Documentation No Location Question & Poll

This post is in regard to documented boats only – if not documented no need to read any further
I’m a USPS Vessel Examiner (VE) (Courtesy Vessel Safety Checks) and have been challenged online by a USCG Aux VE from another area concerning interpretation of one portion of the Fed Regulations regarding proper display of Official (Documentation) Number.

I've obtained opinions from USCG HQ and happy to post in a later post - didn't want to sway the responses at the start.
I feel comfortable with my understanding but wonder what others have experienced as it is obvious the interpretation is not consistent for all areas & agencies.

For those with documented boats I’m curious what your practice is and would like to know about any experiences with VSCs or boardings.

The applicable regs below – the issue being debated is the highlighted section and revolves around “proper” interpretation of “clearly visible”

46 CFR § 67.121 - Official number marking requirement.
“The official number of the vessel, preceded by the abbreviation “NO.” must be marked in block-type Arabic numerals not less than three inches in height on some clearly visible interior structural part of the hull. The number must be permanently affixed to the vessel so that alteration, removal, or replacement would be obvious. If the official number is on a separate plate, the plate must be fastened in such a manner that its removal would normally cause some scarring of or damage to the surrounding hull area.”

USCG Aux – interprets the reg to mean the Doc No must be visible when any LEO or VE boards the boat – in a topside living space, salon, helm etc. and can not be located in engine room or other below deck space or behind a hatch caver.

My interpretation is that engine room, lazarette, etc is acceptable as long as it is visible without moving equipment, bulkheads, etc

I’ll incorporate a poll to track responses and would appreciate hearing about any boarding or Vessel Safety Check situations that resulted in warnings, citations etc for “improper” display of Doc No (not name, home port or state registration no display)

Thanks

I dont even think this is debatable. USCG Aux is incorrect.

On the Nordic Tug we just purchased the Doc # is located in the lazarette. This is our first experience with a documented boat. The surveyor listed it in the report as not being in a visible area. But since it has been Documented since 1986 we are not going to change its location unless we are told to by someone with authority.

mystery said:

I dont even think this is debatable. USCG Aux is incorrect.

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I agree they are incorrect.

That is why boats have the HIN molded into the transom. Visible to anyone.

mystery said:

I dont even think this is debatable. USCG Aux is incorrect.

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Exactly, CGAUX can't add exclusions (can't be in the engine room) to the code.


This seems like a spat between hobbyist organizations

Believe the aux is wrong. Nevertheless, my documentation number is prominently displaced in the pilothouse.

Wait a minute. I am a CG Aux Vessel Examiner and I absolutely know what and how the requirements are for displaying documentation numbers are. Please don’t say the Auxiliary is wrong, ONE VE is wrong. Don’t smear all Aux VEs because one doesn’t know the requirements. Several members here have already stated that the Aux is wrong. That is wrong.

This is one of the reasons I say be very careful and dont take USCGAUX inspections and courses too seriously. I have met way too many that overshadow their knowledge with opinions that mislead.

I have 2 documented vessels. Both have documentation numbers on a facing bulkhead in the engine room. This used to be the standard, numbers cut into, welded on, or engraved / welded to a piece of material and attached to a bulkhead. The purpose was to have them not easily removable. I haven't kept up with the rule as I haven't been tested on it for licensing (USCG captain's license) since the mid 1980s. Wonder if this is a grandfathered rule or not.

Ted

Ours have always been in the ER on a plaque, sized etc per USCG specs. But I have never been boarded or inspected, so can't say whether it would meet other's requirements.

As posted above in post #1...this is straight from the NVDC.

HOW DO I MARK MY VESSEL?

The official number assigned to documented vessels, preceded by the abbreviation "NO." must be marked in block-type Arabic numerals at least*three inches*high on some clearly visible interior structural part of the hull. The number must be permanently affixed so that alteration, removal, or replacement would be obvious and cause some scarring or damage to the surrounding hull area.


Ted, no need to grandfater anything. Your vessels are correctly marked and that one or any USCGAUX examiner who thinks differently needs to show in USCG regs (NOT USCGAUX) or the CFRs where it is even ALLOWED to be in the pilothouse.

I do think I read that some USCG memo or guidance letter said for rec boats, the screw on carved placards are OK..... but in reality, thats NOT the way it was intended (not permanent enough as in theft).

Bacchus said:

This post is in regard to documented boats only – if not documented no need to read any further
I’m a USPS Vessel Examiner (VE) (Courtesy Vessel Safety Checks) and have been challenged online by a USCG Aux VE from another area concerning interpretation of one portion of the Fed Regulations regarding proper display of Official (Documentation) Number.

I've obtained opinions from USCG HQ and happy to post in a later post - didn't want to sway the responses at the start.
I feel comfortable with my understanding but wonder what others have experienced as it is obvious the interpretation is not consistent for all areas & agencies.

For those with documented boats I’m curious what your practice is and would like to know about any experiences with VSCs or boardings.

The applicable regs below – the issue being debated is the highlighted section and revolves around “proper” interpretation of “clearly visible”

46 CFR § 67.121 - Official number marking requirement.
“The official number of the vessel, preceded by the abbreviation “NO.” must be marked in block-type Arabic numerals not less than three inches in height on some clearly visible interior structural part of the hull. The number must be permanently affixed to the vessel so that alteration, removal, or replacement would be obvious. If the official number is on a separate plate, the plate must be fastened in such a manner that its removal would normally cause some scarring of or damage to the surrounding hull area.”

USCG Aux – interprets the reg to mean the Doc No must be visible when any LEO or VE boards the boat – in a topside living space, salon, helm etc. and can not be located in engine room or other below deck space or behind a hatch caver.

My interpretation is that engine room, lazarette, etc is acceptable as long as it is visible without moving equipment, bulkheads, etc

I’ll incorporate a poll to track responses and would appreciate hearing about any boarding or Vessel Safety Check situations that resulted in warnings, citations etc for “improper” display of Doc No (not name, home port or state registration no display)

Thanks

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ER is absolutely acceptable, and the most common location I have seen.

twistedtree said:

ER is absolutely acceptable, and the most common location I have seen.

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I concur; as a former examiner with the Power Squadron, I don't recall there ever being any requirement similar to the Auxiliary's opinion that the PO noted. It's an interpretation, at best, and one that's pretty much pointless. There are more important issues to address in a VSE than splitting hairs over the minutiae of where the doc # is displayed. Focusing on such irrelevant detail serves only to inflate the inspector's self-importance and dilutes the overall purpose of the program. If the number's displayed, visible, can't be altered, and is the correct size, it meets the requirement. Next checklist item?

Thanks - Keep the responses coming

Thanks folks - appreciate the replies & info
Have to admit I'm pleasantly surprised with replies so far.
I thought there would be more variation in interpretation as this USCGAux VE is absolutely adamant about this and claims this interpretation is what is practiced across a large USCGA region in the NE.
My home port is on an inland lake and admit we have many more registered than documented vessels. I suspect it is just the opposite with this group and why I inquired here for a bigger picture.

wwestman - Post #5
- Agree but HIN is a whole different area of regs but is interesting as the requirement is for Two identical HIN's - the "visible" one we are all familiar with on Outside of hull @ Stbd Stern and ""duplicate hull identification number must be affixed in an unexposed location on the interior of the boat or beneath a fitting or item of hardware.
I interpret the "clearly visible" wording in the Doc No section is to differentiate it from the duplicate HIN which is " hidden" rather than restrict the location to a normally occupied living space - but admit that is just my opinion,

markpierce - Post #7
Absolutely agree that pilothouse, salon (or saloon for some) are OK
I believe, (haven't found) that USCG definition of "Hull" includes top side structure above rubrail as long as it is truly part of the structure.

Comodave - Post #8
- I absolutely agree with your point about individuals vs organizations
- I don't mean to attack or slam the individual either. He is doing his best and providing a service intended to promote safe boating and I applaud him for doing it and actually doing more if it than I do.
- My mission is to make sure my interpretation is correct to the best of my ability so I can 1) better inform the public when doing VSC's and 2) Better inform the VE's that I have trained and look to me for direction.

OC Diver - Post #10
Ted I absolutely agree with being OK to cut into, weld on, attach to structural members below - stringers, bulkheads etc as long as they are structural and not removable - no grand fathering required... Further reinforced by this response I received...
Clarification provided by Program Management & Operations Branch (CG-BSX-21) U. S. Coast Guard Boating Safety Division
Responded in writing that “on some clearly visible interior structural part of the hull” replaced the old “main beam” language as no vessel that is made of anything other than wood has a main beam.
I intyerpret Main Beam to be hull structure below deck.

psneeld - Post #12
I am not aware of and don't believe there are and exceptions or different standards applied to recreation vs commercial vessels - in regard to Doc No or HIN at least. There are other regs that do apply to various classes of vessels that do not include recreational vessels. To the best of my knowledge the ones we are discussing here apply universally. Whether enforcement folks have been instructed to "cut recreational boaters a break" by not issuing citations or taking other enforcement action may be another story.
I have had many discussion w/ LEO regarding marine patrols and without exception they have stated (and acted) that they are not out to write citations and force boater off the water - UNLESS the violation is a hazard of significant safety issue. Even in the case of inadequate PFD's our local LEO will frequently issue oloaner PFD's and instruct them to drop off at our marina when done or come see us for a loaner as we have a free loaner program.

I will summarize and post the the responses I have been able to obtain from USCG HQ and NVDC when I get a little time.

Thanks - keep the anecdotes coming and I'm especially interested in those that involve boarding or vessel safety checks

"His claims" and "adamant" has always been my problem with the USCGAUX.

Its a shame a few "wannabes" that "can't" overshadow a lot of hardworking, knowledgeable USCGAUX members.

46 CFR § 67.121 - Official number marking requirement.
“The official number of the vessel, preceded by the abbreviation “NO.” must be marked in block-type Arabic numerals not less than three inches in height on some clearly visible interior structural part of the hull. The number must be permanently affixed to the vessel so that alteration, removal, or replacement would be obvious. If the official number is on a separate plate, the plate must be fastened in such a manner that its removal would normally cause some scarring of or damage to the surrounding hull area.”


The rule clearly states that the Doc No. must be on some clearly visible interior structural part of the hull.


This does not mean the cabin or superstructure above the hull.

psneeld said:

"His claims" and "adamant" has always been my problem with the USCGAUX.

Its a shame a few "wannabes" that "can't" overshadow a lot of hardworking, knowledgeable USCGAUX members.

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Agree
When I provided what I consider high level "official" responses his only come back was restating how many VSC's & how many yrs he's been doing this... louder and louder. But he will not / can not provide any training Doc, response from the chain of command etc to substantiate it.
What is really sad is his Doc No proudly displayed in his cabin is put on with stick on numbers and NOT glassed over... and he claims a scraper used to remove them would leave a mark... DUH - heat gun & acetone

mramoo said:

46 CFR § 67.121 - Official number marking requirement.

The rule clearly states that the Doc No. must be on some clearly visible interior structural part of the hull.

This does not mean the cabin or superstructure above the hull.

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See note above re: Post # 7 - I am not questioning cabin or super structure and absolutely believe that is acceptable.
I believe many commercial vessels in fact display their Doc No in pilothouse, etc
I haven't been able to find the USCG definitions that support this but believe their definition of "Hull" is more broadly defined as "below a rubrail"

Just the word DUH with him is adequate.

When a Sr. Officer somewhat in charge of regional USCGAUX filoatillas, I used to cringe at reports of guys like this and would start the process to remove their qualifications.

But it was a painfully slow process as being volunteers they were considered "helpful" despite any problems.

Just got boarded and inspected by the USCG in September 2018. My Doc # is engraved in a wooden plaque bonded to the inside transom in the lazarrette. They were fine with the location and display. Passed with flying colors.

psneeld said:

Just the word DUH with him is adequate.

When a Sr. Officer somewhat in charge of regional USCGAUX filoatillas, I used to cringe at reports of guys like this and would start the process to remove their qualifications.

But it was a painfully slow process as being volunteers they were considered "helpful" despite any problems.

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We were approached by an overzealous one at a marina in SC. He said "I am with the Coast Guard and here to check your boat." I said "You are not with the Coast Guard, but a volunteer with the Auxiliary and you step on my boat and I'll call the local police."

I found out this had been his approach on other boats and spoke to the gentleman heading the courtesy inspections that day who then sent him home. Apparently, he'd been warned before and the other auxiliary members were even more offended than I was.

There are so many who freely give of their time in an effort to help others, especially inexperienced and new boaters. They make it clear what their roles are. They freely admit what they don't know or aren't sure of. It's a shame that a few do harm to them. Reminds me a bit of community watch programs with good intent but a lot of individuals out of control.

Now, in this thread we're reacting to one person posting on the internet and shouldn't consider that person representative of anything.

Growing up, it was like the Auxiliary and Power Squadron were in a turf war on the lake. At least that changed over the years and they began to work better together.

I love the Auxiliary.


I just can't live with them.

My first documented boat was a Matthews made of wood and the number was cut into a major frame. Never had any problem with that location. All my other boats had the number on a frame in the engine room but being FG the number was not cut in.

Some people like to abuse power they believe they may have.

A CGA vessel inspector pointed out that my doc number was not preceded by “NO.” I ordered a fiberglass placard engraved appropriately, slathered it with 5200, and affixed it to an engine room bulkhead.

Canadian perspective:

I am on my third registered (Canadian equivalent to "Documented") vessel. All have been FG, so no "main beam" on which to affix the Registration No.
I am also
qualified, from 1990, to do "Courtesy Examinations" under the auspices of the CGAux ( now RCMSAR).
"Affixed to the main beam" is liberally interpreted to mean the same as your definition, so long as it is on a part of the structure that can't be easily removed, to discourage theft and changing of the Official Number. In the ER is a good location. In the pilothouse can be a good location, provided that it is obviously going to cause a lot of damage to remove it.

Well, I must say that I've never heard of this requirement, and not even sure if I have the numbers on the boat, or previous boats that I've had. Certainly not in the main cabin. Will look around.

Been boarded once last summer in NC. Passed without issue, except one minor one. I had a copy of the documentation papers, not the original and they said it must be the original. As a practice, I often leave originals at home in a secure place, especially ones that are hard to replace. They said no big deal, but get the original. They never mentioned numbers.

Personally, I'm totally against random boardings, and have expresses this to my political officials. It may not change, but it's totally a waste of taxpayer money. On friends boats, I've been boarded a number of times. The CG has always been friendly and polite, but never found any major safety issues. BUT what a waste of money! The local cops and sheriffs are pricks, every one of them that I've seen, and most don't even know the laws. Have zero use for them. Also a waste of taxpayer money.

Now question: Can someone site the ruling or law that says once you've been boarded or had the VSC, they can't board you in a year.... and who can't board you in a year?

A MUCH better solution would be to simply say, you must have a VSC check every X years instead of registration.

I've got no problem with the volunteer VSC. It's a great program, and of the ones I've seen, they have been fine. Ya always get a jerk at times, most often with anyone that has some authority position when they overstep their bounds. Just gotta deal with them and get rid of them asap.

Another question somewhat related:

Why do we really need a documented boat? Don't need it for pleasure travel anywhere in the US, Canada or Caribbean do we? And in most states, we need state registration, too (just a money grab, but hard to fight), so why pay the CG for renewing the documentation? And at times, wait forever to get it done.... they are SUPER slow.

Does one need a documented boat to operate a charter? I've heard different answers. I'm thinking of chartering one of my boats.

I'm just thinking of dropping it.

Sometimes documentation is required abroad as not all nations even in the Caribbean recognize state registration...other cruisers may point out that is no longer true....cant be sure myself.

Bareboat ir captained charters?

USCG boardings for the most part cost no more as they are part of routine operations and funded up front. Multimission patrols, training, interagency coop, etc...etc... Manning levels, boat inventory, fuel usage all would be funded at the same level if random boardings were stopped..all it would do is shift boardings in the direction of probable cause at first....

This might cause boardings to be a bigger PIA because now if they did stop you for probable cause (and think long and hard about all the USCG mission categories to give them probable cause) you might now be under a microscope. The "random safety/enforcement boarding" might now fall under leagalese for "search and possible seizure".

Seevee
"Now question: Can someone site the ruling or law that says once you've been boarded or had the VSC, they can't board you in a year.... and who can't board you in a year?"
No such law / reg... I've been stopped by CG 2x w/in 1 hr in NY Hbr.
Also no guarantee that w a current VSC decal you won't be stopped. I've talked w CG and LEO about that topic and they sometimes bypass those w decals if other boats w/o are around. Frequently I've found their checks are for training purposes. I had a LEO check 5 boats in a NY canal lock. 4 of them I had inspected and awarded the decal. Another VE had done mine. When I asked LEO about why the check especially all 5. He admitted it was for training but his practice is to single out 1 if in a group... all or none to be "fair"

Also agree... all LEO & CG are basically fixed cost once they leave the office and go on patrol. I'd rather have CG on the water and happy to be checked periodically. I have never been harassed... always very cordial and professional if owner takes the same approach.
They are most often looking for stupid or dangerous actions, at least my experience.