USCG NBSAC 92: Our Public Comments
Nonprofit Grant Comments
For the first time ever, they invited public comments about non-profit grant interest areas before the meeting. Each year the Coast Guard awards nonprofits a tidy some of money to promote boating safety and to run some studies, like the annual life jacket wear rate study. In 2013, the grants totaled over $5.5 million. Many boating safety organization live and die by these grants.
USCG released their advance list of proposed grant areas and invited the public to comment on them or suggest additional areas of interest.
Our non-profit grant public comment letter suggested two additional areas of interest.
1. A survey of kill switch wear rates
2. A test of the ability of boat operators to quickly recognize the many phrases used to represent kill switches and kill switch lanyards
Our and other comments concerning non-profit grants can be viewed on regulations.gov at uscg-2014-0911.
Agenda Item Public Comments
USCG also invited public comment on agenda items for the meeting itself. We sent two separate comment letters.
1. Our first public comment letter encouraged USCG to make over 10,000 reported accidents from 2009-2013 visible to manufacturers and boating safety professionals. These reported accidents are currently not included in Releasable BARD, USCG’s Boating Accident Report Database.
Our first letter was accompanied by an 11 page handout providing charts detailing the reported but invisible accidents.
Our first agenda public comment letter and handout are inline with our recent series of six posts detailing the duty boat and marine drive manufacturers have to monitor their products in the field after sale for potential safety issues. These six posts also explain the importance of making the over 10,000 BARD reported accidents that are currently invisible to manufacturers visible so they can fulfill their duty.
2. Our second agenda public comment letter tries to draw attention the number of large outboard motors striking submerged objects and flipping into boats while still under power. It encourages manufacturers to recognize the problem and take actions to prevent future similar accidents. The letter also notes we were are limited in our ability to identify such accidents with over 10,000 reported accidents currently invisible to us (see our first public comment letter.)
Our agenda comments and others will be viewable on Regulations.gov at uscg-2010-0164 if they can get the page fixed.
We put considerable effort into writing these three comment letters and hope they are actually read and considered by NBSAC members and don’t just get filed somewhere.
We appreciate USCG allowing us to submit these comments.