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SEPTEMBER 2026
was lost, there were few Coast Guard inspectors that would 
calculate effective plate thickness by hand and the tables 
provided in the report were for thicker steel and difficult to 
interpret for thinner plate.
PVA began disseminating the SSC-394 report and guid-
ance to members facing appeals and reconsideration 
processes, but a broader solution was needed: something 
accessible, easy to use, and recognized by the Coast Guard 
at the national level.
An equally important early question was whether SSC-
394’s methodology, developed using steel plate, could 
legitimately be applied to the aluminum hulls common 
among small passenger vessels. CG-ENG confirmed that 
while steel plate was used to develop the original thickness 
reduction figures, the underlying processes and formulas 
are general enough to be applied to aluminum. The five 
key measurement inputs—frequency, average pit depth, 
maximum depth, average diameter, and maximum diam-
eter—are not material-dependent. This was confirmation: 
the PPAT could serve operators with aluminum hulls in 
determining effective plate thickness. 
THE JOURNEY: 2018–2025
What followed was a seven-year effort that was a test of 
patience and persistence in equal measure.
May 2018: PVA formally raised clad welding concerns 
to Coast Guard Quality Partnership (QP) leadership at 
the spring meeting in Alexandria, Va. The issue was on 
the table.
September 2020: A lengthy appeal determination at 
Commercial Vessel Compliance (CG-CVC) was resolved 
but failed to address whether clad welding was acceptable 
as a permanent repair. The fundamental question re-
mained unanswered.

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