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june 2015 FOGHORN 19 regulatoryReport Navigating your risks day and night. As the owner of a passenger vessel you face tough decisions every day from hiring qualied crew to making sure your vessel is in prime condition. At Aon we spend day and night thinking about your maritime risks so buying insurance doesnt have to be another tough decision. We work with you to develop creative approaches and customized solutions that deliver more efficiencies improved protability and greater value. For more information please call 1.800.730.7053 or visit passengervessel.commember-resources.htmlinsurance Risk. Reinsurance. Human Resources. Navigating your Aon Risk Solutions Marine hardship alone is not a valid reason for granting a drydock extension. The last phrase concerning financial hardship has been inter- preted by the Coast Guard and the experience of previous requesters to mean any mention of money or cost avoidance in a request for extension is a poison pill and grounds for denial. The reality of business is everything can have a value so approval or dis- approval of an extension request has financial overtones. Actually the sentence was intended and es- sentially says if the request is solely for cost avoidance of an owners responsibility for safety you have bigger problems than the need for an extension. When the OCMI receives a request for extension an inspector will be assigned to evaluate the condition of the vessel starting with the vessel history and any outstanding re- quirements. In all but a very few instances the inspector will visit the vessel. During the visit the inspector will interview key licensed vessel personnel i.e. master and chief engineer as to their opinion of the vessels condition. The inspector will also obtain written statements from them supporting the vessels suitability to operate for the period of the extension. The inspector will also examine the vessel to the extent necessary to validate in his or her opinion that the vessel is in a condition necessary to operate safely during the requested extension. For Subchapter T vessels this should be sufficient for the OCMI to make a decision on your extension request. The OCMI has the authority to approve vessel drydock extensions of up to one year. For Subchapter K and Subchapter H vessels the request with the OCMIs recommendation will be forwarded to the district and then to Commandant CVC for a decision. This can be a torturous process if time is short. To avoid problems as soon as you determine the need for an drydock period extension review Volume II Section B Chapter 3 PartA.4 of the MSM assess conditions that the Coast Guard may find problematic such as outstanding requirements impacted or unresolved alternative solutions i.e. other repair facilities and any concerns your license crew have with the vessel or its systems. Resolve those issues early in the process. Make sure you request sufficient time to accomplish your drydocking. Since you are asking for an extension you already have experienced at least one unforeseen problem. It may not be the last. As always dont hesitate to call the PVA staff if you want or need advice or assistance. n