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16 MAY 2016 FOGHORN REGULATORYREPORT hazard reporting particularly if they are noteworthy for their difference from your pre-CG 2692 NVIC experi- ence. We will repeat the NVIC 2692 discussions at our upcoming PVA Region Meetings and the fall PVA Regulatory Committee meeting. The intent here is not to find fault or to praise but to understand the progress that has been made in clarity of both purpose and utility of the invested effort. When agencies develop regula- tions the Administrative Procedures Act is focused on balancing effort and benefit. Similarly we should also view most interactions with a regulating agency in this way. We continually cite the Small Business Administrations estimate of the cost of regulation on small business that found the impact of federal regulations on small business is approximately 10500 per employee per year. That is the legacy of regulatory actions that have already come into being. Maybe this NVIC is a step in halting or reversing the growth of regulatory impact In our limited experience to date two specific reports from operators since the publishing of the NVIC have indicated one positive and one prob- lematic experience. Early on we suspected that the NVIC was not a panacea across the entire spectrum of reporting. One omission that would have brought the greatest benefit is raising the reporting threshold dollar amount. Beyond that there was concern that the definition of momentary in the loss of vessel systems could not produce a metric that would aid in understanding the complex systems addressed both me- chanical and human that might be amenable to improvement. One other area of concern was the notation that in a touch-and-go-grounding the Officer in Charge Marine Investigation OCMI could conduct an investiga- tion to validate the report. Of course the OCMI is never limited in the ability to investigate for cause or suspected failures of industry or government. Here the suggestion seems to project a doubt about the reporting masters judgment or a limitation on how much the policy should be tolerated. How do you investigate a touch-and-go without turning it into a report-and- wait situation gplink.com Put Your Fleet at Your Fingertips gplink_halfpage.indd 1 1142015 33702 PM