Supporting Statement 

for

BOATING ACCIDENT REPORT

OMB CONTROL NO.:  1625-0003

COLLECTION INSTRUMENTS:  INSTRUCTION, CG-3865 and CG-3865SP

A.  Justification

1.	Explain the circumstances that make the collection of information
necessary.  Identify any legal or administrative requirements that
necessitate the collection.  Attach a copy of the appropriate section of
each statute and regulation mandating or authorizing the collection of
information.

Title 46 USC 6102(a) requires a uniform marine casualty reporting
system, with regulations prescribing casualties to be reported and the
manner of reporting.  The statute requires a State to compile and submit
to the Secretary (delegated to the Coast Guard) reports, information,
and statistics on casualties reported to the State.  Implementing
regulations are contained in Title 33, Code of Federal Regulations,
Subchapter S - Boating Safety, Part 173 - Vessel Numbering And Casualty
And Accident Reporting, Subpart C - Casualty and Accident Reporting, and
Part 174 - State Numbering And Casualty Reporting Systems, Subpart C -
Casualty Reporting System Requirements, and Subpart D - State reports.

The Federal regulations (33 CFR 173.55) require the operator of any
vessel that is numbered or used for recreational purposes to submit an
accident report to the State authority when:

(1)	A person dies; or

A person is injured and requires medical treatment beyond first aid; or

Damage to the vessel and other property totals $2,000 or more, or there
is a complete loss of the vessel; or

A person disappears from the vessel under circumstances that indicate
death or injury.

The Coast Guard Boating Accident Report form (CG-3865, OMB control
number 1625-0003) is the data collection instrument that ensures
compliance with the implementing regulations and Title 46 USC 6102(b)
that requires the Secretary to collect, analyze and publish reports,
information, and statistics on marine casualties.

States are required to forward copies of the reports or electronically
transmit accident report data to the Coast Guard within 30 days of their
receipt of the report as prescribed by 33 CFR § 174.121 (Forwarding of
casualty or accident reports).  The accident report data and statistical
information obtained from the reports submitted by the State reporting
authorities are used by the Coast Guard in the compilation of national
recreational boating accident statistics.

2.	By whom, how, and for what purpose the information is to be used.

Accident data and statistical information received from the current
collection are used by the Coast Guard to: establish National
Recreational Boating Safety (RBS) Program goals, objectives, strategies
and performance measures; report RBS Program performance to Congress in
the USCG FY Performance Report and Budget in Brief; identify possible
manufacturer defects in boats or equipment; develop boat manufacturing
standards; develop safe boating education and accident prevention
programs; and to publish accident statistics in accordance with Title 46
USC 6102.  Non-receipt of the data and information from the public would
require unnecessary additional investigation by the Coast Guard and
communications with the persons who are required to file accident
reports in compliance with Title 33 CFR 173.55.  Further, many accidents
would remain unreported with potential safety hazards going undetected. 
This would not be in the best interest of the public, State boating
authorities or the Coast Guard.

The Coast Guard uses the information collected for four main purposes:
regulatory studies, non-regulatory studies, USCG Annual Report
publication, and FOIA requests. 

Examples of regulatory studies include a study to determine how many
deaths and injuries could be prevented had the operator of a vessel worn
a wireless lanyard.  For this study, the Coast Guard focused on fields
to determine the effectiveness of a lanyard including: accident
description, prop strike, primary injury, cause of death, and accident
type.  Examples of non-regulatory studies include regional studies
focused on topics such as nighttime boating or PFD wear rate on boat
types, the latter of which required fields such as time of accident,
day/night, accident type, type of boat, life jackets onboard, and life
jackets accessible.

Every year the Boating Safety Division releases a statistics report on
the prior year’s accident data.  The report presents abstracted data
gathered from boating accident reports on four broad topics: causes of
accidents, accident types, casualty information, and operator/passenger
information.  

Information is shared internally in the Coast Guard.  The two most
frequent requestors of data are the Boating Safety Division and the
Office of Performance Measurement and Assessment.  Both of these offices
request abstracted data, usually the number of accidents, deaths, and
injuries during a specific time period.  The Boating Safety Division
uses this information to assess our progress with the program.  The
Office of Performance Measurement and Assessment uses this information
for Coast Guard publications, often in the form of quarterly reports or
forecasts.  

There are other offices within the Coast Guard that have requested
abstracted data on a number of topics including the number of incidents
where flares cause fires on recreational boats, the number of accidents
on salt vs. non-salt waters, and the number of accidents and casualties
by Coast Guard District.  These offices generally request data when
prompted by a conference, publication, or media spotlight on a subject. 

There are also requests from Coast Guard Auxiliarists for abstracted
information or for a database of accident report data.  Examples of
abstracted information include the number of accidents, injuries, and
deaths by state.  Examples of a database request would be all accident
data for the states in that Auxiliarist’s region.  In general,
Auxiliarists request information in preparation for a media interview.

The Boating Safety Division shares information with a number of external
organizations including the National Association of State Boating Law
Administrators, an association of state marine authorities, the National
Boating Safety Advisory Council, is the Congressionally-mandated council
that oversees the Boating Safety Division’s work, members from the
marine and insurance industries, researchers, lawyers, recipients of
non-profit grants, and the media.

If the Boating Safety Division receives permission to release data,
information can be released in a number of ways depending on the scope
of the request.  Often times, databases, spreadsheets and documents are
emailed.  If they are too large, they are copied to a CD-ROM and mailed.


3.	Describe whether, and to what extent, the collection of information
involves the use of automated, electronic, mechanical, or other
technological collection techniques or other forms of information
technology, e.g., permitting electronic submission of responses, and the
basis for the decision for adopting this means of collection.

There are two parts to the collection of data.  Federal regulations are
set up so that the public reports to the State and the State reports to
the Coast Guard.  The public can report by mail using CG-3685.  100% of
the States report to the Coast Guard using an internet based system
called the Boating Accident Report Database (BARD-Web).

BARD-Web supports the Coast Guard’s implementation of a uniform vessel
accident reporting system as required under Title 46 U.S.C, § 6102. 
Fully implementing BARD-Web reflects the Coast Guard’s commitment to
data sharing by enabling local / State / Territory law enforcement
officers to collect and electronically transfer accident report data to
one central location via an Internet connection and a Web browser. 
BARD-Web is located at   HYPERLINK "https://bard.cns-inc.com/" 
https://bard.cns-inc.com/  and enables: (1) State / local personnel to
input casualty data at the accident scene; and (2) casualty data to be
transformed into statistical information that is used to enhance the
safety and security of the public using our nation’s waterways.

4.	Efforts to identify duplication.  Why similar information cannot be
used.

Under the authority of Title 46 U.S.C, the U.S. Coast Guard is the only
federal agency that has been delegated the responsibility to collect,
analyze, and annually publish statistical information obtained from
recreational boat numbering and casualty reporting systems.  The
accident report data and information captured by accident report forms
are electronically submitted from State Boating Law Administrators in
the fifty (50) States, five (5) U.S. Territories and the District of
Columbia to the U.S. Coast Guard.

There are some land management agencies such as the National Park
Service, U.S. Forest Service and Army Corps of Engineers that have their
own accident reporting systems. The Coast Guard works with these
agencies to share data. 

5.	Methods to minimize the burden to small businesses if involved.

This information collection does not have an impact on small businesses
or other small entities.  Form CG-3865 has been structured to require
the minimum amount of information needed to accomplish statutory
obligations and is filled out by individuals and/or State and local law
enforcement officers.

6.	Describe the consequence to Federal program or policy activities if
the collection is not conducted or is conducted less frequently, as well
as any technical or legal obstacles to reducing burden.

If the accident data and statistical information is not collected using
Coast Guard form CG-3865, the mandated statutory requirement and
implementing Federal regulations will not be met resulting in an
unacceptable level of risk to the boating public.  Thus, national RBS
Program effectiveness would be significantly diminished in our ability
to mitigate the risks associated with recreational boating activity.

7.	Explain any special circumstances that would cause the information
collection to be conducted in a manner inconsistent with 5 CFR
1320.5(d)(2):

This information collection is conducted in a manner consistent with the
guidelines in 5 CFR 1320.5(d)(2).  The Coast Guard Boating Accident
Report form is only filed upon the occurrence of a recreational boating
accident that satisfies the Federal reporting requirements contained in
Title 33 CFR 173.55.

8.	Outside consultation for this collection effort.

	A 60-day Notice will be was published in the Federal Register to obtain
public comment on this collection.

9.	Explain any decision to provide any payment or gift to respondents.

There is no offer of monetary or material value for this information
collection.

10.	Describe any assurance of confidentiality provided to respondents
and the basis for the assurance in statute, regulation, or agency
policy.

There are no assurances of confidentiality provided to the respondents
for this information collection.  The system to store information has
gone under the review of a Privacy Impact Assessment and is maintained
and managed accordingly.  Further, under Title 46, U.S.C. § 6102 (b),
if a State marine casualty reporting system provides that information
derived from casualty reports (except statistical information) may not
be publicly disclosed, or otherwise prohibits use by the State or any
person in any action or proceeding against a person, the Secretary may
use the information provided by the State only in the same way that the
State may use the information.

11.	Additional justification for any questions of a sensitive nature.

There are no questions of sensitive language.

Estimates of reporting and recordkeeping hour and cost burdens of the
collection of information.

The estimated number of respondents is 5,000.  There is an estimated
30-minute burden to a respondent for each report filed for an annual
estimated burden of 2,500 hours for the estimated 5,000 reports.

5,000 reports X .5 hours = 2,500 hours

13.	Estimates of annualized capital and start-up costs.   (Do not
include the cost of any hour burden shown in Items 12 and 14).

The cost to the general public to mail a Coast Guard CG-3865 form in
2015 is $.49.  On an annual basis, the approximate cost to the general
public to mail 5,000 forms to the appropriate State reporting authority
as prescribed in Title 33 CFR 173 is $2,450 (5,000 x $.49).

14.	Cost to Federal Government.

The estimated annualized cost to the Federal government to administer
and maintain the fully implemented electronic National Boating Accident
Report Database (BARD) System for the fifty (50) States, five (5) U.S.
Territories and the District of Columbia is approximately $350,000. 
These costs include providing BARD System maintenance, help desk
support,  and implementing system enhancements in response to
evolving/changing user requirements in the fifty (56) reporting
jurisdictions.

15.	Explain the reasons for the change in burden.

There has been no increase or decrease in the estimated annual burden
hours previously reported for this information collection.

16.	For collections of information whose results are planned to be
published for statistical use, outline plans for tabulation, statistical
analysis and publication.

Reports are reviewed on an ongoing basis.  Within five months of the end
of the calendar year, the Coast Guard’s annual Boating Statistics
report (COMDTPUB P16754) will be published.  The Boating Statistics
publication is based on accident reports submitted to State reporting
authorities that are entered into the BARD System.  COMDTPUB P16754
provides general descriptive statistics about the causes and conditions
of accidents, the types of accidents, operator/passenger information and
casualty information.  

17.	Explain the reasons for seeking not to display the expiration date
for OMB approval of the information collection.

USCG will display the expiration date for OMB approval of this
information collection.  

18.	Explain each exception to the certification statement identified in
Item 19, "Certification for Paperwork Reduction Act Submission," of OMB
83-I.

USCG does not request an exception to the certification of this
information collection.

1625-0003												

 PAGE   

 PAGE  3 

