SUPPORTING STATEMENT  

DEFECT/NONCOMPLIANCE REPORT (CG 4917) AND 

CAMPAIGN UPDATE REPORT (CG-4918)

OMB Control No.:  1625-0010

Collection Instruments:  Instruction, CG-4917, CG-4918

A.  JUSTIFICATION:

1.  CIRCUMSTANCES WHICH MAKE COLLECTION OF INFORMATION NECESSARY:  

The Recreational Boating Product Assurance Branch (BSX 23) in the Office
of Boating Safety develops and enforces compliance with U.S. Coast Guard
safety standards and regulations under the authority of 46 U.S.C.
Chapter 43.

Compliance enforcement includes monitoring defect notification and
recall campaigns which boat and engine manufacturers conduct in
accordance with 46 U.S.C. 4310 for failures to comply with applicable
U.S. Coast Guard safety standards or regulations, and for defects which
in the words of the Federal statutes, "create a substantial risk of
personal injury to the public." Boat and "designated" associated
equipment (inboard engine, outboard motor, sterndrive engine or an
inflatable personal flotation device approved under 46 CFR 160.076)
manufacturers use the Defect/Noncompliance Report (CG-4917) and Campaign
Update Report (CG-4918) forms to provide an initial report and to report
their progress in conducting recall campaigns.

Defect/Noncompliance Report (CG-4917):  

According to 46 U.S.C. 4310(d) and (e) and 33 CFR 179.13(a)(2) the
manufacturer shall provide the Commandant of the Coast Guard with an
initial report consisting of certain information about the defect
notification and recall campaign being conducted.  Upon receipt of
information from a manufacturer indicating the initiation of a recall,
the Recreational Boating Product Assurance Branch assigns a recall
campaign number, and sends the manufacturer a CG-4917 form for supplying
the information.  The CG-4917 form describes:

   (1) the manufacturer's reason for conducting defect notification,

   (2) the units affected by the defect or failure to comply,

   (3) the degree of danger to the public with continued use of the
affected product, 

   (4) the extent of the problem, and

   (5) what corrective action the manufacturer plans to take.  

Alternatively, manufacturers are allowed the option of supplying the
required information without using the form.

Campaign Update Report (CG-4918):  

According to 33 CFR 179.15(a), a manufacturer who makes an initial
report required by 33 CFR 179.13 shall send to the Commandant of the
Coast Guard a follow-up report within 60 days after the initial report. 
The follow-up report must contain at least the following information:

  "(1) A positive identification of the initial report;

   (2) The number of units in which the defect was discovered as of the
date of the follow-up report;

   (3) The number of units in which corrective action has been completed
as of the date of the follow-up report; 

   (4) The number of first purchasers not notified because of an out of
date name or address or both; and

   (5) An updating of the information required by Section 179.13."

Section 179.15 also states "Each manufacturer shall submit any
additional follow-up reports requested by the Commandant."  The
Recreational Boating Product Assurance Branch furnishes the manufacturer
with CG-4918 forms for supplying the information.  

Per an agreement with OMB, the first Campaign Update Report form
(CG-4918) must be submitted within 60 days after the manufacturer
submits the Defect Noncompliance Report.  Additional CG-4918 forms must
be submitted within 90-day intervals thereafter, until the recall
campaign reaches an acceptable level of completion.

Alternatively, manufacturers are allowed the option of supplying the
required information without using the form.

2.  HOW, BY WHOM, HOW FREQUENTLY, AND FOR WHAT PURPOSE IS THE
INFORMATION USED AND ACTUAL USE THE COAST GUARD HAS MADE OF THE
INFORMATION FROM THE CURRENT COLLECTION?

The Recreational Boating Product Assurance Branch uses the information
collected with the CG-4917 and CG-4918 forms to:

	   (1) Assess the severity of defects and failures to comply with
applicable safety standards and regulations in boats and designated
associated equipment (designated in 33 CFR 179.03);

	   (2) Determine the degree of danger to the public with continued use
of the product without correction of the defect or noncompliance;

	   (3) Determine whether a manufacturer's proposed method for
correction of the defect or noncompliance is appropriate; and

	   (4) Monitor the progress of manufacturer notifications of owners and
corrections of affected units and determine whether the manufacturer is
exercising reasonable diligence in performing those responsibilities.

Once the Coast Guard receives the Defect/Noncompliance Report (CG-4917),
the information is entered into a database.  The Recreational Boating
Product Assurance Branch uses the database for the purposes of
monitoring when Campaign Update Reports (CG-4918) are due; to quickly
gather significant information about specific recall campaigns; to
evaluate a manufacturer's diligence in conducting a campaign; and in
evaluating the need for safety standards addressing specific problems.  

The Coast Guard Office of Boating Safety has a contractor-run website ( 
HYPERLINK http://www.uscgboating.org  http://www.uscgboating.org ) where
visitors can access a variety of recreational boating safety
information.  One of the popular features of the site is access to a
database where owners can access information concerning defect
notification and recall campaigns. 

 3.  CONSIDERATION GIVEN TO THE USE OF IMPROVED INFORMATION TECHNOLOGY

Manufacturers are not required to use the CG-4917 and 4918 forms.  The
Federal defect notification regulations in 33 CFR 179.13 and 179.15
specify the information the manufacturer must provide in an initial
report – the Defect/Noncompliance Report (CG-4917) and in any
follow-up reports – the Campaign Update Report (CG-4918).   The
Recreational Boating Product Assurance Branch believes use of the forms
is the easiest way to collect the necessary information.  However, the
Coast Guard accepts information provided in other formats such as:

Narrative form such as in a letter;

Via electronic mail; or

Via facsimile. 

75% of the active recall campaigns as of December 2014 send the CG-4917
and CG 4918 forms electronically. The forms are provided to the
manufacturers in either Adobe Acrobat or in Microsoft Word format.

4.  EFFORTS TO IDENTIFY DUPLICATION?

A search of the USCG data collections revealed no duplications of this
information collection. There is no similar data collected 

5.  IF THE COLLECTION OF INFORMATION INVOLVES SMALL BUSINESSES OR OTHER
SMALL ENTITIES, WHAT METHODS USED TO MINIMIZE THE BURDEN?

Small businesses manufacture fewer units annually, therefore minimizing
burdens.  At the same time, however, many small businesses or small
entities might not have computers or facsimile machines and might not be
able to take advantage of reductions in burdens by filing
electronically.

6.  CONSEQUENCE TO COAST GUARD BOATING STANDARDS PROGRAM IF CG-4917 AND
CG ARE WITHDRAWN OR INFORMATION IS COLLECTED LESS FREQUENTLY.

The information is collected quarterly from manufacturers conducting
recalls of their products. A manufacturer conducting a recall campaign
submits one CG-4917 form or some other type of initial report such as a
letter containing the information required by 46 U.S.C. 4310(d) and
179.13.  The manufacturer is then required to submit the first Campaign
Update Report form within 60 days of the initial report, and additional
reports every 90 days thereafter, until an acceptable number of owners
have been notified and an acceptable number of units have been
corrected.  If the Recreational Boating Product Assurance Branch did not
collect the information or collected the information less frequently,
the Coast Guard would not be able to determine: 

   (1) Whether owners of boats, inboard engines, outboard motors or
sterndrive units which failed to comply with applicable U.S. Coast Guard
safety standards or contained defects which create a substantial risk of
personal injury to the public were being notified by the manufacturers
of those products about the existence of the recalls and potential
danger with continued use of the defective products; and

   (2) Whether manufacturers subject to 46 U.S.C. 4310 and 33 CFR 179
were carrying out their statutory and regulatory responsibilities.

7.  EXPLAIN ANY SPECIAL CIRCUMSTANCES RELATED TO THIS INFORMATION
COLLECTION

There are no special circumstances applicable to this information
collection

   8.  DESCRIBE EFFORTS TO CONSULT WITH PERSONS OUTSIDE THE AGENCY 

A 60-Day Notice (See [USCG-2015-0378], July 17, 2015, 80 FR 42509) and
30-Day Notice (XX XX, 2015, 80 FR XXXXX) 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.  EXPLAIN ANY DECISION TO PROVIDE ANY PAYMENT OR GIFT TO RESPONDENTS,
OTHER THAN REMUNERATION OF CONTRACTORS OR GRANTEES. 

The Coast Guard does not provide payments or gifts to respondents in
exchange for the information collected.

10.  DESCRIBE ANY ASSURANCE OF CONFIDENTIALITY PROVIDED TO RESPONDENTS

There are no assurances of confidentiality for this information
collection.  

11.  ADDITIONAL JUSTIFICATION FOR ANY QUESTIONS OF A SENSITIVE NATURE:

There are no questions of a sensitive nature involved in this
information collection.

12.  PROVIDE ESTIMATES OF THE BURDEN OF THE COLLECTION OF INFORMATION:

Total annual first year burdens for respondents – 207 hours

Total annual follow-on burdens for respondents – 184 hours/yr for 2
years

Grand Total burdens/average campaign for respondents – 391 hours

A summary of the recall campaigns initiated annually, since 1994 is
listed below:

	YEAR	NUMBER OF CAMPAIGNS

	1994	77

	1995	101

	1996	57

	1997	49

	1998	52

	1999	31

	2000	27

	2001	70

	2002	65

	2003	63

	2004	43

	2005	67

	2006	77

	2007	33

	2008	38

	2009	33

	2010	24

	2011	21

	2012	11

	2013	9

	2014	12

		960/21 = 46 

An estimated average of four (4) reports is filed annually by each of 46
respondents for a total of 184 responses annually for an average three
year campaign timeframe.

one Defect/Noncompliance Report (CG-4917) and three Campaign Update
Reports (CG-4918) (the first year); and 

four Campaign Update Reports/year for an average of two years.

Responses:   

The Recreational Boating Product Assurance Branch estimates that it
takes approximately one hour to read instructions, gather the required
information and complete a CG-4917 form.

The Recreational Boating Product Assurance Branch estimates that it
takes approximately one-half hour to read instructions, gather the
required information and complete a CG-4918 form.

An average of 46 recall campaigns is conducted by boat, inboard engine,
outboard motor and sterndrive unit manufacturers annually.  

First Year Estimate:

CG-4917:  46 x 1 hour = 46 hours

CG-4918:  46 x ½ hour x 3* = 69 hours**

Follow-on Two Year Estimate:

CG-4918:  46 x ½ hour x 4 = 92 hours/yr x 2 years = 184 hours

*As stated previously, per an agreement with OMB, the Recreational
Boating Product Assurance Branch collects the information in the CG-4917
within 30 days, the information in the first CG-4918 within 60 days
after receipt of the DNR, and additional CG-4918s every 90 days
thereafter. e.g., a total of four reports the first year and four
reports each additional year the campaign remains open.

** According to OMB instructions, if the hour burden on respondents is
expected to vary widely because of differences in activity, size or
complexity, show the range of estimated hour burden, and explain the
reasons for the variance.  Numbers of units involved in recall campaigns
vary widely.  A rowboat manufacturer, who was a small business entity,
and whose boat failed compliance testing, might conduct a recall
campaign for 10 or fewer boats.  A Personal Watercraft (PWC)
manufacturer, however, might conduct a recall campaign for as many as
35,000 boats.  While the one hour estimate for completing the CG-4917
might be somewhat high for a manufacturer recalling 10 or fewer boats,
the larger manufacturers have sophisticated, computerized databases
which they can use to assemble the necessary information making one hour
a reasonable estimate of the time required to gather the information,
even for tens of thousands of units.  

In addition, the larger manufacturers may have designed their hull
identification numbering systems to specifically identify affected
units.  All boats are required to bear two distinct 12 character Hull
Identification Numbers (HINs) (see OMB approval No. 1625-0056).  The
first three characters in the HIN are the Manufacturer Identification
Code (MIC).  Characters four through eight are a manufacturer serial
number consisting of letters of the English alphabet or Arabic numerals
or both.  A manufacturer or importer may choose any serial number
sequence as long as each boat has a different HIN.  Some manufacturers
use the hull serial numbers portion of their boats HINs to indicate
vessel-specific information of significance to the manufacturer, such as
boat type, model, type of propulsion, etc., which can help identify
affected units involved in a recall campaign.   The last four characters
indicate month and year of manufacture and model year, enabling a
manufacturer to further delineate affected units if he or she so
desires.

Records:  In order to provide Campaign Update Reports (CG-4918), the
manufacturer would need to keep records of: 

   (1) Number of units which might contain the problem;

   (2) Number of first purchasers notified;

   (3) Number of dealers/distributors notified;

   (4) Number of units corrected or repaired;

   (5) Number of units inspected and were not affected; and

   (6) Number of owners who refused the offer for correction.

However, there is no other specific recordkeeping requirement associated
with the CG-4917 or CG-4918.

The Recreational Boating Product Assurance Branch estimates one-half
hour per report form for recordkeeping.

First Year Estimate:

CG-4917: 46 x ½ hour = 23 hours

CG-4918: 46 x ½ hour x 3 = 69 hours

Follow-on Two Year Estimate:

CG-4918:  46 x ½ hour x 4 = 92 hours/yr x 2 years = 184 hours

First year burden hours:  

Responses:  115 hours

Recordkeeping: 92 hours

Total:  207 hours

Follow-on burden hours:

Responses:  92 hours/yr x 2 years = 184

Recordkeeping:  92 hours/yr x 2 years = 184

Total: 368 hours

Grand total burden hours/average campaign:  575 hours

13.  PROVIDE AN ESTIMATE OF THE TOTAL ANNUAL COST BURDEN TO RESPONDENTS
OR RECORDKEEPERS RESULTING FROM THE COLLECTION OF INFORMATION.

Total annual first year cost burden to respondents = $4,025.00
(responses) + $3,220.00 (recordkeeping) + $377.66 (postage)  = 
$7,660.66

Total annual follow-on cost burden to respondents = $6,440.00
(responses) + $6,440.00 (recordkeeping) + $90.16 (postage) = $12,970.16 
(two year time) 

Preparation Cost for Responses:  

The Recreational Boating Product Assurance Branch estimates that it
takes approximately one hour to read instructions, gather the required
information and complete a CG-4917 form.   

The Recreational Boating Product Assurance Branch estimates that it
takes approximately one-half hour to read instructions, gather the
required information and complete a CG-4918 form.

First Year Estimate:

CG-4917: 46 x 1 hour = 46 hours

CG-4918: 46 x ½ hour x 3 = 69 hours

Follow-on Two Year Estimate:

CG-4918:  46 x ½ hour x 4 = 92 hours/yr x 2 years = 184 hours

Estimated $35.00 per hour cost for a secretary*

*GS-4 outside Government per COMDTINST 7310.1P  dtd. 01 FEB 2015

First Year Estimate:

CG-4917:  46 x 1 hour x $35.00 = $1,610.00

CG-4918:  46 x ½ hour x 3 x $35.00 = $2,415.00

Follow-on Two Year Estimate:

CG-4918:  46 x ½ hour x 4 x $35.00 = $3,220.00/yr x 2 years = $6,440.00

Total annual first year preparation cost burden to respondents =
$4,025.00

Total annual follow-on preparation cost burden to respondents =
$3,220/yr for 2 years = $6,440.00

Grand Total preparation cost burden/average campaign to respondents =
$10,465.00

Recordkeeping Cost:

The Recreational Boating Product Assurance Branch estimates one-half
hour per report form for recordkeeping.

First Year Estimate:

CG-4917:  46 x ½ hour = 23 hours

CG-4918:  46 x ½ hour x 3 = 69 hours

Follow-on Two Year Estimate:

CG-4918:  46 x ½ hour x 4 = 92 hours/yr x 2 years = 184 hours

Estimated $35.00 per hour cost for a secretary*

*GS-4 outside Government per COMDTINST 7310.1P  dtd. 01 FEB 2015

First Year Estimate:

CG-4917:  46 x ½ hour x $35.00   = $805.00

CG-4918:  46 x ½ hour x 3 x $35.00   = $2,415.00

Follow-on Two Year Estimate:

CG-4918:  46 x ½ hour x 4 x $35.00  = $3,220.00/yr x 2 years =
$6,440.00

Total annual first year recordkeeping cost burden to respondents =
$3,220.00

Total annual follow-on recordkeeping cost burden to respondents =
$3,220/yr for 2 years = $6,440.00

Grand Total recordkeeping cost burden/average campaign to respondents =
$9,660.00

Postage cost:

According to 179.13 and 179.15, the initial report (CG-4917) and any
follow-up reports (CG-4918) to the Commandant shall be sent by first
class mail or certified mail:

If first class mail = $0.49 per response* 

If certified mail = $6.74 per response ($6.25 + postage)**

* ** It’s not realistic to average the two, so costs computed based on
more expensive method.

Three costs make up the $6.74 USPS Certified Mail rates:

1.  First-Class Postage $0.49 (this is a letter size envelope, up to 1
oz in weight)

2.  Certified Mail Fee $3.45

3.  Return Receipt (Green Card) $2.80

Total Cost per Letter $6.74

First Year Estimate:

CG-4917:  46 x $6.74 = $310.04

CG-4918:  46 x 3 x $0.49 = $67.62 (Almost all reports sent first-class
mail)

Follow-on Two Year Estimate:

CG-4918:  46 x 4 x $0.49 = $90.16 (Almost all reports sent first-class
mail)

14.  TOTAL ESTIMATED COST TO FEDERAL GOVERNMENT 

The estimated annual cost to the Federal Government is $1,246.40.  

Estimated printing costs:  $20.00 annually.

Cost of man-hours:  $1,246.40

The estimated average number of respondents annually is 46. I t takes an
estimated five (5) minutes to review and enter the information collected
on a Defect/Noncompliance form (CG-4917) into the computer and an
estimated five (5) minutes to review and enter the information collected
on each Campaign Update Report:

Estimated average cost per man-hour = $80.00

46 x 20/60 = 15.33 x $80.00= $1226.40 + $20.00 (for forms) = $1,246.40

15.  EXPLAIN REASONS FOR PROGRAM ADJUSTMENTS:  This is an ADJUSTMENT due
to a decrease in burden due to fewer recall campaigns in the past three
years.  This is partially a function of the number of boats that fail
compliance testing at the Coast Guard test facility. The Coast Guard’s
factory inspection program has assisted in keeping boat defects/recalls
down through working with manufacturers at the factory to correct
possible defects at the source.  It is also a function of economic
forces; in a down economy there are fewer boat manufacturers and in turn
a fewer number of recalls.

16.  OUTLINE PLANS FOR TABULATION, STATISTICAL ANALYSIS AND PUBLICATION:
 The collection of this information does not involve statistical
evaluation or publication.

17.  DISPLAY OF EXPIRATION DATE. USCG will display the expiration date
for OMB approval of this information collection.

18.  EXPLAIN EACH EXCEPTION TO THE CERTIFICATION STATEMENT IDENTIFIED IN
ITEM 19OF OMB FORM 83-1.

B.  DESCRIPTION OF COLLECTIONS OF INFORMATION THAT EMPLOY STATISTICAL
METHODS:  The collection of this information does not involve
statistical methods,

1625-0010					

			

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