How to survive a Coast Guard inspection

Each year, the Coast Guard and passenger vessel operators in many parts of the country go through annual inspections prior to seasonal start-ups.

This can a very stressful time for operators that have pending charters and are under pressure to get vessels back up and running and generating revenue. In many cases these inspections go smoothly with just minor changes that the inspector and operator agree to. This is the way things should go. But this year (2015) I have been hearing far too many stories about overzealous inspectors who are writing CG-835s (Notice of Merchant Marine Inspection Requirements) that contain long lists of seemingly minor corrections that sometimes result in “no-sails.”

Sometimes the 835s are the result of confusion between old and new regulations or sometimes Coast Guard inspectors misinterpret regulations due to inexperience. Regulations are often difficult, and your inspector may not always correctly interpret the rules. So, what is your recourse when an inspector asks for corrections for items that had been approved by inspectors for many years? In many cases, it is an understanding or agreement between the operator and the inspector based on regulation.

Do your research and ask for help whenever you have a question. I ask other operators for advice and seek guidance from the Passenger Vessel Association, who has experienced staff to help out.

Communication is also important. Be sure that you know your Coast Guard chief of inspection, OCMI (Officer in Charge of Marine Inspection) and sector commander. If you are not successful solving your problem with the inspector, don’t hesitate to call the Coast Guard office to request an immediate meeting with the inspector and his or her commanders to discuss the issue. Offer a defense, give your position and know the facts.

If you are unsuccessful at the local level, don’t be afraid to appeal the decision up the Coast Guard’s chain of command.

(Editor’s note: This blog first appeared in the August 2015 issue of WorkBoat. Recently, the Coast Guard developed a new form, CG-835V, Vessel Inspection Requirements, which was specifically tailored to capture more detailed deficiency data that is aligned with globally accepted Port State Control methodologies.)

About the author

Capt. Alan Bernstein

Alan Bernstein, owner of BB Riverboats in Cincinnati, is a licensed master and a former president of the Passenger Vessel Association. He can be reached at 859-292-2449 or abernstein@bbriverboats.com.

2 Comments

  1. –Have the written regs in hand and understand how they apply to your vessel. Assume nothing–check everything. What’s your method find out about new regs?…be sure you’re up to date and in compliance.
    –Do your own pre-inspection. Be tough on yourself. Allow nothing to slide.
    –Know your inspectors. If you get a jg, explain each step of what you’re showing, why you’re showing in this sequence, and what they’ll see for a satisfactory result. If you get a warrant officer, just ask them where they want to start.
    –Let them know first thing about anything that won’t pass and how you’re getting it ready to pass. Have everything so ready that there’s nothing they can surprise you with. Don’t hide anything. If they find something hidden, they’ll assume there’s more hidden, and they’ll dig deep.
    –If you’re given a requirement you feel is unjust, show where the regs allow what you have–because you know the regs for your vessel as well or better than the inspector.

    • Alan brought it up, Ken brought it home. If you are an operator with seasonal stress from your break-out inspections, listen to what these guys have to say.

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