Supporting Statement

for

Course Approval and Records for Merchant Mariner Training Schools

OMB No.:  1625-0028

COLLECTION INSTRUMENTS:  Instruction

A.  Justification  

1)  Circumstances that make the collection of information necessary.  

Title 46 United States Code (U.S.C.) 2103 authorizes the Secretary
(under which the Coast Guard is operating) to prescribe regulations to
carry out the provisions of Subtitle II regarding Vessels and Seamen,
including the interests of marine safety and seamen’s welfare.  Title
46 U.S.C. 2104 provides that the Secretary may delegate such duties to
any officer, employee, or member of the Coast Guard, which would include
National Maritime Center (NMC) personnel.  Additionally, 46 U.S.C. 7315
authorizes a license or document applicant to substitute the completion
of an approved course for a portion of the required sea service.  Title
46 Code of Federal Regulations (CFR) 10.402 specifies the information
that must be submitted for the Coast Guard to evaluate and approve each
course.  Title 46 CFR 10.403 specifies recordkeeping requirements that a
school teaching approved courses must meet for each student taking each
course.  The Coast Guard is obligation under the STCW Convention to
validate the training received by merchant mariners and to ensure that
the approved training is part of a Quality Standards System (QSS).

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.  

On a daily basis, NMC personnel review submitted information to ensure
training courses and programs meet minimum standards for Coast Guard
approval.  Members of the public, including U.S. merchant mariners,
attend approved courses to meet regulatory requirements or to enhance
their ability to perform their jobs.  The agency uses the information to
enforce regulations, and to compare existing courses with new
international standards for specific training.  

The recordkeeping requirements helps the Coast Guard monitor the
performance of schools with approved courses.  

3)  Consideration of the use of improved technology.  

Information is submitted in writing or electronically via e-mail to 
HYPERLINK "mailto:D05-PF-NMC-2-Courses@uscg.mil"
D05-PF-NMC-2-Courses@uscg.mil  or online at  HYPERLINK
"http://www.uscg.mil/nmc/training/audit/mtad.asp"
http://www.uscg.mil/nmc/training/audit/mtad.asp .  For guidance on
submissions, see Coast Guard Navigation and Vessel Inspection Circular
(NVIC)   HYPERLINK
"https://www.uscg.mil/hq/cg5/nvic/pdf/2014/nvic-03-14_Course_Approval_Fi
nal_with_encls_20140122.pdf"  03-14 .  We estimate that 100% of the
reporting and recordkeeping requirements can be done electronically.  At
this time, we estimate that 50% of the responses are collected
electronically.  

4)  Efforts to identify duplication.  

Similar data in this field is not available.  The Coast Guard is the
only agency collecting this information for use as described in the
answer to item 2 above.

5)  Methods to minimize the burden to small entities if involved.  

In general, both the reporting and recordkeeping burden is proportional
to the number of courses that a school submits for approval.  Thus,
small businesses that offer only a few courses would have a reduced
burden.  Additionally, there is no application fee for respondents and
direct communication between applicants and the Coast Guard is
encouraged.  Finally, all training schools seeking approval of courses
must follow the same procedures.

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

The Coast Guard’s ability to evaluate training received by mariners as
an equivalent to service experience will be reduced. This may lead to
less-qualified mariners and a corresponding increase in maritime
accidents.

7)  Special collection circumstances.  

This information collection is conducted in a 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.  This information collection request is
covered by the Marine Information for Safety and Law Enforcement (MISLE)
and Merchant Mariner Licensing and Documentation System Privacy Impact
Assessments (PIAs) and the MISLE and Merchant Seamen’s Records System
of Records Notices (SORNs).  Links to the aforementioned PIAs and SORNs
are provided below:

  HYPERLINK
"https://www.dhs.gov/sites/default/files/publications/privacy_pia_uscg_m
isle.pdf" 
https://www.dhs.gov/sites/default/files/publications/privacy_pia_uscg_mi
sle.pdf   

   HYPERLINK
"https://www.dhs.gov/publication/dhsuscgpia-015-merchant-mariner-licensi
ng-and-documentation-system" 
https://www.dhs.gov/publication/dhsuscgpia-015-merchant-mariner-licensin
g-and-documentation-system   

  HYPERLINK
"https://www.gpo.gov/fdsys/pkg/FR-2009-06-25/html/E9-14906.htm" 
https://www.gpo.gov/fdsys/pkg/FR-2009-06-25/html/E9-14906.htm   

  HYPERLINK
"https://www.gpo.gov/fdsys/pkg/FR-2009-06-25/html/E9-14911.htm" 
https://www.gpo.gov/fdsys/pkg/FR-2009-06-25/html/E9-14911.htm   

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 number of respondents is 324.

The estimated annual number of responses is 3,633.

The estimated annual hour burden is 139,807 hours.

The estimated annual cost burden is $7,256,951.

The burden to respondents is provided in Appendix A.  Respondents are
training providers (some, but not all, offer STCW-related course).  All
wage rates used are in accordance with the current edition of COMDTINST
7310.1(series) for “Out-Government” personnel.  

We estimate that it takes 31 hours per course approval submission and
that a submission is done by a technical specialist.  The position of a
technical specialist is equivalent to a GS-13.  

We estimate that it takes 40 hours per approved course for student
recordkeeping and that a submission is done by an administrative
specialist.  The position of an administrative specialist is equivalent
to 

a GS-9.  

We estimate that it takes 206 hours to develop a new STCW QSS Manual and
complete the associated recordkeeping and that the work is done by a
technical specialist.  The position of a technical specialist is
equivalent to a GS-13.  Additionally, we estimate that annually will
receive new QSS Manuals from about 5% of the total number of STCW
training schools.  

We estimate that it takes 9 hours to annual review an STCW QSS Manual
and complete the associated recordkeeping and that the work is done by a
technical specialist.  The position of a technical specialist is
equivalent to a GS-13.  

We estimate that it takes 10 hours to conduct an internal audit of the
STCW QSS and complete the associated recordkeeping and that the work is
done by a technical specialist.  The position of a technical specialist
is equivalent to a GS-13.  Audits are done twice in a 5-year period
(i.e., 40% of the total STCW training schools annually).  

13)  Estimate of annualized capital and start-up costs.  

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

14)  Estimate of annualized Federal Government costs.  

The annualized Federal Government cost estimate is $871,000 (see
Appendix B).  We estimate that is takes a member of a CG Regional
Examination Center about 2 hours to conduct a course review (& if
needed, a site visit write-up).  We estimate that is takes a member of
the CG NMC about 10 hours to conduct a course (& site visit) evaluation
and another 1 hour to complete a course approval determination.  All
Coast Guard activities are done by a GS-13.  

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 reporting and recordkeeping requirements of this
collection.  The reporting and 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)  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.

  International Convention on Standards of Training, Certification and
Watchkeeping for Seafarers.  

  Estimated by 12 classes/course, 20 students/class, and 10 min (0.1667
hrs) burden/student record.  

1625-0028

  PAGE  3  of   NUMPAGES  4 

