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FOGHORN
For years, that judgment call was made largely by eye. Now, 
for the first time in decades, vessel owners and operators 
across the country have access to a free, rigorous, and sci-
entifically grounded tool to evaluate pitted plate for them-
selves, before a Coast Guard inspector ever steps aboard.
The Pitted Plate Assessment Tool (PPAT), developed 
through a joint Coast Guard/PVA working group and 
now available at passengervessel.com/ppat, is the product 
of a journey that began with a member concern raised at a 
meeting in Alexandria, Va., in May 2018. What followed 
was nearly seven years of advocacy, collaboration, setbacks, 
and perseverance—a story that says a great deal about what 
a well-functioning industry association can accomplish.
THE PROBLEM
Inconsistency, Cost, and No Clear Standard
In years past, the evaluation of ship hull plates during dry-
docking was highly dependent on the personal judgment 
of the evaluator. Initial scantlings in older vessels left a wid-
er margin for error, and borderline cases were generally re-
solved conservatively—replace the plate and move on. That 
approach had its own logic in an era when profit margins 
were larger and regulatory exposure was lower.
Today’s operating environment is different. Margins are 
tighter. An unnecessary plate replacement—especially for 
a small passenger vessel operator—can run to tens of thou-
sands of dollars in materials, labor, and lost revenue during 
an extended drydocking. At the same time, missing a genu-
inely compromised plate is not an option: a crack that was 
once a “nuisance leak” can result in a significant incident, 
regulatory action, or worse.
 
The result was a growing inconsistency across Coast Guard 
sectors nationwide. PVA members in different parts of the 
country were receiving conflicting guidance on base metal 
repair (clad welding) approvals. Some proposals for alterna-
tives to crop and renew, including clad welding, were being 
rejected without clear criteria. Appeals and reconsideration 
requests were dragging on for months, sometimes years, 
without resolution.
PVA’s Director of Regulatory Affairs and Risk Manage-
ment, Eric Christensen, began hearing from members 
on this issue repeatedly. After advocating for individual 
members on a case-by-case basis, he recognized a systemic 
gap and brought the matter to PVA’s Safety and Security 
Committee. A rigorous, field-usable standard existed; it 
just wasn’t being applied consistently.
THE FOUNDATION
SSC-394 and the PIT Program
The technical solution was not new. The Ship Structure 
Committee had commissioned exactly this kind of research 
back in the 1990s. SSC-394, SR-1356: Strength Assessment 
of Pitted Plate Panels, developed under the direction of 
Rear Admiral James Card, U.S. Coast Guard Chairman of 
the Ship Structure Committee, provided both a method-
ology and a field tool—a program called “PIT”—for eval-
uating pitted plating on scene. By recording a handful of 
measurable parameters and running a calculation, a field 
inspector could make a defensible, data-backed recom-
mendation on the effective plate thickness of a particular 
section of plate.
The problem was that SSC-394 had largely been forgotten, 
and the original PIT computer program had effectively 
disappeared. When the PVA/Coast Guard working group 
first engaged Coast Guard Engineering (CG-ENG) staff 
in early 2022, the Coast Guard searched their SSC archive 
and could not locate the PIT program at all. That gap con-
firmed what PVA already suspected: if the field tool itself 
FOGHORN FOCUS
Now, for the first time in 
decades, vessel owners  
and operators across the 
country have access to  
a free, rigorous, and  
scientifically grounded  
tool to evaluate pitted  
plate for themselves, before 
a Coast Guard inspector 
ever steps aboard.

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