Supporting Statement

for

Audit Reports under the International Safety Management Code 

OMB No.:  1625-0084

COLLECTION INSTRUMENTS:  Instruction

A.  Justification

1)  Circumstances that make the collection of information necessary. 

The International Safety Management (ISM) Code applies to U.S. vessels
subject to the International Convention for the Safety of Life at Sea,
as amended (SOLAS 74/88).  It requires that U.S. shipping companies and
their vessels possess a Document of Compliance (DOC) and Safety
Management Certificates (SMC) respectively, as outlined in the ISM Code.
 Information showing the compliance status of U.S. vessels in
international trade must be provided to the Coast Guard by Recognized
Organizations.  Certain classification societies possess this
recognition under 46 CFR Part 2 and Part 8.  The statutory authority for
the requirement is in 46 U.S. Code 3203.  The regulations are in 33 CFR
Part 96.

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 & 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.  

Information describing companies’ and vessels’ compliance with the
ISM Code must be verified by the Coast Guard through an audit and its
corresponding report.  Information must be collected to determine the
compliance status of U.S. vessels, subject to SOLAS 74/88, engaged in
international trade.  Ongoing audits of vessels’ and companies’
safety management systems which impact the SMC and DOC status are
conducted by organizations recognized by the Coast Guard.  Authorized
classification societies perform audits of vessels and reports are
generated as the auditor inputs the relevant information into their
laptop.  These audit reports are later uploaded to the Societies’
databases and the information is made available for retrieval by the
Coast Guard.

Collecting the information ensures that vessels remain in substantial
compliance with the international conventions to  which the United
States is signatory and will not be delayed or detained while conducting
international commerce.  When visiting foreign ports, these certificates
attest that the vessel meets applicable requirements of Chapter IX of
SOLAS 74/88 to the satisfaction of the organization recognized by the
Coast Guard to issue ISM certificates.  Without compliance, American
flag ships could be detained  in foreign ports.  Unless sooner returned
or revoked, these certificates are valid for five years.  “Interim”
SMCs and DOCs are valid for six months and 12 months respectively. 
Interim certificates may be issued to companies/vessels that are new or
newly acquired.  Collection is necessary when the status of the
certificate changes. 

3)  Consideration of the use of improved information technology.  

The classification societies have implemented a system of reporting and
recordkeeping which is done electronically.  At this time we estimate
that 100% of the responses are collected electronically.  Classification
society auditors upload the information as they perform the audits.  For
example, online access to the audit reports performed by ABS is done by
logging onto the ABS website at http:// HYPERLINK "http://www.eagle.org"
www.eagle.org  and clicking on the link marked “My Eagle Login”. 
The electronic database which has been implemented, allows the Coast
Guard online access to classification societies’ reports and
recordkeeping.  Audit reports are not submitted directly to the Coast
Guard, rather uploaded to Societies’ internal databases.  These
reports are made available to the Coast Guard and are retrieved on a
periodic basis for review.

4)  Efforts to identify duplication.  

The Coast Guard established specific criteria for organizations to be
recognized to act on our behalf.  Close contact and continuous
communication with these organizations ensures that no duplication
occurs.

5)  Methods to minimize the burden to small business 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 current information, the possibility of vessels being delayed or
operating under unsafe conditions increases.

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. 


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)
Privacy Impact Assessment (PIA) and System of Records Notice (SORN). 
Links to the MISLE PIA and SORN 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.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   

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

There are no issues of a sensitive nature involved in this information
collection.  

12)  Estimates of annual hour and cost burdens to respondents.  

The estimated number of annual respondents is 390.  

The estimated number of annual responses is 3,204.  

The estimated hour burden is 10,221 hours.  

The estimated cost burden is $906,617.  

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

The reporting and recordkeeping burden will be imposed only on those
vessels required to comply with the ISM Code.  The specific
recordkeeping requirements in the ISM Code are an international
standard.  The regulations themselves prescribe no additional
recordkeeping on the companies or classification societies.  The
estimated reporting information was obtained from the MISLE database. 
The frequency of response varies since the requirements are based on
parameters established in individual safety management systems.  Also,
the complexity of the Safety Management System (SMS) is based on the
type and number of vessels operated.  

Companies must use classification societies to attain the required ISM
certificates.  Hence, the number of annual respondents is comprised of
the companies that own the vessels subject to the International
Convention for the Safety of Life at Sea, as amended (SOLAS 74/88), and
the classification societies that the Coast Guard recognizes to act on
our behalf.  

Each company and each vessel must have a SMS and should be internally
audited once a year to verify whether safety and pollution-prevention
activities comply with the SMS., These audits are reviewed by
appropriate management personnel to ensure the results of the audits are
brought to the attention of all personnel having responsibilities in the
involved areas and that timely corrective actions can be made.

Classification societies also perform verification audits on the
validity of a company’s DOC as well as a vessel’s SMC.  Company
verification audits are performed annually and vessels audits occur
twice in five years.  During the annual company audits, classification
societies process and update company SMS vessel audit reports.  

We estimate that it takes about 4 hours to document a SMS audit for a
company and 5 hours to document a SMS audit for a vessel and that the
tasks are done by a technical specialist.  The position of a technical
specialist is equivalent to a Lieutenant (O-3).  

We estimate that it takes 2 hours for a classification society to
process the vessel audit information and that the task is done by an
administrative specialist.  The position of an administrative specialist
is equivalent to an E-3.  

We estimate that it takes about 2 hours for a classification society to
verify the audit of a company or vessel and that the task is done by a
shore side specialist.  The position of a shore side specialist is
equivalent to an E-5.  

13)  Total 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 $96,876 (see Appendix
B).  We estimate that it takes about 2 hours to review a vessel SMS
audit and 1 hour per company SMS audit, a task typically performed by a
Lieutenant (O-3).  The wage rate used is in accordance with the current
edition of COMDTINST 7310.1(series) for “In-Government” personnel.

15)  Reasons for the change in burden.  

The change in burden is an ADJUSTMENT due to change (i.e., decrease) 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 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.

1625-0084

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