22 MAY 2018 • FOGHORN SAFETYMATTERS By Eric Christensen, Director of Regulatory Affairs and Risk Management O n April 5, 2018, with little fanfare, the U.S. Coast Guard rolled out a revised CG-835 form; the CG-835V: Vessel Inspection Requirements. The previous CG-835 form was used for both vessel and facility inspections. The new CG-835V is just for vessels and it has some new features intended to drive safety culture within the industry and provide better data analytics to the Coast Guard. According to CAPT Matt Edwards, Chief of Commercial Vessel Compliance at Coast Guard Headquarters, “We are trying to incentivize Safety Management Systems and a good safety culture.” Can Safety Culture be Improved with a Form? Harmonization, Control Actions, and Detention Whenever the U.S.-flag domestic fleet hears the term “harmonize” from the Coast Guard, we immediately think of international standards and how they will trickle down to domestic operators in mostly a negative way. So, when the Coast Guard release that accompanied the new form stated the new form would “…harmonize the Coast Guard’s defi- ciency data with globally accepted Port State Control (PSC) methodologies…” there was a question of impact. The new form breaks down deficiency actions into codes that are recognized internationally. This has a couple of benefits according to the Coast Guard. First, the inspection workforce will be trained to the same standards whether conducting domestic inspections or foreign vessel examina- tions. Second, the code will allow the Coast Guard to better analyze what systems are causing vessels operating in U.S. waters, or flying the U.S. flag the greatest deficiencies and associated severity. Many of the actions associated with the codes at the bottom of the form will be familiar to the domestic passenger vessel industry – rectify prior to a certain date, prior to departure, prior to carrying passengers, etc. The most sig- nificant code added to the CG-835V form is Code 30 – Ship Detained. Detention is not a term familiar to the domestic fleet but has a significant impact internationally. Vessels are detained where there is objective evidence that defi- ciencies noted during an inspection or exam can be traced back to a breakdown in the company’s SMS. For companies without SMS, a detention would highlight a company’s lack of proactive management of their safety or environmental policies and procedures. So, a detention reflects the severity of deficiencies noted during an inspection. The Coast Guard closely tracks detentions at the head- quarters level. Where “no-sail” requirements are managed at the local Officer in Charge, Marine Inspection or OCMI level, detentions receive the attention of the Coast Guard Commandant. As the Coast Guard continues to implement risk-based inspections, vessels with a Code 30 in their history will receive additional scrutiny. Self Reporting Deficiencies One significant improvement, with clear ties to safety management is the “Self Reported” box. Since vessel owners and operators are responsible for maintaining their vessels as per the regulations, they should be most familiar with the condition of the vessel. When issues are found on a vessel Ad 1 | 1/4p | 3.375” x 4.875” www.propspeed.com PROPSPEED® is effective on: Propellers | Rudders | Shafts | Struts | Trim tabs | IPS drives | Thrusters Keel coolers | Underwater lights (clear coat) | Any underwater metal surface PROPSPEED® can be used on boats of all types & sizes Both recreational and commercial, from sport-fishers, cruisers, sailboats and superyachts to work boats like ferries, trawlers, tugboats, research ships and patrol boats. Save on your boat’s running costs Having clean props and running gear lowers maintenance costs, reduces corrosion and decreases fuel burn.