how to undertake a review by examining several types of policy documents and offering ideas on how to improve them, as appropriate; • Provides examples of organizations that have put in place a structured and transparent approach for maintaining regulatory-like documents; and • 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.
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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)
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74 USCG VESSEL STABILITY REGULATIONS AND GUIDANCE (MMT) individual letters.
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REVIEW OF USCG POLICY AND GUIDANCE DOCUMENTS 75 That review, in the committee's judgment, could consist of asking the following kinds of question (depending on the level of the policy document) : • Has any part of the guidance been incorporated into a regulation?
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76 USCG VESSEL STABILITY REGULATIONS AND GUIDANCE Is Any Part of the NVIC Inconsistent with Other USCG Policy Documents or Regulations? Paragraph (9)
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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 USCG's 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.
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78 USCG VESSEL STABILITY REGULATIONS AND GUIDANCE • Watertight closures are required for all openings up to the point of equilibrium. • There must be no openings through which progressive flooding can occur within 15 degrees of equilibrium.
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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?
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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)
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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 independent 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.
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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 committee's effort to find the stability policy guidance, which could be similarly problematic to the marine community and USCG personnel.
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REVIEW OF USCG POLICY AND GUIDANCE DOCUMENTS 83 • Include mandatory expiration and review dates on policies. • Host information on a publicly accessible website.
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84 USCG VESSEL STABILITY REGULATIONS AND GUIDANCE • 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 • PFM 2-89, Location of Watertight Bulkheads on Passenger Vessels • PFM 10-85, Watertight and Weathertight Closure Devices • USCG Letter to John Gilbert dated August 04, 1993–Commandant Policy on Downflooding Points for Damaged Stability Requirements on Passenger Vessels in All Waters • USCG Letter to Harry Warticovshi dated November 04, 1993– Commandant Policy on Downflooding Points for Intact and Damaged Stability Requirements • Coast Guard Marine Safety Manual, Volume IV, Chapter 6– 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.
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REVIEW OF USCG POLICY AND GUIDANCE DOCUMENTS 85 SUMMARY As part of the committee's 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.
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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.
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