Supporting Statement

for

Various International Agreement Pollution Prevention 

Certificates and Documents, and Equivalency Certificates

OMB No.:  1625-0041

COLLECTION INSTRUMENTS:  CG-5352, CG-5352A, CG-5352B, CG-6047, CG-6047A,
CG-6056, CG-6056A, CG-6056B, CG-6056C, CG-6057, CG-6059, CG-6059A,
CG-6060, CG-6060A & Instruction

A.  Justification  

1.  Circumstances that make the collection of information necessary.  

Title 33 U.S.C. 1901-1911 requires implementation of the International
Convention for the Prevention of Pollution from Ships 1973, as modified
by the Protocol of 1978 (MARPOL 73/78).  The United States Coast Guard
is delegated the authority to implement the requirements of MARPOL.  The
requirement to possess an international certificate is mandated by the
Act to Prevent Pollution from Ships 1980 (Pub. L. 96-478; 33 U.S.C.
1901-1911). Additionally, the Coast Guard has the authority to issue
Flag State documents to prove equivalent compliance with MARPOL 73/78. 
The Coast Guard is also authorized to administer/enforce the
International Convention on the Control of Harmful Anti-Fouling Systems
on Ships (2001) (IAFS Conv) (Pub. L. 111-281, Title X).  

–MARPOL Certificates and other related MARPOL requirements are listed
below:

a) IOPP Certificates and supplements (33 CFR 151.19) (forms CG-5352,
CG-5352A & 

CG-5352B)  

Each U.S. oil tanker of 150 gross tons and above and each other U.S.
ship of 400 gross tons and above; that engages on international voyages
to ports or off-shore terminals under the jurisdiction of other parties
to MARPOL 73/78.

b) Evidence required for ships not party to MARPOL 73/78 (33 CFR 151.21)

All oil tankers of 150 gross tons and above and all ships of 400 gross
tons and above.

c) Retain discharge data recorded by a cargo monitor (33 CFR 157.37(d))

All tank vessels 150 gross tons or more carrying oil in bulk.

d) Statement of Voluntary Compliance (International Maritime
Organization resolutions MEPC.94(46) & MEPC.111(50)) (form CG-6057)  

Each U.S. single hull tank vessels 15 years old and older. 

e) International Air Pollution Prevention (IAPP) Certificates and
International Energy Efficiency (IEE) Certificates (MARPOL 73/78 Annex
VI) (forms CG-6056, CG-6056A, CG-6056B, 

CG-6056C, CG-6060 & CG-6060A)

Each U.S. ship of 400 gross tons and above; that engages on
international voyages to ports or off-shore terminals under the
jurisdiction of other parties to MARPOL 73/78.

-IAFS Conv Certificates:

f) International Anti-Fouling Systems (IAFS) Certificates (IAFS Conv)
(forms CG-6059 &

CG-6059A)  

Each U.S. ship of 400 gross tons and above; that engages on
international voyages.

–Flag State documents: 

g) Equivalency Certificate for MARPOL 73/78 (Revised) Annex IV (Sewage)
International Convention for the Prevention of Pollution from Ships (33
CFR 159) (forms CG-6047 & 

CG-6047A)

Annex IV applies to all new vessels built on or after September 27,
2003, which are 400 gross tons International Tonnage Convention (ITC),
and above. The Annex also applies to new vessels less than 400 gross
tons (ITC), which are certified to carry more than 15 passengers. 
Existing vessels 400 gross tons (ITC) and above and those existing
vessels less than 400 GT (ITC) which are certified to carry more than 15
passengers need not comply until September 27, 2008.  Existing federal
regulations concerning sewage are outlined in 33 CFR 159 under
‘Marine Sanitation Devices.’  

h)  Ship-to-Ship (STS) Operations for MARPOL 73/78 (Annex I, Regs 40 &
41)

Each oil tanker and tank barge of 150 gross tons and above, that engages
in transfers of oil at sea.  

a) IOPP Certificates and supplements.  All ships engaged in
international voyages are required to comply with IOPP certificate
requirements.  Due to the complex requirements of MARPOL 73/78 and the
language difficulties associated with international trade, a uniform
certificate listing vital information about the ship’s characteristics
in a standard form is necessary.  The format of the certificate was
agreed upon by the United States and other signatories to MARPOL 73/78. 
The IOPP Certificate is valid for a period of 5 years from the date of
issue.

The IOPP certificates serve the necessary function of providing, in
standard format and language, for ships of various countries, all the
information needed by an inspecting official to efficiently determine
whether a ship is in compliance with the requirements of MARPOL 73/78.

b) Evidence required for ships not party to MARPOL 73/78.  This
implements Article 5(4) of MARPOL 73/78, and is intended to prevent a
ship from obtaining more favorable treatment due to its non-party
status.  Such ships will be required to have surveys conducted and valid
documentation that the ship is in compliance with MARPOL 73/78.

c) Retain discharge data recorded by a cargo monitor.  The installation
and use of cargo monitor and control systems on tank vessels that are
150 gross tons or more is required by 33 CFR 157.  Each tank vessel must
retain the printout of discharge data from that system for at least
three years.

d) Statement of Voluntary Compliance.  In order to satisfy signatory
port states, owners of single hull tankers 15 years old and older may
voluntarily comply with the Condition Assessment Scheme outlined in
International Maritime Organization (IMO) resolution MEPC.94(46).  The
format of the certificate was agreed upon by IMO and other signatory
nations the revised to MARPOL 73/78 regulations 13G and 13H.  The
Statement of Voluntary Compliance is valid for a period of not more than
5 years from the date of issue.  The Certificate may never be valid
beyond a single hull tanker’s phase-out date required by the Oil
Pollution Act of 1990.

e) IAPP and IEE Certificates. All ships engaged in international voyages
are required to comply with IAPP & IEE certificate requirements.  Due to
the complex requirements of MARPOL 73/78 and the language difficulties
associated with international trade, a uniform certificate listing vital
information about the ship’s characteristics in a standard form is
necessary.  The format of the certificate was agreed upon by the United
States and other signatories to MARPOL 73/78.  The IAPP Certificate is
valid for a period of 5 years from the date of issue.  The IEE
Certificate is issued without expiration date.  

f) IAFS Certificates.  Each U.S. ship of 400 gross tons and above; that
engages on international voyages must demonstrate compliance with the
IAFS Convention.  The IAFS Certificate is valid until the anti-fouling
system is changed or replaced, or upon transfer of the ship to the flag
of another country.  

g) Flag State document for MARPOL 73/78 Annex IV (Sewage).  Since MARPOL
73/78 Annex IV has not been ratified by the United States, and U.S.
flagged vessels on international voyages sailing in the waters of
countries that have adopted MARPOL 73/78 Annex IV will be subjected to
Port State control boardings, these vessels will need to demonstrate
equivalent compliance through the Flag State documents issued by the US
Coast Guard.  

h) STS Operations (Transfer of Oil Cargo between Oil Tankers at Sea)
(MARPOL 73/78 Annex I, Regs 40 & 41).

Each oil tanker and tank barge of 150 gross tons and above, that engage
in transfers of oil at sea, and that engage in an STS oil-transfer
operation is required to carry and follow an “STS Operations Plan,”
based on the International Maritime Organization (IMO) Manual on Oil
Pollution, Section 1: Prevention. Regulation 41 also requires that the
person in charge of STS Operations be qualified to perform all relevant
duties, and that records of STS Operations be retained on board for 3
years.  

This information collection supports the following strategic goals:

Department of Homeland Security

Prevention

Protection

Coast Guard

Maritime Safety

Protection of the Natural Resources

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) and b) This data is used by Coast Guard inspectors to prepare for
inspections requested by ship owners or operators and to issue an IOPP
Certificate in a minimum amount of time.  The IOPP Certificate makes
possible the efficient and effective enforcement of MARPOL 73/78, saving
both the government and the ship owner/operator time and expense. 
Without a standard IOPP Certificate, the routine inspection of a ship
upon entry to a port would be extremely burdensome and time consuming
for both the government inspector and ship operator.  The potential
delay represents a significant expense to the ship owner due to lost
time for the ship to transfer cargo.

c) This recordkeeping requirement stems directly from the requirements
of Regulation 15(3)(a) of Annex I of MARPOL 73/78 that each vessel
retain the printout of cargo monitor discharge data from the recording
device (part of the control system for three years.)  This requirement
has been incorporated in 33 CFR 157.37(d).  These printouts verify the
vessel’s compliance with oil discharge standards.  There is no
requirement that these printouts be submitted to any agency.

In the event of an oil discharge this information will be used to verify
if the vessel causing the discharge violated the oil discharge limits of
MARPOL 73/78.  If the vessel did not, it could be used by the vessel
operator as mitigating evidence regardless of the presence of visible
traces of oil.  This would not be possible if this information was not
available.  However, this information is not required to be submitted to
an agency, merely retained by the vessel and/or ashore for 3-years.  In
addition, this is a specific requirement of MARPOL 73/78, to which the
United States is party, and under the terms of this treaty, must be
implemented.  

d) MARPOL 73/78 Annex I Regulations 13G and 13H have not been ratified
by the U.S. Senate, however, certain U.S. flag vessels may be required
by signatory nations to prove compliance with those provisions through
Flag State documents.  In order to satisfy signatory port states, owners
of single hull tankers 15 years old and older may voluntarily comply
with the Condition Assessment Scheme outlined in International Maritime
Organization resolution MEPC.94(46).  

e) This data is used by Coast Guard inspectors to prepare for
inspections requested by ship owners or operators and to issue an IAPP
or IEE Certificate in a minimum amount of time.  The Certificates makes
possible the efficient and effective enforcement of MARPOL 73/78, saving
both the government and the ship owners and operator’s time and
expense.  Without standard Certificates, the routine inspection of a
ship upon entry to a port would be extremely burdensome and time
consuming for both the government inspector and ship operator.  The
potential delay represents a significant expense to the ship owner due
to lost time for the ship to transfer cargo.  MARPOL 73/78, Annex VI
entered into force for the U.S. on January 8, 2009.  

f) This data is used by Coast Guard inspectors to prepare for
inspections requested by ship owners or operators and to issue an IAFP
Certificate in a minimum amount of time.  The IAFS Certificate makes
possible the efficient and effective enforcement of IAFS Convention,
saving both the government and the ship owner/operator time and expense.
 Without a standard IAFS Certificate, the routine inspection of a ship
upon entry to a port would be extremely burdensome and time consuming
for both the government inspector and ship operator.  The potential
delay represents a significant expense to the ship owner due to lost
time for the ship to transfer cargo.

g) Since MARPOL 73/78 Annex IV has not been ratified by the United
States, and U.S. flagged vessels on international voyages sailing in the
waters of countries that have adopted MARPOL 73/78 Annex IV will be
subjected to Port State control boardings, these vessels will need to
demonstrate equivalent compliance through the Flag State
documents--Certificates of Equivalency or Statements of Voluntary
Compliance—issued by the US Coast Guard.  

h) This data is used to ensure compliance with the STS Operation
requirements, including the development and periodic review of STS
Operations Plan, and retention of records are required by the Plan.  

3.  Considerations of the use of improved technology.  

Information is not submitted to the Coast Guard.  Upon successful
completion of an inspection, the CG will issue the appropriate
Certificate(s).  The Certificate(s) should be posted on the vessel.  For
oil tanker discharge monitoring and control systems, per Resolution
MEPC.108(49) dated 18 July 2003, monitoring and control system data may
be recorded and stored electronically (paragraphs 6.9.1 & 6.9.3).  This
information is not sent to the Coast Guard, rather it is made available
upon inspection.  We estimate that 50% of all recordkeeping is done
electronically.  

4.  Efforts to identify duplication.  

The Coast Guard is the only agency, Federal, State or private that
requires this information collection and that administers these MARPOL
73/78 requirements on commercial vessels.  The regulations allow foreign
vessels to show compliance through an IOPP Certificate, or an
Equivalency Certificate, rather than directly submitting information to
the Coast Guard.  This avoids duplication on an international level.

5.  Methods used to minimize the burdens to small entities 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.  

Without these international Certificates and Statements of Voluntary
Compliance, a ship could encounter severe international trade
restrictions and delays.  Most certificates are reissued every 5 years. 
Without the cargo monitor discharge data, engine fuel and exhaust
emissions data, or the Certificate of Equivalency for MARPOL 73/78 Annex
IV (Sewage), it would not be possible to confirm that the ship is
operating in compliance with U.S. regulations and/or international
pollution prevention-related treaties. 

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 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. 


There are no assurances of confidentiality provided to the respondents
for this information collection.

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 annual respondents are 1,566.

The estimated annual responses are 11,527.

The estimated annual burden hours are 73,900.

The estimated annual cost is $3,026,953.

The burden to respondents is provided in Appendix A.  Table 2, available
at the end of these calculations in this section, provides a summary of
all the different components involved in this collection of information
with the grand totals. 

a) IOPP Certificates and supplements.

The total number of U.S. vessels affected by the IOPP Certificate
requirements is estimated to be 1,556 (1,044 Nontank Vessels + 461 Tank
Barges + 51 Tank Ships as shown in Table 1).  This figure was obtained
from the U.S. Coast Guard Marine Information for Safety and Law
Enforcement database (MISLE).  The required posting of an IOPP
Certificate and supplement take approximately twenty minutes (0.33
hours) per ship.  The IOPP Certificate will be issued once every five
years.  Approximately 1,556 vessels are required to have an IOPP
Certificate.  The total number of annual responses is estimated to be
311 (rounding 1,556 ships / 5 years).  The total estimated annual burden
on the public is 103 hours (rounding up 311 x 0.33 hours/ship).  Total
cost to the public is estimated to be $6,283 per year (103 hours/year x
$61 hour).

b) Evidence required for ships not party to MARPOL 73/78.

The Coast Guard does not maintain the data required to calculate burden
on foreign-flagged vessels trading in U.S. waters that are not signatory
to MARPOL 73/73.  We have historically estimated this population to be
approximately 10.  The presentation and compilation of the required
information needed is expected to take approximately twenty hours per
ship.  The total estimated annual burden on the public is 200 hours (10
ships x 20 hours/ship).  Total cost is estimated to be $12,200 per year
(200 hours/year x $61 hour).

c) Retain discharge data recorded by a cargo monitor.

There are approximately 512 tank vessels in the U.S. fleet that are
required to keep records of cargo monitor discharge data (461 Tank
Barges + 51 Tank Ships).  To estimate the annual burden the following
assumptions are made:

each vessel operates for 350 days a year; 

a ballast discharge is made every 20 days, making approximately 17
discharges per year; 

recordkeeping takes ¼ hour per ballast discharge; and . 

a person with an equivalent wage to a GS-11 would be in charge of
keeping the record, receiving an hourly salary of $61. 

The total number of annual responses is estimated to be 8,704 (rounding
512 ships * 17 discharges per year).  The total estimated annual burden
on the public is 2,176 hours (rounding up 8,704 x 0.25 hours/ship). 
Total cost to the public is estimated to be $132,736 per year (2,176
hours/year x $61 hour).

d) Statement of Voluntary Compliance.  

The total number of U.S. vessels affected by the Statement of Voluntary
Compliance (SVC) is estimated to be 0 (0 Tank Barges + 0 Tank Ships). 
This figure was obtained from the data available from the MISLE
database.  The completion of the SVC is estimated to take approximately
thirty minutes (0.17 hours) per vessel.  The SVC lasts for five years
and approximately 0 vessels are applicable for the program.  The total
number of annual responses is estimated to be 0 (0 ships /0 years).  The
total estimated annual burden on the public is 0.00 hours (0 x
0.17hours/ship).  Total cost to the public is estimated to be $0 per
year (0.00 hours/year x $61 hour).

e) IAPP & IEE Certificates.

The total number of U.S. vessels affected by the IAPP & IEE Certificate
requirements is estimated to be 1,556 (1,044 Nontank Vessels + 461 Tank
Barges + 51 Tank Ships as shown in Table 1).  This figure was obtained
from the MISLE database.  The required posting of a Certificate takes
approximately ten minutes (0.17 hours) per ship.  An IAPP Certificate is
issued once every five years.  

Approximately 311 vessels (1,556/5) will receive an IAPP Certificate
annually.  The total estimated annual burden on the public is 53 hours
(311 x 0.17 hours/ship (rounded)).  Total cost to the public is
estimated to be $3,233 per year (53 hours/year x $61/ hour).

f) IAFS Certificates.  

The total number of U.S. vessels affected by the IAFS Certificate
requirements is estimated to be 0 at this time.  The total number of
annual responses is estimated to be 0 (0 ships /0 years).  The total
estimated annual burden on the public is 0.00 hours (0 x 0.17
hours/ship).  Total cost to the public is estimated to be $0 per year
(0.00 hours/year x $61 hour).

g) Flag State documents (Certificates of Equivalency) for MARPOL 73/78
Annex IV (Sewage).

The Coast Guard estimates that the 1,556 vessels are candidates for the
Certificate of Equivalency.  We also assume that only 75% of the
eligible vessels will apply for the certificate.  Approximately 1,556
vessels will have 1,167 responses (1,556 vessels *75%).  We assume that
it takes 10 minutes to post the Certificate of Equivalency, and that
someone of rank equivalent to O-4 posts the document, and the equivalent
wage rate for this is $104/hour.  The estimated annual burden for
posting the Certificate of Equivalency is 200 hours and the cost is
$20,800.  See Appendix A, table 2 for details. 

h)(1) Initial STS Operations Plan preparation

The Coast Guard estimates that there are 512 oil tankers and tank barges
of 150 gross tons and above, that engage in transfers of oil at sea, and
that engage in an STS oil-transfer operation.  We assume that it takes
135 hours to prepare an initial STS Operations Plan per vessel and
assume that training and development specialists will prepare the STS
Operations Plan at the rate of $40.07.  The estimated one-year burden
for the STS Operations Plan is 69,120 hours.  The total cost to the
public is estimated to be $2,769,638 for one year (69,120 hours/year x
$40.07 hour).

h)(2) Recurring STS Operations Plan update

The Coast Guard estimates that there are 512 oil tankers and tank barges
of 150 gross tons and above, that engage in transfers of oil at sea, and
that engage in an STS oil-transfer operation.  We assume that it takes 4
hours to prepare an annual recurring STS Operations Plan update per
vessel and assume that specialists will prepare the STS Operations Plan
at the rate of $40.07.  The estimated one-year burden for the STS
Operations Plan update is 2,048 hours.  The total cost to the public is
estimated to be $82,063 per year (2,048 hours/year x $40.07 hour).

13.  Estimate of annual 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 annualized Federal Government cost estimate is $126,398. This cost
is comprised of 2 elements.  

a) International treaty Certificates

It takes the Coast Guard an average of 2.0 hours to complete each
Certificate.  We assume a GS-13 is involved with the issuance of the
forms, at an hourly rate of $85.  For the Statement of Voluntary
Compliance, it takes approximately 30 minutes for the Coast Guard to
review the form.  Regarding cargo monitor discharge records, we assume
no specific costs are associated with them, as these records would be
examined in the general course of a Coast Guard inspection or
investigation.  The total cost of this element is $105,740.

b) Issuing Flag State documents

These documents are generally completed by someone of a rank equivalent
to W-3, and the applicable government wage rate is $106/hour.  We
estimate that it takes about 10 minutes a document, and since the total
number of applications is 1,167 the total cost to the government is
$20,658 [$106 * 0.167 * 1,167]. 

15.  Explain the reasons for the change in burden.  

The change in burden is an ADJUSTMENT due to a change (i.e., increase)
in the estimated annual number of responses.  There is no proposed
change to the recordkeeping requirements of this collection.  The
recordkeeping requirements, and the methodology for calculating burden,
remain unchanged.  

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 certificates associated with this collection are prescribed by an
international treaty (e.g., MARPOL) that the U.S. Government is
signatory to.  These certificates either have specific five year
expiration dates related to requirements set out in treaty, or are valid
indefinitely.  The addition of an expiration date to these
certificates—that for OMB approval—may cause several problems. 
First, it may cause U.S.-flag vessel owner/operators to interact with
the Coast Guard more frequently than required to reconcile the existence
of up to 2 expirations dates on their ships’ certificates.  Second, it
may cause confusion with foreign Port Sate Control boarding officers,
resulting in U.S.-flag ships being delayed or detained in foreign ports
due to up to 2 differing expiration dates.  It is for these reasons that
expiration dates for OMB approval are not displayed on the certificates
associated with this collection.  However, the OMB expiration date is
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.  

Appendix A

TABLE 1.  Vessels with Int’l treaty Certificates

(Carry oil and are greater than 150 gt., and all other ships greater
than 400 gt.)

Types of Vessels

	Nontank Vessels

	Freight Barge	189

Freight Ship	229

MODU	47

Oil Recovery	46

Towing Vessel	34

Industrial Vessel	93

OSV	268

Research Vessel	16

School Ship	4

Passenger Inspected.	118

Tank Vessels

	Tank Barge	461

Tank Ship	51

Ships – TOTAL 	1,556



Table 2. Summary of the Requirements for COI 1625-0041

Requirement	Annual Respondents	Annual Responses	Annual Burden Hours	Wage
Rate	Annual Costs

a) IOPP Certificates and supplements	1,556	311	103	$61 	$6,283 

b) Evidence required for ships not party to MARPOL 73/78	10	10	200	$61 
$12,200 

c) Retain discharge data recorded by a cargo monitor	512*	8,704	2,176
$61	$132,736 

d) Statement of Voluntary Compliance 	0*	0	0	$61	$0 

e) IAPP & IEE Certificates	311*	311                              	53	$61
$3,233 

f) IAFS Certificates	0*	0                                 	0	$61	$0 

g) Flag State documents (Certificates of Equivalency)	1,167*	1,167      
                         	200	$104	$20,800 

h(1)) Initial STS Operations Plan preparation	512*	                     
  512 	                        69,120 	$40.07	$2,769,638 

h(2)) Recurring  STS Operations Plan update	512*	                       
       512 	                               2,048 	$40.07	$82,063 

TOTAL	1,566	11,527	73,900	 	$3,026,953 

NOTE—These respondents are the same as, or a subset of, the
respondents listed in row (a).  

Table 3 Estimate of Annual Burden for Vessels that Retain Cargo Monitor
Discharge Data

 	 	Annual Discharges	Hour Burden	Cost Burden

Type of Vessel	Number of Vessels	(17 per vessel)	(0.25 hrs. per
discharge)	($61 per hr.)

Tank Barges	461	7,837	1,959	$119,499 

Tank Ships	51	867	217	$13,237 

Total*	512	8,704 	2,176 	$132,736 

*NOTES—Figures may be rounded

                  The totals from this Table are shown in Table 2 row
(c).  

Table 4 Estimate of Annual Burden for Vessels with the 

Certificate of Equivalency for MARPOL 73/78 Annex IV (Sewage)

Types of vessels that are candidates for Flag State documents	Number of
vessels in each category	Annual burden hours (assuming 10 minutes –
0.17 hours – to post the document)	Cost of burden hours (wage rate
$104/hour) 

Freight Ship	229	39	$4,056 

Towing Vessel	34	6	$624 

Tank Ship	51	9	$936 

Passenger Inspected	118	20	$2,080 

Industrial Vessel	93	16	$1,664 

Freight Barge	189	32	$3,328 

MODU	47	8	$832 

OSV	268	46	$4,784 

Research Vessel	16	3	$312 

School Ship	4	1	$104 

Tank Barge	461	78	$8,112 

Oil Recovery	46	8	$832 

Total*	1,556 	266	$27,664 



About 75% will actually apply for the Certificate of Equivalency *

	

1,167 	

200	

$20,800 

*NOTES—Figures may be rounded.  



                  The totals from this Table are shown in Table 2 row
(g).  

Table 5 Hour Burden per Vessel – Initial STS Operations Plan
preparation

Procedures	Hours per procedure	Hourly Cost	Total Cost

General requirements	12	$40.07	$480.84

Step-by-step description of the entire STS Operation	12	$40.07	$480.84

A description of the mooring and unmooring procedures and arrangements,
including diagrams where necessary, and procedures for tending the oil
tankers' moorings during the transfer of cargo;	12	$40.07	$480.84

A description of the cargo and ballast transfer procedures, including
those used while underway or anchored and procedures for connecting and
testing integrity of cargo hoses and hose to manifold interface, topping
off cargo tanks and disconnecting cargo hoses	12	$40.07	$480.84

The titles, locations and duties of all persons involved in the STS
operation;	12	$40.07	$480.84

Procedures for operating the emergency shut-down and communication
systems and for rapid breakaway;	12	$40.07	$480.84

A description of the drip trays and procedures for emptying them	12
$40.07	$480.84

Procedures for reporting spillages of oil into the water;	12	$40.07
$480.84

An approved contingency plan which meets the requirements of 6.2.9; and
12	$40.07	$480.84

A cargo and ballast plan	12	$40.07	$480.84

Records retention: records of STS operations shall be retained on board
for three years and be readily available for inspection	3	$40.07	$120.21

An approved contingency plan which meets the requirements of 6.2.9; and
12	$40.07	$480.84

Burden per Vessel	135 	 	$5,409.45











Total Burden for 512 Vessels 

(respondents & responses)	69,120

$2,769,638



NOTE—The totals from this Table are shown in Table 2 row (h)(1).  

  See Enclosure (2) to COMDTINST 7310.1N (equivalent to the GS-11
out-of-govt. rate).

  See Enclosure (2) to COMDTINST 7310.1N (equivalent to the GS-11
out-of-govt. rate).

  See Enclosure (2) to COMDTINST 7310.1N (equivalent to the GS-11
out-of-govt. rate).

  See Enclosure (2) to COMDTINST 7310.1N (equivalent to the GS-11
out-of-govt. rate).

  See Enclosure (2) to COMDTINST 7310.1N (equivalent to the GS-11
out-of-govt. rate).

  See Enclosure (2) to COMDTINST 7310.1N (equivalent to the GS-11
out-of-govt. rate).

  See Enclosure (2) to COMDTINST 7310.1N (equivalent to the GS-11
out-of-govt. rate).

  See Enclosure (2) to COMDTINST 7310.1M (equivalent to the O-4
out-of-govt. rate). 

    HYPERLINK "http://www.bls.gov/oes/2012/may/oes131151.htm" 
http://www.bls.gov/oes/2012/may/oes131151.htm  median wage rate is used
* 1.49 loaded wage rate. 

    HYPERLINK "http://www.bls.gov/oes/2012/may/oes131151.htm" 
http://www.bls.gov/oes/2012/may/oes131151.htm  median wage rate is used
* 1.49 loaded wage rate. 

1625-0041

  PAGE  11  of   NUMPAGES  11 

