RBTCP SOW .pdf

STATEMENT OF WORK (SOW)

RECREATIONAL BOAT TESTING AND COMPLIANCE INSPECTION PROGRAM

U.S. COAST GUARD (USCG)

BOATING SAFETY DIVISION AND PRODUCT ASSURANCE BRANCH

1.0 GENERAL

1.1 Scope

The purpose of this requirement is to acquire technical and management services for the Coast

Guard’s Recreational Boat Testing and Compliance Program (RBTCP). The RBTCP enforces the requirements of 46 USC 43 and 33 CFR Subchapter S. This work consists of:

1. inspecting boats to ensure compliance with applicable requirements at manufacturer facilities, boat shows, boat dealers and other designated locations;

2. testing recreational boats that are less than 20 feet in length for compliance with flotation requirements; and

3. testing associated marine equipment, specialized boats and equipment manufactured for sale in the United States.

1.2 Background

The Recreational Boating Product Assurance Branch (CG-BSX-23) of the Coast Guard’s Office of Auxiliary & Boating Safety (CG-BSX) is responsible for oversight and enforcement of

Federal requirements for recreational boats and associated marine equipment. This work is conducted under the auspices of the RBTCP, which was launched in October 2003 and in the last option year of the current contract will test 35 boats for compliance with flotation requirements and inspect approximately 490 manufacturers, 200 dealers and 10 boat shows to ensure boat builder compliance with federal laws and regulations. The number of recreational boat builders is constantly changing, and to allow the most flexibility to verify compliance with federal laws and regulations, the Coast Guard seeks to establish a minimum number of manufacturer, dealer and boat show inspections per year, with the option of adding more inspections on a contract year basis based on mission requirements and funding availability.

The Federal Boat Safety Act of 1971, as codified into Title 46 United States Code Chapter 43, gives the Coast Guard authority to establish minimum safety standards for recreational boats and associated equipment and authorizes the Coast Guard to conduct inspections of recreational boat manufacturing facilities to ensure compliance with Federal boating safety regulations. The first

Federal regulations were adopted from industry standards published by the American Boat and

Yacht Council (ABYC) and other boating industry associations. These minimum standards covered boat identification, safe loading, safe powering, and flotation for boats less than 20 feet in length. Eventually, regulations for level flotation, electrical systems, gasoline fuel systems, ventilation, start-in-gear protection for outboard motors, navigation lights and engine cut-off switches were added.

One element of oversight and enforcement is accomplished by physically testing boats and associated marine equipment for compliance with these Federal safety regulations. Boats are purchased on the open market, targeting those boats that are likely to fail one or more segments of the testing procedure. If a boat fails the initial test, the manufacturer is required to repair it so that it complies with flotation regulations, and it is then retested. If the boat passes the original test it is sold, and if it fails it is sold after it is successfully retested. Historically, approximately

70% of all boats acquired for testing fail the initial test, and an ongoing goal of the test program is to identify and remove noncompliant boats from the market. In addition to testing boats and associated equipment at their facility, the Contractor also administers testing of specialty boats and associated equipment utilizing recognized laboratories and testing facilities.

1.3 Contractor Personnel

1.3.1 Project Manager. The Contractor shall provide a single Project Manager who shall be responsible for all Contractor work performed under this contract. The Project Manager is further designated as Key by the Government (SOW 1.4).

1.3.1.1 The Project Manager shall be the single point of contact for the Contracting Officer and the Contracting Officer’s Representative (COR). The Project Manager shall be one of the senior level employees provided by the Contractor for work under this contract. During any absence of the Project Manager, only one alternate shall have full authority to act for the Contractor on all matters relating to work performed under this contract. The Project Manager shall be able to read, write, speak, and understand English. The Contractor shall not replace the Project Manager without prior written notification to the COR and prior written approval of the Contracting

Officer.

1.3.1.2. The Project Manager shall be available to the COR via telephone between the hours of

0800 and 1700 Eastern Time, Monday through Friday, and shall respond to a request for discussion or resolution of technical problems within one (1) business day of notification.

1.3.1.3 All technical communications between the Contractor and the Government shall normally be through the Project Manager and the COR. At times, Compliance Inspectors may find it necessary to consult directly with a Coast Guard Marine Investigator or Engineer for compliance or technical guidance; the Project Manager shall be responsible for ensuring all technical issues raised by field Compliance Inspectors, when resolved, are posted in the Compliance Inspector

Notations section of the Recreational Boating Safety Database (RBSDB).

1.3.2 Personnel Qualifications. The Contractor shall provide qualified personnel to perform all requirements specified under this contract within two (2) months of the contract award date.

Contractor personnel will be deemed qualified if they:

1. are legal residents of the United States;

2. have at least six months experience with inspecting, manufacturing, or surveying recreational or commercial boats;

3. have passed the Coast Guard’s Recreational Boat Compliance Specialist Exam; and

4. have met the Coast Guard’s personnel qualification standard for the position of

Compliance Inspector and/or Boat Test Engineer (SOW 3.0).

Upon providing proof of the qualification requirements above, each contractor employee will receive a letter designating the person as qualified from the Chief of the Recreational Boating

Product Assurance Branch (CG-BSX-23). The contractor will not allow any member to conduct the respective tasks of Compliance Inspector or Boat Test Engineer on their own without a qualification letter signed by the Chief of the Recreational Boating Product Assurance Branch

(CG-BSX-23).

The contractor shall ensure that at least two persons are qualified as Boat Test Engineer (one primary Boat Test Engineer and one secondary), and a minimum of three persons are qualified as

Compliance Inspectors to conduct all aspects of the compliance inspections. Any of the three

Compliance Inspectors cannot also be the primary Boat Test Engineer.

1.3.3 Employee Conduct. Contractor employees shall present a professional appearance at all times and their conduct shall not reflect discredit upon the Coast Guard. Each contractor employee is authorized to wear a shirt with the logo of the Coast Guard’s Office of Auxiliary &

Boating Safety. These shirts are provided at the contractor’s expense. The COR will provide the contractor with the digital logo for use.

1.3.3.1 Removing Employee for Misconduct. The Government may, at its sole discretion, direct the contractor to remove any employee for misconduct. Such removal does not relieve the contractor of the responsibility to provide the required services under this contract.

1.3.4 Employee Safety. Contractor shall ensure safety regulations are adhered to and that employees wear appropriate safety attire when working in the contractor’s boat test facility or when visiting manufacturing sites.

1.3.5 Conflict of Interest. The Contractor shall not employ any person who is an employee of the United States Government if that employee would, or could appear to, cause a conflict of interest. Any contractor employee who previously worked for a manufacturer shall not conduct compliance inspections on that manufacturer. All conflict-of-interest issues will be reported to and coordinated with the Contracting Officer. Prior to conducting any private flotation testing the contractor will notify the COR.

1.4 Key Personnel. Before replacing any individual designated as Key by the Government, the

Contractor shall notify the Contracting Officer and the COR in advance, submit written justification for replacement, and provide the name and qualifications of any proposed substitute(s). All proposed substitutes shall possess qualifications equal or superior to those of the Key person being replaced. The Contractor shall not replace Key Contractor personnel without written approval and acknowledgement from the Contracting Officer. Key personnel for the anticipated contract will be the Project Manager and the Primary Boat Test Engineer.

1.5 Security. Contractor access to the Coast Guard’s RBSDB is required under performance of contract and the information contained in the database must be treated as Sensitive but

Unclassified information. Contractor employees shall safeguard this information against unauthorized disclosure or dissemination. The Contractor shall not release any information in, or derived from, the RBSDB without written authorization of the COR.

1.5.1 Non-Disclosure Agreements. The contractor shall require all persons not employed for work under this requirement to sign a non-disclosure statement when afforded the opportunity to observe any testing or inspections accomplished in accordance with any requirement of this contract. This requirement does not apply to Government employees.

1.6 Period of Performance. The period of performance of this requirement is a one (1) year base period with four (4) one-year option periods.

1.7 Place of Performance.

1.7.1 Boat Test Facility Location. All work performed in accordance with recreational boat testing shall be performed at the Contractor’s facility, which must be located in the Continental

United States. The Contractor may engage a subcontractor to conduct boat and associated equipment testing at a location determined by the subcontractor with the approval of the COR.

1.7.2 Inspection Locations. All work performed in accordance with recreational boat compliance inspections shall take place at individual recreational boat manufacturing locations, retail facilities and boat shows located in the Continental United States, Alaska, Hawaii, Puerto

Rico, U.S. Virgin Islands, Guam, and any other U.S. Territory. Additionally, compliance inspections may be conducted in Canada, Mexico or other foreign countries if mutually agreed upon between the contractor and the Coast Guard.

1.8 Travel. Travel is required. The Contractor will be reimbursed for transportation expenses in accordance with the Federal Acquisition Regulations (FAR) – subsection 31.205-46.

1.8.1 Travel Funding Expenditure Notice. When the Contractor expects total funding expended for travel to reach 75 percent of the total funds available on each travel Contract Line-

Item Number (CLIN), the Contractor shall notify the COR. The notice shall state the estimated amount of additional funds required to continue performance for the period specified in the

Schedule.

1.9 Kick-Off Meeting. The Contractor shall attend a Kick-Off Meeting with the Contracting

Officer and the COR no later than five (5) business days after the date of the award. The purpose of the Kick-Off meeting, which will be chaired by the Contracting Officer, is to discuss objectives and review the Contractor’s Project Execution Plan. The Kick-Off meeting shall be held virtually via teleconference or at the Government’s facility.

1.10 Progress Meetings. The Project Manager shall meet with the COR on a monthly basis, or a less frequent schedule as determined by the COR to discuss program progress, exchange information, and resolve emergent technical problems and issues. These meetings shall normally take place via video conference but may be in-person at a location mutually agreeable to the contractor and the Coast Guard.

1.11 Intellectual Property. All data, electronic media, video productions, photographs, and procedures developed by work conducted on this contract are the property of the Government.

The Contractor will not release any of this material unless the Coast Guard gives explicit written permission for release. At the completion of this contract, all data shall be returned to the Coast

Guard. Not later than thirty (30) calendar days prior to the end of the final period of performance of the contract, the Contractor shall request return/disposition instructions from the COR.

2.0 REQUIREMENTS.

2.1 Administrative Procedures, Project Execution Plans, Manuals, and Reports

2.1.1 Draft Project Execution Plan. At the kick-off meeting the Contractor shall submit a detailed draft Project Execution Plan for the COR’s review. The Project Execution Plan shall provide policies and procedures for how the Contractor shall meet all the requirements in the

SOW and provide all the deliverables such as timelines for qualification of inspectors, number of inspectors etc. The COR will provide comments on the draft plan within five (5) business days of receipt of the draft project execution plan.

2.1.2 Final Project Execution Plan. Within five (5) business days after receiving feedback from the COR concerning the Draft Project Execution Plan, the Contractor shall deliver for approval, a final Project Execution Plan.

2.1.3 Compliance Inspectors Manual. Within fifteen (15) business days after the kick-off meeting, the Contractor shall develop a manual for use by the Contractor’s Compliance

Inspectors from existing Government established Compliance Program materials. A comprehensive Compliance Inspector’s manual describing the procedures and requirements necessary to successfully perform a manufacturer inspection while minimizing disruption to a manufacturer's operations. A copy of this manual will be provided to each inspector. The

Compliance Inspectors Manual shall include:

• Annual compliance inspector training plan;

• Inspection scheduling plan;

• How to handle non-cooperative and non-responsive manufacturers;

• Standardized “leave behind documents” (folder that has inspection related information);

• How to collect, package, and ship samples of boats and associated equipment that are collected for testing at the direction of the COR;

• Post Incident inspection procedures;

• Manufacturer Compliance Inspection Checklist; and

• Recreational Boat Reference Chart & Inspection Items.

The Compliance Inspector Manual shall not be implemented until approved by the Government.

The COR will provide written comments on the submitted Compliance Inspector Manual within five (5) business days of receipt of the Compliance Inspector Manual from the contractor. The contractor will provide a final copy of the manual to the COR within five (5) days after receipt of the COR’s comments.

2.1.3.1 Contractor shall review the Compliance Inspector Manual annually and submit changes to the COR for review within thirty (30) business days after the exercise of each option period.

The COR will provide written comments on any submitted changes within five (5) business days.

2.1.3.2 Contractor will post “Lessons Learned” and “CI Notations” to the Lessons Learned section of the RBSDB. Lessons learned document policy changes and CI Notations address issues encountered during any inspection and describe how they were resolved.

2.2 Compliance Inspector Training. In addition to initial personnel qualifications, the contractor shall conduct an initial training with all compliance inspectors present and annual training with all compliance inspectors present every contract year thereafter. The contractor shall provide the training plan to the COR fifteen (15) business days prior to the training date, the annual training plan shall be reviewed by the COR. The COR will provide written comments on the contractor’s Compliance Inspector training program within five (5) business days of receipt.

2.2.1 Initial Training. Initial training should be conducted within thirty (30) business days of contract award. The training shall cover the references listed in SOW 3.0 and 5.0, the

Compliance Inspectors Manual (SOW 2.1.3) and the RBSDB. The training shall also provide

Compliance Inspectors with communication, record keeping and other skills necessary for

Compliance Inspectors to present themselves in a professional and effective manner.

2.2.2 Annual Training. Annual training shall ensure that Compliance Inspectors remain current with federal laws and regulations, current Coast Guard policies as well as changing trends in the manufacture of recreational boats. Compliance Inspectors shall attend the first NMMA

Engineering Compliance Seminar offered after contract award and every other year thereafter.

Training offered by organizations such as the American Boat and Yacht Council (ABYC), the

National Association of State Boating Law Administrators (NASBLA), or other sources that provide technical instruction in areas relative to boat structures and marine systems can be included as part of the training plan.

2.3 Compliance Inspection & Testing Administration

2.3.1 Compliance Inspection Reference Chart. All inspections will be conducted to the requirements listed in the compliance inspection reference chart provided in SOW 3.0.

2.3.2 Inspection Scheduling. The contractor shall schedule all inspections.

2.3.2.1 Manufacturer inspections. The Contractor shall schedule all manufacturer inspections utilizing a list of manufacturers provided by the COR at the beginning of the contract year.

2.3.2.2 Dealer/ Boat Show inspections. Dealer and boat show inspections shall be approved by the COR in advance and should be proposed by the contractor to avoid duplication of manufacturers and also provide geographic diversity.

2.3.2.3 Remote Education inspections. Upon notification from the Coast Guard of new MIC assignments the contractor will schedule remote education inspections at a date/time agreeable to the contractor and the new MIC assignee.

2.3.2.4 Remote Manufacturer inspections. If options for this inspection type are exercised, the

COR will provide a list of manufacturers to the contractor.

2.3.3 Administrative Reports Required. The contractor is required to provide the Coast Guard with two administrative reports. Examples of these reports can be found in SOW 3.0.

Report Type When Due Delivered by/Located in

Boat Acquisition Report Real-Time In RBSDB

Monthly Status Report First week of each month PDF via email

2.3.4 Case Reports. The Contractor shall submit all data collected through manufacturer, dealer and boat show inspections and testing to the Coast Guard’s RBSDB. The Coast Guard will ensure that the contractor has access to the RBSDB. The Contractor shall designate each compliance inspection as a case with a unique tracking number. Each case commences with a visit and ends when all comments, conflicts, and any other pending issues have been resolved.

The format of case numbers will start with the calendar year, followed by a two-letter designator for the case type, and ending with a sequential 4-digit case serial number.

The case type designators are as follows:

• BS - Boat Show Inspections.

• CG - Boat Test.

• DL - Dealer Inspections.

• MF - Manufacturer Inspections.

• RE - Remote Education Inspections.

• RI - Remote Manufacturer Inspections.

For example, case number 24CG0003 indicates that:

• the boat was tested in calendar year 2024;

• CG designates it as a boat test; and

• 0003 demonstrates that it was the 3rd boat tested that year.

For boat tests that require one or more retests, a suffix of R1, R2, and R3 will be used after the case serial number to denote how many re-tests have been done on a boat. For example, case number 24CG0003R2 indicates that:

• the boat was tested in calendar year 2024;

• CG designates it as a boat test;

• 0003 demonstrates that it was the 3rd boat tested that year; and

• R2 shows that it is the second re-test on a boat.

In this particular example, there should also be a report for the original test (24CG0003) and the first retest (24CG0003R1).

2.3.5 Manufacturer Notification of Inspection/Test Results. The Contractor shall use a standard notification letter format provided in SOW 3.0 for drafting inspection and test results for delivery to manufacturers. The Contractor shall send all notification letters to CG-BSX-23 no later than two (2) business days after approval from CG-BSX-23. Contractor shall utilize the

RBSDB to store all notification letters generated for manufacturers during the performance period.

2.4 Recreational Boat Compliance Inspections

2.4.2 Number of Inspections. Once the Final Project Execution Plan (SOW 2.1.2) and

Compliance Inspector Manual (SOW 2.1.3) are accepted by the Government, the Contractor shall conduct a minimum of:

• 550 recreational boat manufacturer inspections per year, with 2 options for 50 additional manufacturer inspections for each option.

• 250 remote education inspections, with 2 options for 25 additional remote education inspections for each option.

• 20 dealer inspections, with 1 option for 10 additional dealer inspections.

• 5 boat show inspections,

• 50 optional remote manufacturer inspections - The Coast Guard may also exercise two options of 25 each for each contract year.

Options may be exercised based on funding availability and mission requirements. Inspections will primarily be conducted at manufacturing and importer facilities that are actively manufacturing or importing boats and have products available for inspection. Repeat visits shall be scheduled only at the direction of the COR.

2.4.2.1 Manufacturer Inspections (MF)

Manufacturer inspections are intended to determine the manufacturer’s overall compliance with safety standards. During the physical inspection the compliance inspector will utilize a holistic approach to look at various models at the different stages of build if available. The compliance inspector should utilize any vessel(s) necessary to determine compliance per the Recreational

Boat Reference Chart & Inspection Items table in SOW 3.0. For manufacturers with exemptions or utilizing an equivalency, the contractor will inspect to the technical requirements of the exemption or equivalency.

Where access to vessel inspection items is restricted, all reasonable inspection efforts should be made to view entire systems. This may include opening of engine hatches, inspection ports, removing minor obstructions such as inspection plates or speakers, and utilizing cameras, borescopes, etc. to capture the complete system.

Manufacturer inspections will consist of:

1. Pre-inspection. This is an initial scheduling call. This will set expectations and determine:

a. the date and time of inspection;

b. how long the inspection is anticipated to take;

c. type and length of vessels being built;

d. list of models in production with anticipated production levels; and

e. required documents. (e.g. first purchaser’s list, capacity, flotation, and powering calculations for all applicable models.)

Note: Compliance inspectors will review all documentation prior to scheduled inspections.

2. In-brief. Upon arriving at the facility, the compliance inspector will meet with the company point of contact and:

a. Set expectations of the inspection;

b. Verify the company’s MIC profile within the RBSDB;

c. Review of exemptions and equivalencies (if applicable);

d. Review required documents;

e. Review of any outstanding cases or campaigns or Coast Guard correspondence;

f. Review of Coast Guard websites, Boating Safety Circulars, USCG/ABYC Risk

Mitigation Seminar.

3. Physical inspection

a. Using the documents provided by the manufacturer, the Manufacturer Inspection

Compliance Checklist and the Recreational Boat Reference Chart & Inspection

Items found in SOW 3.0, the inspector will review all available models in production and discuss all aspects of the regulations as well as voluntary standards specified by the Coast Guard.

b. The inspector will utilize a multitude of inspection devices to help facilitate a full and comprehensive inspection that may include borescopes, inspection mirrors, multi-meters, tape measure etc.

4. Out-brief

a. Inspection results overview;

b. Any items that require follow up (contractor deliverables/ manufacturer deliverables) and what the next steps are;

c. Coast Guard Engineer POCs; and

d. Questions.

5. Post inspection

a. Enter data into the RBSDB;

b. Communicate any unusual circumstances to the Coast Guard; and address any follow up issues with the manufacturer.

2.4.1.2 Remote Education inspections (RE).

Remote Education inspections are for new builders that have been recently assigned a MIC.

Within thirty (30) calendar days of notification by the Coast Guard of MIC issuance, the compliance inspector will schedule a Remote Education inspection, at a date/time mutually agreeable to both the compliance inspector and the manufacturer. These inspections are intended to provide a new builder with a Coast Guard education of what to expect as a builder and should provide preventative action to ensure that a new builder starts off on the right foot. All remote inspections will require access to various online meeting platforms such as Google Meet, MS

Teams or Zoom.

Remote Education inspections will consist of:

a. the date and time of inspection;

b. how long the inspection is anticipated to take;

c. type and length of vessels being built;

d. list of models in production with anticipated production levels; and

e. required documents. (e.g. first purchaser’s list, capacity, flotation, and powering calculations for all applicable models.)

Note: Compliance inspectors will review all documentation prior to scheduled inspections.

2. In-brief. At the beginning of the meeting, the compliance inspector will meet with the company point of contact and:

a. Set expectations of the education discussion;

b. Verify the company’s MIC profile within the RBSDB;

c. Review required documents;

d. Review of Coast Guard websites, Boating Safety Circulars, Boat builders

Handbook, USCG/ABYC Risk Mitigation Seminar.

3. Education discussion

a. Review lengths and types of boats intended to be produced;

b. Discuss statutory and regulatory requirements and applicable voluntary standards; and,

c. Discuss recordkeeping and defect notification requirements

4. Out-brief

a. Any items that require follow up (contractor deliverables/ manufacturer deliverables) and what the next steps are;

b. Coast Guard Engineer POCs; and

c. Questions.

5. Post inspection

a. Enter data into the RBSDB;

b. Communicate any unusual circumstances to the Coast Guard; and

c. Address any follow up issues with the manufacturer.

2.4.1.3 Dealer Inspections (DL)

The purpose for dealer inspections is to ensure that recreational boats offered for sale to the public comply with all Federal minimum safety standards using the Recreational Boat Reference

Chart & Inspection Items table found in SOW 3.0. A minimum of ten (10) boats are to be inspected at each dealer unless otherwise approved by the COR. Dealer inspection reports will be completed in the same fashion as manufacturer reports to the greatest extent possible. The

Compliance inspector will coordinate dealer inspections to ensure that large dealers with multiple locations are not repeated within a contract year. All vessel inspections will incorporate every facet of requirements and will not negatively impact the dealer. This may include opening of engine hatches, inspection ports, removing minor obstructions such as inspection plates or speakers, and utilizing cameras, borescopes, etc. to capture the complete system.

Dealer inspections will consist of:

1. In-brief. At the beginning of the inspection, the compliance inspector will meet with the dealer point of contact and:

a. Set expectations of the inspection;

b. Review of Coast Guard websites, Boating Safety Circulars, Boat builders

Handbook, USCG/ABYC Risk Mitigation Seminar.

2. Physical inspection

a. Using the documents provided by the manufacturer, the Manufacturer Inspection

Compliance Checklist and the Recreational Boat Reference Chart & Inspection

Items found in SOW 3.0, the inspector will review all available models in production and discuss all aspects of the regulations as well as voluntary standards specified by the Coast Guard.

b. The inspector will utilize a multitude of inspection devices to help facilitate a full and comprehensive inspection that may include borescopes, inspection mirrors, multi-meters, tape measure etc.

3. Out-brief

a. Any items that require follow up and what the next steps are;

b. Questions.

4. Post inspection

a. Enter data into the RBSDB

b. Communicate any unusual circumstances to the Coast Guard.

2.4.1.4 Boat Show Inspections (BS)

The purpose for boat show inspections is to ensure that recreational boats offered for sale to the public comply with all Federal minimum safety standards using the Recreational Boat Reference

Chart & Inspection Items table found in SOW 3.0. They allow for a large-scale cursory inspection of boat and associated equipment manufacturers and new and emerging technology.

These inspections are intended to both, allow for the inspector to identify compliance failures as well as familiarize themselves with new technology, trends, new models, and imported vessels.

A minimum of 20 boats are to be inspected at each boat show. Boat Show inspection reports will be completed in the same fashion as dealer reports to the greatest extent possible.

2.4.1.4.1 Boat show visits should be distributed across the country and each boat show must be approved by the COR. Approval request must include date, location, anticipated manufacturer attendance.

2.4.1.4.2 Boat Show inspections will consist of:

1. Physical inspection

a. Using the documents provided by the manufacturer, the Manufacturer Inspection

Compliance Checklist and the Recreational Boat Reference Chart & Inspection

Items found in SOW 3.0, the inspector will review all available models in production and discuss all aspects of the regulations as well as voluntary standards specified by the Coast Guard.

b. The inspector will utilize a multitude of inspection devices to help facilitate a full and comprehensive inspection that may include cameras, borescopes, inspection mirrors, multi-meters, tape measure etc.

2. Post inspection

a. Enter data into the RBSDB.

b. Communicate any unusual circumstances to the Coast Guard.

2.4.1.5 Remote Manufacturer Inspection (RI).

The purpose for remote manufacturer inspections is to ensure that recreational boats offered for sale to the public comply with all Federal minimum safety standards. This is a new program that aims to determine compliance with applicable regulations through submission of a technical file to the Coast Guard and a subsequent meeting to review that technical file via video conference using platforms such as Google Meet, MS Teams or Zoom. Examples of documents that may be included in the technical file and submitted to the compliance inspector and reviewed prior to the remote inspection are:

• first purchasers list;

• photos of capacity labels;

• photos of HINs;

• photos of fuel hoses;

• installation diagrams;

• flotation testing videos/photos; and

• other applicable documents to prove compliance.

2.4.1.5.1 Remote Manufacturer Inspections must be directed by the COR. Documentation provided by manufacturers will be stored in the RBSDB.

2.4.1.5.2 A Remote Manufacturer Inspection (RI) will consist of:

a. the date and time of inspection;

b. how long the inspection is anticipated to take;

c. type and length of vessels being built;

d. list of models in production with anticipated production levels; and

e. required documents. (e.g. first purchaser’s list, capacity, flotation, and powering calculations for all applicable models.)

Note: Compliance inspectors will review all documentation prior to scheduled inspections.

2. Inspection

a. In-brief. Upon start of the meeting, the compliance inspector will meet with the company point of contact and:

i. Set expectations of the inspection;

ii. Verify the company’s MIC profile within the RBSDB;

iii. Review of exemptions and equivalencies (if applicable);

iv. Review required documents;

v. Review of any outstanding cases or campaigns or Coast Guard correspondence;

vi. Review of Coast Guard websites, Boating Safety Circulars, USCG/ABYC

Risk Mitigation Seminar.

b. Document review

i. Using the documents provided by the manufacturer, the Manufacturer

Inspection Compliance Checklist and the Recreational Boat Reference

Chart & Inspection Items found in SOW 3.0, the inspector will review all available models in production and discuss all aspects of the regulations as well as voluntary standards specified by the Coast Guard.

c. Out-brief

i. Inspection results overview;

ii. Any items that require follow up (contractor deliverables/ manufacturer deliverables) and what the next steps are;

iii. Coast Guard Engineer POCs; and

iv. Questions.

3. Post inspection

a. Enter data into the RBSDB.

b. Communicate any unusual circumstances to the Coast Guard. If substantial noncompliance was noted, or the manufacturer did not appear to be knowledgeable with federal requirements, a recommendation for an in-person visit inspection should be made to the COR.

2.4.2 All remote inspections require the manufacturer to be able to electronically produce and transmit files to the compliance inspector. Also, each manufacturer must be able and willing to conduct meetings via videoconference using platforms such as Teams, Zoom, Google Meeting or similar programs. Failure by the manufacturer to meet these requirements makes them ineligible from remote inspections.

2.4.3 Manufacturer Verifications. At the direction of the COR the contractor may attempt to verify if a manufacturer is still in business. All efforts will be documented in the RBSDB in the

Factory Profile comments section and any business status change will use the MIC

Administrative Change form and submitted to the COR via email.

2.4.3.1 Physical Verification– billed at the cost of a manufacturer inspection and will consist of:

• Visiting last known address

• Visiting neighboring properties and inquiring about the manufacturer

• Visiting local governmental offices (police, planning/zoning, courthouse)

2.4.3.2 Remote Verification- billed at the cost of a remote education inspection and will consist of:

• Calling/emailing the manufacturer

• Checking manufacturer website/social media

• Checking Google Street View

• Checking status of state business license

2.4.4 Post Incident Inspections. Post incident inspections may be conducted on boats involved in casualties where statutory or regulatory non-compliance or a substantial risk safety defect may have contributed to loss of life, serious injury or property damage. The Contractor shall develop a recreational boating post incident inspection procedure which will include the option for retaining independent subject matter experts relevant to each incident causative factor. Each of these inspections will be quantified as Manufacturer Inspection (MF) for the purposes of invoicing and must be at the direction of the COR. Inspections will specifically target regulatory non-compliance and manufacturer defects. Each inspection will be completed with a detailed inspection report provided to the Coast Guard for forwarding to appropriate State authorities.

Each recreational boating post-incident inspection will have an individual case number and tracked as such.

2.4.5 Associated Material Sample Collection. When requested by the COR, the Contractor shall collect associated material samples used by manufacturers in the production of boats (e.g.

flotation foam, fuel hoses) and forward these samples to a testing facility specified by the

Government. Purchase costs and other forwarding (shipping) expenses are reimbursable. The method of collection, packaging, and shipping instructions shall be in accordance with procedures contained in the Compliance Inspector Manual per SOW section 2.1.3. Contractor will invoice at cost plus G&A. This will include the contractors fee for shipping, handling, packaging etc. in addition to the subcontracted laboratory fee. Note: may include hazardous materials and all local, state, and federal laws for transportation must be met.

2.4.6 Purchasing of Boats and Associated Marine Equipment. The contractor shall recommend to the COR candidate boats and associated marine equipment for testing. Boats must have a capacity label and shall have standard equipment and accessories supplied by the manufacturer. Recommendations shall be based on the contractor’s judgment that there is a high probability of non-compliance with 33 CFR Part 183 and include a justification why the boat may be a failure, and research into the potential scope/sales numbers of desired model.

2.4.6.1 At the beginning of the contract, the contractor will start to build a comprehensive list of a minimum of 50 candidate boats to buy and will maintain that list for the length of the contract in the Boat Acquisition Report (SOW 3.0). During the course of any compliance inspection the contractor should identify recreational boats and associated marine equipment that should be considered for acquisition for flotation and other testing. This list will be jointly reviewed by the contractor and the COR on a quarterly basis or more frequently as needed. Items for consideration will be number of units sold within the last 3 years, boat costs in relation to boat buying budget, potential for failing flotation requirements and availability. Used or demonstration boats will only be considered in unusual circumstances at CORs direction.

2.4.6.2 The contractor shall shop for boats on the recommended list to determine the fair market price. The contractor shall submit to the COR via email at least three (3) price quotes. If the boat or equipment is available from one source only (e.g. the manufacturer), then the contractor shall submit one (1) price quote and catalogue prices for two (2) similar boats.

2.4.6.3 Upon written agreement from the COR, the contractor shall buy boats and associated equipment at fair market prices. The contractor shall submit to the COR purchasing records with its invoices. The contractor shall obtain a manufacturer’s proof of origin (e.g. Certificate of

Origin or Manufacturer’s Statement of Origin) for each boat purchased.

2.4.6.3.1 Boats shall be purchased new from a boat dealer, retailer, or manufacturer, and should be within 1 model year that the purchase is made. Used or demonstration boats will only be considered in unusual circumstances at CORs direction. All boats shall have a capacity label affixed. The Contractor shall purchase test boats with consideration to the availability of cost-effective means of transportation to the test site, availability of storage at the test site, workload at the test site, and resale market opportunities. If optional equipment is offered which may have an impact on the compliance test results, the COR may authorize purchase of the optional equipment. The Government, at its discretion, may select boats offered by manufacturers and individuals at no cost.

2.4.6.3.2 All purchases of boats and associated marine equipment shall be completed in a discrete manner; the Contractor shall not indicate to the seller in any way that the boat is being purchased on behalf of the Coast Guard for compliance testing. When circumstances of the purchase of the boat make it necessary to disclose its purpose, the Contractor shall examine the purchased boat to ensure that it is representative of that type of boat available to the general public.

2.4.6.4 The contractor should aim to purchase and conduct a minimum 10 boat tests per quarter.

This will improve the chances of completing all tests and retests within a contract year and reduce buying of low priority boats at the end of a year to only obtain contract numbers. If after the 3rd quarter of the contract more than 10 boats remain untested the Coast Guard may reduce the total number of boats for that contract year.

2.4.6.5 The government will reimburse the contractor for all boats purchased at a rate of 70% of the cost. All boats bought should be attempted to be purchased utilizing cost saving measures to the government such as lowest MSRP found, without outboard, without trailer, and closest to the test facility to reduce shipping costs.

2.5 Transportation and Storage of Boats

The Contractor shall ensure that purchased boats are transported to the test facility and shall be responsible for storage and security of boats and associated marine equipment before, during, and after testing

2.5.1 Transportation. Invoices for transportation cost, records, and quotations must be retained by the Contractor and provided to the Government along with the Contractor’s invoice seeking reimbursement for the purchase of the boat

2.5.2. Storage. The Contractor shall be accountable for all boats and associated marine equipment and must maintain a verifiable inventory at all times. Boats and associated marine equipment shall be stored indoors to prevent tampering and preserve their testing characteristics and value.

2.6 Testing of Boats and Associated Marine Equipment

A minimum of 35 recreational boats will be tested per year and will be selected for purchase and testing from the Boat Acquisition Report in SOW 3.9.

2.6.1 All flotation testing of boats must be conducted at a test facility capable of conducting in-water testing of boats in accordance with SOW 2.7 and the Coast Guard’s Test Procedures (SOW

3.0). In addition to flotation testing, all purchased boats will be inspected for compliance with all applicable statutory and regulatory requirements. This will include the foam performance capabilities referenced in 33 CFR 183.114.

2.6.2 Boat Test Billing. The contractor will bill boat tests as either initial tests or retests.

2.6.2.1 Initial tests include prepping the boat for test (measurement, marking, de-rigging and re-rigging of the boat, etc.) presoak and the test itself.

2.6.2.2 Retests involve receiving the boat from the manufacturer after repairs have been made and retesting to confirm repairs were adequate. Retests involve less effort by the contractor and will not be invoiced as the same rate as an initial test.

2.6.3 Flotation Testing Failures. When a boat fails flotation testing, the repaired boat shall be re-tested after corrections to the boat have been made and within five (5) business days of the boat being returned to the Boat Test Facility (BTF). If a re-test cannot be conducted in this time frame the contractor shall request an extension in writing from the COR with justifications.

Manufacturers are responsible for all repair decisions and procedures regarding the preparation of failed boats and their re-test. After consultation with the boat test engineer, boats undergoing re-test may not require a second 18-hour pre-soak. If the boat passes flotation testing and fails other aspects of the inspection, the test report (SOW 2.6.4) will reflect each aspect of the inspection failure. The boat will be retested until it passes federal regulations.

2.6.4 Test Reports. The Contractor shall retain a test report file for each boat tested under this contract. The Contractor shall provide a copy of this test report for each boat tested in PDF format that will be provided to the manufacturer. An approved test report template will be provided to the contractor (SOW 3.0). Alternative test reporting may be allowed upon approval of the Coast Guard.

2.6.4.1 Each test report shall consist of a computer file in Portable Document Format (PDF) using Adobe Acrobat® Pro 2024 or higher and uploaded to the RBSDB with an email notification to the case engineer and the COR that the report is available.

2.6.4.2 Not later than five (5) business days after a test or re-test, the Contractor shall:

2.6.4.2.1 Send the Coast Guard Boat Test Engineer a copy of the test results and draft test report, who will them and provide the Contractor feedback in the form of approval or disapproval.

2.6.4.2.2 The contractor shall provide the Coast Guard with a copy of the final test report via email within five (5) business days.

2.6.4.2.3 If disapproved, the draft report will be returned to the Contractor with Coast Guard

Boat Test Engineer comments attached within five (5) business days of receipt from the contractor.

2.6.4.2.4 The Contractor shall return the corrected report within five (5) business days of receipt of the disapproved report and Coast Guard Boat Test Engineer’s comments.

2.7 Boat Test Facility Requirements

The contractor shall have a facility to test boats for Coast Guard flotation requirements.

2.7.1 Test Tank. The test tank shall be a minimum of 22’ L x 10’ W x 6’ D. The test tank must be painted in a neutral color that will not affect photographs of boats inside the tank.

2.7.1.1 Freshwater must be used to produce the required buoyancy forces on the boat. The water must be clear in order to obtain clear photographic documentation of the flooded boat, equipment and weights.

2.7.1.2 Three calibrated load cells and hoists capable of raising a sunk test boat to a level attitude are required. These load cells must be supported and arranged so that the load cells may be affixed to the test boat at three points; one forward and two aft. They must be positioned so that they hang perpendicular to the surface of the water when supporting the boat. This is to assure that the measurements taken from the load cells are accurate indications of the lift or buoyance required to raise the test boat.

2.7.2 Facility Maintenance. The contractor shall maintain the entire boat test facility, test fixtures, and instrumentation in a neat, clean, and painted condition with test instruments set up in an orderly manner consistent with Best Management Practices (BMPs).

2.7.3 Facility Security. The contractor shall provide appropriate security measures to protect each manufacturer’s test boats, engines, and equipment from tampering by unauthorized personnel.

2.7.4 Test Instrumentation Calibration. Prior to the contractor testing boats for compliance with flotation requirements, a test instrumentation calibration system shall be implemented and maintained in accordance with established calibration practices and test weights shall be certified.

2.7.4.1 Measuring and test equipment shall be stored and used under appropriate environmental conditions to assure their accuracy and reliability.

2.7.4.2 All measuring instruments shall be calibrated by a certified/qualified/licensed technician at the beginning of each contract year. Calibration records shall be maintained for all measuring and test equipment.

2.7.4.3 Weights used for compliance testing shall be confirmed by the contractor or a commercial facility at the beginning of the contract and at periodic intervals not exceeding 3 years, or whenever repainted or if significant damage may affect the total weight. Accuracy of weight shall be at least to the tenth of a pound.

2.7.4.4 All measuring and test equipment shall be labeled with the following information:

1. Date of calibration

2. Date of next scheduled calibration

3. Name of person/company who calibrated the equipment.

2.7.4.5 The contractor shall provide a written calibration procedure to the Coast Guard which includes a minimum the following information for all measurement and test equipment:

1. Type of equipment, manufacturer, model number, etc.

2. Measurement range

3. Accuracy

4. Calibration interval

5. Type of standard used to calibrate the equipment.

2.7.4.6 The contractor shall keep records of calibrations for all test instrumentation in a manner which assures the maintenance of established calibration schedules. All such records shall be readily available for inspection when requested by the Coast Guard. The calibration system must be accepted by the Coast Guard before testing may begin.

2.7.5 Boat Handling Equipment. Handling rigs and associated equipment used to lift the test boat into and out of the test tank must be designed to satisfy the following requirements:

2.7.5.1 The handling rigs must have a rated load capacity greater than the dry weight of the boat plus the dry weight of any manufacturer supplied accessories.

NOTE: Test weights need not be included in the lifting capacity of the rig as these weights may be placed in and removed from the boat after it is placed in the test tank. This practice is recommended in order to eliminate undue strain on the boat structure when unsupported by the water

2.7.5.2 Slings or hooks used to lift the test boat must be designed so that they do not puncture the hull or cause damage to the boat structure. All slings, hooks and handling equipment must be clearly labeled with the manufacturers’ Safe Working Loads (SWL).

2.7.5.3 During the flotation test, the handling rigs should be removed or accounted for, so that they do not affect the test results.

NOTE: The flotation tests should be conducted in such a manner that damage to the boat structure is minimal. Slings or lines may be placed in the test tank under the boat so that they do not touch the boat, but so that the slings can catch and support the boat in the event that the b oat sinks.

2.8 Independent Laboratory Testing

When requested by the COR, the contractor shall facilitate the use of independent laboratory testing to evaluate recreational boats and associated equipment. The contractor will invoice at cost plus G&A. This will include the contractors fee for shipping, handling, packaging etc. in addition to the subcontracted laboratory fee.

2.9 Manufacturer Repair of Boats

When a boat fails a flotation test or retest, the contractor shall allow the manufacturer to take possession of the boat to repair it and bring the boat into compliance.

2.9.1 Boat Manufacturer Release. Prior to release of the boat, the Contractor must obtain written agreement from the manufacturer stating that said manufacturer will return the boat to the

Contractor's facility for…