Pete

Although the intent of this rule makes clear sense on a business aspect for manufacturers of lifesaving equipment, it does not take into account that these companies are foreign companies making lifesaving equipment for US flag vessels with the name "USCG approved" affixed to the equipment. Therefore having Coast Guard inspectors attend these oversight exam makes clear sense then having an "independent laboratory/company" have control over such critical maritime equipment, where profit is #1 and law/rule/order may take the backseat. Allowing this to happen may possibly lead to lack of CG oversight or more complacency with companies making "lifesaving equipment" for US citizen's safety. In a world where many countries do not like the US, I do not see how we can make this happen. I would assume CG inspectors are finding flaws and complacency during these exams, especially with a CG approval stamp. Although if the CG believes they do not have enough resources to conduct these exams or expertise, then I would recommend to the CG to seek additional resources from Congress or train more personnel to conduct such exams. In a way, this rule is giving up jobs to American citizens, which is not right. In this economy, the US government should be looking for ways to increase US employment, not give it away to foreign countries and increase their employment rates and especially when it comes to saving a US life with such equipment. Therefore, my comment to this proposed rule is to carefully consider what you are proposing. To me it sounds as if the CG has been doing well over the years, although, I could see that the CG may just need some extas bodies and resources to properly train their personnel in order to conduct these types of exams. Please note, that there are still US citizens looking for jobs, and this could mean employment to US tax payers. Thank you.