Kirsten Elaine Lorgen-Knapp

I support proposed rule, USCG-2010-0625, as a means to inform employers of commercial fishing vessels about the opportunity to request a waiver of citizenship requirements. Despite the costs of requesting a waiver, it seems clear that if employers are better informed, they will be less likely to violate the rules or to operate shorthanded. While the previous procedure as established in the 2001 policy letter was similar, incorporating the procedure into the CFR may make the opportunity easier for employers to become aware and take advantage of, since employers are generally required to review relevant parts of the CFR each year to be aware of changes. Nonetheless, the inclusion of the dockside safety examination, despite ensuring that vessels comply with applicable safety regulations and perhaps facilitating another pathway to check compliance with citizenship requirements, is an unnecessary burden upon employers and government. While safety is paramount for fishing vessels, the issue of citizenship of employees has little correlation to overall safety of vessel functions; thus, not only is this requirement redundant of safety requirements already enforced by the Coast Guard, but is an unmerited target of fishing vessels employing people of different citizenship status’. If the Coast Guard determines a need for further safety regulation, a new proposed rule may be necessary, but as part of the rule at hand the idea seems absurd: what does the dockside safety exam have to do with employee nationality? The dockside examination requirement for those applying for a citizenship waiver should be eliminated from the proposed rule. Since 2001, the procedure has worked for hundreds of vessels requiring additional crew; the procedure does not require alteration, in my opinion, and will benefit from being brought into further visibility.