Supporting Statement

for

Declaration of Inspection Before Transfer

of Liquid Cargo in Bulk

OMB No.: 1625-0039

COLLECTION INSTRUMENTS:  Instruction 

A.  Justification

1.  Circumstances that make the collection of information necessary.  

Title 33 U.S.C. 1221 authorizes the Coast Guard to establish procedures,
methods, and equipment requirements to prevent the discharge of oil and
hazardous material from vessels and both onshore and offshore
facilities.  Title 33 U.S.C. 1225 and 46 U.S.C. 3703 authorized the
Coast Guard to establish procedures, methods, and equipment requirements
to prevent damage to vessels and facilities resulting from an
unauthorized discharge of oil or hazardous substances into the
environment.  The Declaration of Inspection (DOI) is required to ensure
safety during transfer of liquid cargo in 33 Code of Federal Regulations
(CFR) 156.150 and 46 CFR 35.35-30.  A Person-in-Charge (PIC) designated
under 33 CFR 154.710 and 155.700 completes the DOI for each bulk
transfer conducted.  A copy of the DOI must be kept on board the vessel
and facility for one month from the date of signature.  

Coast Guard personnel, under the direct supervision of the Captain of
the Port (COTP), conduct regulatory compliance inspections of vessels
and facilities that transfer oil and hazardous materials in bulk.  The
DOI is checked to ensure compliance and to determine culpability in
spill and accident investigations.

This information collection supports the following strategic goals:

Department of Homeland Security

Prevention

Protection

Coast Guard

Maritime Safety

Protection of Natural Resources

Prevention Policy & 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.  

As part of the Coast Guard’s Port Safety and Security Program, this
information is used in order to identify potential or actual violations
of the regulations.  The DOI must be completed for the U.S. to ensure
compliance with specific procedures to prevent pollution of U.S. waters
or damage to vessels and facilities.  If no records were kept, a PIC may
not know their responsibilities (in case of foreign nationals working on
foreign ships that transfer oil or hazardous materials in bulk in U.S.
ports) or they may not follow all of the proper procedures.  The result
would be a significant increase in the risk of pollution or damage. 
Also, it would be more difficult to ascertain culpability for accidents
and spills.

3.  Consideration of the use of improved technology.  

The DOI may be in written or electronic form.  We estimate that 0% of
DOI activities are done electronically.  

4.  Efforts to identify duplication.  

The Coast Guard monitors State and local regulatory activity in this
field.  No State, local, or other Federal agencies have been identified
that require equivalent information.  No similar information is
available.

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.  

Presently, a DOI is completed each time a bulk transfer is conducted and
is kept for one month following each transfer operation.  Reducing the
use of DOIs could be detrimental in determining the causal factor for
accidents and spills.  Also, there is the possibility of increased
pollution if proper prevention procedures are not followed.

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 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.  Estimates of annual hour and cost burdens to respondents.  

The annual number of respondents is 14,058.

The annual number of responses is 259,903.

The estimated annual hour burden is 77,973.

The estimated annual cost burden is $5,307,840.

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

Declaration of Inspection (DOI):  Each time a vessel conducts a transfer
of oil or other hazardous materials, a DOI must be completed and kept. 
Completing a DOI constitutes a response.  This requirement covers all
U.S. vessels and all non-U.S. flagged ships that carry oil and hazardous
materials in bulk.  We estimate the annual frequency of responses varies
by vessel type.  We estimate that it will take vessel personnel about
0.3 hours (18 minutes) to verify that the required procedures have been
followed and to sign the DOI.  For U.S. Tank Ships and Non-U.S. Vessels,
we estimate that the DOI will be completed by a Mate.  For U.S. Tank
Barges and U.S. Nontank Vessels, we estimate that the DOI will be
completed by a tankerman.  The position of a Mate is analogous to a
Lieutenant (O-3) and the position of a tankerman is equivalent to an
Ensign (O-1).  

13.   Estimates of 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 $76,440 (see Appendix
B).  Coast Guard personnel review DOIs during cargo transfer
monitorings, periodic inspections, random boardings, and post-casualty
investigations.  The number of reviews is about 20% of all annual DOIs. 
We estimate that it will take a CG petty officer (E-5) about 0.03 hours
(i.e., 1.5 minutes) per review.  The wage rate shown is in accordance
with the current edition of COMDTINST 7310.1(series) for
“In-Government” personnel.  

15.  Explain the reasons for the change in burden.  

The change in the 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 Coast Guard will display the expiration date for OMB approval of
this information collection.  

18.  Explain each 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. 

  The use of any electronic DOI system is at the discretion of an
owner/operator of the waterfront facility or vessel that engages in oil
or hazardous materials transfers.  

  The time estimate (i.e., 18 minutes) to complete a DOI reflects both
the vessel and facility time.  

OMB 2115-0506		  DATE \@ "MM/dd/yy"  09/14/15 

1625-0039  

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