A long-anticipated move to clarify Coast Guard marine casualty reporting requirements is being welcomed by passenger vessel companies and other marine operators, who say varying interpretations have sown confusion in the industry for years.
Formally titled Navigation and Vessel Inspection Circular No. 01-15, the document was released by the Coast Guard on July 21.
Besides advising operators of how the rules for reporting should work, the circular instructs Coast Guard officers — the area and sector level, down to commanders of individual units — to update their policies and procedures for conducting casualty investigations.
The directive was welcomed by the Passenger Vessel Association, which for years has highlighted problems with what operators saw as seemingly random and onerous reporting requirements for inconsequential incidents, such as momentary, touch-and-go groundings without damage.
At an industry day last year hosted in Miami by the PVA and Coast Guard, PVA regulatory affairs consultant Peter Lauridsen said “the Coast Guard has driven casualty reporting far beyond the definition.”
On Friday the PVA hailed the Coast Guard’s move in an email to members, while saying its staff is analyzing the full text to prepare their own supplemental guidance for operators. “Industry has been awaiting NVIC guidance from the Coast Guard for years, and during this time operators have struggled with running their businesses in an uncertain environment,” PVA said. “In some instances Coast Guard has stopped operators from sailing because of conflicting interpretation of the requirements and second-guessing of seasoned mariners' professional decisions.”
The clarifications give more clear guidance on when mariners are expected to submit a CG-2692, the standard reporting form for accidents. There are specific clarifications for reporting certain accidents — as in commercial diving operations — and specific exemptions, as for accidents involving shipyard workers that are not the result of a vessel accident. At no time shall a written CG-2692 be requested unless the reported occurrence is determined by a qualified investigative officer to be a reportable marine casualty. Other clarifications say when mariners need not file a casualty report, but should report hazardous conditions. That includes momentary grounding bumps, and falls overboard where the person is recovered without injury or death.