Commercial 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.    

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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 65 pages. 

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 business.          

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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.

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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 fryingchicken 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.

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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
http://msep.d11nuscgaux.info/docs/UPV6PackInspectionFormJuly07.pdf
 
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.

http://www.uscg.mil/pvs/SPV.asp

 
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://homeport.uscg.mil/mycg/portal/ep/contentDetailViewPopup.do?BV&contentType=EDITORIAL&contentId=90229
 
                                                             With CFR 46 mandates at.
http://www.access.gpo.gov/nara/cfr/waisidx_01/46cfr28_01.html
  
 
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.

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Haul-out 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.

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COI for New Boats, Conversions, and New to Zones
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.
 
Conversions (pleasure 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.

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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.

http://www.uscgboating.org/regulations/boat_builders_handbook_and_regulations.aspx

 

 
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.

http://www.safetyseal.net/

WEATHER INFORMATION 
Weather websites... 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
https://www.fnmoc.navy.mil/PUBLIC/
 
Or, maybe you just want the Pacific, from the University of Hawaii.
http://weather.hawaii.edu/current/hawwx.cgi?banner=uhmet
 
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.
http://weather.noaa.gov/fax/hawaii.shtml
 
Looking for a Naval Architect? Try Brian Trenhaile's website here in Hawaii at:
www.Hawaii-Marine.com
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TO BE CONTINUED>>>
 
Contact me at,
Phone: 808-375-8260
Bob Dupuis AMS
Marine Surveyor/Consultant