COMDTINST 16715.5
Technical and Hazardous Materials Division. Through day to day involvement in the plan
review process, Marine Safety Center personnel gain an excellent working knowledge of
the regulations, which permits them to be able to provide consistent and uniform application
of regulations. It also places the Marine Safety Center in an ideal position to make
technical/regulatory determinations. The added benefit of "one stop shopping" for the
industry places us in a better position to serve our customers.
4.
DISCUSSION. Determinations concerning regulatory implementation of a technical nature
can now be performed by the Marine Safety Center. A consequence of providing
interpretion of existing regulations is frequently the creation of policy. With this shift in
responsibility, it is recognized that the MSC will often be establishing policy in the plan
review area. However, program policy will remain the responsibility of G-M. It may be
difficult to clearly define for the maritime community and Coast Guard field units the
boundary between these two categories. Thus, it is paramount that we facilitate the
implementation of this new approach. In this regard, the Marine Safety Center will be the
first point of contact for all interpretations of technical requirements involving the vessel
design and approval aspects of the commercial vessel safety program. The Marine Safety
Center will determine if the request falls under their new authority. If so, it will be handled
by the appropriate division at the Marine Safety Center. If the request requires a
determination affecting program policy, it will be forwarded to the appropriate division in
G-M. Likewise, any waivers or exemptions from the regulations will remain the
responsibility of G-M. The Marine Safety Center and Commandant(G-M) will maintain an
effective communication process to ensure that technical decisions and interpretations made
at the MSC are fed back into continued improvement of the regulations. Effective
immediately, all commercial vessel design issues shall be directed to the Marine Safety
Center. The marine Safety Center will take appropriate action for all requests including
those that require technical and/or regulatory interpretations. All requests that are identified
as outside the scope of technical regulatory implementation will be forwarded by the
Marine Safety Center to the appropriate division in G-M.
J. F. McGOWAN
Captain, U.S. Coast Guard
Acting Chief, Office of Marine Safety,
Security and Environmental Protection
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