The Coast Guard's Alternate Compliance Program (ACP) is one of the most significant regulatory reinvention programs of the 1990s. As contained within Title 46, Part 8, Subpart D of the Code of Federal Regulations (CFR), the ACP is intended to reduce the regulatory burden on the maritime industry while maintaining existing levels of safety and providing increased flexibility in the construction and operation of U.S. flag vessels. In this voluntary program, Classification Society Rules, International Conventions, and an approved U.S. Supplement provide an alternative that is equivalent to the CFR. Compliance with this equivalent alternative standard is administered through survey and inspection conducted by authorized classification society surveyors. A Certificate of Inspection (COI) is issued by the Coast Guard to a vessel enrolled in the ACP based upon the classification society reports.

Guidance on the ACP program is found in Marine Safety Manual (MSM), Vol. II, Sec. B, CH 9, and Navigation and Vessel Inspection Circular (NVIC) 2-95, CH-2. Links to the MSM, NVIC and other marine inspection documents are found at: http://www.dco.uscg.mil/About-Us/

The USCG has recently launched the improved Alternate Compliance Program webpage, now known as the Commercial Vessel Inspection Alternatives and Delegated Functions” site. The site can be accessed by clicking here. As before, the website contains a full listing of delegated authorization, class society functions, and Administration Agreements. These are easily viewable in the updated Summary Table of Authorizations.

The Maritime Security Act of 1996 (MSA) authorized the establishment of a Maritime Security Fleet under the Maritime Security Program (MSP), which serves as a means for establishing a fleet of commercially viable and military useful vessels to meet national defense as well as other security requirements.

On January 19, 2012, in an effort to establish a more consistent and comprehensive approach to inspecting MSP vessels, the Coast Guard published a draft Navigation and Vessel Inspection Circular (NVIC) requesting comments from all interested parties to ensure that the full range and significance of issues related to Coast Guard inspection processes for MSP vessels are identified.

Comments are due March 19, 2012.

If you have questions on this notice, call or email Mr. John Hannon, Domestic Vessels Division, U.S. Coast Guard; telephone (202) 372–1222, email John.J.Hannon@uscg.mil

Supporting Documents

• NVIC 01-13, Change 1

SIP is an alternative to traditional Coast Guard inspections that was developed in response to the Maritime Regulatory Reform Initiative. The Maritime Regulatory Reform Initiative challenged the Coast Guard to re-evaluate its regulatory programs and to develop alternatives that would ensure the same level of safety.

Originally, Coast Guard Districts and OCMIs were encouraged to explore options for streamlining the traditional inspection process. This resulted in numerous “prototype” SIPs created and tested by local Coast Guard units and Districts. Soon, however, it became apparent that the diversity of these programs was actually an impediment to each program’s success. Since each local version of SIP differed in the type and manner of USCG oversight, verification of the vessel’s compliance with regulatory safety requirements became an issue when vessels were inspected in OCMI zones other than the one in which the SIP enrollment was made. Some OCMIs were reluctant to accept another OCMI zone’s validation of the vessel’s compliance because there lacked a consistent inspection practice for ascertaining compliance. Accordingly, it became necessary to develop a consistent national policy regarding SIP.

The significant difference between SIP and the traditional annual inspection program is in the process of how compliance is ensured. SIP is primarily an “overlay” of the Code of Federal Regulations (CFR) requirements that regulate vessel safety. It identifies an alternative process for ensuring compliance with the CFR, where company personnel conduct frequent, periodic examinations of the various vessel systems, document their findings, and take the necessary corrective actions specified in the USCG approved plans when discrepancies are discovered. The Coast Guard will still conduct required inspections of the vessel(s), however, the manner of conducting the inspection will be considerably different. SIP is not strictly or singularly a “self-inspection” program. Under SIP the marine inspector’s primary focus will be to review the implementation and management of the SIP by the company and check some critical vessel systems to verify accuracy of the records.

SIP is based on maintaining enrolled vessels in a continual state of compliance. This continual state of compliance is assured through the development of an OCMI-approved Company Action Plan (CAP) and Vessel Action Plan(s) (VAP).

These plans:

• Stipulate the company’s commitment to a partnership with the Coast Guard to ensure the vessels operate in a continual state of compliance.
• Identify the responsibilities of company personnel for ensuring that this commitment is fulfilled in addition to identifying the vessel specific systems that will be examined:
  • By whom
  • When
  • How to record the examination
  • What to do in the event a discrepancy is discovered

The company will develop these plans with the assistance of a USCG SIP Advisor, assigned to work with the Company SIP Representative.

For additional information and a list of frequently asked questions, please consult Navigation and Vessel Inspection Circular (NVIC) 2-99 here or contact the SIP Program Manager.

SIP Program Manager: (202) 372-1216
Email: hqs-pf-fldr-cg-543@uscg.mil

These are individual pages in the Vessel Action Plan that list each item on the vessel required by regulation to be periodically inspected.
ICRs:

• Indicate every possible system/subsystem on a vessel, required by regulation, which must be periodically inspected.
• Specific reference is made to the relevant Code of Federal Regulations.
• Criteria or performance standard is explained.
• Outline the actions to be taken when a deficiency is noted during periodic inspections.
• Each procedure must match the numbering system on the Inspection Schedule and Verification form.

The CAP describes a company’s organization, policies, and responsibilities required for participation in the SIP.

Correction Report (CR)
A document that sets out specific vessel deficiencies and is used to record their correction by the company. Correction Reports will identify a specific deficiency, the date it was identified, the corrective measure taken, the repair date, and the source or vendor.

  PDF      MS Word

Examination Checklist
Any document or form approved in the VAP, to be used by company employees to record the periodic examinations required by the VAP. A separate Examination Checklist is optional. For example, companies may use the ISVs and CRs to satisfy this need.

  PDF      MS Word

Inspection Schedule and Verification (ISV) Form
The document that lists the items to be inspected and the intervals for their inspection, and on which is recorded the completion of required examinations and tests conducted by designated company employees. The ISV form:

• Identifies which systems/subsystems require inspection.
• The frequency of inspection.
• Provides a record of the inspection findings.
• Vessel specific.

  PDF      

USCG SIP Inspection Form
This Coast Guard SIP Inspection Form is broken down into the following four categories.

• Administrative Review
• SIP Performance Review
• Materiel Review
• Conclusion / Recommendation

  PDF      MS Word