Department of Homeland Security 

Office of Inspector General 

U.S. Coast Guard's 
 

Marine Safety Program-


Offshore Vessel Inspections 
 

OIG-11-86 June 2011 
Office a/Inspector General 

U.S. Department of Homeland Security 

Washington, DC 20528 

Homeland 

Security 

JUNO 1 Z011 

Preface 

The Department of Homeland Security (DHS) Office ofInspector General (OIG) was 

established by the Homeland Security Act of2002 (Public Law 107-296) by amendment 

to the Inspector General Act of1978. This is one of a series of audit, inspection, and 

special reports prepared as part of our oversight responsibilities to promote economy, 

efficiency, and effectiveness within the department. 

This report addresses the strengths and weaknesses of the Coast Guard's offshore vessel 

inspection process. It is based on interviews with employees and offiCials of relevant 

agencies and institutions, direct observations, and a review of applicable documents. 

The recommendations herein have been developed to the best knowledge available to our 

office, and have been discussed in draft with those responsible for implementation. We 

trust this report will result in more effective, efficient, and economical operations. We 

express our appreciation to all of those who contributed to the preparation of this report. 

. ·lC ards 

Assistant Inspector General for Audits 
Table of Contents/Abbreviations 

Executive Summary .............................................................................................................1 
 

Background..........................................................................................................................2
 


Results of Audit ...................................................................................................................6 
 

Marine Safety Inspection Guidance for Offshore Vessels.............................................6 
 

Recommendation ...........................................................................................................7 
 

Management Comments and OIG Analysis ..................................................................7 
 

Recording Inspection Results .......................................................................................8 
 

Recommendations........................................................................................................10
 

Management Comments and OIG Analysis ................................................................10 
 

MISLE Database Quality Control................................................................................11 
 

Recommendation .........................................................................................................13 
 

Management Comments and OIG Analysis ................................................................13 
 

Other Concerns ............................................................................................................14 
 

Appendixes 

Appendix A: Purpose, Scope, and Methodology.......................................................15 
 

Appendix B: Management Comments to the Draft Report .......................................18 
 

Appendix C: Major Contributors to this Report........................................................20 
 

Appendix D: Report Distribution ..............................................................................21 
 

Abbreviations 

Coast Guard United States Coast Guard 
 

DHS Department of Homeland Security 
 

FY fiscal year 
 

GAO Government Accountability Office 
 

MISLE Marine Information for Safety and Law Enforcement
 


OCMI Officer in Charge, Marine Inspection 
 

OIG Office of Inspector General 
 

OMB Office of Management and Budget 
 
OIG
 


Department of Homeland Security 

Office of Inspector General 

Executive Summary 

The U.S. Coast Guard’s Marine Safety program is intended to 

ensure the safety of tens of thousands of U.S. mariners, millions of 

passengers on ferries and other vessels, and tens of millions of 

recreational boaters. The Marine Safety program includes Marine 

Safety Inspections of most vessel types; these inspections can 

uncover unsafe vessels, prevent certain incidents from occurring, 

and ensure that vessels have sufficient lifesaving equipment 

onboard to respond to an incident. For this audit, we focused on 

the Marine Safety Inspections for offshore vessels such as floating 

production systems, offshore supply vessels, and mobile offshore 

drilling units. 

We planned this audit to determine whether the U.S. Coast Guard 

has the capabilities and resources needed to inspect offshore 

vessels and ensure the safety of maritime commerce. We did not 

identify any instances of uninspected offshore vessels. Although 

we did identify a few instances of vessels being inspected by 

unqualified personnel, 99% of the inspections reviewed were 

conducted by qualified personnel. However, we determined that 

the U.S. Coast Guard does not have adequate information to plan 

and resource future Marine Safety program activity levels. 

The Marine Safety program has not developed and implemented 

all the guidance Marine Inspectors need to conduct offshore vessel 

inspections and record the results of those inspections. Program 

officials also have not established a formal review process for 

Marine Safety domestic vessel inspection data. With insufficient 

guidance and oversight to ensure consistent and reliable data, the 

U.S. Coast Guard cannot determine its current or future resource 

requirements for this program. 

We made four recommendations to improve the U.S. Coast 

Guard’s management of the Marine Safety program. The U.S. 

Coast Guard concurred with all four recommendations and is 

taking action to implement them. 

U.S. Coast Guard’s Marine Safety Program – Offshore Vessel Inspections 


Page 1 

Background Background 

The U.S. Coast Guard (C The U.S. Coast Guard (Coast Guard) adm oast Guard) administers navigation and inisters navigation and 

vessel inspection laws, rules, and regulations governing m vessel inspection laws, rules, and regulations governing marine 

safety. It is also tasked with inspecting the vessels to which these It is also tasked with inspecting the vessels to which these 

laws apply. laws apply. The Coast Guard’s Ma The Coast Guard’s Marine Safety program rine Safety program is intended is intended

to ensure the safety of tens of thousands of U.S. m to ensure the safety of tens of thousands of U.S. mariners, mriners, millions 

of passengers on ferries and other v of passengers on ferries and other vessels, and tens of m ssels, and tens of millions of 

recreational boaters by inspecting vessels to ensu recreational boaters by inspecting vessels to ensure that theyre that they 

operate safely and have the necessary safety equipm operate safely and have the necessary safety equipment onboard. ent onboard. 

By preventing m By preventing marine casualties, th rine casualties, the Coast Guard also p e Coast Guard also protects thotects the 

marine environm arine environment from oil spil ent from oil spills and the inls and the introduction of other duction of other 

harmful substances, and strengthens the econom harmful substances, and strengthens the economy by minimizing 

property loss and disruptions to maritime commerce. property loss and disruptions to maritime commerce. 

Marine Safety Inspections of U.S. a Marine Safety Inspections of U.S. and foreign vessels ensure that nd foreign vessels ensure that 

safety and environm safety and environmental protectental protection standards are m ion standards are met. The 

inspections are com inspections are comprehensive in nature, and often encom prehensive in nature, and often encompass 

machinery, electrical, piping, indus achinery, electrical, piping, industrial, navigation, and pollution trial, navigation, and pollution 

prevention system prevention systems. The Coast Guar The Coast Guard reports that in a typical year, d reports that in a typical year, 

the Marine Safety program the Marine Safety program conducts mconducts more than 70,000 dom re than 70,000 domestic 

vessel inspections and 10,000 Port vessel inspections and 10,000 Port State Control exam State Control examinations of inations of

foreign vessels. foreign vessels. 

For this audit, we focused on For this audit, we focused on 

the Marine Safety Inspections the Marine Safety Inspections 

for offshore vessels such as for offshore vessels such as 

floating production system floating production systems, 

offshore supply vessels, and offshore supply vessels, and 

mobile offshore drilling units. mobile offshore drilling units. 

Offshore vessels com Offshore vessels comprise 

approximapproximately 8% of the fleet ately 8% of the fleet 

inspected by the Coast G inspected by the Coast Guard. 
 uard.

From January 2009 to June January 2009 to June 
 

2010, Coast Guard’s District 8 2010, Coast Guard’s District 8 

conducted approxim conducted approximately 88% oately 88% o

Coast Guard’s Inspected Fleet

General Dry

Offshore 

Vessels, 8%

Barges, 34%

Source: U.S. Coast Guard, 2006–2009 
 

f all offshore vessel inspections. f all offshore vessel inspections. 
 

Inspection Process Inspection Process 

United States law subjects certain categories of domestic and 

foreign-flagged or foreign-built vessels to Coast Guard inspections 

and certifications. 1 In general, to obtain or renew a Certificate of 

Inspection for a domestic vessel, the owner or operator of the 

1 46 U.S.C. § 3301 et seq. and 46 C.F.R. Chapter I. 

Passenger 

Ships, 52% 

Cargo Ships, 1%o Ships, 1% 

Other Vessels, Other Vessels, 

5% 

U.S. Coast Guard’s Marine Safety Program – Offshore Vessel Inspections 


Page 2 

vessel submits an application to the Coast Guard to the Officer in 

Charge, Marine Inspection (OCMI) of the marine inspection zone 

in which the inspection is to be made. The Coast Guard then 

schedules the inspection. Upon completion of the safety 

inspection, and on condition that the vessel and its equipment are 

approved by the inspector, the Coast Guard issues a Certificate of 

Inspection or a Temporary Certificate of Inspection. After 

receiving the first Certificate of Inspection, and in addition to 

Certificate renewal inspections, domestic vessels are still subject to 

annual or biannual inspections, depending on the category of 

vessel. 

With certain exceptions, all domestic and foreign vessels bound for 

or departing from ports or places in the United States must submit 

a Notice of Arrival to the National Vessel Movement Center. 

After the information is imported into the Coast Guard’s Ship 

Arrival Notification System for screening and viewed using the 

Marine Information for Safety and Law Enforcement (MISLE) 

database, the vessel potentially becomes subject to a safety 

examination. 

With certain exceptions and depending on the category of vessel, 

foreign vessels of countries that are signatories to the 1974 

International Convention for the Safety of Life at Sea are issued a 

Certificate of Compliance upon satisfactory completion of a 

compliance examination by the OCMI. Foreign vessels of nonsignatory countries to that Convention may be issued a Certificate 

of Inspection or a Temporary Certificate of Inspection. 

Aside from the regulations guiding inspections, the Coast Guard 

does not employ an independent method to identify vessels 

needing annual inspections. Further, the Coast Guard does not 

proactively schedule vessel inspections because vessel owners are 

responsible for notifying the Coast Guard of required inspections. 

Inspection Data 

The Coast Guard’s MISLE database is the central repository for all 

inspection data and is the primary information source for 

inspection and investigation work. MISLE is one of the data 

sources that supports key Coast Guard management decisions, 

such as establishing human capital requirements, quantifying 

resource shortfalls, and reallocating existing resources. 

U.S. Coast Guard’s Marine Safety Program – Offshore Vessel Inspections 

Page 3 
In 2008, the Government Accountability Office (GAO) assessed 

the effectiveness of the Coast Guard’s facility inspection program 

and to what extent the Coast Guard ensures that program 

compliance data collected and reported are reliable. The GAO 

reported that flaws in the Coast Guard’s database complicate its 

ability to conduct program analysis or provide other information 

for making management decisions. The GAO recommended that 

the Coast Guard assess MISLE compliance data, including the 

completeness of the data, data entry, consistency, and data field 

problems, and make any changes needed to utilize MISLE data 

more effectively. 

In a response to the GAO, on August 25, 2010, the Coast Guard 

described steps taken to improve consistency and data entry time. 

Specifically, the Coast Guard indicated that it had developed 

training web portals, headquarters help desks, courses, training 

teams, seminars, and conferences to help field personnel keep up 

with the changes to MISLE. These actions may result in improved 

data consistency and reduce the time it takes to input data into 

MISLE. However, as highlighted in this report, improvements are 

still needed to ensure the completeness and accuracy of vessel 

safety inspection data input into MISLE. 

Marine Inspector Qualifications 

The Coast Guard conducted a performance analysis in April 2005 

to determine the requirements for Coast Guard Marine Inspectors. 

In October 2007, the Coast Guard revised its Performance 

Qualification Standards for Marine Inspectors as part of its effort 

to enhance mission execution. In an earlier DHS OIG report, 

United States Coast Guard’s Management of the Marine Casualty 

Investigations Program (May 2008), we determined that the 

August 2007 revisions of the Marine Casualty Investigator 

Performance Qualification Standards lowered the standards by 

removing prequalification requirements of a Hull or Machinery 

and Small Vessel Inspector. 

To determine if the October 2007 revisions to the Marine Inspector 

Performance Qualification Standards lowered the standards, we 

reviewed and compared selected standards for domestic and 

foreign vessel safety inspections with the earlier standards. 

Although the Coast Guard removed some qualification 

requirements from its October 2007 standards, it added 

qualification requirements to all the standards included in our 

U.S. Coast Guard’s Marine Safety Program – Offshore Vessel Inspections 

Page 4 
review except one. We did not find any evidence that the Coast 

Guard lowered the requirements in the October 2007 Marine 

Inspector Performance Qualification Standards that we reviewed 

for this audit (see Appendix A for more details). 

Historical Issues 

In 2007, the House Committee on Transportation and Infrastructure 

scrutinized the Marine Safety program’s ability and preparedness to 

meet the demands of a dynamic global maritime environment. The 

committee was concerned whether the Coast Guard had the human 

capital and technical expertise to safeguard the maritime industry. 

In response to these concerns and to significant changes in the 

maritime industry, the Coast Guard developed its fiscal year (FY) 

2009–2014 Marine Safety Performance Plan. This plan included 

courses of action to determine workload and set appropriate 

staffing levels, as well as improve the quality of training, reduce 

maritime casualties, facilitate commerce, improve processes and 

management, and improve human resource capabilities. 

In January 2010, the GAO reviewed the Coast Guard’s efforts to 

develop electronic tools to allow for more data-driven management 

decisions on personnel requirements and preparedness. It reported 

that resource constraints and problems with coordination and data 

reliability might challenge the Coast Guard’s efforts. As of 

October 2010, the Coast Guard reported a shortfall of 104 Marine 

Inspectors in its Marine Safety program. However, this analysis 

was based on MISLE data that may be incomplete and inaccurate. 

Program Budget 

From FY 2004 to FY 2011, the budget for the Marine Safety 

program represented between 6% and 9% of the overall Coast 

Guard budget. The FY 2010 and requested FY 2011 Marine 

Safety budgets were approximately $650 million per year. The 

Marine Safety budget supports all Marine Safety program 

elements, including marine safety, security, and environmental 

protection. 

U.S. Coast Guard’s Marine Safety Program – Offshore Vessel Inspections 


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Results of Audit 
 

We identified no instances of uninspected offshore vessels and few instances of 

vessel inspections being conducted by unqualified personnel. Qualified personnel 

conducted 99% of the inspections we reviewed (see Appendix A for details). 

However, the Coast Guard needs to improve its guidance and oversight of 

offshore vessel inspections. The Coast Guard has not developed and implemented 

all the guidance Marine Inspectors need to conduct offshore vessel inspections 

and record the results of those inspections. The Coast Guard also has not 

established a formal review process for Marine Safety domestic vessel inspection 

data. 

With insufficient guidance and oversight to ensure consistent and reliable data, 

the Coast Guard cannot determine its current or future resource requirements for 

this program. Gaps in guidance may affect the quality and consistency of safety 

inspections. Because there is no formal review process, program personnel could 

be using inconsistent and unreliable inspection data and cannot make key program 

decisions accurately. 

Marine Safety Inspection Guidance for Offshore Vessels 

Agency program offices are required to establish proper internal controls, 

which include standards for policies and procedures. According to Office 

of Management and Budget (OMB) Circular A-123, as revised, 

information should be communicated to relevant personnel at all levels 

within an organization. This includes providing updated guidance and 

management communication to operational staff. The Coast Guard has 

not developed and implemented all guidance Marine Safety Inspectors 

need to conduct all aspects of offshore vessel inspections. 

The Coast Guard’s vessel inspection workload includes inspecting the 

construction of new vessels, including offshore vessels. There is currently 

no Marine Inspector Performance Qualification Standard for inspecting a 

vessel under construction. A draft New Construction Project Inspector 

Performance Qualification Standard was developed in May 2008 but has 

not yet been made final. 

Without a consistent standard or competency for inspecting vessels under 

construction, inspections are conducted differently from unit to unit, 

potentially affecting the consistency and quality of inspections. For 

example, Coast Guard headquarters conveyed that to oversee the new 

construction of a barge, a Marine Inspector would need to be a qualified 

barge inspector. However, one sector we visited in District 8 does not 

require that a Marine Inspector be qualified to inspect the new construction 

U.S. Coast Guard’s Marine Safety Program – Offshore Vessel Inspections 

Page 6 
 

of a particular type of vessel until that vessel is approximately 80% 

complete. Another unit in District 8 assigns only Marine Inspectors who 

are qualified to inspect a particular type of vessel to inspect the new 

construction of that type of vessel. Developing clear and consistent 

guidance for this type of inspection work could also assist the training and 

professional development of Marine Inspectors. 

Recommendation 

We recommend that the Assistant Commandant for Marine Safety, 

Security and Stewardship, U.S. Coast Guard: 

Recommendation #1: Complete and disseminate to field units 

New Construction Project Inspector Performance Qualification 

Standards and update the Marine Safety Manual accordingly. 

Management Comments and OIG Analysis 

The Coast Guard provided written comments to this report. 

Following each recommendation is a summary of the Coast 

Guard’s plans and progress in response to our recommendations 

and our analysis. A copy of the Coast Guard’s response is 

included in Appendix B. 

Management Comments to Recommendation #1 

Concur. The Coast Guard will begin its analysis of the Marine 

Inspector Course in the third quarter of FY 2011 and will consider 

new construction and plan review as part of the analysis. These 

tasks will be incorporated into the Performance Qualification 

Standards and curriculum job aids developed for inspectors. The 

Coast Guard anticipates it will implement this recommendation in 

the third quarter of FY 2012. 

OIG Analysis 

We consider the proposed action to be responsive to the 

recommendation. However, this recommendation will remain 

open and resolved until we receive and review the Performance 

Qualification Standards and job aids developed for inspectors that 

include standards and guidelines for the inspection of vessels under 

construction, including an update to the Marine Safety Manual. 

U.S. Coast Guard’s Marine Safety Program – Offshore Vessel Inspections 


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Recording Inspection Results 

Internal controls associated with the recording of the Coast Guard’s 

inspection data need to be improved. Specifically, adequate MISLE user 

guidance should be developed to better guide Marine Inspectors to input 

consistent and complete inspection data into MISLE. OMB Circular A123, as revised, requires that internal controls be in place over information 

systems, including application controls, to ensure that transactions are 

properly authorized and processed accurately and that the data are valid 

and complete. The Coast Guard should establish safeguards to prevent the 

editing and closing of inspection cases until someone other than the 

originating Marine Inspector reviews the cases. 

MISLE User Guidance 

Although the Coast Guard has developed inspection input guidance 

for the examination of foreign vessels, it has not developed 

comprehensive guidance for recording activity data collected 

during domestic vessel safety inspections. The sectors and Marine 

Safety Units we visited in District 8 reported that their inspection 

results are recorded inconsistently from unit to unit. Although a 

vessel owner schedules one inspection, the Coast Guard could 

perform several types of inspection activities at that time. Some 

Coast Guard units record one inspection as one activity, whereas 

other units record one inspection, including the different activities 

that make up that inspection, as several different activities. The 

difference in the way units record inspection data can create the 

appearance that one unit has completed more inspections than 

another unit performing the same amount of work. The data input 

also may not accurately reflect field activity. Although some 

MISLE user guidance does exist, 25 of the 51 Marine Inspectors 

we interviewed expressed some level of concern with the MISLE 

database, including inadequate, incomplete, inconsistent, or 

missing MISLE guidance. 

The Port State Control program uses MISLE data to screen foreign 

vessels and evaluate risk factors applicable to a vessel’s compliance 

with international safety and environmental standards. Vessels 

posing the greatest risk undergo examinations. At one sector we 

visited, the Port State Control examiners are advised to recalculate 

certain data taken from MISLE because the information is 

inaccurate. 

U.S. Coast Guard’s Marine Safety Program – Offshore Vessel Inspections 


Page 8 

 

Personnel interviewed were concerned with the transparency of 

resource allocation decisions based on activity levels as 

represented in MISLE. Although headquarters has recognized this 

as an issue, it has not yet developed interim guidance to clarify and 

correct these inconsistencies. The inconsistencies in data input 

prevent decision makers from obtaining a clear picture of the work 

being done. In addition, these unit-to-unit disparities cause the data 

extracted from MISLE to be inconsistent, which creates more work 

for end users of the data because they have to take different data 

entry methods into consideration. The discrepancies also make it 

difficult for the Coast Guard to accurately report workloads, and can 

affect resource considerations. 

To test the data input into the MISLE system for consistency, we 

compared 62 randomly selected hardcopy Certificates of Inspection 

against data entries in MISLE that corresponded with the same 

certificate activities. Of the 62 hardcopy Certificates of Inspection 

reviewed, 56 did not match the certificate entries made by Marine 

Inspectors in MISLE. In one example, the certificate indicated that 

eight different inspection activities had taken place, while the 

MISLE information indicated only two activities. In another 

example, the Certificate of Inspection indicated that only 3 

inspection activities had taken place, while the MISLE data 

indicated 11 activities. In the cases where the Certificate of 

Inspection information did not match or include the same level of 

detail in MISLE, we could not determine what types of inspections 

were conducted. 

After the prior inspection database crashed in late 2001, MISLE 

was quickly launched, and corresponding guidance and policy 

were never developed. In December 2009, a team of volunteers 

began developing the Domestic Vessel User Guide. Their efforts 

have been delayed because members have been called to assist 

with mission-critical activities, including Haiti relief and 

Deepwater Horizon support. Currently, the project is on hold 

pending the development and implementation of a newer version 

of MISLE. 

Access Controls 

Sufficient internal controls within MISLE to track edits or prevent 

Marine Inspectors from opening and closing their own inspection 

activity have not been established. Inspection cases can be 

reopened by any Marine Inspector at the originating sector or 

U.S. Coast Guard’s Marine Safety Program – Offshore Vessel Inspections 

Page 9 
Marine Safety Unit, but MISLE does not track the changes and 

shows only that the activity was edited. Cases can also be opened 

and closed by the same individual without being reviewed. 

Internal controls, including application controls, must be in place 

over information systems. Application controls should be 

designed to ensure that transactions are properly authorized and 

accurately processed, and that the data are valid and complete. 

Controls should be established at an application’s interfaces to 

verify inputs and output, such as edit checks. 

The Coast Guard uses MISLE data to conduct research on vessel 

history in preparation for safety inspections, to follow up on 

deficiencies recorded in previous inspections, and to support 

findings if appealed by vessel owners. Without adequate access 

controls for MISLE, these data may be faulty. 

Marine Safety program officials said that Marine Inspectors must 

have the access to edit and close activities because it enables 

flexibility and timeliness. However, the chance for mistakes and 

abuse increases when any one individual is able to open, modify, 

and close inspection records. By establishing access controls for 

MISLE data, the Coast Guard would minimize inaccurate 

inspection data. Without such controls, potentially inaccurate 

inspection data may be used throughout all Coast Guard missions to 

report performance and to make resource and operational decisions. 

Recommendations 

We recommend that the Assistant Commandant for Marine Safety, 

Security and Stewardship, U.S. Coast Guard: 

Recommendation #2: Develop and disseminate MISLE user 

guidance for domestic vessel safety inspections. 

Recommendation #3: Augment MISLE access controls, and 

develop subsequent policy, so that the same person cannot open, 

complete, and close an inspection case. 

Management Comments and OIG Analysis 

Management Comments to Recommendation #2 

Concur. The Coast Guard is currently developing policy for the 

data entry of domestic vessel safety inspections into MISLE. User 

U.S. Coast Guard’s Marine Safety Program – Offshore Vessel Inspections 

Page 10 
guides based on this policy for use with the next version of MISLE 

(5.0) are also under development. The Coast Guard anticipates 

completing the development of the policy and user guides from the 

fourth quarter of FY 2011 through the third quarter of FY 2012. 

OIG Analysis 

We consider the ongoing actions to be responsive to the 

recommendation. However, this recommendation will remain 

open and resolved until we receive and review the final and 

disseminated policy and relevant user guides. 

Management Comments to Recommendation #3 

Concur. The Coast Guard will recommend establishing access 

control levels to MISLE 5.0 developers, and provide policy to the 

field regarding opening, completing, and closing an inspection 

case. The Coast Guard anticipates implementing this 

recommendation in the third quarter of FY 2013. 

OIG Analysis 

We consider the proposed action to be responsive to the 

recommendation. However, this recommendation will remain 

open and resolved until we receive confirmation that the Coast 

Guard has recommended establishing access control level to 

MISLE 5.0 developers, and we receive and review the final policy 

disseminated to the field establishing internal controls for opening, 

completing, and closing an inspection case. 

MISLE Database Quality Control 

Not all MISLE entries of vessel inspections and examinations of offshore 

vessels are reviewed for consistency, accuracy, and completeness. 

Further, processes are not in place to detect overdue deficiencies of 

vessels, so some deficiencies have remained unaddressed for as long as 

1 year. OMB Circular A-123, as revised, requires that periodic review, 

reconciliations, or comparisons of data be included as part of the regular 

assigned duties of personnel. 

The Coast Guard units we visited in District 8 have some review processes 

in place, but they are not sufficient to ensure that inspection data are 

consistent, accurate, and complete. In addition, the Coast Guard does not 

formally conduct periodic reviews of inspection cases for domestic vessels 

to ensure that deficiencies have been properly closed. Without mandated 

U.S. Coast Guard’s Marine Safety Program – Offshore Vessel Inspections 

Page 11 
case reviews, the Coast Guard units have established inconsistent practices 

that could cause more work for another Coast Guard unit later. 

Inconsistencies may also allow vessels with overdue deficiencies to 

operate in another Coast Guard unit’s area of responsibility undetected for 

up to a year or until the next reinspection. 

The District 8 office reviews a sample of approximately 10% of all foreign 

vessel examinations each month and 100% of the towing vessel 

examinations, but does not review any domestic vessel inspections. 

Approximately once per month, District 8 staff extracts data of all 

inspection cases in MISLE open for more than 6 months for review. 

Reportedly, all units with open cases are contacted and requested to close 

the open cases or provide an explanation. This review looks only at cases 

that are still open and does not ensure that closed cases are accurate and 

complete. The district reported that it has neither the time nor the 

personnel to devote to additional domestic vessel inspection reviews, 

including those of offshore vessels. During our review, the District 8 

Prevention Department had only 16 individuals working in support of the 

726 Marine Inspection personnel in the field involved with offshore vessel 

safety inspections. 

As of November 2010, 96 domestic offshore vessel inspection cases in 

District 8 remained open for longer than 6 months (see Table 1). For 

example, one case was open for 1,117 days. These 96 inspection cases 

may have associated open deficiencies; however, the Coast Guard does 

not know whether these cases include deficiencies because they have not 

been reviewed. The Coast Guard should improve its process for 

deficiency follow-up to prevent unsafe vessels from operating in U.S. 

waters. If the Coast Guard does not ensure that all deficiencies are closed, 

it cannot ensure the safety of maritime commerce. 

 Table 1. Open Inspection Cases in Excess of 6 Months* 

Days Open Over 

6 Months 

Offshore Vessel Activities 

0–100 days 64 

101–500 days 14 

501+ days 18 

Source: U.S. Coast Guard, as of November 2010 

One sector in District 8 established a local policy and process to follow up 

on all deficiencies issued by Marine Inspectors at the sector. Although it 

is a time-consuming practice, inspection cases are monitored until all 

related deficiencies are closed. Even when a vessel leaves that sector’s 

area of responsibility, the Marine Inspector is required to contact the Coast 

U.S. Coast Guard’s Marine Safety Program – Offshore Vessel Inspections 

Page 12 
Guard unit where the vessel is operating to verify that the vessel owner 

has closed the deficiency. If this follow-up does not occur, deficiencies 

can stay open until the vessel’s next annual inspection. The deficiency 

may not be so severe as to cause serious risk to people or the environment 

if left open until the next re-inspection, but the Coast Guard does not have 

the information to determine the severity of open deficiencies. Consistent 

requirements and procedures across Coast Guard units could minimize 

error, improve the integrity of the inspection data, and ensure greater 

safety of maritime commerce. 

Mandated and enforced case review would ensure that cases and 

associated vessel deficiencies are closed in a timely manner. A case 

review process would also allow a third party to assess the consistency, 

accuracy, and completeness of the data. Regular and consistent inspection 

case review could also improve the accuracy, completeness, and 

consistency of MISLE data used to make key management decisions, 

resource allocations, and mission-critical decisions for vessel inspection 

and investigation activities. 

Recommendation 

We recommend that the Assistant Commandant for Marine Safety, 

Security and Stewardship, U.S. Coast Guard: 

Recommendation #4: Develop and implement formal policy and 

procedures for the periodic review of MISLE inspection activities, 

including the review of open activities, overdue deficiencies, 

follow-up, and closure. 

Management Comments and OIG Analysis 

Management Comments to Recommendation #4 

Concur. The Coast Guard will establish policy for the review of 

MISLE inspection activities by Coast Guard Areas and Districts, 

and establish timelines for MISLE case review completion. The 

Coast Guard anticipates implementing this recommendation in the 

second quarter of FY 2012. 

OIG Analysis 

We consider the proposed action to be responsive to the 

recommendation. However, this recommendation will remain open 

and resolved until we receive and review the final policy and 

U.S. Coast Guard’s Marine Safety Program – Offshore Vessel Inspections 

Page 13 
procedures requiring the periodic review of MISLE inspection 

activities, including the review of open activities, overdue 

deficiencies, follow-up, and closure of inspection records in MISLE. 

Other Concerns 

Additional Towing Vessel Workload 

The Coast Guard Authorization Act of 2010 required the Secretary 

of DHS to issue a final rule regarding new inspection requirements 

for towing vessels. The regulation, to be issued by October 15, 

2011, will transition towing vessels from an uninspected to an 

inspected fleet. The Coast Guard estimates that more than 5,300 

towing vessels in the United States will have to be inspected. 

Although the Coast Guard is taking steps to prepare for inspections 

of towing vessels, adding more than 5,300 vessels will increase the 

Coast Guard’s inspection workload significantly. With an increase 

in inspection work and data entry, consistent policies and procedures 

for MISLE data entry and the review of inspection cases for 

accuracy and completeness will become even more critical. 

U.S. Coast Guard’s Marine Safety Program – Offshore Vessel Inspections 


Page 14 

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Appendix A 

Purpose, Scope, and Methodology 

We conducted this audit to determine whether the Coast Guard has 

the capabilities and resources to conduct inspections of offshore 

vessels to ensure the safety of maritime commerce. We narrowed 

our scope to include the following offshore vessels, as categorized 

by the Coast Guard: 

Commercial Dive Support Vessel 

Floating Production System 

Floating Storage Offloading Vessel 

Lift Boat 

Mobile Offshore Drilling Unit 

Offshore Supply Vessel 

We conducted site visits to Sector New Orleans, LA; Sector Mobile, 

AL; Marine Safety Unit Morgan City, LA; Marine Safety Unit 

Houma, LA; and District 8 in New Orleans, LA. We based our site 

visit selections on offshore vessel inspection data provided by the 

Coast Guard, which showed that approximately 88% of the 

inspections of offshore vessels conducted between January 1, 2009, 

and June 30, 2010, occurred in District 8. At these site visits, we 

interviewed employees and officials, made direct observations, and 

reviewed applicable documents. We also interviewed officials at 

Coast Guard’s headquarters in Washington, DC. 

We performed testing to verify whether qualified Marine Inspectors 

or Port State Control Examiners conducted each inspection, and 

whether the inspections conducted on a particular vessel were the 

inspections required and written on that vessel’s Certificate of 

Inspection. 

We reviewed a random sample of 361 MISLE inspection records. 

We compared those records against qualification dates within the 

Coast Guard’s Training Management Tool database and 

qualification letters. We found that 357 inspections (98.9) were 

conducted by qualified Marine Inspectors or Port State Control 

Examiners, and that 4 inspections (1.1%) were not. 

We requested the Certificates of Inspection for 62 offshore vessels 

operating in District 8. The list of activities performed during each 

annual Certificate of Inspection examination was recorded. We 

also requested the MISLE data for the same 62 offshore vessels. 

The information was filtered to show data from the same year as 

the Certificate of Inspection examinations and that the subsequent 

list of activities was recorded. We compared these two sets of data 

U.S. Coast Guard’s Marine Safety Program – Offshore Vessel Inspections 

Page 15 
Appendix A 

Purpose, Scope, and Methodology 

to determine whether the MISLE data reflected the same activities 

as those listed on the Certificate of Inspection examinations. Our 

testing revealed that only 6 of the 62 vessels showed the same 

number of activities in the MISLE database as was recorded on the 

Certificate of Inspection. 

We reviewed Coast Guard documents, including relevant 

ALCOAST messages and the Marine Inspector Performance 

Analysis Report, dated April 2005, conducted by the Coast Guard’s 

Performance Systems Branch. We also compared the Coast 

Guard’s current Marine Inspector Performance Qualification 

Standards for foreign and domestic vessel safety inspections dated 

October 2007 with corresponding versions that predate October 

2007, to determine the changes over time. We reviewed the 

following Marine Inspector Performance Qualifications Standards: 

Barge Hull Mobile Offshore Drilling 

Unit 

Drydock Machinery Steam Control Verification 

Inspector/Foreign 

Passenger Vessel 

K-Boat Hull-tank Foreign Freight Vessel 

Inspector 

Liferaft Offshore Supply 

Vessel 

Foreign Chemical Tank 

Vessel 

Machinery T-Boat Foreign Tank Vessel 

Inspector 

We conducted this performance audit between April and December 

2010 pursuant to the Inspector General Act of 1978, as amended, 

and according to generally accepted government auditing 

standards. Those standards require that we plan and perform the 

audit to obtain sufficient, appropriate evidence to provide a 

reasonable basis for our findings and conclusions based upon our 

audit objectives. We believe that the evidence obtained provides a 

reasonable basis for our findings and conclusions based upon our 

audit objectives. 

We appreciate the cooperation and courtesies extended to our 

review team by Coast Guard officials. Appendix C identifies 

major contributors to this report. 

U.S. Coast Guard’s Marine Safety Program – Offshore Vessel Inspections 


Page 16 

U'$.o._n,. Hom.I..,d C<Imm..,,"," ((;""'1 !Io<urlty """" ..vo_ ........ United Sla,.. .-_ """"' Go*"

CO"1 Guar"

16700

April 7, 2011

MEMORANDUM

From: Eric P, Chri'lense~ Reply l<> G. L Boone. COR

COMOT (CG-S·n) AllIlof: (202) 372-12IS

'" Anne L Richards. Assi"an,lnspcc1Or General IOf Audits

S"bj: COl>1.\fENTS TO 010 ORAIT REPORT: U.s. COAST MARINE SAfETY

PROGRAM -OfFSHORE VF~"SEL INSPECTIONS

Ref: fa) Your memo did (fl Mar 2011 w/a'taehme;ll

L Thank )'0" for Ille OJlPOl1uniry '0 ,..,view and co",melll 10 your draft "'pon. Specific comm<n1S

and amidpatcd comple'ion and implementation <!ale, art: <oclo,.,<I. Tho: U.s. Co"" Guard ..... no

concern, "i'h Il1e release of 'hi' informalion '0 ,he public.

2. We apprecia'e )'OU! .taff'. external ,,,,,;"w ofour proccs"" ,hat are vilal 10 our Maritime Safety

Mission. If'he", i. anything el", my ....ifcan <10 l<> help "i'h ,hi. ",pon <10 not he.iwe 10 ask.

3. Queslio.... cot><:<:ming 'hi' m=orandum and conttnen" ma)' b< di""'cJ to Commander Lot

Boone a' (202) 372·121 S or ~<OW5.1,b<~'!If·'i,.u<>~.Lnil.

Appendix B 

Management Comments to the Draft Report 

U.S. Coast Guard’s Marine Safety Program – Offshore Vessel Inspections 
 

Page 17
 

Appendix B 

Management Comments to the Draft Report 

Comments to OIG Draft Report: U.S. Coast Guard 
 

Marine Safety Program – Offshore Vessel Inspections 
 

The U.S. Coast Guard has no concerns with the release of this information to the public. 

Recommendation #1: Complete and disseminate to field units New Construction Project 

Inspector Performance Qualification Standards and update the Marine Safety Manual 

accordingly. 

Response: Concur - The analysis of the Marine Inspector Course (MIC) that will begin 

in the 3rd quarter of FY11 will take into account new construction and plan review as 

part of the analysis along with any other new/additional tasks that may be identified. 

These tasks will be incorporated into the PQS and curriculum job aids developed for 

inspectors. 

Anticipated implementation: 3rd Qtr, FY12 

Recommendation #2: Concur - Develop and disseminate MISLE user guidance for 

domestic vessel safety inspections. 

Response: Concur – Policy for MISLE entries of domestic vessel safety inspections is 

currently being developed by CG-543. User guides for the next version of MISLE 

(Version 5.0), based on this policy, is also under construction. 

Anticipated completion: 4th Qtr FY11 through 3rd Qtr, FY12 

Recommendation #3: Augment MISLE access controls, and develop subsequent policy, 

so that the same person cannot open, complete, and close an inspection case. 

Response: Concur – CG-543 will recommend establishing access control levels to 

MISLE 5.0 developers, and provide policy to the field regarding opening, completing, 

and closing an inspection case. 

Anticipated implementation: 3rd Qtr, FY13 

Recommendation #4: Develop and implement formal policy and procedures for the 

periodic review of MISLE inspection activities, including the review of open activities, 

overdue deficiencies, follow-up, and closure. 

Anticipated implementation: 2nd Qtr, FY12 

U.S. Coast Guard’s Marine Safety Program – Offshore Vessel Inspections 


Page 18 

Appendix B 

Management Comments to the Draft Report 

Response: Concur – CG-543 will establish policy for review of MISLE inspection 

activities for Coast Guard AREAS and Districts to follow, and establish timelines for 

MISLE case review completion. 

U.S. Coast Guard’s Marine Safety Program – Offshore Vessel Inspections 


Page 19 

Appendix C 

Major Contributors to this Report 

Brooke Bebow, Audit Director 

Andrea Rambow, Audit Manager 

Emily Pedersen, Program Analyst 

Gwen Priestman, Program Analyst 

Rebecca Mogg, Program Analyst 

Keith Nackerud, Program Analyst 

Katrina Bynes, Program Analyst 

Matthew Noll, Independent Referencer 

U.S. Coast Guard’s Marine Safety Program – Offshore Vessel Inspections 


Page 20 

Appendix D 

Report Distribution 

Department of Homeland Security 

Secretary 

Deputy Secretary 

Chief of Staff 

Deputy Chief of Staff 

General Counsel 

Executive Secretariat 

Director, GAO/OIG Liaison Office 

Assistant Secretary for Office of Policy 

Assistant Secretary for Office of Public Affairs 

Assistant Secretary for Office of Legislative Affairs 

Office of Management and Budget 

Chief, Homeland Security Branch 

DHS OIG Budget Examiner 

Congress 

Congressional Oversight and Appropriations Committees, as 

appropriate 

U.S. Coast Guard’s Marine Safety Program – Offshore Vessel Inspections 
 

Page 21
 

ADDITIONAL INFORMATION AND COPIES 

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fax your request to (202) 254-4305, or visit the OIG web site at www.dhs.gov/oig. 

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Attention: Office of Investigations - Hotline, 

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