Coast Guard: More Information Needed to Assess Efficacy and Costs of Vessel Survival Craft Requirements

GAO-21-247 Published: Mar 31, 2021. Publicly Released: Mar 31, 2021.
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Fast Facts

Appropriate lifesaving equipment can help increase the chance of surviving boat or ship accidents. This includes survival craft, such as lifeboats, which keep accident victims out of the water.

The U.S. Coast Guard uses accident data to determine which lifesaving equipment should be required on boats and ships. But in the data we reviewed, we found that the Coast Guard didn't collect some key data for assessing equipment effectiveness—e.g., data on types of equipment used in accidents.

We also found opportunities for the Coast Guard to improve its estimates of the cost of survival craft requirements.

Our recommendations address these issues.

Out-of-water survival craft helps ensure people are not immersed in water during a vessel emergency

two people on an out-of-water survival craft floating in a large body of water

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Highlights

What GAO Found

Coast Guard data show that during fiscal years 2010 through 2019 most people survived vessel accidents, and out-of-water survival craft, such as a lifeboat, was used more often than other types of lifesaving equipment. However, the Coast Guard has limited information about people involved in vessel accidents, such as their date of birth, potential disability, and type of lifesaving equipment used, if any. For example, Coast Guard data did not include the type of lifesaving equipment used, if any, for about 45 percent (1,733 of 3,847) of accident survivors. By requiring its investigators to collect date of birth, known disability, and use of lifesaving equipment information of survivors and casualties of vessel accidents, the service could better assess the efficacy of lifesaving equipment.

Examples of Out-of-Water Survival Craft

Examples of Out-of-Water Survival Craft

The Coast Guard estimated costs and benefits of requiring vessel owners to carry out-of-water survival craft in its 2013 and 2017 reports to Congress, but the estimates were not fully accurate or complete. The Coast Guard did not use economically justifiable discount rates to account for the time value of money nor document its rationale, as recommended by the Office of Management and Budget (OMB). In its 2013 report, this resulted in estimated net costs $32.3 million higher than if it had. By fully implementing OMB best practices, the Coast Guard can better ensure its future estimates are accurate and complete.

The Coast Guard's 1991 guidance for determining cold water areas (59 degrees Fahrenheit and below) is based on outdated water temperature data. The guidance designates cold water areas where commercial vessels are to carry certain lifesaving equipment. Our analysis of the most recent water temperature data found that temperatures increased off the Atlantic coast for all months and Pacific coast for 10 months of the year—which does not match temperatures in the guidance. For example, the data shows that, for the month of September, waters measuring over 59 degrees expanded across almost half the area in the Gulf of Maine that the Coast Guard designated as “cold water” in 1991. By reviewing its cold water areas determination guidance to determine if it reflects current temperature data, and if necessary revising it, the Coast Guard would better ensure commercial vessels are operating with appropriate lifesaving equipment.

Why GAO Did This Study

Since 2010, the Department of Homeland Security's (DHS) Coast Guard investigated over 50,000 maritime vessel accidents, including some resulting in casualties (dead or missing persons). The Coast Guard investigates accidents and requires vessels to carry lifesaving equipment to reduce the likelihood of casualties. Among this equipment are out-of-water survival craft to ensure no part of a person is immersed in water.

The Coast Guard Authorization Act of 2016 includes a provision for GAO to examine the extent of vessel-based casualties from water immersion and the efficacy of various lifesaving equipment. This report assesses the extent the Coast Guard has (1) data from 2010 through 2019 showing vessel-based casualties and survivability; (2) estimated costs and benefits of implementing out-of-water survival craft requirements for vessel owners; and (3) guidance for designating cold water areas and corresponding equipment requirements based on the best available data. GAO reviewed Coast Guard guidance and vessel accident data and interviewed Coast Guard and industry officials.

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Recommendations

GAO makes four recommendations, including that the Coast Guard require investigators collect data about people's use of lifesaving equipment in accidents, fully implement cost estimate best practices for out-of-water survival craft requirements, and if necessary, update cold water areas determinations. DHS concurred with 3 of 4 recommendations. GAO continues to believe the findings in the report support the recommendations.

Recommendations for Executive Action

Agency Affected Recommendation Status
United States Coast Guard The Commandant of the Coast Guard should ensure that the Director of Inspections and Compliance revises its vessel accident investigations guidance to require Coast Guard investigators to collect date of birth, known disability, and use of lifesaving equipment of people in vessel accidents who were casualties due to water immersion, or who used lifesaving equipment. (Recommendation 1)
Open
DHS did not concur with our recommendation that the Coast Guard revise its vessel accident investigations guidance to require its investigators to collect date of birth, known disability, and use of lifesaving equipment of people in vessel accidents who were casualties due to water immersion, or who used lifesaving equipment. DHS stated that Coast Guard Marine Casualty Investigating Officers are not required by statute or regulation to collect date of birth, known disability, and use of lifesaving equipment of people in vessel accidents who were casualties due to water immersion, or who used lifesaving equipment. It stated that Investigating Officers already collect this type of information on a case-by-case basis when the information is needed for a specific investigative purpose, such as when an officer determines that an involved subject's disability was a contributing factor to a marine casualty. With respect to these concerns, however, we do not believe the lack of statutory or regulatory requirements prevents the Coast Guard from issuing requirements for its investigators to collect this information. We recognize the Coast Guard's concern about collecting personally identifiable information in its accident reports (specifically date of birth) and not wanting to place additional requirements on its investigators without purpose. Although DHS disagrees that collecting date of birth information would have any significant investigative benefit unless age is relevant to the cause of the accident, the purpose served by our recommendation is not limited to investigating vessel accidents. Our recommendation supports a broader marine safety purpose of strengthening the service's ability to assess the sufficiency of its survival craft regulations---and improving the survivability of children and the elderly. Because collecting date of birth information is clearly relevant to that purpose, it would not be improper under DHS's Privacy Policy. Moreover, as we state in the report, the Coast Guard already collects date of birth information in vessel accident reports, but it does so inconsistently. For example, Coast Guard data showed it had done so for about 40 percent of people involved in vessel accidents during fiscal years 2010 through 2019. In summary, the Coast Guard's quality management system framework states that the service should ensure continual improvement to meet its marine safety mission to reduce casualties. The Coast Guard achieves this mission, in part, by using a risk-based approach to survival craft requirements using factors such as survivability and casualty analysis. Its 2017 Non-Immersion Survival Craft report to Congress and our own analysis highlight opportunities for the Coast Guard's continued improvement to meet its marine safety mission. Requiring its investigators to collect age, known disability, and usage of lifesaving equipment information in all cases, not just some cases, could help the service assess this risk. As of February 2022, the Coast Guard reported its response remained unchanged. It noted that the determination of the chance that a person could have been killed, lost at sea, or injured as a result of a marine casualty can be accomplished through the investigation's causal findings and the role of the involved subject, either passenger or crew. Further, it reported that the level of granularity in individual subject detail in this recommendation is moot in the process of determining an individual's risk status in a reportable marine casualty. Without specified regulatory requirements, the Coast Guard does not intend to collect the additional age and disability information unless it is necessary to determine causal factors of a vessel accident or personnel casualty.
United States Coast Guard The Commandant of the Coast Guard should ensure that the Director of Commercial Regulations and Standards fully implements OMB and GAO cost and benefit estimate best practices in developing future estimates of the implementation costs for out-of-water survival craft requirements, including relying on the most current inflation information and discounting future costs and benefits for cost effectiveness projections, and documenting its methods for calculating acquisition costs. (Recommendation 2)
Open
DHS concurred with our second recommendation that the Coast Guard fully implement OMB and GAO cost and benefit estimate best practices in developing future estimates of the implementation costs for out-of-water survival craft requirements, including relying on the most current inflation information and discounting future costs and benefits for cost effectiveness projections, and documenting its methods for calculating acquisition costs. DHS stated that the Coast Guard Office of Standards Evaluation and Development will ensure that all future out-of-water survival craft economic analyses utilize real discount rates of 3 and 7 percent-per OMB Circular A-4, Regulatory Analysis, dated September 17, 2003, as well as the Coast Guard's current practice for all economic analyses, including regulatory impact analyses, and corresponding GAO cost and benefits best practices. It stated that the office will also utilize best practices for the DHS Chief Regulatory Economist's Value of Statistical Life, dated March 1, 2021, for future out-of-water survival craft economic analyses, and will update the Coast Guard's survival craft cost analysis every 5 years, pursuant to the Coast Guard Authorization Act of 2016. It estimated completing these actions by December 31, 2021. In September 2021, Coast Guard reported it will continue to ensure it is fully implementing OMB and GAO cost and benefit estimate best practices for future calculations of cost for out-of-water survival craft requirements as CG-REG implements a system of evaluation and control including rigorous peer review, Coast Guard best practices documents, and DHS best practices documents to ensure implementation and alignment of OMB Circular A-4, as well as corresponding GAO cost and benefits practices. This includes relying on the most current cost data, inflation information, discounting future costs and benefits for cost effectiveness projections, and documenting its methods for calculating acquisition costs. Currently the Coast Guard is in the process of finalizing the "Non-Immersion Survival Craft Report to Congress" which is updated every five years, and which the Coast Guard anticipates will be submitted to Congress not later than December 31, 2021.
United States Coast Guard The Commandant of the Coast Guard should ensure that the Director of Inspections and Compliance analyzes its cold water determinations using the best available long-term water temperature data and, if appropriate, update its cold water areas determination guidance for certain lifesaving equipment requirements on commercial vessels. (Recommendation 3)
Open
DHS concurred with our third recommendation that the Coast Guard analyze its cold water determinations using the best available long-term water temperature data and, if appropriate, update its cold water areas determination guidance for certain lifesaving equipment requirements on commercial vessels. It stated that the Coast Guard Office of Commercial Vessel Compliance will review the water temperatures and determine whether updates to the May 20, 1991, Navigation and Vessel Inspection Circular (NVIC 7-91), "Determination of Cold Water Areas," are needed. It estimated completing these actions by December 31, 2021. In September 2021, the Coast Guard stated it had engaged the National Oceanic and Atmospheric Administration (NOAA) to review water temperature data to determine if updates to the NVIC 7-91 are required. It estimated a December 31, 2021 completion date. In February 2022, the Coast Guard reported the Office of Commercial Vessel Compliance had received water temperature data from NOAA and completed an initial review. It stated it was in the process of determining if updates to the NVIC 7-91 is required---and estimated implementing the recommendation by April 29, 2022.
United States Coast Guard The Commandant of the Coast Guard should ensure that the Director of Inspections and Compliance establishes a process to routinely review and update, if appropriate, its cold water areas determination guidance for certain lifesaving equipment requirements on commercial vessels using the best available temperature data. (Recommendation 4)
Open
DHS concurred with our fourth recommendation that the Coast Guard establish a process to routinely review and update, if appropriate, its cold water areas determination guidance for certain lifesaving equipment requirements on commercial vessels using the best available temperature data. DHS stated that the Office of Commercial Vessel Compliance (CG-CVC) will establish a process to review Navigation and Vessel Inspection Circular "Determination of Cold Water Areas" (NVIC 7-91) every 5 years, and update the information as appropriate, using its Mission Management System process. It estimated completing these actions by December 31, 2021. In September 2021, the Coast Guard stated that CG-CVC reported was currently reviewing NVIC 7-91 and updating the information, as appropriate. It also stated that it would document the updates and review using CG-CVC's Mission Management System process, which will maintain the necessary review schedule. In February 2022, the Coast Guard stated that CG-CVC conducted an initial review of NVIC 7-91 and will update information, as appropriate. It further stated that its updates and review will be documented using CG-CVC's Mission Management System process, which will maintain the necessary review schedule. it estimated implementing the recommendation by April 29, 2022.

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