Overview
Title
Collection of Information Under Review by Office of Management and Budget; OMB Control Number 1625-0084
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ELI5 AI
The Coast Guard wants to keep asking people for information about how safe ships are, but they're asking if there's a better way to do it without taking too much time or effort. They're inviting everyone to share their thoughts on this by January 8, 2025.
Summary AI
The U.S. Coast Guard is seeking public comments on their request to extend approval for an information collection related to audit reports under the International Safety Management Code. This involves ensuring that U.S. vessels comply with international treaties on safety management systems. The Coast Guard invites feedback on the necessity, utility, and potential burden of the information collection by January 8, 2025, through the Federal eRulemaking Portal. The estimated annual burden for respondents has increased due to more responses received.
Abstract
In compliance with the Paperwork Reduction Act of 1995 the U.S. Coast Guard is forwarding an Information Collection Request (ICR), abstracted below, to the Office of Management and Budget (OMB), Office of Information and Regulatory Affairs (OIRA), requesting an extension of its approval for the following collection of information: 1625-0084, Audit Reports under the International Safety Management Code; without change. Our ICR describes the information we seek to collect from the public. Review and comments by OIRA ensure we only impose paperwork burdens commensurate with our performance of duties.
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AnalysisAI
The document presented is a public notice from the U.S. Coast Guard, seeking comments on their request to extend the approval for an ongoing information collection regarding audit reports under the International Safety Management Code. This process is essential for ensuring that U.S. vessels comply with international safety management treaties. Public input is requested to assess whether this information collection continues to be necessary and efficient.
General Summary
The notice, released under the Paperwork Reduction Act of 1995, outlines a request by the Coast Guard to the Office of Management and Budget for extending approval to collect information from certain public stakeholders. This collection is titled "Audit Reports under the International Safety Management Code" and is designed to evaluate whether U.S. vessels meet international safety standards. The Coast Guard is inviting public comments until January 8, 2025, on the necessity and impact of this information collection.
Significant Issues or Concerns
Several issues emerge from this notice. Firstly, the document mentions an increase in the estimated hour burden from 15,512 hours to 16,814 hours annually but does not elaborate on the factors contributing to this rise. This absence of detail might suggest inefficiencies or a need for clear justification that might concern respondents about potentially unnecessary bureaucracy.
Another point of concern is the complex language used in the document. This complexity could pose an obstacle for the lay public, unfamiliar with legal and regulatory jargon, limiting public participation in the comment period. Furthermore, the document does not clarify how audit processes are conducted consistently across vessels and companies, which might raise concerns about the fairness and transparency of these evaluations.
The notice indicates no responses were received in a previous request for comments, dated September 3, 2024. The absence of public engagement might reflect a lack of awareness among stakeholders or inadequacies in how notifications reach the public.
Additionally, the document mentions exploring automated collection techniques to reduce the paperwork burden but does not detail specific methods or technologies. This lack of specificity could reduce confidence that meaningful reductions in burden will be achieved without further detail.
Finally, there is a noticeable absence of discussion on which organizations or individuals might benefit from this collection of information. Transparency about potential biases or advantages could improve public trust in the process.
Impact on the General Public
For the general public, especially those involved in maritime industries, this document represents an opportunity to influence regulatory practices that govern safety management systems on U.S. vessels. However, if the complexity of language or lack of awareness on the part of stakeholders persists, public engagement may remain minimal.
Stakeholder Impacts
For vessel owners and operators, the request to extend the information collection may impose an increased reporting burden due to the rise in estimated total hours required, which could entail additional costs or allocation of resources. On the flip side, these stakeholders may benefit from enhanced safety management standards resulting from thorough audits.
On a broader scale, organizations authorized to issue certificates under the ISM Code may face scrutiny over how audits are conducted, potentially prompting a push for more standardized criteria and transparency in audit processes. Reductions in paperwork burdens through innovative collection techniques could benefit these organizations, but the document should provide more concrete plans to realize these efficiencies.
Overall, this procedural request signals the Coast Guard's ongoing commitment to safety management but highlights areas for increased transparency and public engagement efforts.
Issues
• The document does not provide specific details on how the increased hour burden estimate from 15,512 to 16,814 hours is calculated, which could indicate potential inefficiencies or justifications needing clarification.
• The language in this document might be considered complex, especially for those not familiar with legal and regulatory processes, which could limit public understanding and response.
• The document lacks detail on the methods or criteria used by organizations to conduct audits of vessels and companies, which might raise concerns about consistency and fairness.
• No justification is provided for why the previous request for comments, dated September 3, 2024, did not receive any public comments, which might indicate a lack of public engagement or awareness.
• The document does not specify any measures or examples of how the Coast Guard could minimize the paperwork burden through automated techniques, though it mentions the potential to do so.
• There is no mention of specific organizations or individuals that might potentially benefit from the information collection, which could imply lack of transparency if any bias exists.