Mariners are hurt by poor marine casualty reporting and data 

In the November 2014 issue (“Is marine casualty reporting now an enforcement tool?”), Capt. Alan Bernstein wrote that the “Coast Guard’s marine casualty reporting program has evolved into an enforcement tool instead of a data collection plan.”

While I understand his concerns, our association previously commented at length to the Coast Guard and the DHS Office of Inspector General on the abject failure of the data collection program to collect meaningful data, particularly on reportable personal injuries suffered by mariners.

 In 2004, our association discovered that one egregious oilfield employer failed to report 44 injuries on form CG-2692 (marine accident report) after the injured parties brought suit against their employer in the U.S. District Court for the Western District of Louisiana. The OIG discovered evidence of another 100-plus lawsuits filed on other employers in the Eastern District of Louisiana where no CG-2692s were filed. This information contributed to an outstanding report in 2008 that brought to light many shortcomings in the Coast Guard’s Investigations and Casualty Analysis program.

We followed up in 2012 and reported our concerns to a different OIG team that produced another report in 2013. Its executive summary crystallizes our concerns: “The USCG does not have adequate processes to investigate, take corrective actions, and enforce federal regulations related to the reporting of marine accidents. These conditions exist because the USCG has not developed and retained sufficient personnel, established a complete process with dedicated resources to address corrective actions, and provided adequate training to personnel on enforcement of marine accident reporting.”

In its personal injury and illness “300-series” of reporting forms, OSHA displays far more interest in the welfare of its land-based workforce injuries and illnesses than does the Coast Guard with our working mariners’ injuries.

By not cracking down on the Coast Guard’s Investigations and Casualty Analysis Branch and enforcing complete, prompt and accurate accident and personal injury data, the Department of Homeland Security is not performing effective oversight and bringing about meaningful changes that Congress has the right to expect. 

If DHS cannot do the job, perhaps Congress needs to provide adequate resources to the Coast Guard or re-evaluate their expectations. 

The Coast Guard’s data collection has the foundation of a sand castle and the tide is coming in.

Richard A. Block 


National Mariners Association 

Houma, La.