Strengthening U.S. Coast Guard Oversight and Support of Recognized Organizations: The Case of the Alternate Compliance Program (2021) / Chapter Skim
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67 The review of the findings and recommendations from the El Faro investigations and the actions agreed to by the U.S. Coast Guard (Coast Guard)
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68 STRENGTHENING U.S. COAST GUARD OVERSIGHT AND SUPPORT OF ROs actions agreed to by the Commandant and recommended by the El Faro investigators.
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DATA, METRICS, AND RISK-INFORMED TOOLS 69 In recognizing that a full replacement for MISLE may take several years, the committee recommends steps that can be taken in the interim to meet nearer-term ACP oversight needs while also informing plans for MISLE's replacement. DATA AND DATA SYSTEMS In response to Marine Board of Investigation recommendations (Safety Recommendation 21 and Administrative Recommendation 4)
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70 STRENGTHENING U.S. COAST GUARD OVERSIGHT AND SUPPORT OF ROs were rife with missing, incorrect, and inconsistent data.2 In accessing PSIX, the committee also found many omissions, inconsistencies, and errors in vessel status and inspection records.
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DATA, METRICS, AND RISK-INFORMED TOOLS 71 BOX 4-1 Summary of Relevant Findings from the U.S. Government Accountability Office's Review of the Coast Guard's Marine Information for Safety and Law Enforcement System The Coast Guard's Marine Information for Safety and Law Enforcement (MISLE)
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72 STRENGTHENING U.S. COAST GUARD OVERSIGHT AND SUPPORT OF ROs have been identified.
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73 T A B L E 4 -1 D es ir ab le F ea tu re s an d C ap ab ili ti es o f a V es se l D at ab as e fo r th e A lt er na te C om pl ia nc e Pr og ra m a nd t he M ar it im e Se cu ri ty P ro gr am S el ec t Fl ee ts D at ab as e C oa st G ua rd A cc es s R O A cc es s V es se l C om pa ny A cc es s Pu bl ic A cc es s V es se l pa rt ic ul ar s, i nc lu di ng ty pe , si ze , to nn ag e, d at e of b ui ld , A C P or M SP , R O , ve ss el n am e, v es se l co m pa ny • C on du ct s ea rc he s ba se d on v es se l pa rt ic ul ar s • C on du ct s ea rc he s ba se d on v es se l pa rt ic ul ar s • C on du ct s ea rc he s ba se d on v es se l pa rt ic ul ar s • C on du ct s ea rc he s ba se d on v es se l pa rt ic ul ar s C oa st G ua rd a nd R O st at ut or y in sp ec ti on re po rt s, d efi ci en ci es , an d co rr ec ti ve a ct io ns w it h as so ci at ed n ar ra ti ve r ep or ts an d se ar ch ab le c od es • A cc es s to a ll in sp ec ti on da ta w it h se ar ch ca pa bi lit ie s • V al id at e C oa st G ua rd ve ss el i ns pe ct io n da ta an d cl as si fic at io n ce rt ifi ca ti on s in da ta ba se • D ev el op K PI s ba se d on co m bi ne d C oa st G ua rd an d R O i ns pe ct io n da ta • Pe rf or m a ut om at ed ri sk t ar ge ti ng o f ve ss el s ba se d on C oa st G ua rd pl us R O d at a • A cc es s to a ll in sp ec ti on da ta w it h se ar ch ca pa bi lit ie s • V al id at e R O v es se l in sp ec ti on d at a an d cl as si fic at io n ce rt ifi ca ti on s in da ta ba se • de ve lo p K PI s ba se d on co m bi ne d C oa st G ua rd pl us R O i ns pe ct io n da ta • Pe rf or m a ut om at ed ri sk t ar ge ti ng o f ve ss el s ba se d on c om bi ne d C oa st G ua rd p lu s R O da ta • V al id at e co m pa ny ve ss el d at a an d ce rt ifi ca te s in d at ab as e • Id en ti fy e rr or s fo r ev en tu al M IS L E re vi si on • A cc es s to C oa st G ua rd – an d R O -i ss ue d st at ut or y in sp ec ti on d efi ci en ci es w it h sh or t de sc ri pt io n of de fic ie nc ie s, w it h se ar ch ca pa bi lit ie s (d es cr ip ti on s si m ila r to d efi ci en cy in fo rm at io n av ai la bl e in PS IX a nd i n E qu as is )
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74 D at ab as e C oa st G ua rd A cc es s R O A cc es s V es se l C om pa ny A cc es s Pu bl ic A cc es s C oa st G ua rd a nd R O Sa fe ty M an ag em en t C er ti fic at e (S M C )
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DATA, METRICS, AND RISK-INFORMED TOOLS 75 Following its El Faro investigation, the Marine Board of Investigation recommended that the Coast Guard publish an annual report on U.S. fleet compliance that also contains statistics and metrics on the performance of TPOs, including the ROs authorized for the ACP.
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76 STRENGTHENING U.S. COAST GUARD OVERSIGHT AND SUPPORT OF ROs Statistic 2: Statutory Findings of Deficiencies per Recognized Organization Vessel Survey The Coast Guard reports that ROs visited 4,377 U.S.
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DATA, METRICS, AND RISK-INFORMED TOOLS 77 Nevertheless, comparisons of U.S. fleet performance internationally can offer insight into the general performance record of the ROs active in the United States.
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78 STRENGTHENING U.S. COAST GUARD OVERSIGHT AND SUPPORT OF ROs Classification Societies' (IACS's)
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DATA, METRICS, AND RISK-INFORMED TOOLS 79 to implement and maintain a quality management system (QMS)
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80 STRENGTHENING U.S. COAST GUARD OVERSIGHT AND SUPPORT OF ROs manner that is difficult to search and analyze, such as entries that are made in narrative form.
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DATA, METRICS, AND RISK-INFORMED TOOLS 81 programs. These unenrolled vessels, therefore, could serve as comparison fleets, relating their inspection experience to that of the enrolled vessels when appropriately differentiated by vessel type.
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82 STRENGTHENING U.S. COAST GUARD OVERSIGHT AND SUPPORT OF ROs illustrate how such data could be used, Table 4-4 shows casualty and incident rates for the same groupings of vessels used in Table 4-3.
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DATA, METRICS, AND RISK-INFORMED TOOLS 83 RISK-INFORMED OVERSIGHT The Statement of Task calls on the committee to consider "the prospects for introducing a more automated risk-based program for the RO oversight program and associated vessels." Indeed, in responding to recommendations of the Marine Board of Investigation, the Commandant stated that "the Coast Guard must, and will, establish a risk-based and enduring policy framework that is simpler to execute and enables more robust oversight of delegated functions." The Commandant further agreed to refine internal risk models to inform oversight of vessel compliance and RO performance, such is in determining when and how often marine inspectors should attend SMS audits; the frequency, timing, and scope of ACP oversight examinations; and any additional oversight that is needed to ensure that ROs are properly executing their delegated functions. The progress made by the Coast Guard in furthering the actions agreed to by the Commandant has proved difficult for the committee to assess, particularly regarding the development of risk-based models and their ease and simplicity of use.
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84 STRENGTHENING U.S. COAST GUARD OVERSIGHT AND SUPPORT OF ROs Assessment List" that contains 10 percent of the ACP fleet.
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DATA, METRICS, AND RISK-INFORMED TOOLS 85 SUMMARY ASSESSMENT AND RECOMMENDATIONS Having reviewed the data systems, performance metrics, and risk-based processes employed by the Coast Guard to support and oversee the ACP and ROs, the committee concludes and recommends the following: • The Coast Guard's progress toward a more data-driven and riskbased approach to verifying compliance and overseeing the performance of ROs has not kept pace with the strides made in establishing needed policies, organizational capabilities, and procedures. Moreover, there are few promising signs that the Coast Guard is on the verge of marked progress in becoming more data driven and risk based as needed for the effective and efficient implementation of these policies, organizational capabilities, and procedures.
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86 STRENGTHENING U.S. COAST GUARD OVERSIGHT AND SUPPORT OF ROs • There are relatively few U.S.
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DATA, METRICS, AND RISK-INFORMED TOOLS 87 The data set should also be structured to meet CVC-4's need for calculating specified KPIs, performing risk-based profiling of vessels and ROs, and enabling other data analyses for oversight purposes. Additional data set filtering could enable access and use by vessel owners and the public.
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88 STRENGTHENING U.S. COAST GUARD OVERSIGHT AND SUPPORT OF ROs purposes of the Coast Guard, ROs, vessel companies, and the public, as discussed earlier in this chapter.
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