The Coast Guard will no longer require plan review for certain microprocessor-based control systems on small passenger vessels.
The Coast Guard Office of Commercial Vessel Compliance (CVC) originally promulgated Policy Letter 17-07 to establish standardized plan review requirements for all small passenger vessels using microprocessor-based control systems. As controls technology has matured, an industry-standard approach has emerged that ensures that loss of power to the control system will not result in an increase in shaft speed or propeller pitch. The Marine Safety Center (MSC) has identified that plans submitted for common, simple systems have become redundant descriptions of how the equipment functions “out of the box,” making their preparation and submission an unnecessary burden on industry.
CVC Policy Letter 17-07 has been cancelled. Vessels certificated under Title 46, Code of Federal Regulations (CFR) Subchapter K (“K boats”) must still comply with the existing requirements of 46 CFR 121.620(d), including for plan submission. Vessels certificated under 46 CFR Subchapter T (“T boats”) that use steam, all-electric, or “unusual” propulsion must still comply with the requirements of 46 CFR 182.220 and may be required the cognizant Officer in Charge, Marine Inspection to submit plans for approval. All other T boats are no longer required to submit plans for microprocessor-based control systems. MSC’s Plan Review Guide E2-23 has been updated to remove reference to Policy Letter 17-07, and to reiterate the applicable regulations for the smaller subset of vessels that are still required to submit plans. MSC’s Plan Review Guides are available here.
This action reduces the overall cost of compliance for the U.S. small passenger vessel fleet and improves MSC’s ability to provide timely service delivery. Questions concerning this blog post should be directed to msc@uscg.mil.
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