What is COMDTINST M16782.1?

1. A FIRST LOOK:Information and IssuesRecreational Boating Accident Reporting Manual (COMDTINST M16782.1)Federal Register Notice; request for commentshttps://federalregister.gov/a/2015-20738

2. Notice published: Aug. 21, 2015Manual posted: Aug. 27, 2015Docket No: USCG-2015-0753on www.regulations.govComment deadline: Nov. 19, 2015

3. Official USCG Contact for the Notice: Susan Weber, susan.m.weber@uscg.milIn Susan’s absence: Don Kerlin, donald.j.kerlin@uscg.milContact will be allowed to provide clarification on content of the manual outside of the formal comment and response process; must document all questions received and answers given.

4. What is COMDTINST M16782.1?

5. A replacement for CG-449, Standard Method of Reporting (Boating Accidents), last published September 1973 • Replacement format is a Commandant’s Instruction, a manual with eight sections and eight appendices

6. Sections in the body of the manual • Reporting Recreational Boating Accidents • Authorities and Coast Guard Policy • Data Collection • Recreational Boating Accident Reports and Investigations • Entry, Review and Use of Data • Reporting Vessel Defects, Safety Issues and Bridge Allisions • Contacts • Boating Safety Resource Links

7. Appendices • Recreational Boating Accident Report, Form 3865 • Regulatory Texts • Vessel Determinations • Glossary of Terms and Abbreviations • Accident Scenarios in the Annual Recreational Boating Statistics Report • Boating Safety Sources and Points of Contact • BARD Data Web Transfer Service • Narrative Example

8. What’s the stated intent of the manual?

9. To consolidate Coast Guard policies and operating procedures into a manual on reporting, investigation, processing of recreational boating accidents • To give “current requirements” and “expanded information” on reporting procedures • Proposes that its use by reporting authorities will “clarify reporting requirements and enhance data quality.”

10. Calls for—and efforts directed toward—replacing the old guidance, in some form, have been in the works for at least a decade

11. Are there any related USCG regulatory or policy activities currently in the works or recently completed?

12. In Progress since 2012….Regulatory project on accident reporting system and processes • Another Federal Register Notice, set to close Sept. 29…Coast Guard’s intent to submit an ICR to OMB for approval of extension of collection 1625-0003 Boating Accident Report • July 21, 2015 issuance…Marine Casualty Reporting Procedures Guide with Associated Standard Interpretations (NVIC, 01-15; COMDTPUB P16700.4)

13. What does a “first look” at the manual’s content suggest?

14. The COMDTINST M16782.1 is more than a replacement for CG-449; it covers far more ground than the original • The appendices to the manual are absolutely critical; they deserve closer review – especially, D (Glossary) and E (Accident Scenarios)

15. Previous, related work and recommendations by NASBLA and the National Boating Safety Advisory Council (NBSAC), like… • NBSAC Accident Reporting Task Force recommendations related to potential policy and regulatory action; accepted by NBSAC in 2009, and included in Obj. 9 of the National RBS Strategic Plan 2012-2016 • NASBLA ERAC / USCG Accident Reporting Terms & Definitions Project standardized lists in five report areas approved by NASBLA membership, 2012-13; using review process approved by NASBLA Board & USCG BSX in 2011 Are notable largely for their omission, not incorporation into the manual.

16. In some places, the manual repeats what’s in regulation, with no additional interpretation/guidance • In others, the provisions are still somewhat vague, subject to varying interpretations • And in others, the provisions contradict current practice or recommendations made by NBSAC and NASBLA, among others

17. What are a couple of examplesof provisions in the manualthat deserve a closer look?

18. Reportable accident scenarios: Authorities and Coast Guard policy (Section 2.C.5(e), p. 2-4) “Beyond what is required by regulation, there are accident scenarios to be reported that the Coast Guard considers within the scope of the National Recreational Boating Safety Program because the agency feels it is important to evaluate them to determine what, if any, safety measures could prevent future accidents of the same type…” (italics added)

19. Casualties resulting from departing the vessel (Appendix E, p. E-1, A.2.a.) “Casualties resulting from departing an anchored/moored vessel will be included as a reportable accident scenario because the individuals were still engaged in boating.” (italics added)

20. What are some general questions that should be asked about the utility of this manual?

21. The manual states • that each reporting authority should use it because such use will clarify reporting requirements and enhance data quality … • and that it should be in the possession of each field officer responsible for conducting recreational boating accident investigations

22. Does the manual sufficiently clarify reporting requirements to be of use to the targeted audiences … • your agency as the reporting authority? • the officers / investigators in your state? • data entry personnel? • any other partnering agencies or users? • What kinds of implications are the provisions going to have on our current practices?

23. The manual states • that it provides current requirements along with expanded information on the reporting procedures for recreational boating accidents

24. Does the “expanded information” – by virtue of including the information in the manual – mean • “additional requirements” beyond those already in place? • or does it just refer to the examples and illustrations of current requirements?

25. What’s the shelf life of this COMDTINST manual? • How does the release and review of this manual draft affect our response to the open Federal Register Notice on the BAR collection? • Do the remaining 67 days give enough time to complete the review and comment…or does it warrant a request for extension?

26. What questions do you have?