60 Proceedings | Vol. 83, No. 1 the United States and allowing CIs to inspect multiple brands in one location. Hull identification numbers (HINs) are the biggest deficiency noted in all inspection types. This is because every recreational vessel is required to have a HIN. For example, even a kayak needs a HIN, though other federal safety standards don’t apply. Deficiencies with flotation are found primarily only during boat tests, a small subset of overall inspections. The chart below shows categories with high levels of deficiencies that were noted in 2023 during inspections. HINs, safe loading, flotation, and dis- play of capacity and certification are most often noted as deficient. After reviewing the deficiencies chart, an obvious question may be, what about fuel and electrical systems as boats become larger and more advanced? The short answer is that 33 CFR Subchapter S, Subpart I, Electrical Systems and Subpart J, Fuel Systems do not apply to gasoline powered outboard boats, which are the overwhelming percentage of boats sold in the United States. We expect this industry trend of bigger boats and a higher propor- tion of outboard boats to continue and, in the absence of federal standards, voluntary standards fill the gap. In the rare instance where a builder fails to comply with voluntary standards and introduces a boat to the mar- ket with an unsafe fuel or electrical system, the Coast Guard’s authority to initiate a recall due to a substantial risk safety defect can be exercised to mitigate the unsafe condition. As federal regulations become more obsolete, volun- tary standards become more important to fill the gap until regulations can catch up. The Coast Guard partici- pates in the development and maintenance of American Boat and Yacht Council standards as well as applicable International Standards Organization, the National Fire Protection Association and the Society of Automotive Engineers standards. It is critical to ensure voluntary standards do not conflict with minimal federal safety standards and are consistent with the intent of the Federal Boat Safety Act. CG-BSX-23 also conducts inves- tigations into unique boating accidents to determine if a recall is necessary or if updates to the regulations or standards are warranted. The RBTCP is managed wholly out of Coast Guard Headquarters, but that doesn’t mean that local Coast Guard units don’t run into issues with recreational boats. When they do, CG-BSX-23 is available to assist. Should Coast Guard units have questions on recreational boat standards—Coast Guard require- ments or voluntary standards—or need assistance with an investiga- tion, it is recommended they reach out to CG-BSX-23. The office can also provide resources for a recreational boat casualty investigation, including independent lab testing and subject matter expert consultation. Born in the 1970s, the RBTCP con- tinues to evolve and serves as the primary compliance method for recre- ational boat manufacturers and is the check for an otherwise self-certifying compliance program. It’s a critical part of ensuring more than 3,000 manufacturers comply with minimal safety standards and provides an excellent avenue for the Coast Guard to work with builders to continue improving safety on the water. About the author: Kevin Ferrie is a retired Coast Guard officer who served an active-duty career in the commercial compliance industry. In his role as an engineer in CG-BSX-23, he oversees all manufacturers in the northern half of the United States. Endnote: 1. 33 C.F.R. § 181 Subpart C requires every recreational vessel have a HIN. Find the Compliance Inspection Checklist at https://www.safeafloat.com under the Boat Builders Tool Kit in the Factory Checklist Tab The Coast Guard’s Boating Product Assurance Branch, CG-BSX-23, can be reached at [email protected] For more information
