PVA: Improve USCG Form 2692 Requirements

In a letter responding to a Federal Register notice about the renewal of Coast Guard Form 2692, Passenger Vessel Association (PVA) President Jay Spence insisted that the Coast Guard issue new instructions clarifying the circumstances in which a Form 2692 should or should not be submitted by passenger vessel operators. 
 
 

The Coast Guard solicited comments on its proposed application to the Office of Information and Regulatory Affairs (OIRA) renewing approval of Coast Guard Form 2692.  OIRA is part of OMB and was created as a result of the Paperwork Reduction Act of 1980.  It is charged with reviewing federal regulations and reducing paperwork burdens, including a current review of the Coast Guard Form 2692.  OIRA, in their review, measures affected publics, the hours associated with reporting as well as related costs before renewing Coast Guard Form 2692, which requires the reporting of a marine accident, injury or death.  
 
 

PVA President Spence stressed that the proposed Coast Guard’s submission is flawed because the analysis “substantially understated the impact of the reporting requirement on passenger vessel operators.” 
 
 

In addition, he stated that “…the maritime industry has long complained and the Coast Guard has acknowledged that its field unit policies and practices frequently dictate the submission of CG 2692 forms for ‘non-reportable’ marine incidents and events. This overreaching may be from a misplaced excess of caution, misinterpretation of subjective regulatory language, a lack of trust regarding industry’s faithfulness of disclosure or the field command’s perceived need, under Maritime Domain Awareness policies, to collect an overabundance of information and data.  Regardless of the reason, the result is that the Coast Guard requires the submission of many more CG 2692 forms than is justified by prior OIRA approval.”
 
 

PVA President Spence also offered PVA’s assistance in this review.