Recreational Boat Manufacturer Factory Visit Program
by Richard Vance Kanehl
U.S. Coast Guard Office of Boating Safety
As of 2003, the Coast Guard Recreational Boat Manufacturer Identification Code Database (uscgboating.org/recalls/mic_database.htm) indicates approximately 4,000 in-business recreational boat manufacturers and importers. This number has remained relatively stable with an influx and loss of approximately 8% of the boat manufacturers each year. The Recreational Boating Product Assurance Division of the Coast Guard Office of Boating Safety is responsible for overseeing the implementation, maintenance, and enforcement of Federal recreational boat safety regulations. The Factory Visit Program is the primary method for the Office of Boating Safety to ensure recreational boat manufacturers are complying with the safety regulations.
In August 1971, Congress passed the Federal Boat Safety Act. Among other things, this act authorized the Coast Guard to establish national construction and performance standards for manufacturers of recreational boats, and to develop enforcement mechanisms. This includes (as listed in 33 CFR §179-181) the display of capacity information, safe loading, safe powering and flotation standards for monohull boats of less than 20 feet in length, except sailboats, canoes, kayaks, and inflatables. The Coast Guard has also published standards covering electrical, fuel and ventilation systems applicable to all boats with permanently installed gasoline engines. From the early 1970s to the mid-1980s, boat manufacturing safety regulations were enforced by personnel from Coast Guard District Offices. From 1988-1995, designated Coast Guard military and civilian personnel from the Marine Safety and Inspection Offices assumed these responsibilities. In 1995, the Coast Guard decided that factory visits would only be conducted when there was evidence that a boat, or its components, contained a defect which could cause an injury or death. For the next several years, the factory visits were only conducted on an as-needed basis. However, organizations such as BOAT/US and the American Boat & Yacht Council (ABYC), expressed concerns to Congress that this arrangement was inadequate to ensure recreational boat construction safety standards. As a result, the Transportation Equity Act for the 21st Century “TEA-21”, directed the Coast Guard Office of Boating Safety to revise and strengthen the recreational boat compliance programs. As the Factory Visit Program is not necessarily inherently governmental work, it was renewed as a PilotProgram in 2001 with a private contractor. Factory visits are now completed by “Compliance Associates” who have an extensive background in boat construction standards. The Compliance Associates have also received training from the American Boat & Yacht Council to ensure standardization of procedures and knowledge of Federal regulations. Since many manufacturers have not been visited in several years, the primary emphasis of the PilotProgram has been to substantiate the nation-wide boat building and importer industry, and to ensure their basic compliance with the boating safety standards. It is important to note that the emphasis of the Factory Visit Program has been to provide education and guidance on how to build safer boats, rather than compliance enforcement.
Typical Factory Visit
A typical factory visit is a comprehensive effort toward educating boat manufacturers in Federal safety regulations. The local Compliance Associate prepares for each visit by writing to the boat builder or importer to provide an explanation of the program and to make an appointment. Upon arriving at the facility, the Compliance Associate asks to see the plant, the construction process and current boat production. During an examination of current production, the Compliance Associate looks for:
a) non-compliance with Federal regulations involving safety standards applicable to the boat manufacturer
b) incorrect installation of equipment, such as navigation lights, according to Federal regulations
c) construction practices that differ from recognized voluntary industry safety standards.
Once the factory visit is completed, violations of Federal regulations are identified. Potential noncompliance items that cannot be confirmed by inspection—such as safe loading figures that appear too large or insufficient flotation material—are discussed, and management's calculations and test procedures are reviewed.
When possible, foam and other component samples are obtained. A test lab, contracted by the Coast Guard, subjects these products—along with boats bought on the open market—to more extensive evaluations ensuring their proper performance and adherence to performance standards.
Violations of the Federal regulations are discussed with the manufacturer and voluntary compliance is encouraged to increase boating safety, as well as to help create good customer relations. Practices related to voluntary industry standards are also discussed. The manufacturer receives a written report of all noted violations.
Types of Factory Visits
There are two main types of factory visits
Inspection Factory Visit
: This occurs when a boat manufacturer or importer has a vessel on the premises, available for inspection. Boats are reviewed for compliance with the Federal Regulations that are applicable to that type of boat. The individual components, such as flotation material, fuel lines, construction drawings and mandatory records are also reviewed.
Education Factory Visit:
While many manufacturers have boats on-site, some build-to-order or use just-in-time delivery thereby minimizing the potential that a boat will be available for review. New manufacturers may not have completed, or even begun, boat construction efforts. When this occurs, the Compliance Associate completes an Education Factory Visit. Even if a completed vessel is not available, boat builders still view this type of visit as being of much value. Not only are immediate questions answered, but they gain a resource for future situations where assistance to understand or interpret a regulation ensures a product line is in compliance with Federal safety regulations. Prior review of procedures and plans can also prevent costly mistakes before construction begins.
Since 2001, the Factory Visit Program has conducted more than 3,500, factory visits at recreational boat manufacturing and importation facilities throughout the United Sates. Most of these visits have focused on boat manufacturers that are subject to Federal safety standards. Manufacturers of boats not subject to Federal safety standards, e.g., sailboats, canoes, kayaks and inflatables, are visited less frequently.
With the renewed Factory Visit Program, the Coast Guard has greatly increased the certified percentage of boats that are compliant with Federal safety regulations, thereby increasing the overall safety of recreational boats. The Pilot-Program, from 2001 until present, concentrated on providing all boat builders with a basic level of understanding of the Federal safety regulations. Starting in 2004, there will be an even greater emphasis on assisting boat builders with more complex problems and how to incorporate proven safety enhancement measures. Educational materials, such as a CD-Rom containing an easy-to-understand interpretive guides of the regulations, will provide every level of boat builder with a more comprehensive understanding of different ways to build better and safer boats for the United States recreational boating public.
Vance Kanehl, Richard. Boatbuilders Handbook Part 1 - Regulation and Other Information.
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