Lots of “shoulds,” no “shalls” Somebody with more knowledge of these things than me should explain if this has any teeth or is just for show.
Earl
You just summed up the USCG “regulatory” philosophy which is, do not regulate.
It’s mostly just common sense stuff. There’s more of a risk from the batteries that the passengers bring onboard than what’s currently there in equipment.
“Shall”=regulations=process involving all stakeholders=congressional involvement=years.
“Should”= fast, easy, and cheap dissemination of important information. Legal standing is weak, but of secondary importance to getting the word out.
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Pretty much. However, during an inspection, don’t be surprised if the Inspector comments on power-strips and charging batteries.
Since this is in response to the M/V Conception fire, I think the focus is indeed on batteries and chargers that passengers bring on board.
Earl
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They established those lithium batteries and chargers are known hazards as the condition they are in is not known when brought on board, they reference the aviation industry’s restrictions but fail to adopt the aviation regulation and insist on not making a regulation by saying “should” instead of “shall” . Imagine if our highway driving regulations said, one should not drive into on coming traffic, one should come to a complete stop at stop signs, one should not drink alcohol and drive. But in light of known hazards the driving regulations say you shall not do these things and for good reason. If the USCG recognizes there is a known danger which has already resulted in loss of lives why not make a firm regulation?
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The CG considers financial repercussions. The nice PSA is clearly aimed at dive boat operators but new CG regs would affect a wider segment of vessels that qualify as SPVs. The burden of divers’ power hungry gear is a live aboard dive boat problem. I guess a specific type of charging system couldn’t be made part of their COI without a regulation passed first.
That is a major difference between the NTSB and the Coast Guard. The NTSB is not required to consider the economic impact of their recommendations. The Coast Guard is required to consider it as part of the regulation process.
Voluntary policies are also used as a first step when regulations cannot be published immediately.