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MARCH 2016 FOGHORN 17 By Peter Lauridsen PVA Regulatory Affairs Consultant REGULATORYREPORT O n February 4 2016 the U.S. Coast Guard issued CG-CVC Policy Letter 16-02 addressing the use of non-metallic sea strainers on inspected small passenger vessels Subchapter K and T. This long-await- ed clarification resulted from a series of events that brought into question the widespread use of non-metallic sea strainers in the raw water systems on those inspected passenger-carrying vessels. A short history of need for the de- velopment of the sea strainer policy spans many years. In 1996 the revised Subchapter T and initial Subchapter K were issued with the adoption of the metallic standard for vital piping systems. This change was not explored during the public comment periods as- sociated with the development of the regulations so the concept of what constituted a system was not defined. Apparently non-metallic sea strainers continued to be installed in newly con- structed vessels as before. Sometime in the 2011-2012 time frame the Marine Safety Center MSC began to call out non-metallic strainers for disapproval during required vessel plan reviews. The rationale was that a vital system was the piping and all appurtenances connected thereto. This denial of approval was called out in a vessel under construction where non-metallic strainers were being installed. The shipbuilder appealed on the basis that the non-me- tallic sea strainers were wanted for their visibility that permitted easy monitor- ing and alerting crew to the need to service them before they led to engine shut down. There was also a cost con- sideration since the non-metallic unit had proved as reliable as the more expensive all metal strainers. Non-metallic strainers had long been used in Subchapter T vessels prior to 1996. The appeal was denied. Sometime afterward a marine inspector required Non-Metallic Sea Strainers