1625-0029_SS_r1_2014_AR

1625-0029

Supporting Statement

for

Self-propelled Liquefied Gas Vessels

OMB No.: 1625-0029

COLLECTION INSTRUMENTS: Instructions

A. Justification

1. Circumstances that make the collection of information necessary.

The Coast Guard is tasked by 46 U.S.C. 3703 with the protection of life, property, and the marine environment from the hazards associated with the transport of bulk liquid dangerous cargoes. Title 46 CFR Part 154 accomplishes this task for the transport of liquefied gases in bulk on self-propelled vessels by regulating the design, construction, equipment, personnel safety, and operation of these vessels. There are both reporting and recordkeeping requirements in these regulations. The reporting documentation provides a means for vessel owners or operators to obtain approval to carry liquefied gases in the U.S. waters. This documentation is an integral part of the Coast Guard’s administration of the Commercial Vessel Safety Program, specifically, the Certificate of Inspection program for U.S. flag vessels and the Certificate of Compliance program for foreign flag vessels.

The recordkeeping requirements of Part 154 are intended to ensure that vessel personnel are alerted to those safety issues regulated and controlled by operational standards rather than by design standards. A thorough review of the posting and recordkeeping requirements contained in these regulations found that they are considered to be necessary for safe operation and maintenance of the vessel and they are not an unreasonable burden. Parts of these requirements are routinely performed by the vessel operators in the course of good business practice. However, since it cannot be assured that every vessel will operate under good business practices, these requirements will remain part of the regulations for self-propelled liquefied gas vessels.

This information collection supports the following strategic goals:

Department of Homeland Security

• Prevention

• Protection

Coast Guard

• Marine Safety

• Maritime Stewardship

Prevention Policy & Response Policy Directorates (CG-5P & CG-5R)

• Safety: Eliminate deaths, injuries, and property damage associated with commercial maritime operations.

• Human and Natural Environment: Eliminate environmental damage associated with maritime transportation and operations on/around the nation’s waterways.

2. Purpose of the information collection.

There are 16 reporting and recordkeeping requirements contained in this collection (see Appendix A). The reporting information is used by the Coast Guard in three ways: 1) as a means to verify compliance with the requirements of Part 154; 2) as a means to communicate specific information on special designs not covered by the regulation; and, 3) to obtain information necessary to schedule a Certificate of Compliance examination. Three of the recordkeeping items: numbers 1, 2 and 5 [Subchapter D Certificate of Inspection, IMO Certificate of Fitness, and SOLAS Certificates] must be maintained on board the vessel. The other records maintained by the vessel operator are not submitted directly to the Coast Guard. They are examined on board the vessel by Coast Guard inspectors and vessel personnel to ensure they meet the requirements. Without this collection of information, the Coast Guard would have no way to determine if a vessel meets U.S. safety requirements for the transport of liquefied gases.

3. Consideration for using of improved information technology.

The submissions of vessel plans may be by hard copy (U.S. mail) or electronically via e-mail to the Coast Guard Marine Safety Center (MSC) at msc@uscg.mil. Contact info for the MSC is at the following link: http://homeport.uscg.mil/msc. We estimate that 40% of the responses are done electronically.

4. Efforts to identify duplication.

No similar reporting or recordkeeping data is collected by any other Federal agency. There is no duplication of effort as no other Federal, State or local agencies have similar programs.

5. Methods to minimize the burden to small entities if involved.

This information collection does not have an impact on small businesses or other small entities.

6. Consequences to the Federal program if the collection was conducted less frequently.

Less frequent collection of information would not allow the Coast Guard to determine if liquefied gas vessels meet approved construction standards and operating procedures. Without these determinations, there may be increased possibilities for casualties due to the hazards associated with the carriage of liquid bulk dangerous cargoes.

7. Special collection circumstances.

This information collection is conducted in manner consistent with the guidelines in 5 CFR 1320.5(d)(2).

8. Consultation:

A 60-day Notice (See [USCG-2014-0330], July 3, 2014, 79 FR 38051) and 30-Day Notice (September 19, 2014, 79 FR 56383) were published in the Federal Register to obtain public comment on this collection. The Coast Guard has not received any comments on this information collection.

9. Provide any payments or gifts to respondents.

There is no offer of monetary or material value for this information collection.

10. Describe any assurance of confidentiality provided to respondents.

There are no assurances of confidentiality provided to the respondents for this information collection.

11. Additional justification for any questions of a sensitive nature.

There are no questions of sensitive language.

12. Estimates of annual hour and cost to respondents.

• The estimated annual number of respondents is 267.

• The estimated annual number of responses is 7,791.

• The estimated annual hour burden is 7,890 hours.

• The estimated annual cost burden is $820,534.

Appendix A describes of each of the 16 collection of information-related requirements. The burden to respondents is provided in Appendix B. The vessel population¹ is for gas carriers (active status) that have a Certificate of Compliance (COC) (foreign flag) or Certificate of Inspection/Certificate of Fitness (COI/COF) (U.S. flag).

Items 1, 2 and 5, have both a reporting and recordkeeping responsibility, but the recordkeeping burden is negligible and, therefore, these items were not included in the Appendices as recordkeeping items. Other recordkeeping items, except for items 12-16, entail only filing or posting a document. These burdens, at mere minutes per year, are considered to be negligible.

We expect that a crewmember or shore-side management specialist is responsible for these reporting and recordkeeping requirements. The position of a crewmember or a shore-side management specialist is analogous to a Coast Guard Lieutenant (O-3). The wage rate used is in accordance with the current edition of COMDTINST 7310.1(series) for “Out-Government” personnel.

13. Total annualized capital and start-up costs.

There are no capital, start-up or maintenance costs associated with this information collection.

14. Estimates of annualized Federal Government costs.

The estimated annual Federal Government cost is $59,775 (see Appendix C). Costs are incurred during the review of certain applications and records. Recordkeeping information in items 9 through 16 are not reported to the Coast Guard, hence there is no cost to the Federal Government. Item 9, however, is issued by the Coast Guard and therefore has an associated processing cost. Appendix C gives the estimated costs to the Federal Government for reporting and recordkeeping items 1 through 9. Tasks are typically performed by a Lieutenant (O-3). The wage rate used is in accordance with the current edition of COMDTINST 7310.1(series) for “In-Government” personnel.

15. Reasons for the change in burden:

The change in burden is an ADJUSTMENT due to changes (i.e., increase) in the vessel population. There is no proposed change to the reporting and recordkeeping requirements of this collection. The methodology for calculating burden remains unchanged. The reporting and recordkeeping requirements remain unchanged.

We have dropped any reference to CG forms in this collection as these forms are either accounted for under separate information collection request (form CG-5148 in 1625-0094) or are no longer in use (form CG-4355). Form CG-5148 [Certificate of Fitness] is not used in this collection. All burden for that form is accounted for in ICR 1625-0094. Form CG-4355 is no longer used. The form was discontinued to allow respondents (manufacturers of certain hazardous materials) to submit information to the CG in any format they prefer. All burden for this requirement is accounted for in ICR 1625-0007. There are no changes to the burden as a result of these actions.

16. Plans for tabulation, statistical analysis, and publication.

This information collection will not be published for statistical purposes.

17. Approval for not explaining the expiration date for OMB approval.

The Coast Guard will display the expiration date for OMB approval of this information collection.

18. Explain each exception to the certification statement.

The Coast Guard does not request an exception to the certification of this information collection.

B. Collection of Information Employing Statistical Methods

This information collection does not employ statistical methods.

Appendix A. Description of Each Paperwork Burden Item

Item 1. Subchapter D Certificate of Inspection

CFR Cite: 46 CFR 154.15, 154.1801 and 154.1804

Plans and calculations must be submitted to the Coast Guard as a prerequisite for an endorsement of a U.S. flag vessel’s Subchapter D Certificate of Inspection (COI). A copy of the COI must be maintained on board the vessel. The COI is valid for a period of five years. This paperwork burden constitutes both a reporting and recordkeeping burden on the public. The reporting burden applies only to new U.S. flag liquefied gas vessels. The recordkeeping burden applies to both new and existing U.S. flag liquefied gas vessels. U.S. flag liquefied gas vessels are also required to hold a valid Certificate of Fitness (COF) as a prerequisite for both an initial and a renewal COI. The COF is issued to U.S. flag gas carrier vessels by Coast Guard and is approved under OMB collection 1625-0094. Note: There have been no new U.S. gas carrier vessels in the past several years.

Item 2. IMO Certificate of Fitness

CFR Cite: 46 CFR 154.22(a)(1) and 154.1802(a)

The IMO Certificate of Fitness (COF) is prepared by a vessel’s flag administration or its representative. A valid document indicates a new vessel is in compliance with the IMO Gas Code, Resolution A.328(IX), or an existing vessel is in compliance with the IMO Existing Gas Code, Resolution A.329. Generally, an IMO COF is sufficient evidence that a new or existing foreign flag vessel meets Part 154. Foreign flag vessels are required to obtain and submit to the Coast Guard a valid COF as a prerequisite for issuance of a Certificate of Compliance (COC). A copy of the valid COF must be maintained on board the vessel. The COF is valid for a period of five years from the date of issuance. Renewed COFs must be submitted to the Coast Guard when issued. This paperwork burden applies to both new and existing foreign flag liquefied gas vessels. This paperwork burden item constitutes both a reporting and a recordkeeping burden on the public.

Item 3. Vessel Plans

CFR Cite: 46 CFR 154.22(a)(2)-(7)

The Coast Guard requires that vessel plans be submitted. These plans detail the general arrangement, piping, firefighting, and safety aspects of the vessel. The Coast Guard reviews but does not approve the plans. The Coast Guard uses them for reference during vessel inspections by Coast Guard personnel. These plans are a permanent record of the vessel’s design and are a prerequisite for initial COC issuance. This paperwork burden item applies to both new and existing foreign flag liquefied gas vessels.

Item 4. Classification Society Certification

CFR Cite: 46 CFR 154.22(a)(9)(i)

Classification society certification of hull steel selection and cargo containment pressure/temperature control must be submitted to the Coast Guard for COC issuance. In this way the Coast Guard ensures that the requirements of Part 154, which exceed IMO Gas Code standards, are met. These documents accompany the vessel’s IMO COF. They are prepared and submitted once, during initial certification of the vessel. This paperwork burden item only applies to new foreign flag liquefied gas vessels.

Item 5. SOLAS Certificates

CFR Cite: 46 CFR 154.22(a)(9)(ii) and 154.1802(c)(1)

The Coast Guard requires new foreign flag vessels to submit copies of the vessel’s Cargo Ship Safety Construction Certificate and Cargo Ship Safety Equipment Certificate issued under the International Convention of Safety of Life at Sea, 1960. These documents are prepared by the vessels’ flag administrations or their representatives, and are indications that certain minimum international safety and construction standards are met. Submission of these documents is also a prerequisite for COC issuance. Copies of valid SOLAS Certificates must be on board the vessels. The 154.1802(c)(1) paperwork burden item constitutes both a reporting and recordkeeping burden on the public. The reporting burden applies only to new foreign flag gas vessels. The recordkeeping burden applies to both new and existing foreign flag liquefied gas vessels.

Item 6. Liquefied Gases Not Described in Part 154

ICR 1625-0007 addresses this requirement.

An owner/operator must send to the Coast Guard technical information on a liquefied gas that is not described under Part 154. This paperwork burden item applied to both new and existing liquefied gas vessels. While this item is listed in this appendix, the burden associated with this requirement is accounted for under OMB collection 1625-0007.

Item 7. Equivalents

CFR Cite: 46 CFR 154.32(b) and 154.34

Applications for equivalency are submitted to the Coast Guard to request use of equipment of fittings that do not meet the requirements of Part 154. Ship owners or operators may make such requests because they believe the substituted equipment or fitting provides the same level of safety of those meeting the requirements of Part 154. This section allows for technical improvements or substitutions without frequent regulatory revisions. This paperwork burden applies to both new and existing liquefied gas vessels.

Item 8. Request for Certificate of Compliance Examination

CFR Cite: 46 CFR 154.151(b) and (c)

The request for COC Examination is submitted to the Coast Guard following completion of the vessel plan review. Certain information is required to be included in the request in order that the Coast Guard can schedule an exam in a U.S. port. A satisfactory exam in a prerequisite for issuance of a COC. This paperwork burden item applies to both new and existing foreign flag liquefied gas vessels.

Item 9. Certificate of Compliance

CFR Cite: 46 CFR 154.1802(a) and (b)

The COC is prepared by the U.S. Government. It is issued to a foreign flag liquefied gas ship if it is in compliance with the requirements of 46 CFR part 154. A copy of the COC must be on board the vessel. The COC is valid for a period of two years from the date of issuance. This paperwork burden item applies to both new and existing foreign flag liquefied gas vessels.

Item 10. Loading and Stability Manual

CFR Cite: 46 CFR 154.1809

This manual is prepared during the vessel design and initial certification phases. It is necessary to ensure that the vessel is loaded, off-loaded and ballasted safely and to ensure that the required stability is maintained. Generally, only one is prepared during the vessel’s lifetime. It is retained on board the vessel. This paperwork burden item applies to both new and existing liquefied gas vessels.

Item 11. Cargo Manual

CFR Cite: 46 CFR 154.1810

This manual is prepared during the vessel design and initial certification phases. It is necessary to ensure that all cargo operations are done safely. Generally, it includes: 1) a description of the cargo’s properties, hazards and first aid measures, 2) procedures for conducting each cargo handling operation, and 3) maintenance of all safety systems. Generally, only one is prepared during the vessel’s lifetime. It is retained on board the vessel. This paperwork burden item applies to both new and existing liquefied gas vessels.

Item 12. Cargo Location Plan

CFR Cite: 46 CFR 154.1816

As needed, a plan detailing the cargo loading scheme must be prepared. It must include the location and number of each tank and the cargo contained in it. The plan is retained on board the vessel and must be available to ship and Coast Guard personnel. It is very important during an emergency. This paperwork burden item applies to both new and existing liquefied gas vessels.

Item 13. Shipping Document

CFR Cite: 46 CFR 154.1820

Each loading, this shipping document must be prepared. This document contains the history of the cargo, i.e., shipper, loading terminal, quantity loaded, etc. The document is kept on board the vessel. It is very useful during an emergency and accident investigation. This paperwork burden item applies to both new and existing liquefied gas vessels.

Item 14. Safety Relief Valve – Changing Set Pressure

CFR Cite: 46 CFR 154.1846

A log entry must be made when the safety relief valve (SRV) set pressure is changed. This ensures that ship and boarding personnel are aware of the SRV setting. The SRV setting determines the quantity of liquid cargo that may be safety loaded into a tank. This paperwork burden item applies to both new and existing liquefied gas vessels.

Item 15. Air Breathing Equipment

CFR Cite: 46 CFR 154.1852

A log entry must be made after each inspection of the compressed air breathing equipment. The entry gives the date of inspection and condition of the equipment. The equipment must be tested each month. The equipment may be needed for safe containment system entry and escape. This paperwork burden applies to both new and existing liquefied gas vessels.

Item 16. Speed Reduction Placard

CFR Cite: 46 CFR Part 154.1862

The placard is prepared during the vessel’s initial certification phase. It is posed in the wheelhouse. The placard identifies the limiting speed used in the dynamic load analysis calculations. This paperwork burden applies to both new and existing liquefied gas vessels.

Appendix B: Total Estimated Annual Burden on Industry
Respondents
Gas Carriers -- Foreign				267
Gas Carriers -- U.S.				0
Total Respondents				267
Item Number	Number of Respondents per Year	Number of Responses per Respondent	Burden Hours per Response	Total Annual Response	Total Annual Burden in Hours	Total Annual Burden in Dollars
1	0	1	100	0	0	$0
2	67	1	0.5	67	33.5	$3,484
3	13	1	0.5	13	6.5	$676
4	13	1	0.5	13	6.5	$676
5	13	1	0.25	13	3.3	$338
7	2	1	20	2	40	$4,160
8	147	1	2	147	294	$30,576
12	267	7	1	1,869	1,869	$194,376
13	267	7	2	1,869	3,738	$388,752
14	267	2	0.5	534	267	$27,768
15	267	12	0.5	3,204	1,602	$166,608
16	60	1	0.5	60	30	$3,120
Total Annual Number of Respondents			267
Total Annual Number of Responses			7,791
Total Annual Hour Burden			7,890
Total Annual Cost Burden			$820,534
NOTE: Figures may not sum due to rounding.

Appendix C: Estimated Annual Federal Government Cost
Item Number	Burden Hours per Response	Responses per Year	Annual Hours	Cost
1	900	0	0	$0
2	4	67	268	$20,100
3	2	13	26	$1,950
4	2	13	26	$1,950
5	1	13	13	$975
7	5	2	10	$750
8	3	147	441	$33,075
9	1	13	13	$975
Total:			797	$59,775
Total Annual Government Cost			$59,775

1 The estimated number of total annual respondents was obtained through the U.S. Coast Guard’s Marine Information for Safety and Law Enforcement system (MISLE) by using Mission Analysis and Reporting System (MARS Cubes).

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