I will try to describe on this page what I have learned about commercial boats, that Certificate of Inspection, actual inspections, standards, and all responsibilities, those assumed and presumed by everyone. I have worked with commercial vessels from both sides of the fence. Someone to guide the process is essential. Someone that understands the intended use, the mandates in the CFR's, and the best or better in systems will save you money in the long run. Save in down time, service of systems, lost charters, you name it.

U.S. Coast Guard

First, those US Coast Guard personnel I have worked with, here on Hawaii and on the mainland are trying to ensure your passengers are not going to get hurt by fire, electrocution, or drowning. That’s what all the CFR’s are all about, commercial (46) or private (33). Their MSO offices have experienced inspectors, some have worked at other districts, run rotation programs for CG personnel are exposed to the COI inspection process, inspect boat builders at their factories, etc. etc. They may not know everything about boats; they do know what there looking for when they inspect your vessel for commercial service. If you are under the impression that the Coast Guard inspector is there for anything else, you’re in trouble from the start. That type of “mind set” (attitude) may completely obliterate your ability to get valuable, helpful, and non-punitive information from the authorizing authority for free, and sets the tone for the rest of your relationship as long as you’re in business.   

Second, you or someone in the company had better know that boat better than the Coast Guard. They want to see that someone knows this boat, its strengths and weaknesses. It should be disconcerting to you, if your master, first mate, maintenance or primary “caretaker” of the vessel did not know all the systems thoroughly. Those thoughts go through the inspectors heads also. Add an Accident Report and investigation, now that inspector and his paperwork are scrutinized. My suggestion, if you are not that knowledgeable person onboard, get someone that will be. The down time costs may include cancelled charters and loss of reliability and reputation to your customers or booking agents. That you do not want to pay.

Third, be upfront about any issues the boat currently has, in compliance with a COI. Trying to “hide” an issue just evolves inspectors to investigators. Most repairs, not structural or system changes can be implemented and documented in the maintenance log. That’s the log next to the crew training and E.P.R.I.B test logs! Ongoing issues, or “fix it” 835’s, can be accommodated for by the Coast Guard in your offshore routing. Structural repairs, improvements, changes, etc., they want to know all about. They want to see the drawings from a Naval Architect, who is doing the repair or change, and will visually inspect the complete process at all stages. Again, that issue of protecting you and your customers from fire, electrocution, and drowning and there is no usually charge for the service.

My only negative experience with the U.S. Coast Guard and it was not mine, nor really negative, nor even initiated by the Coast Guard, was in the early nineties, riding in the trough, crossing that 300 something miles from Cabo San Lucas to Puerto Vallarte. A cruising friend of mine on a 31’ ketch, 60 miles ahead of me was contact on the radio by a U.S. Navy destroyer. They stated they had a Coast Guard contingent aboard and wanted to get some info on my friends last CG inspection. This was as the north wind was blowing around 40 knots, the tide was coming out of the 900 mile long and 200 mile wide, Sea of Cortez and making “square” breaking waves at 18-20 feet. My friend had tried running with it but had been pooped 6 times and was thinking about wearing a mask and snorkel on deck so he could see anything, when they radioed him! Well, he had radioed back that he did not know if he still had the paperwork aboard, that the decal was on the main mast on the forward deck and did not want to go out there to get the number right now. The U.S. Navy radioed again and chastised him about that. So, he radioed back again and informed them that they must know nothing about cruisers at all. He told them that small boat cruisers do not have room for everything they want to take and much less for the paperwork! I guess they felt slighted somewhat so they radioed that they were going to board. Again, he radioed back and agreed to be boarded but considering the hazardous conditions he asked that they come to a stop in that trough and provided his vessel with a “wind and wave break” for safety purposes. After a considerable pause they radioed back to him that the boarding was cancelled and would follow up with him at another time. My friend was a little upset at the whole affair and could not believe that this had happened in those conditions. His first mate at the time was a woman from England that was deep frying chicken through out that rolly, whole day! 60 miles behind, my first mate ran the boat the whole trip. I was on deck, seasick and wet, 24 hours a day for three days.

I have put some links here to help you get info directly from the U.S. Coast Guard sites that I selected and the appropriate chapters of the Federal Code if the site is not functioning. Some of these are lengthy, but your company should have them on file to answer your own questions. SOME OF THESE US COAST GUARD SITES HAVE BEEN CHANGING FASTER THAN I CAN KEEP UP WITH THEM, LET ME KNOW IF YOU HAVE PROBLEMS AND I WILL TRY TO GET YOU TO ANOTHER SITE.

First we’ll start at the smaller boat and work up., if you have a un-inspected commercial boat, “6 pack”, check here for a list of requirements...  Subchapter C of 46CFR

Moving bigger, here is a T-boat site out of USCG District in Tampa Florida, that great site out of Maimi is no longer up as of October 2006. Sbchapter T of 46CFR

This site is where you can download and print a copy of the inspectors book, just scroll down to T-ot K -Boat and go to it.

http://www.uscg.mil/tcyorktown/mschools/MII/CG840.shtm

And the commercial boat site from the State of Hawaii.

http://www.hawaii.gov/dlnr/dbor/borrecn.html

Commercial Fishing Vessels have their own National Coast Guard site here.

http://www.uscg.mil/hq/g%2Dm/cfvs/

With CFR 46 mandates at.

http://www.access.gpo.gov/nara/cfr/waisidx_01/46cfr28_01.html

And a 65 page Stability Guide lines you can download at.

http://www.uscg.mil/hq/g%2Dm/cfvs/Stability%20Book%202nd%20Ed%202004.pdf

Equipment and Standards

I survey to the ABYC Standards with CFR regulations, NFPA, etc. If you want info on those ABYC Standards see…

http://www.abycinc.org/standards/toc.cfm

In the past, ABYC Standards became CFR requirements and I believe that will continue. There are differences, as an example; ABYC Section H-41 for safety rails on pleasure craft, wants to see a minimum 24” tall stanchion, no more than 84” apart and 24” between horizontal lifelines, etc., etc., and take a 400 lbs impact. COI(Certificate of Inspection) requirements for SPV’s(Small Passenger Vessel’s) wants 39” tall with no more than 4” open “squares” horizontal and vertical, that will take a 200 lbs impact. What I have found as a consultant is that combining some of those ABYC etceteras, as the 400lbs. impact requirement, and the SPV requirement makes a lot of sense and cents, and 84" between stanchions just won't work on a SPV. Not only does the vessels comply with mandates but is now built stronger at a relatively lower costs compared to the required constant and expensive unsightly repairs with the lesser requirements. Not convinced, have 2 adults put their combined weight on on of your stanchions.

Or, as another example, ABYC H-22, defines what a bilge pump must be made of, where installed, the electrical and plumbing requirements, water flow rates, voltage parameters, dry running time, etc. but makes no mention of the bilge pumps being UL (Underwriters Laboratories) listed and marked. SPV’s must have that UL listing tag, no ifs, ands, or buts. When you look at any boat store catalog, you will see in their list of bilge pump stock numbers like a 2000 GPH and a 2000 GPH UL (at additional costs of course). I have work with UL in a past life, getting approval for designs of flammable and potentially explosive systems; they check every part in every component and run them through some extreme tests, even the labels.

What the U.S. Coast Guard and the CFR’s have ensured is that UL, NFPA, FM, ASTM, ANSI, etc. all those testing and inspecting organizations have a hand in what goes into commercial vessels. The idea is that equipment that has been built to some specification and tested will last for a certain period of time and enhance safety. Why would you do otherwise? Why not buy the better quality if it is better quality? Again, think long term on overall costs, including downtime, loss charters, regulatory problems, and reputation loss.

Procedures

Whatever your timetable to haul for your COI inspection, what I have seen that increases costs most of the time, is lack of planning. They usually know exactly what month it will be due and have started to make arrangements, for the haul, for items you have to subcontract to fix, notified the Coast Guard, etc. but failed to implement the crews responsibilities.

The efficient operations I have seen are those that talk to all the crew to get their “gotta fix this” issues long before and had the “primary caretaker” make his lists (those that can only be fixed on the hard). Then the CiC (commander in chief) puts together all those fix it items on a list, gave one to each member in the fix it team, assigned duties (applicable with their skills), then NAILED one to the bulkhead at haulout! Now everyone knew what had to be done, who was to do it, and when it was to be done. The only variables were things that were found at haul or previously not known.That kind of organization was in the yard and back out again, operating, with an updated COI, in a short time. Takes a lot of planning, but then, you know when it is due and you want to make money not spend money!

The other time/money savers I have been a part of, are after a unexpected repair or damage claim. An unexpected haulout that is within a few months of the mandated Coast Guard inspection. Again, it takes a “fast on your feet” plan but why haul now for three or four days then again in 6 or 8 months. If you next scheduled haul does not involve massive repairs or massive cosmetics, why not? It will alter your next due date but if you’re doing planned hauls those do not costs as much or take as much time as in the past. You have knowledge concerning the requirements, you have someone to inspect what the Coast Guard will look at, you have a dedicated maintenance person, and you already know from your log what needs to be fixed.  It requires cooperation from the MSO but I have found them to be accommodating when the circumstances are explained. They know this is your livelihood, and if you have developed a good relationship, they will try to help.

TO BE CONTINUED>>>

Contact me at,

Email: Bob@BoatSurveysHawaii.com

 808-375-8260

Bob Dupuis

Marine Surveyor/Consultant