Submitted by Lt. Cmdr. Chris Nichols, Office of Commercial Vessel Compliance
Coast Guard Form CG-835, Vessel/Facility Inspection Requirements, has been used to document deficiencies on Coast Guard inspected vessels and facilities. Recently, the Coast Guard completed development of a new form, CG-835V: Vessel Inspection Requirements, which was specifically tailored to capture more detailed deficiency data in a manner that is aligned with globally accepted Port State Control methodologies. The CG-835V was developed in conjunction with corresponding enhancements to the Coast Guard’s internal database, MISLE, in order to support better data analytics and the development and monitoring of Key Performance Indicators for the U.S. flag fleet and the Recognized Organizations (ROs) that perform statutory certification and services on the Coast Guard’s behalf.
To harmonize the Coast Guard’s deficiency data with globally accepted Port State Control (PSC) methodologies, the CG-835V includes deficiency codes and vessel control actions similar to those found on the PSC Form B. For example, the CG-835V includes the addition of Code 30 – Ship Detained as well as Code 17 – Rectify deficiencies prior to departure, which will replace the traditional “No-Sail” control action. A Code 30 – Ship Detained constitutes a Flag State Detention and will be reserved for those serious deficiencies that indicate a serious failure, or lack of effectiveness, of the implementation of the Safety Management System (SMS) or Towing Safety Management System (TSMS). For vessels that are not required to have an SMS or TSMS, a Code 30 – Ship Detained may be used when a substandard condition exists that is not being proactively managed by the company, vessel owner, or operator. Other serious deficiencies that must be rectified prior to the vessel sailing but are not serious enough to warrant a detention may be assigned a Code 17 – Rectify deficiencies prior to departure.
Vessel owners and operators are primarily responsible for the condition and operation of their vessel. An owner or operator that has a strong safety culture and has identified a substandard condition with an associated corrective action should receive credit for highlighting deficiencies to the Marine Inspector. A “Self Reported” box included on the new CG-835V will enable consideration to be given to a vessel owner or operator on future risk based or targeted inspection programs. For items issued during a shipyard period (new construction, major conversion, drydock, etc.) or for certain deficiencies issued to towing vessels enrolled in the TSMS option of Subchapter M, a Marine Inspector may identify the condition as a “Work List Item.” Work List and Self Reported items will not be reflected in the Coast Guard’s public facing Port State Information Exchange (PSIX) searchable database.
Finally, to maintain effective oversight of third parties (also called Recognized Organizations) acting on behalf of the Coast Guard, a copy of the CG-835V will be provided to these organizations. If applicable, a Recognized Organization’s actions to clear a Coast Guard identified deficiency will be tracked to verify the condition has been properly resolved as well as serve as data for Coast Guard audits of Recognized Organizations’ operations.
Marine Inspectors will begin using the CG-835V in the coming weeks. Coast Guard Facility Inspectors will continue to use the legacy CG-835 to document deficiencies on regulated facilities.
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Categories: Commercial Vessel Compliance