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NMMA’s Public Comments on USCG-2011-0497 as a Wordle

We covered the National Marine Manufacturers Association NMMA public comments on the U.S. Coast Guard (USCG) Advance Notice of Proposed Rulemaking on Recreational Vessel Propeller Strikes and Carbon Monoxide Poisoning in our regulations section.

At the close of our coverage, we presented a wordle of NMMA’s comments.

This post presents a much larger version of that wordle. Read More→

Review of public comments on U.S. Coast Guard’s (USCG) Advanced Notice of Proposed Rulemaking titled, Recreational Vessel Propeller Strike and Carbon Monoxide Poisoning Casualty Prevention. Comments were due by November 25, 2011.

We were disappointed with the total number of responses, but thank all those on both sides of the propeller safety issue for responding.

As of today, December 2nd, USCG lists a total of 27 items in that docket. We will list and briefly summarize them below, by Docket Item Number. Read More→

0 Categories : Regulations

The U.S. Coast Guard (USCG) requested public comments for their Advanced Notice of Proposed Rulemaking titled, Recreational Vessel Propeller Strike and Carbon Monoxide Poisoning Casualty Prevention. National Marine Manufacturing Association (NNMA) responded on November 25, 2011.

NMMA Public Comment Letter on USCG-2011-0497

NMMA Public Comment Letter on USCG-2011-0497

While we may not agree with the six page letter written by Cindy Squires it was very well written. She has a law degree, works from NMMA’s Washington D.C. Office, and now often writes environmental and safety regulatory responses, in place of John McKnight who wrote many previous similar documents. She is NMMA’s Chief Counsel for Public Affairs & Director of Regulatory Affairs.

NMMA’s letter is easy on the eyes, makes good use of open space, uses over sized top and bottom margins, and is arranged into six numbered sections, with section six being the conclusion. Their comments are printed on NMMA’s letterhead with the blue wave at the bottom of page one and NMMA’s logo in the top left. We discuss each numbered section of their letter below. Read More→

0 Categories : Regulations

USCG published an advanced notice of proposed rulemaking (NPRM) for Recreational Vessel Propeller Strike and Carbon Monoxide Poisoning Casualty Prevention, USCG-2011-0497, in the Federal Register on August 26, 2011.

The deadline for public response was November 25, 2011.

The U.S. Coast Guard sought comments on specific measures to protect recreational boaters in the water at the stern. Similar to the earlier Kill Switch NPRM, it asked a large number of very specific questions. Read More→

0 Categories : Regulations

Kill Switch Lanyard

Lanyard photo courtesy of The U.S. Coast Guard

The United States Coast Guard (USCG) published an Advanced Notice of Proposed Rulemaking (Regulations) in the Federal Register on June 8, 2011. The proposal is titled, Installation and Use of Engine Cut-Off Switches on Recreational Vessels.

As part of the proposal, the Coast Guard also published a Preventable Fatalities and Injuries Report listing boating accidents from 2002 through 2006 in which the use of an Engine Cut-Off Switch / Kill Switch would have likely prevented the fatalities or injuries resulting from an operator falling overboard or otherwise being ejected.

The USCG proposal includes a Background Section with a history of the Coast Guard’s efforts to reduce vessel and propeller strikes since about 1990.

While the Coast Guard engine cut-off proposal seeks input on almost countless points, the two primary kill-switch issues being debated are: Read More→

0 Categories : Regulations