Marine Casualty Reporting and the CG-2692

What the rule requires

Everything on this topic starts with one question: is the occurrence on the list in 46 CFR §185.202(a)? Until you have answered that, no clock has started and no form is owed. The regulation also fixes the order of business — notice is given immediately after the addressing of resultant safety concerns, not before them 46 CFR §185.202. Fight the fire first, then telephone the Sector.

The reportable occurrences

Grounding and bridge allision. An unintended grounding, or an unintended strike of (allision with) a bridge, is reportable on its face — no damage threshold, no injury, no minimum duration aground. An intended grounding or bridge strike is reportable only if it creates a hazard to navigation, the environment, or the safety of a vessel, or independently meets one of the other criteria.
Loss of manoeuvrability. Loss of main propulsion or primary steering, or any associated component or control system, that reduces the maneuverability of the vessel.
Seaworthiness or fitness for service. An occurrence materially and adversely affecting seaworthiness or fitness for service or route, the regulation naming fire, flooding, and failure of or damage to fixed fire extinguishing systems, lifesaving equipment, auxiliary power generating equipment, or bilge pumping systems.
Loss of life.
Injury requiring professional medical treatment — treatment beyond first aid — and, for a person engaged or employed on board a vessel in commercial service, rendering that individual unfit to perform routine duties.
Property damage in excess of $25,000, for an occurrence that meets none of the criteria above. The figure includes labor and material to restore the property to its pre-casualty condition; it excludes salvage, cleaning, gas freeing, drydocking and demurrage.

Two of those bullets carry the qualifier that decides most questions. Loss of steering counts only where manoeuvrability was in fact reduced. The dollar test applies only to an occurrence that fails every other criterion — damage below $25,000 arising out of an unintended grounding is still reportable, because the grounding itself is the trigger.

The one carve-out worth knowing: death or injury of a shipyard or harbor worker does not invoke the loss-of-life or injury criteria where the accident resulted from neither a vessel casualty nor a vessel equipment casualty and is subject to OSHA reporting under 29 CFR part 1904. A mooring line parting and killing a longshoreman standing on the pier is the case the exam builds from this paragraph.

You back out of the slip, touch bottom on the shoal off the fairway, and a passing tug pulls you clear in twenty minutes. No damage found, nobody hurt. Reportable?

Yes. This is an unintended grounding under §185.202(a)(1), which carries no damage threshold, no injury requirement and no minimum time aground. The $25,000 figure never enters the analysis, because it applies only to an occurrence meeting none of the other criteria.

The two clocks

Immediate notice goes to the nearest Sector Office, Marine Inspection Office, or Coast Guard Group Office. Nothing in the regulation requires it in writing, and nothing permits delaying it until the facts are tidy.

The written report is a separate duty. The owner, master, agent, or person in charge must, within five days, file a written report of any marine casualty, delivered to a Coast Guard Sector Office or Marine Inspection Office, on Form CG-2692 (Report of Marine Accident, Injury, or Death), supplemented as necessary by CG-2692A (Barge Addendum) and CG-2692B (Report of Required Chemical Drug and Alcohol Testing Following a Serious Marine Incident) 46 CFR §185.206. The written report is in addition to the immediate notice.

The relief runs one way only. Filed without delay after the occurrence, the written report suffices as the immediate notice — telephoning the Sector never relieves you of the CG-2692. Where the casualty involves a hazardous condition, notice given under §185.203 satisfies §185.202 .

Drugs, alcohol, and the logbook

For each casualty reportable under §185.202, the owner, agent, master, or person in charge must determine whether there is any evidence of alcohol or drug use by individuals directly involved 46 CFR §185.210. That determination is an affirmative duty attached to every reportable casualty, not something triggered by suspicion.

What goes on the CG-2692 is the identity of any individual for whom evidence of drug or alcohol use or intoxication was obtained, and the method by which it was obtained — personal observation or chemical testing.

Where evidence of intoxication is obtained, an entry must be made in the Official Logbook if one is carried; the individual must be informed of the entry, and the entry must be witnessed by a second person. A refusal to submit to or cooperate in a timely chemical test — whether directed by a Coast Guard commissioned, warrant or petty officer, another authorized law enforcement officer, or by the owner, agent, master or person in charge — is noted in the Official Logbook if carried and in the CG-2692, and is admissible as evidence in any administrative proceeding.

Voyage records

Where a vessel is involved in a marine casualty as defined in 46 CFR 4.03-1, the master or person in charge ensures compliance with 46 CFR Subpart 4.05 and retains the voyage records required by 46 CFR 4.05-15 for 30 days 33 CFR §164.61. The 30 days run from the casualty if the vessel stays in the navigable waters of the United States; if she departs those waters within 30 days of the casualty, the period runs from her return to a United States port.

For tank vessels, the notice, reporting and voyage-record requirements are those of part 4 of the chapter 46 CFR §26.08-1.

Telling it apart

The criterion that sorts these three reports is who receives it. Get that wrong and every associated figure comes out wrong with it, because each regime carries its own dollar threshold and its own deadline.

Immediate notice — receiver: nearest Sector Office, Marine Inspection Office, or Coast Guard Group Office. Deadline: immediately after resultant safety concerns are addressed. No form, no dollar test of its own; it is owed for anything on the §185.202(a) list.
Written CG-2692 — receiver: a Coast Guard Sector Office or Marine Inspection Office. Deadline: five days. Governs the property-damage figure of over $25,000 and carries the drug-and-alcohol block.
§28.80 casualty report — receiver: the underwriter of primary insurance, or an organization accepted by the Commandant, the accepted organization being Verisk Insurance Solutions, ISO Claim Search Solutions 46 CFR §28.80. Applies to a commercial fishing industry vessel casualty except one required to be reported to the Coast Guard on CG-2692 under part 4. Deadline: as soon as possible after the casualty. Threshold: damage initially estimated at $2,500.00 or more, and it also runs on loss of life, loss of the vessel, an injury beyond first aid rendering the individual unfit for routine duties, or damage impairing seaworthiness.

The underwriter's own obligation is the third figure in this cluster and belongs to the insurer, not the master: the underwriter of primary insurance for a commercial fishing industry vessel reports each casualty to an accepted organization within 90 days of receiving notice, and again whenever it pays a claim.

A commercial fishing vessel's gurdy fails and a crewman needs sutures ashore, leaving him unfit for duty. Where does the report go?

This injury is reportable to the Coast Guard, so the CG-2692 route applies and §28.80 does not — §28.80(a) opens by excepting any casualty required to be reported to the Coast Guard on Form CG 2692 in accordance with part 4. The insurance report exists to capture fishing-vessel casualties falling outside the Coast Guard requirement, which is why its damage threshold is $2,500 rather than $25,000.

Working a question

You are master of an inspected small passenger vessel. Off the entrance jetty the port main loses oil pressure and shuts down; you make the dock on one engine with reduced manoeuvrability. During the securing, a deckhand's hand is crushed at the windlass and the emergency room closes the wound with sutures. He is unfit for duty for the balance of the week. A crewman tells you the injured deckhand smelled of alcohol at crew call. Damage to the engine is estimated at $9,000.

Address the safety concerns first. Vessel secured, passengers ashore, injured man to medical care. §185.202(a) sequences notice after this, not before.
Test the event against the trigger list. Two independent triggers are met: loss of main propulsion reducing manoeuvrability, and an injury requiring treatment beyond first aid that rendered a person employed on board in commercial service unfit for routine duties. The $9,000 is irrelevant — the dollar criterion applies only to an occurrence meeting none of the others.
Give immediate notice to the nearest Sector Office, Marine Inspection Office, or Coast Guard Group Office. One notice covers the casualty; you do not make two calls for two triggers.
Make the drug-and-alcohol determination required by §185.210 for the individual directly involved, and record the method — here, observation by a crewman, plus any chemical test result obtained.
Enter it in the Official Logbook if the vessel carries one, inform the deckhand of the entry, and have a second person witness it. A refusal to test goes in the same two places and is admissible against him later.
File the CG-2692 within five days at a Sector Office or Marine Inspection Office, appending CG-2692B as necessary, with the drug-and-alcohol identification and method entered on the form.
Retain the voyage records required by 46 CFR 4.05-15 for 30 days after the casualty, or 30 days after return to a United States port if the vessel leaves navigable waters of the United States inside that period.

Where candidates lose the point

Answering that a grounding with no damage need not be reported. The distractor pairs a brief grounding with "pulled off by tugs in 30 minutes, no damage" and it reads harmless. An unintended grounding is its own trigger under §185.202(a)(1); the damage figure is never reached.
Applying $25,000 to everything. The threshold governs only an occurrence that meets none of the other criteria. A fire that damages the bilge pumping system is reportable at any cost, on the seaworthiness criterion.
Carrying $2,500 or 90 days into a CG-2692 question. Both belong to the commercial fishing industry vessel insurance report — $2,500 as the damage estimate that triggers the owner's report to the underwriter, 90 days as the underwriter's own deadline.
Treating "72 hours" as the injury trigger. The 72-hour figure in §28.80(c)(11) identifies whose personal details go into an insurance report — an individual incapacitated more than 72 hours or deceased. Coast Guard reportability turns on treatment beyond first aid plus unfitness for routine duties, with no waiting period.
Believing the phone call ends the matter. Notice and the written report are separate duties, and only the sequence works in one direction: a CG-2692 filed without delay covers the notice, never the reverse.
Missing the harbor-worker exclusion, or over-reading it. The exclusion is confined to shipyard and harbor workers whose accident resulted from neither a vessel casualty nor a vessel equipment casualty and is OSHA-reportable. A cargo boom failure that kills the same worker is a vessel equipment casualty and stays reportable.

Check yourself

Your steering gear jams hard over for ninety seconds in the channel before the second pump restores control. Nobody hurt, nothing damaged. What do you owe?

Immediate notice and a CG-2692 within five days. §185.202(a)(3) covers loss of primary steering, or any associated component or control system, that reduces the maneuverability of the vessel. Restored control does not undo the occurrence; the operative words are "reduces the maneuverability," which it plainly did.

A mooring line parts alongside and kills a longshoreman standing on the pier. The line was sound and the accident is OSHA-reportable. Is the loss-of-life criterion invoked?

No. §185.202(b) excludes the death or injury of shipyard or harbor workers from paragraphs (a)(5) and (a)(6) where the accident resulted from neither a vessel casualty nor a vessel equipment casualty and is subject to OSHA reporting under 29 CFR part 1904. Change one fact — make it a cargo boom failure — and the exclusion falls away.

You have telephoned the Sector Office within the hour and given a full account. A crewman tells you no form is needed because the Coast Guard already knows. Correct?

No. The written report on CG-2692 is in addition to the immediate notice, and is due within five days to a Coast Guard Sector Office or Marine Inspection Office. Only the reverse substitution is permitted: a written report filed without delay suffices as the notice.

Your vessel drags her anchor onto a mudbank while you are aboard and refloats on the tide. Damage: $18,000 to the rudder. Which criterion do you cite?

The unintended grounding, §185.202(a)(1). Candidates reach for the dollar test, see $18,000 against $25,000, and answer that no report is required. The dollar criterion applies only to an occurrence not meeting any of the other criteria in the section.

You obtain a positive breath test on the mate directly involved in a reportable allision. What must go where?

The individual's identity and the method by which the evidence was obtained — chemical testing — go into the CG-2692 under §185.210(b). An entry goes into the Official Logbook if one is carried, the mate must be informed of it, and a second person must witness the entry.

Your vessel is involved in a reportable casualty on 3 May and sails from United States navigable waters on 10 May, returning 1 June. Until when must the voyage records be kept?

30 days after 1 June. 33 CFR §164.61(b)(2) runs the period from the vessel's return to a United States port where she departs the navigable waters of the United States within 30 days of the casualty. Had she stayed, the 30 days would have run from 3 May.

A commercial fishing vessel's net drum and hydraulics are damaged, initially estimated at $4,000. No injuries, vessel seaworthy. What is required?

A report under §28.80 to the underwriter of primary insurance or to an accepted organization, as soon as possible after the casualty, because the estimate exceeds $2,500.00. No CG-2692 arises from these facts, and §28.80 applies precisely because the casualty is not one required to be reported to the Coast Guard on that form.