b'the PVA Annual Convention at Mar- always the predominant factors iTrends 2024 in Portland, Ore., whenrather than economics. Appeals shouldhe said Appeals should not be viewed asquestioningcompetencybutanc.That certain types of construc- not be viewed asopportunity for the Coast Guard totion, equipment, and/or repairsquestioningreevaluateitsprocessesandimproveare more economically advanta-decision-making. Appeals are criticalgeous to the vessel operator andcompetency but an toanyqualitymanagementsystemcanprovidethesamemeasureopportunity for the aimed at continuous improvement.of safety.Coast Guard toBALANCING ACT d.That some repairs can be safelyreevaluate its processes There are times when the process useddelayedandcanbemoreeco-nomicallyaccomplishedataand improve decision- bythelocalCoastGuardtoissuea requirementorplaceanoperation- different place and time.making. Appeals are alcontrolthroughaCG-835runscritical to any quality counter to their own guidance. Belowe.That the overall safety of a ves-isanextractfromVolumeIIofthesel and its operating conditions,management system Coast Guard Marine Safety Manual,suchasroute,hoursofopera- aimed at continuous Section A, Chapter 1, paragraph F.2.tions,andtypeofoperation, discussingtheneedtobalancead- shouldbeconsideredindeter- improvement. ministration of inspection regulationsmining inspection requirements. with practical vessel operations.RDML WAYNE ARGUINf.That vessels are sometimes sub-TheCoastGuardsobjectiveisjecttotheoperationalrequire-toadministervesselinspectionments of organizations and agen-laws and regulations and promotecies other than the Coast Guard. safe, well-equipped vessels that are suitable for their intended service.g.Thatabalancemustbemain-It is not the Coast Guards intenttained between the requirements to place unnecessary economic andof safety and practical operation. operational burdens upon the mar- Arbitrarydecisionsoractions itimeindustry.Whendetermin- that contribute little to the ves-inginspectionrequirementsandsels safety must be avoided.procedures,inspectionpersonnel must recognize and give due con- Vesselownersandoperatorsshould sideration to the following factors:feel free to use any of the above con-siderationswhendiscussingrequire-a.That the burden for proposingments with their local Coast Guard.acceptable repairs rests upon the vessels owner, not upon the re- RECONSIDERATION of inspections and the prevention de-pair facility or the inspector.If a vessel owner or operator disagreespartment head and can be as informal with a requirement issued by a marineas a phone call. However, putting your b. Thatdelaystovessels,whichinspector or local Coast Guard office,concernsinwriting(email)ispre-canbecostly,needtobebal- thefirststepistorequestreconsid- ferred as there will be a paper trail anced against the risks imposederationunder46CFRPart1.03.and a documented response from the bycontinuedoperationofReconsiderationisdirectedtotheCoast Guard. The final authority for thevessel,withsafetyoflife,marine inspector. If needed, reconsid- reconsideration is the OCMI if your property, and the environmenteration can be escalated to the chiefissue is not resolved at a lower level.35 JUNE 2024'