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Sunday, December 3, 2023

OIG Tells the Coast Guard to Determine the Impact and Effectiveness of the Streamlined Inspection Program

OIG is calling for an evaluation to determine the impact that SIP has on the Coast Guard’s mission and resources.

The United States Coast Guard has a process to enroll vessels in the Streamlined Inspection Program (SIP) in accordance with the Code of Federal Regulations (C.F.R). SIP aims to promote a more effective and efficient process to ensure vessels traveling in U.S. waterways comply with regulatory safety requirements.

However, the Office of Inspector General (OIG) says the Coast Guard cannot demonstrate that the oversight functions it uses ensure SIP-enrolled vessels remain in continuous compliance with the C.F.R. In fact, OIG’s audit found that the Coast Guard has not identified or assessed SIP’s contributions to mission success or established key performance indicators since the program’s inception in 1998. A Coast Guard official told OIG that the lack of key performance indicators impacts their ability to understand their resource needs.

In discussions with OIG, a local Coast Guard official described SIP as one of many subprograms that operate within the regulatory aspects of the Coast Guard’s enterprise system, which is managed by officials in headquarters. This enterprise system does not produce specific key performance indicators that would help the Coast Guard understand the effectiveness and efficiency of SIP operations in contributing to its mission and to determine if SIP is a productive use of taxpayer dollars. Additionally, OIG determined that the Coast Guard does not ensure that SIP is operating as intended, or that reported SIP outcomes are accurate and reliable, or that the benefits of this alternative inspection program are made available to vessels under its fleet of responsibility. 

Although SIP participants must maintain their vessels in a continuous state of compliance, in 2021, the Coast Guard issued 105 CG-835 forms for deficiencies on 25 of the 38 (66 percent) SIP-enrolled vessels. According to a Coast Guard official, it is possible that any vessel in operation could have equipment break or experience other conditions that may not be immediately identified by the operator. Therefore, it is reasonable to expect that marine inspectors may discover deficiencies during SIP inspections. 

Vessel operators have 30 days to resolve deficiencies that do not directly affect safety. OIG determined 23 of the 25 vessels resolved their deficiencies in 30 days or less. However, two SIP-enrolled vessels recorded as active had deficiencies that went unresolved for more than 30 days. One vessel had a structural deficiency that had been outstanding for 253 days. The other had four deficiencies related to propulsion and auxiliary machinery, lifesaving appliances, fire safety, and emergency systems. These deficiencies were outstanding for 519 days. When OIG inquired why the second vessel had open deficiencies for more than 30 days, Coast Guard officials responded that the vessel was placed in a shipyard after an onboard fire. After further review, OIG discovered the vessel status was miscoded and should have been reported as “laid-up,” not “active.” 

Out of hundreds of casualties reported by Coast Guard, 34 casualties that occurred during calendar year 2021 involved 10 (26 percent) of the 38 SIP-enrolled vessels. Among these, OIG identified some casualties that could be tied to vessel deficiencies.

Although a Coast Guard official emphasized that SIP is neither intended to, nor expected to, eliminate vessel deficiencies, OIG said it is important to note that without key performance indicators, there is no way to assess whether casualties involving SIP-enrolled vessels occur at an acceptable level for the program. 

The Coast Guard’s lack of oversight could be attributable to the fact that the SIP participation rate is less than one percent. The 38 vessels enrolled in SIP during 2021 represents less than one percent of the 6,592 total passenger vessels subject to inspection under the Coast Guard’s fleet of responsibility. When OIG inquired about the low enrollment, a Coast Guard official responded that many vessels participate in other alternative inspection regimes beyond SIP, such as the Alternate Compliance Program, Maritime Security Program, MSP-Select, and Towing Safety Management System. Coast Guard officials further explained it would be unrealistic to expect all U.S. documented or registered vessels that have a Certificate of Inspection to participate in SIP. In addition, Coast Guard officials responded that some companies find the four-step enrollment process to be “a lot of work on the front end”. Further, a Coast Guard official said that a general lack of program awareness, coupled with the lack of resources, may deter companies from participating in SIP. 

As a result of its audit, OIG is recommending that the Coast Guard require the Office of Commercial Vessel Compliance to develop and implement key performance indicators to facilitate the systematic assessment and evaluation of SIP. The Coast Guard agreed and estimated a completion date of August 30, 2024. OIG is also recommending that the Office of Commercial Vessel Compliance collects and evaluates relevant and accurate SIP outcomes to ensure the program is operating as intended. The Coast Guard said the Office will identify relevant SIP outcomes, which will be used to develop key performance indicators for the program. Finally, OIG is calling for an evaluation to determine the impact that SIP has on the Coast Guard’s mission and resources. The Coast Guard again concurred and it will benchmark key performance indicators, outcomes, and resource utilization against traditional inspections to ensure SIP is effective in maintaining a similar level of safety.

Read the full report at OIG

Kylie Bielby
Kylie Bielby
Kylie Bielby has more than 20 years' experience in reporting and editing a wide range of security topics, covering geopolitical and policy analysis to international and country-specific trends and events. Before joining GTSC's Homeland Security Today staff, she was an editor and contributor for Jane's, and a columnist and managing editor for security and counter-terror publications.

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