U.S. Coast Guard Updates Marine Casualty Reporting Forms

by Blank Rome LLP
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Action Item: The U.S. Coast Guard released an updated version of the CG-2692 forms for reports of marine casualties, commercial diving casualties, and outer continental shelf-related casualties. Vessel owners and operators are encouraged to review the new forms and ensure the new forms are used for future reports.

New Development

On July 1, 2016, the U.S. Coast Guard released a new version of the CG-2692 forms for reports of marine casualties, commercial diving casualties, and outer continental shelf-related casualties. The new forms streamline required fields, introduce new addendums for involved persons and personnel casualties, and allow for electronic completion and signature. The new CG-2692 is available here and the complete series is here (Homeport website under "Investigations," "Casualty Reporting Forms"). The old CG-2692 forms may be used until December 31, 2016, but it is recommended that companies start the transition to the new forms now.

Background

The old CG-2692 forms have remained largely unchanged for nearly 40 years. Over the past three years, however, the Coast Guard has worked to revise and modernize the forms to make them less cumbersome and time consuming to complete. As part of this effort, the Coast Guard also released the Navigation and Vessel Inspection Circular 01-15 ("NVIC"), Marine Casualty Reporting Procedures Guide with Associated Standard Interpretations, in July 2015 with the purpose of clarifying and assisting vessel owners and operators in understanding the marine casualty reporting requirements.

New CG-2692

The new CG-2692 has been streamlined to remove unnecessary data fields and revised to better align with the requirements of, and terminology used in, applicable laws and regulations. For example, for a single vessel marine casualty, the old form required completion of 75 data fields, whereas the new form requires only 40. The Barge Addendum and Report of Mandatory Chemical Testing Following a Serious Marine Incident have also been updated. In addition, two new addendums have been introduced. An Involved Persons and Witnesses Addendum, CG-2692C, allows for easy listing of any involved persons or witnesses and a Personnel Casualty Addendum, CG-2692D, allows for easy listing and description of injured, dead, or missing persons.

The new CG-2692 forms may be filled out electronically, including a digital signature, and emailed to the nearest Coast Guard office. The Coast Guard’s goal is to eventually make the CG-2692 forms able to be completed and submitted entirely online, with the information automatically going to the nearest Coast Guard field unit based on the geographic location provided on the form.

The new CG-2692 forms are available and should be used for all future reportable casualties. However, the old versions of the forms may be used until December 31, 2016. It is important to note that the revision of the CG-2692 forms has not changed the marine casualty reporting requirements, but merely updated the forms by which such reports are submitted. For further guidance on marine casualty reporting, see our previous article, available here.

Conclusion

The new CG-2692 forms are intended to reduce the burden of marine casualty reporting on vessel owners and operators. Owners and operators are encouraged to review the new forms and begin to use them for future marine casualty reports.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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