When I was training to become a Coast Guard marine inspector years ago, I noticed the doorway on a crewboat was 28 inches wide. When I looked up the regulation, I found that the door for a passenger compartment is required to be 32 inches wide. The other inspector breaking me in was reluctant to make the owner enlarge the doorway. All I could imagine was some very large passengers getting stuck in the capsized boat that we had certified.
Some say that regulations are written in blood. To have an effective compliance program, there must be an understanding of the intent of the regulations. Research is often necessary, but some owner/operators don't have the time, manpower, or desire to figure out if a certain regulation applies, or what the intent of the regulation is. As a result, many companies end up "chasing their tails" by relying solely on others' opinions and interpretations.
Compliance is a complicated business, but not an impossible one. Here are a few insider secrets. When a company becomes aware of a regulation, the first step should be to review the applicability in the regulations and ensure the regulation applies and that there are no exceptions. The next step should be to review the policy guidance on the topic. When dealing with the U.S. Coast Guard, policy guidance comes in a number of forms, such as: the Marine Safety Manual; Navigation and Vessel Inspection Circulars (NVICs); Headquarters policy letters; District policy letters; and local Captain of the Port policies. Additionally, the Federal Register can be reviewed for the date the regulation was published because it is footnoted at the end of each regulatory citation. The Federal Register has explanations for the regulations as well as the public comments and the Coast Guard's responses. This provides excellent insight into the intent of the regulations. These resources are all available online these days, so there is no good excuse for not preparing yourself before problems arise. Stay ahead of the curve and, in the words of my old Chief Quartermaster, who thankfully never answered my questions, "Look it up."
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