Is marine casualty reporting now an enforcement tool?

I am concerned that the Coast Guard’s marine casualty reporting program has evolved into an enforcement tool instead of a data collection program.

Regulations require commercial operators in U.S. waters to fill out and submit a form CG-2692 to the Coast Guard after a serious marine accident such as a grounding, allision with a bridge, loss of propulsion, loss of life, an injury requiring medical treatment and property damage exceeding $25,000.   

The 2692 is intended to provide the Coast Guard with data to identify trends and causes of casualties. However, if an operator fails to fill out a 2692 when required, he or she faces a possible civil penalty of up to $25,000 and potential action against a mariner’s license. 

Recently, there have been several troubling incidents where operators have filled out and submitted 2692s and then faced alleged violations weeks later. In several cases, mariners were reprimanded, and even accused of negligence, in incidents that either were not reportable or barely qualified as reportable. For many of them, this has put their licenses and livelihoods in jeopardy. 

When you consider the confusion that exists nationally about submitting  casualty reports, the situation becomes particularly troubling. In particular, if an operator believes that an incident is not reportable and the Coast Guard disagrees, penalties can be levied. To make matters worse, in many ports, the Coast Guard has adopted a “when in doubt, fill it out” attitude.  

Marine casualty reporting has overstepped its regulatory mandate and morphed into a divisive and intimidating enforcement tool for the Coast Guard. The industry feels that by completing and submitting a form 2692 there is a presumption of guilt. What happened to the original purpose of the 2692 as a data collection tool to better understand safety trends?  

The Passenger Vessel Association (PVA) has been vocal about the problems with the current marine casualty reporting system. PVA has urged the Coast Guard to ensure that its personnel adopt consistent reporting requirements for each port and to shift from a law enforcement mentality to one that focuses on safety prevention and improvement. Until that happens, the maritime industry is particularly vulnerable.  

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.

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