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Operational Excellence through Leadership and Compliance

Maritime Compliance Report

Welcome. Staying in compliance takes dedication, diligence and strong leadership skills to stay on top of all the requirements which seem to keep coming at a rapid pace. With this blog I hope to provide visitors with content that will help them in their daily work of staying in compliance. I hope you find it a resource worthy of your time and I look forward to your feedback, questions, comments and concerns. Thanks for stopping by.

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Congratulations to E.N. Bisso & Son

Congratulations to E.N. Bisso & Son for its recent ISM certfication by ABS. The company has worked hard to achieve this goal with VP Mike Vitt leading the effort for the company. E.N. Bisso & Son partnered with Maritime Compliance International a decade ago. When they made the decision to seek ISM certification we developed their safety management system (SMS) into the ISM format, provided safety management workbooks for all captains to complete and learn the company's SMS, and conducted quarterly visits to each vessel to ensure steady progress. The ISM manual was approved with no deficiencies, the Document of Compliance was issued to the company following a successful audit, and now the vessels are being audited and issued their Safety Management Certificates. It is a pleasure to work with such dedicated clients.
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Nontank Vessel Response Plans

Hopefully you made the deadline of January 30th to submit your Nontank Vessel Response Plan (NTVRP) to the Coast Guard. According to Coast Guard Headquarters, on January 31, 2014, all old nontank vessel response plans were to be deactivated. That’s because the long awaited final rule for the nontank vessel response plan regulations was published a few months ago. The old nontank vessel response plans were drafted based upon Coast Guard guidance, which is now superseded by the regulation.


The regulation applies to any vessel operating in U.S. water that is measured 400 gross tons or more, regulatory or ITC. From there, the sub-applicabilities get a little complicated based upon capacities. Some of the additional service requirements include fire-fighting and salvage, dispersants, aerial surveillance, shoreline protection and shoreline clean-up. If applicable, evidence of signed contracts for these services must be submitted with the NTVRP.

 

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Checklists

When should a checklist be required?


Have you ever wondered why a watch relief checklist is common in the industry, but a bridge transit procedure checklist is not? I’m not sure the reason is given much thought. Consultants seem to think lots of forms make their manuals more professional, managers like the idea of having everything documented, and mariners feel they are the victims of a useless paperwork onslaught. A mariner, who was sick of all the foolish paperwork he was forced to do, once wrote about making a fake ISM form for how many sugar cubes were used by individuals at the ship’s coffee mess. His point was proved when the crew did indeed; fill out the ISM sugar cube usage form.

 

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Is the Coast Guard “in bed” with BP?

Here in New Orleans much of the discussion on talk radio is centered on the Coast Guard’s handling of the BP/ Deepwater Horizon oil disaster. Following the lackluster response to Katrina, the general public and local officials want swift and decisive action from federal responders. The problem is that the existing process set up by law makes the spiller responsible for the clean-up. The federal government requires operators to have response plans and contracts in place to clean up oil spills. The feds are responsible to make sure that the approved plans are followed. The general public and local officials have little understanding or tolerance for such processes during an emergency. In fact, some people seem to think that in a disaster all laws become suggestions commonly referred to as “red tape.”

 

If we want to improve our response in the future we must look at the factors which make government respond the way it does: laws and regulations. If an agency charged with enforcing laws and regulations steps in to intervene on response activities, they are looked at as obstructionist bureaucrats. Nothing will make federal agencies respond differently the next time by declaring them “Stuck on stupid.” Perhaps if the federal on-scene coordinator had waiver authority for all laws and regulations, and was shielded from all personal liability, the response would be smoother. Short of that, I suspect the general public will continue to be disappointed.

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