Report - The Coast Guard’s Need for Experienced Marine Safety Personnel

Full report here (pdf) The Coast Guard’s Need for Experienced Marine Safety Personnel

September 19, 2019


For at least four decades, Congress has been concerned about the Coast Guard’s ability to maintain an adequate staff of experienced marine safety personnel to ensure that vessels meet federal safety standards. The 2015 sinking of the U.S.-flag cargo ship El Faro during a hurricane near the Bahamas with the loss of 33 lives renewed attention to the Coast Guard’s persistent difficulty with hiring and training a marine safety workforce with technical knowledge of vessel construction and accident investigation, as the safety inspections of the vessel were found to have been inadequate. In the Hamm Alert Maritime Safety Act of 2018 (P.L. 115-265), Congress directed the Coast Guard to brief congressional committees of jurisdiction on its efforts to enhance its marine inspections staff. In the Frank LoBiondo Coast Guard Authorization Act of 2018 (P.L. 115-282), Congress requested a report from the Coast Guard detailing the courses and other training a marine inspector must complete to be considered qualified, including any courses that have been dropped from the training curriculum in recent years.

Congress’s concern about the Coast Guard’s inspection staff comes at a time when the agency’s vessel inspection workload is increasing by about 50% because towing vessels have been added to its responsibilities. Additionally, Congress has been increasing the agency’s role in fishing vessel safety. Adding to the Coast Guard’s safety responsibilities is the construction of several liquefied natural gas (LNG) export terminals as well as the increasing use of LNG as ship fuel.

Vessel safety inspections are especially critical for the U.S.-flag fleet, like the El Faro, because a majority of it is much older than the 15 to 20 years of age at which ships in the foreign-flag worldwide oceangoing fleet are typically scrapped. Over half of the U.S.-flag commercial fleet is over 20 years old; the El Faro had been in service for 40 years. Vessels that transport cargo or passengers domestically (from one U.S. point to another U.S. point) must be built in the United States, as required by the Jones Act. The comparatively high cost of domestic ship construction encourages ship owners to keep Jones Act vessels in service well beyond their normal retirement age. In general, older vessels are believed to have a higher risk of structural defects and to require more intensive inspection.

Currently, the Coast Guard’s marine inspection staff consists of 533 military and 138 civilian personnel, while its accident investigation staff consists of 120 military staff and 38 civilians. As a military organization, the Coast Guard frequently rotates its staff among various duty stations, so personnel may not develop the knowledge and experience required of a proficient marine inspector or investigator. A common perception inside the agency that marine safety is an area that retards promotion also may be thwarting efforts to boost this mission’s workforce.

The Coast Guard recently has stated its intention to improve the quality of its inspection workforce and to make marine safety an attractive long-term career path by extending promotion potential. However, its recent statements are similar to statements made 10 years ago, when some Members of Congress advocated transferring the marine safety function to a civilian agency. It is unclear what the agency has accomplished over the last decade regarding its inspection workforce. Government audits dating to 1979 have been consistently critical of the proficiency level of Coast Guard inspectors and accident investigators. Reorganizing the marine safety function under a civilian agency, perhaps as an element of a larger reorganization of navigation functions in the federal government, might improve the quality of safety inspections and investigations, but other federal agencies with transportation-related safety inspection workforces have had similar issues with retaining experienced personnel.


They pawned off far too much responsibility to ABS. If the USCG wants to see what is wrong, they should re-read the report in the Marine Electric. They are chronically spread too thin, without an adequate budget, to cover their expanded duties.

Perhaps a return to the core missions is in order: keep the lighthouses and buoys watching properly (from the US Lighthouse Service), enforce US law to 200nm (expanded Revenue Cutter Service), life safety within that zone (Lifesaving Service), and merchant vessel inspections (Steamboat Inspection Service).

Warfare has changed, hanging some depth charges and extra guns (insta Uboat killer) doesn’t make a warship any more. It will require a huge cultural adjustment, but the USCG needs to take a serious look at what they can do given limited resources and political clout versus what they need to do to meet the safety needs of the marine transportation system.

Port State Inspectors in most other countries are ex mariners with, typically, a decent bit of seagoing experience. Why don’t they start a part time corp of inspectors who are just mariners who live near a port and are willing to do it as a side gig? Require a certain amount of training be completed and certain standards are up to USCG specifications and then just call them when needed for a nominal fee. If nothing else, at least they could answer questions the inspectors may have.


Maybe only retired mariners should be considered to avoid any conflicts of interests.


“Experience” is meaningless unless you do something useful with it. I would suggest class society oversight be more often and more intense.

Audit each recognized class society at their US based hierarchy in addition to rotating local office audits
Randomly audit individual surveyors by conducting an inspection immediately after or in conjunction with the class society surveyor.

There already is a means for retired/current mariners to be involved with Marine Safety through the USCG Auxiliary.

This of course presumes that going to sea for X-number of years provides the seasoned mariner with as much/more regulatory knowledge than the USCG inspector. I have found exactly the opposite to be true.

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I would sign up for that for sure

You’d be hard pressed to find a group with as little credibility as the CG Auxiliary. The idea of one of those guys walking up the gangway to perform an “inspection” is laughable.


I am not in the auxiliary but I have considered it. I have read the requirements for it and it’s not as simple as just saying, hey I’m in the Auxiliary and I’m here to inspect your ship. There are PQSs to do and you have to be signed off on by the Captain of the Port.

My only point was that the means exists for mariners to do it. Whether someone actually jumps through all the hoops to do it, well …

AFAIK, all the USCG Auxillary does is personal vessel safety inspections and watercraft operator classes (“Boating Safely”). I was a member when I was 17 and I just said “I want to join” and was given an ID. Now, post 9/11, there’s a little more security clearance required to join/renew but not much.

I only know what I have read


I am sure that it is the rare auxiliary member who can actually obtain this as it should be.

True from the WAFI side, last I knew.

From the report:

The report noted that the Coast Guard Merchant Marine Safety Manual in effect at the time stated as a customarily accepted fact that it takes three years of experience to become a qualified marine inspector, adding that “every 2 to 3 years the Coast Guard rotates its staff among various duty stations such as search and rescue, buoy tenders, and high- and medium-endurance cutters,” and that “about the time personnel become proficient in one area, such as vessel inspection, they are transferred and assigned to another job.”

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BrownWaterGuy has a point that the CG Aux might be a vehicle to attain that goal but it would have to be completely reinvented. Not to downplay the work they are doing for the recreational boating community but it is far short of what would be required to conduct ship inspections.

This quote you make refers to a 1979 GAO report, and the nature of the workforce then —inspectors rotated between ships and shore— and now, is quite different. Inspection is now a career path where they don’t go back and forth anymore and there have been increasing amounts of civilians added to bring stability as well.

The report excerpted is lacking in data. This is an area where trends matter more than tragedy. Yet little is spoken of save big casualties and findings taken in isolation. Safety inspections of the El Faro were inadequate according to the NTSB, but the safety inspections were ABS’ responsibility. Meanwhile, the same NTSB report concludes the condition of the hull was not a problem, when read with the folllowing, it suggests that the overall program of inspections is pretty good since the longevity of Jones Act hulls appears effective past what is normal life cycles elsewhere in foreign flags.


If the USCG spent less time on small boats harassing the average law abiding pleasure boater (increased greatly post 2001) using the archaic law that allows them to search without probably cause (which I contend was originally intended to search FOREIGN vessels, not those of citizens) and more time concentrating on real safety of commercial vessels, we all would benefit. But muh homeland security and muh “terrorism”.

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you’re mistaken. The point was to provide an absolute ability to search vessels to enforce the laws of customs and that there would be complicit countrymen involved in domestic vessels enabling the crime (see section on breaking bulk below). Also they were scrupulous about law and overreach, especially at the founding hence the particular instructions from Hamilton below. Also, the dudes inspecting the boats aren’t doing ship inspections, they can handle both.

“You will have a right for example & it will be your duty to seize Vessels & Goods in the cases in which they are liable to seizure for breaches of the Revenue Laws, when they come under your notice. But all the powers you can exercise will be found in some provisions of the Law, & it must be a rule with you to exercise none with which you are not clearly invested.

It is understood that by Inhabitant is intended every person residing in the United States whether Citizen or Foreigner. The reason of this limitation is, that Citizens & resident Foreigners are supposed to be acquainted with the Laws of the Country; but that foreign Citizens residing in foreign Countries have not the same knowledge & consequently ought not to be subjected to penalties in regard to a thing which they might not know to be necessary.

But since you cannot be presumed to know before hand what Vessels are owned in whole or in part by Citizens or Inhabitants, it will of course be your duty to demand the Manifests of all indiscriminately…

…always keep in mind that their Countrymen are Freemen [so clearly they meant to inspect both foreign and domestic] & as such are impatient of every thing that bears the least mark of a domineering Spirit. They will therefore refrain with the most guarded circumspection from whatever has the semblance of haughtiness, rudeness or insult. If obstacles occur they will remember they are under the particular protection of the Laws, & that they can meet with nothing disagreeable in the execution of their duty which these will not severely reprehend.”

What customs and duties are inland (including far upstream tidal) boaters potentially skating?

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  1. the duties on the cargo they received from the foreign boats who broke bulk outside proper customs ports

  2. the laws on safety requirements and anything after we’re built on top of established authority to search any and all vessels within the previously established jurisdiction for new items and could have changed it, limited scope, they didn’t. Intentionally.

  3. counter drug enforcement relies on the same set of authority and laws. So all those small boats can’t ever possibly be used for smuggling drugs?

A 23’ bayliner bowrider on a river that is so far from the ocean it can’t make it to salt water without refueling is a risk of smuggling drugs?

Sure why not?

The point you wanted to make is the law wasn’t applicable to Domestic craft. It is. Not liking it? Well that’s something to get over.