Vessels And Some Pleasure Info Too!
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 available
systems that 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, the US Coast Guard has changed in the last couple of years
and the system for COI boats has changed also. In fact they hired a retired
admiral named Card to survey and review this part of the service; you can go to
this website and read what he discovered, it's not flattering and 65pages. http://www.uscg.mil/hq/cg5/cg54/marinesafety.asp
Still, the 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, now sector, 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
Second, you or someone in your 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, or maintenance guy of the vessel did not know all the
systems thoroughly. Those thoughts may go through that inspectors head also.
Add an incident, Accident Report and investigation, now that inspector and his
paperwork are going to be scrutinized by his boss. 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 and your booking agents. That's a cost you do not want to pay.
Third, be upfront about any issues the boat currently has that are
not 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 Vallarta. 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 friend's 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 and K-boat site out of USCG Homeport. If
you get lost, or can't find it email me and I send you my download pdf file.
And the commercial boat site from the State of Hawaii.
Commercial Fishing Vessels have their own National Coast Guard site
With CFR 46 mandates at.
Equipment and Standards
I survey to the ABYC Standards with CFR regulations, NFPA, etc. If
you want info on those ABYC Standards see...
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
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.
COI for New Boats, Conversions, and New
My experience with new boats is that if you're going to build one
for charter (SPV) service look at an already approved and running model, which
has a COI. Then you can go to a naval architect and use that as a "sister
ship" with whatever modifications you want and he can do within limits.
Otherwise, a new design will take you additional time for Coast
Guard approval. With a sister ship, scantlings have already been checked
and approved at MSC, Washington, D.C.
Your 'sister ship" MSC approvals will entail any structural
modifications and their ramifications on stability, plus the machinery, and
electrical modifications. See this website for plan submittals, at MSC.
As they state in their website, work with the Coast Guard district
wherever that builder is and it would be nice if that builder has built COI
boats in the past. The site talks about using ABS, or a P.E. (licensed
Professional Engineer) or other entity as a third party approval and one may be
of service to you with some systems. My recommendation, utilize the Coast Guard
in that district. They will coordinate with MSC to make sure it's done right.
At the same time they get to know the boat intimately, and your vessel is on
the COI "track" until completion. Of course, hire a guy like me to pull
everyone in the same direction! The Coast Guard will make you comply with their
specifications, builders will build to those mandates, so who is making sure
you're getting the best bang for your buck? Is that 39" safety rail
systems really going to hold up, is that bilge pump alert system really going
to last? Also, when your modifications require a "change" of equipment from the
"sister ship", try to get something already "off the
shelf". A newly designed, custom fuel tank, will have to be "tested" by
Coast Guard. One that is on the shelf at a tank builder has already been
approved, labeled, etc. and may only require some small area modifications
by the builder or maybe you just carry 5 gallons less. Bang for the buck!
Is MSC thorough or tough? I had to go back to one boat, months after it was
built and have changed one 3' wire that would not carry enough current at
300% load. (Fire hazard) So yes, they are. Pre-approval from MSC is the better
way to go, but I have seen a builder bypass the pre-approval, it's a risk
he accepted but sure had the owner on edge, builders demand payments as
they build. That builder will also have to submit engineering drawings for all
systems he installs, but have him do them on time. I have done some engineering
drawings because the boat was done, paid for, delivered, and we were still
waiting for the builder, who is now busy with a new boat! The owner ended up
paying twice for drawings so that he could get the vessel in service.
So now you're done, almost.
You have the boat at the builder and it has a COI for that district. Hopefully,
you got as much included in those COI parameters, limited coastwise, coast
wise, oceans, as you can, next is delivery. Not good to have
your operating limits only out to 20 miles and that nice island you want
to charter to is 50 miles away. On delivery, yet another
recommendation, whatever is the least expensive, even under its own power.
You're last hurdle before making money on that boat is a New to Zone COI. The
Coast Guard district you will operate in must give their "stamp of approval",
New to Zone inspection. They want to know that boat too. If all your
engineering drawings are in MSC, the originating district and MSC will copy to
the operating district. They check all the safety items, your drug program, do
some fire, overboard, and abandon ship drills and you're usually good to go.
All the hard work has been done; they don't need to do it again.
New to Zone COI's work well for used charter boats bought in one
state and put into service in another. The issue now will be all
those new mandates from the Coast Guard you are required to comply with.
If that boat is 10 years old and "grandfathered" into outdated requirements,
they may have you "upgrade" to the current standards.
craft to commercial) are a little different, but the same issues. That 50'
Delta pleasure boat you want to buy and put into charter probably has a COI
some where in the US. Track down the
builder or naval architect and find out if it has a "sister ship" in
commercial service. Then get a local naval architect and the Coast Guard
district involved where you are having the conversion done to get started
in the process. Again, structural modifications will require some
stability testing (calculations done by the architect after some in the water
measurements) and all those engineering drawings.
Any good boatyard can do the job; they probably cannot do the
drawings nor may know the requirements. The naval architect can do
the specifications and drawings, the local district will guide you
through the mandates, get someone knowledgeable or hire me to make sure
you spend you money wisely. Again, a currently operating COI boat is
the usually the simplest to put into service in a new district.
PLEASURE VESSELS REGULATORY INFORMATION
This is the U.S. Coast Guard's national site. If you want to
learn what you are mandated to have with you on your vessel for recreational
use. Scroll down on the "Table of Contents" to the right and you can
print a checklist. These are minimum life saving regulations.
Also, a copy of the
Examiner's checklist for the Vessel Safety Decal from USCG District 14 here in Honolulu. Get the decal, it
may save you time and aggravation the next time your out there.
How about this, the U.S. Navy worldwide!
Now this is not your
average weather site, you may need a PHD to understand all this
information. Just scroll down to Tropical Eastern Pacific and click and you can
click on sea surface/streamlines or
if you click
on MyWXMap on the left hand side of the page, then click "public
charts no login required", then move across the top to CHARTS, then scroll
to sfc istch/wind.slp you can get surface wind info. Hey, play around in
this site, I'm still discovering helpful stuff for when I'm out there.
you just want the Pacific, from the University of Hawaii.
Or maybe that old
weather fax machine finally died and you wired that modem into your SSB. Here's
the NOAA website for weather fax, this page is the Pacific but look around and
get any area you want.
Looking for a Naval Architect? Try Brian Trenhaile's website here
in Hawaii at:
TO BE CONTINUED>>>
Bob Dupuis AMS