Supporting Statement for 

Title 46 CFR Subchapter Q:  Lifesaving, Electrical, Engineering and
Navigation Equipment, Construction and Materials & Marine Sanitation
Devices (33 CFR 159)

OMB No.: 1625-0035

COLLECTION INSTRUMENTS:  CGHQ-10030 & Instruction 

A.  Justification

1.  Circumstances that make the collection of information necessary.

The authority to prescribe regulations for lifesaving, electrical,
engineering, and navigation equipment, construction and materials, and
its use on inspected vessels derives from 46 U.S.C. 3306.  These
regulations are also authorized under 46 U.S.C. 3703 and 4302.  Specific
Subparts of Title 46 Subchapter Q are also authorized under 46 U.S.C.
2103 and 5115, and 33 U.S.C. 1321(j), and 1903.  Title 46 CFR Chapter I
Subchapter Q Parts 159 through 165 (165 requirements currently found in
NVIC 8–01 (Change 2)) contains the technical standards for approval by
the Coast Guard of specific types of safety equipment and materials that
are to be installed on vessels subject to Coast Guard jurisdiction.  The
authority to prescribe regulations for marine sanitation devices (MSD)
is at 33 U.S.C. 1322(b)(1).  The MSD regulations are found at 33 CFR
Part 159.

a.  Approval procedures for lifesaving, electrical, engineering, and
navigation equipment, construction and materials, and marine sanitation
devices (MSDs):  The general approval procedures for the equipment and
material of Subchapter Q are described in 46 CFR 159.  The standards for
Coast Guard approval of different equipment and material are contained
in 46 CFR Parts 160-165, as described below: 

Lifesaving Equipment: 		46 CFR Part 160 

Electrical Equipment: 		46 CFR Part 161

Engineering Equipment: 	46 CFR Part 162

Construction:			46 CFR Part 163

Materials:			46 CFR Part 164

Navigation Equipment		46 CFR Part 165 (NVIC 8-01, Change 2)

MSDs				33 CFR Part 159

The overall authority for the reporting and recordkeeping requirements
applicable to all manufacturers of approved equipment, thus making it
applicable also to the equipment and material in Subchapter Q, is
described in 46 CFR 2.90 and 2.95.  In general, safety equipment and
material standards are intended to ensure that manufactured equipment
meet minimum levels of performance and safety.  To show that these have
been met, manufacturers are required to submit drawings, specifications,
and laboratory test reports before Coast Guard approval is given, as
described in the above regulations.  

When the Coast Guard approves emergency and safety equipment for use
aboard commercial vessels and pleasure craft, the manufacturer is issued
a Certificate of Approval (COA).  This certificate and all other
documents (drawings, test reports, etc.) form the basis for the
certificate and must be retained for the period for which the
certificate is in effect (usually five years).  

Navigation equipment requirements are currently required by SOLAS V for
vessels engaged on international voyages.  These requirements will be
codified in a proposed rule creating 46 CFR Part 165.  Currently, these
approvals are being conducted in accordance with NVIC 8–01 (Change 2).

Furthermore, the regulations in 46 CFR 160 require liferafts and certain
life preservers to be serviced periodically.  This servicing must be
recorded so that it can be determined later that it was indeed done. 
Servicing records for lifesaving devices are retained by the servicing
organization for use by Coast Guard inspection personnel.  These records
form the basis of a servicing certificate, a copy of which is retained
on the vessel or drilling unit.  It serves as evidence that the
equipment is in operating condition and that the equipment was serviced
in accordance with the applicable regulations by an authorized servicing
facility.  Reports by liferaft servicing facilities of deficient
liferafts and deficient liferaft servicing are used to identify
production problems that could affect multiple liferafts in field
service, and liferaft servicing facilities requiring closer Coast Guard
oversight.  Such reports are occasional, only being required when a
reportable deficiency is observed.

b.  Instructional Materials:  Manufacturers are required to produce, and
vessel operators are required to use, instructional materials for
certain lifesaving, fire protection, engineering and navigation
equipment.  For the equipment cited in Subchapter Q requiring
instructional material, the manufacturers are generally required to
submit the instructional materials along with the application package to
the Coast Guard for approval.  Instructional material is necessary
because vessel crewmembers must have access to information on the proper
operation of lifesaving, fire protection, engineering and navigation
equipment.  These materials are used during training sessions and during
emergencies.  Applicable parts as can be seen in the Appendix A. 

c.  Markings:  Subchapter Q requires manufacturers to identify
lifesaving, electrical, engineering and navigation equipment and some
construction and materials, with the following: manufacturer, model
number, capacity, approval number and other information concerning its
performance.  Additional markings are required in the case of certain
equipment, and are outlined in the applicable requirements for the
equipment in question.  Generally, vessel operators and Coast Guard
inspectors use this information to determine compliance with
regulations.  Applicable parts as can be seen in the Appendix A. 

d.  Production Tests and Laboratory Inspections:  Subchapter Q
regulations also require the manufacturer to conduct and maintain
records of production tests for some of the equipment and material. 
These tests are mainly material tests necessary to ensure that the
material being used in the construction of a lifesaving appliance meets
the minimum performance requirements with regard to strength, buoyancy,
and fire retardancy, as applicable.  The manufacturing processes are
also inspected regularly by lab inspectors – who issue their own
reports to the manufacturer – from independent laboratories certified
by the Coast Guard to ensure quality control.  Applicable parts as can
be seen in the Appendix A. 

e.  Independent and Recognized Laboratories:  Independent Lab:  Some of
the production tests described above are required to be done through, or
certified by, ‘independent’ laboratories.  Thus, before laboratory
test reports can be accepted, the laboratory must demonstrate its
technical qualifications and independence.  The laboratory can satisfy
this requirement by submitting the information specified in 46 CFR
159.010-5 to the Coast Guard.  This is a reporting requirement that each
laboratory has to meet only once and is thus a one-time burden.

Recognized Lab:  Certain Subparts in Subchapter Q, Parts 159-165, not
only require that the laboratory is Coast Guard accepted, but also that
it is a ‘recognized laboratory’ listed in the Subpart.  At present,
there are 4 recognized labs.  

The Coast Guard established regulations, in 46 CFR 159.010 and in some
Subparts of Subchapter Q, for an independent laboratory seeking to
become a recognized laboratory for conducting tests and inspections. 
Only laboratories that enter into a Memorandum of Understanding (MOU)
with the Coast Guard may perform the functions of a recognized
laboratory.  The MOU is a collection of information that is prepared and
submitted to the Coast Guard for approval by the laboratory seeking
recognition.  The MOU specifies the approval functions the laboratory
performs for the Coast Guard, and the laboratory’s working
arrangements with the Coast Guard.  The establishment of the MOU will
ensure that all independent laboratories that are recognized by the
Coast Guard follow similar procedures.  Provisions for ‘round-robin’
testing in the MOU will ensure that various recognized laboratories’
testing similar equipment using similar testing procedures obtain
comparable results.

This information collection supports the following strategic goals:

Department of Homeland Security

Prevention

Protection

Coast Guard

Maritime Safety

Maritime Stewardship

Prevention Policy and Response Policy Directorates (CG-5P & CG-5R)

Safety:  Eliminate deaths, injuries, and property damage associated with
commercial maritime operations.

Human and Natural Environment:  Eliminate environmental damage
associated with maritime transportation and operations on and around the
nation’s waterways.

2.  Purpose of the information collection.  

a.  Approvals, b.  Instructional Materials, and c.  Markings:  Technical
plans, drawings, specifications, instructional materials, test reports
and service records are submitted to the Coast Guard to obtain and
maintain approval for a variety of lifesaving and safety equipment.  The
submitted technical data is then reviewed to determine compliance with
the technical requirements contained in specific regulations.  The plans
and drawings are copies of production drawings utilized by the
manufacturer in making the equipment.  The required instructional
materials and markings are also submitted to the Coast Guard with the
overall application for approval. 

When Coast Guard approval is issued, a COA is sent to the manufacturer
of the equipment.  The certificates, plans, specifications, and
laboratory test reports used to issue approval are retained by the
manufacturer of the approved equipment to identify the specific
equipment approved and to permit the production of equipment identical
to the equipment samples originally tested.  The certificates also
specify an expiration date and provide the terms of the approval. 
Subchapter Q thus requires that these documents be filed and retained by
the manufacturer. 

d.  Production Tests and Laboratory Inspections:  Independent testing
laboratories that test the materials and equipment for compliance with
the applicable Coast Guard regulations issue reports.  The manufacturer
is required to retain laboratory or production test reports used by the
manufacturer to obtain approval from the Coast Guard.  

Production test reports for approved equipment are reviewed either by
the independent laboratory or Coast Guard inspectors to determine that
production stock will be identical to those originally tested and
approved.  The purpose of these reports is to enable a comparison
between the construction and properties of production units to the
prototypes originally evaluated prior to issuance of Coast Guard
approval.

e.  Independent and Recognized Laboratories:  Upon being accepted by the
Coast Guard, the Independent Laboratories meet the criteria for the
reports they themselves issue to be accepted.  The information that each
laboratory must submit to gain such Coast Guard acceptance or
recognition:

Identifies the laboratory and principal person(s) to contact;

Verifies the independence of the laboratory from the organizations whose
products the laboratory will test;

Verifies the technical qualifications of the test personnel; and

Verifies the adequacy of equipment and facilities to conduct the testing
for which application is made.

An MOU, in the form of a prepared and signed document, is submitted to
the Coast Guard by an independent laboratory seeking Coast Guard
‘recognition’ to perform certain approval and production tests
specified in 46 CFR Subchapter Q.  A particular laboratory submits it
only once, at the time of initial application for recognition.  The MOU
is used by the Coast Guard to evaluate the capabilities of the
laboratory to perform the functions specified in the relevant
regulations, and to document the responsibilities of the laboratory and
of the Coast Guard in relation to equipment testing, inspection, and
approval.

3.  Consideration of the use of improved information technology.  

The information may be submitted in writing or electronically via
e-mail.  We estimate that about 90% of the reporting and recordkeeping
requirements can be done electronically.  At this time, we estimate that
approximately 90% of the responses are collected electronically.  

4.  Efforts to identify duplication.  

There is no duplication, since the information is reported or kept only
once for each organization and each item.  There are no other Federal
Agencies or States with programs dealing with the same equipment and
technical requirements.  On the contrary, other Federal Agencies have
relied on Coast Guard approval as evidence of suitability for the
purpose intended when ordering items such as lifesaving equipment.

The information is unique to each piece of equipment or material and
organization, and no other information can be used in its place.

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.  

6.  Consequences to the Federal program if collection were conducted
less frequently.  

This information is collected only once for each item manufacturer,
testing, and servicing organization.  The records that are submitted or
retained are the minimum needed to identify the equipment and ensure
that it has been tested and serviced properly.  There is thus no way to
reduce this frequency.

For laboratory acceptance, where the information is also collected only
once, if the information is not collected the Coast Guard would be
unable to evaluate the qualifications and procedures of laboratories
desiring recognition to perform and/or oversee certain tests of approved
equipment on behalf of the Coast Guard.  

7.  Special collection circumstances.  

This information collection is conducted in manner consistent with the
guidelines in 5 CFR 1320.5(d)(2).

8.  Consultation.  

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

9.  Provide any payments or gifts to respondents.  

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

10.  Describe any assurance of confidentiality provided to respondents. 


All information collected complies with the Freedom of Information Act
(FOIA) and Privacy Act.  If a manufacturer considers certain information
proprietary (e.g., trade secret), the Coast Guard will follow the
exception permitted by FOIA (5 U.S.C. 552(b)(4)) and maintain
confidentiality.  

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

There are no questions of sensitive language.

12.  Estimate of annual hour and cost burdens to respondents.  

The estimated number of annual respondents is 958.  

The estimated number of annual responses is 711,461.  

The estimated hour burden is 118,594 hours.  

The estimated cost burden is $4,818,786.  

The burden to respondents is provided in Appendix B.  The wage rates
used are in accordance with the current edition of COMDTINST
7310.1(series) for “Out-Government” personnel.

a.  Approvals

i)  NEW APPLICATIONS:  We estimate that it will take a technical
specialist about 2 hours to prepare a new COA approval request. 
Additionally, we estimate that we will receive COA approval requests for
new equipment equivalent to 3% of the total valid COAs of all type
approved equipment.  The position of a technical specialist is analogous
to a GS-13.  

ii)  RENEWAL APPLICATIONS:  We estimate that it will take a technical
specialist about 0.5 hours to prepare a COA renewal request. 
Additionally, since a COA is generally valid for a 5-year period, we
estimate that each year will receive COA renewal requests for 20% of all
type approved equipment.  The position of a technical specialist is
analogous to a GS-13.  

iii)  MANUFACTURER RECORDKEEPING:  We estimate that annually it will
take a clerical specialist about 0.17 hours (10 min.) for each COA to
prepare and file the relevant documents, plans and test reports.  The
manufacturer usually retains these records as business records.  The
position of a clerical specialist is analogous to a GS-7.  

iv)  SERVICING FACILITY RECORDKEEPING:  We estimate that it will take a
clerical specialist about 2 hours annually to prepare and file servicing
facility records of lifesaving equipment.  The position of a clerical
specialist is analogous to a GS-7.  

v)  SERVICING FACILITY PROBLEM REPORTS:  We estimate that it will take a
technical specialist about 1 hour to prepare a lifesaving equipment
problem report.  We estimate that we will receive 1 problem report per
servicing facility per year.  The position of a technical specialist is
analogous to a GS-13.  

b.  Instructional Materials

i)  NEW EQUIPMENT:  We estimate that it will take a technical specialist
about 8 hours to draft the training or instructional material for Coast
Guard approval and to provide the material with the equipment. 
Additionally, we estimate that each year will receive new instructional
materials requests for 1.5% of all type approved equipment with
instructional materials.  The position of a technical specialist is
analogous to a GS-13.  Equipment approvals with this burden are shown in
the Appendix A (Column F).  

ii)  REVISIONS:  We estimate that it will take a technical specialist
about 2 hours to update (revise) the training or instructional material
for Coast Guard approval and to provide the material with the equipment.
 Additionally, since a COA is generally valid for a 5-year period, we
estimate that each year we will receive instructional materials revision
requests for 20% of all type approved equipment with instructional
materials.  The position of a technical specialist is analogous to a
GS-13.  Equipment approvals with this burden are shown in the Appendix A
(Column F).  

iii)  PACKING:  We estimate that it will take a workshop specialist
about 0.1 hours (6 min.) to produce and pack the instructional material
with each manufactured piece of type approved equipment.  We estimate
the number of annual responses as equal to 100% of all type approved
equipment with instructional materials times 200 units per type approved
equipment.  The position of a workshop specialist is analogous to a
GS-5.  

c.  Markings

i)  NEW:  We estimate that it will take a workshop specialist about 0.1
hours (6 min.) to stencil or stamp the required marking on each newly
approved piece of type approved equipment.  We estimate the number of
annual responses as equal to 2.5% of all type approved equipment that
require markings times 200 units per type approved equipment.  The
position of a workshop specialist is analogous to a GS-5.  

ii)  REVISIONS:  We estimate that it will take a workshop specialist
about 0.1 hours (6 min.) to stencil or stamp the required marking on
each manufactured piece of type approved equipment.  Additionally, since
a COA is generally valid for a 5-year period, we estimate the number of
annual responses as equal to 20% of all type approved equipment with
marking requirements times 200 units per type approved equipment.  The
position of a workshop specialist is analogous to a GS-5.  Equipment
approvals with this burden are shown in the Appendix A (Column G).  

d.  Production Tests and Laboratory Inspections

i)  PRODUCTION TEST RECORDS:  We estimate that it will take a clerical
specialist about 2 hours annually to prepare and file production test
records of equipment.  There is 1 report per equipment manufacturer. 
The position of a clerical specialist is analogous to a GS-7.  Equipment
approvals with this burden are shown in the Appendix A (Column H).  

ii)  LABORATORY INSPECTIONS:  We estimate that it will take a clerical
specialist about 24 hours annually to prepare and file laboratory
inspection quality control procedure records of equipment.  The position
of a clerical specialist is analogous to a GS-7.  Equipment approvals
with this burden are shown in the Appendix A (Column H).  We estimate
that all manufacturers of the approved pieces of equipment that are
required to maintain production test records also undergo lab
inspections.

e.  Independent and Recognized Laboratories. 

i)  INDEPENDENT LABORATORY APPLICATIONS:  We estimate that it will take
a technical specialist about 4 hours to prepare a new independent
laboratory application request.  We estimate that we will receive 2
applications per year.  The position of a technical specialist is
analogous to a GS-13.

ii)  RECOGNIZED LABORATORY MOU APPLICATIONS:  We estimate that it will
take a technical specialist about 80 hours to prepare an MOU
application.  We estimate that we will receive 0.1 MOU applications per
year (i.e., 1 per 10-year period).  The position of a technical
specialist is analogous to a GS-13.

iii)  RECOGNIZED LABORATORY MOU UPDATES:  We estimate that it will take
a technical specialist 15 hours to prepare an MOU update.  We estimate
that we will receive 1 MOU update per year.  The position of a technical
specialist is analogous to a GS-13.

13.  Total of annualized capital and start-up costs.  

There are no capital, start-up or maintenance costs associated with this
information collection.

14.  Estimates of annualized Federal Government costs.  

The estimated annual Federal Government cost is $914,738 (see Appendix
C).  The costs consist of processing applications for product approvals,
processing independent laboratory acceptances, filing lifesaving device
service records, lifesaving device manufacturers’ production test
monitoring, and lab application reviews.  The wage rates used are in
accordance with the current edition of COMDTINST 7310.1(series) for
“In-Government” personnel.  

i)  NEW EQUIPMENT APPLICATION REVIEWS:  We estimate that it takes a
technical specialist between 4 and 80 hours to review and process each
application (including instructional materials).  For calculation
purposes, we use 24 hours per application.  The position of a technical
specialist is analogous to a GS-14.  

ii)  RENEWAL EQUIPMENT APPLICATION REVIEWS:  We estimate that it takes a
technical specialist about 4 hours to review and process each renewal
application (including instructional materials).  The position of a
technical specialist is analogous to a GS-14.  

iii)  LIFESAVING DEVICE SERVICING RECORDS:  We estimate that it will
take a clerical specialist about 0.05 hours (3 min.) to prepare and file
each copy of a servicing report at the local Coast Guard Marine
Safety/Inspection Office.  The position of a clerical specialist is
analogous to a GS-12.  

iv)  SERVICING FACILITY PROBLEM REPORT REVIEWS:  We estimate that it
takes a field unit technical specialist about 0.5 to review a servicing
facility problem report.  The position of a field unit technical
specialist is analogous to a Lieutenant (LT; O-3).  

v)   PRODUCTION TESTS AND QUALITY CONTROL PROCEDURES MONITORING
(ONSITE):  We estimate that it takes about 1 staff year (2,000 hours)
for Coast Guard personnel to monitor the monitor production tests and
quality control procedures for certain manufacturers.  The 1-year
estimate for a LT is shared between several Coast Guard offices.  At the
present time, most production tests are monitored by independent
laboratories in lieu of Coast Guard personnel.  

vi)   PRODUCTION TESTS AND QUALITY CONTROL PROCEDURES MONITORING (VIA
INDEPENDENT LAB REPORTS):  We estimate that it takes a technical
specialist about 2 hours to review a production test report.  The
position of a technical specialist is analogous to a GS-14.  

vii)  INDEPENDENT LABORATORY APPLICATION REVIEWS:  We estimate that it
takes a technical specialist about 2.5 hours to review and process each
application.  The position of a technical specialist is analogous to a
GS-14.  

viii)  RECOGNIZED LABORATORY MOU APPLICATION REVIEWS:  We estimate that
it will take a technical specialist about 40 hours to review and process
each MOU.  Coast Guard engineering and legal specialists conduct the
review.  The position of a technical specialist is analogous to a GS-14.
 

ix)  RECOGNIZED LABORATORY MOU APPLICATION UPDATE REVIEWS:  We estimate
that it will take a technical specialist about 35 hours to review and
process each MOU update.  Coast Guard engineering and legal specialists
conduct the review.  The position of a technical specialist is analogous
to a GS-14.  

15.  Explain the reasons for the change in burden.  

The change (i.e., increase) in burden hours is an ADJUSTMENT due to an
increase in the estimated annual number of responses.  There is no
proposed change to the reporting or recordkeeping requirements of this
collection.  The reporting and recordkeeping requirements remain
unchanged.  The methodology for calculating responses and burden was
revised for Instructional Materials (Packing) and Marking (Revisions). 
The revision is needed to more fully account for the activity level.  

16.  Plans for tabulation, statistical analysis and publication.  

This information collection will not be published for statistical
purposes.

17.  Approval for not explaining the expiration date for OMB approval.  

The OMB expiration date will be displayed on the Instruction sheet
related to the information collection request.  

18.  Exception to the certification statement.  

The Coast Guard does not request an exception to the certification of
this information collection.

B.  Collection of Information Employing Statistical Methods  

This information collection does not employ statistical methods.

  Navigation and Vessel Inspection Circular (NVIC) 8-01 (Change 2) is
available at—   HYPERLINK
"http://www.uscg.mil/hq/cg5/nvic/pdf/2001/NVIC_8-01_CH-2.pdf" 
http://www.uscg.mil/hq/cg5/nvic/pdf/2001/NVIC_8-01_CH-2.pdf  .  

  International Convention for the Safety of Life at Sea (SOLAS) Chapter
V—Safety of Navigation.  

  To obtain a count of all type approved equipment, we use the CGMIX
database and include all type approved equipment listed as
“APPROVED”, “PENDING”, and “EXPIRED” (within the last 12
months).”  

1625-0035  

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