b'SAFETY MATTERSSAFETYReconsideration and Appeal Know Your OptionsERIC CHRISTENSEN // PVA DIRECTOR OF REGULATORY AFFAIRS & RISK MANAGEMENTA s a follow-up to last monthsthose rare occasions when it is neces- Coast Guard inspector or Officer in articleonmanagingopera- sary to challenge an interpretation orCharge, Marine Inspection (OCMI). tionalrestrictions,therearerequirement made by your local U.S.There is a process in the regulations to cover such a scenario and it is every owners and operators right to use the process. The process can be as simple as asking the inspector if the require-ment issued is truly applicable to the vessel, or as complicated as going all the way up to Coast Guard headquar-ters seeking relief with a boatload of documentation. In recent cases, reconsideration and ap-peal exercised by PVA members under Title 46 Code of Federal Regulations (CFR) Part 1.03, has resulted in chang-estoCoastGuardpolicy(drydock credit), affirmation of grandfathering (rail heights), rescission of a Notice of Violation(security),liftingofopera-tional restrictions (security), and iden-tification of a regulatory drafting error (carpet in way of bar areas).FEAR OF RETRIBUTIONRegardlessofthecomplexityofthe situation, vessel owners and operators shouldnotbeconcernedaboutup-setting their local inspector by ques-tioningthevalidityorapplicability of a particular requirement. As I have heard at numerous Coast Guard In-dustry Days across the country from mid-levelandseniorCoastGuard leadership,retributionwillnotbe tolerated. That sentiment was driven home by RDML Wayne Arguin, as-sistantcommandantforprevention policy, during his keynote address at FOGHORN 34'