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.

To avoid missing critical updates, don’t forget to sign up by clicking the white envelope in the blue toolbar below.

Towing Vessel Inspections NPRM Published

The Notice of Proposed Rule making on Towing Vessel Inspections has been published in the Federal Register.  Here is a link: http://edocket.access.gpo.gov/2011/pdf/2011-18989.pdf

More on this to follow, stay tuned....

  1923 Hits
  0 Comments
1923 Hits
0 Comments

Towing Vessel Inspection Regulations Cleared by OMB

The towing vessel inspection regulations known as Subchapter M have been cleared by the Office of Management and Budget (OMB). The Notice of Proposed Rule Making (NPRM) is expected to be published this month. These regulations include a safety management system (SMS) for the towing industry. Some companies have had an SMS for many years and may be less concerned than those who have not yet adopted an SMS.  However, there may be cause for concern even for those who have had an SMS for quite some time due to differing expectations on implementation.

Continue reading
  2355 Hits
  3 Comments
2355 Hits
3 Comments

USCG / EPA Collaborate on Enforcement

The U.S. Coast Guard and the U.S. Environmental Protection Agency have recently signed a memorandum of understanding (MOU) regarding the enforcement of MARPOL Annex VI.  MARPOL Annex VI deals with air pollution from vessels.  I used the word "vessels" because this Annex has wide applicability and does not only apply to ships or vessels on an international voyage. In fact in the U.S. Coast Guard had previously published enforcement guidance specifically for enforcing this Annex on U.S. vessel of any gross tons, not on an international voyage. This recent MOU explains each agency's role in the enforcement of the Annex. It comes in the wake of the MOU earlier this year between the same two agencies regarding the enforcement of the Vessel General Permit (VGP).
Continue reading
  2185 Hits
  0 Comments
2185 Hits
0 Comments

Increased Scrutiny of SMS Implementation by U.S. Coast Guard

When it comes to what constitutes full implementation of a safety management system such as the International Safety Management (ISM) Code, there seems to be a disconnect between what different stakeholders believe to be adequate. Different flag states, recognized organizations, class societies, and port state control authorities enforce the code to their own standards, not to mention each individual auditor’s experience and subjective opinions.  The real disparity becomes painfully clear during times of major accident investigations and litigation, when everything is put under a microscope and the level of implementation that was considered “satisfactory” at the last audit can now constitute alleged negligence.

Continue reading
  2782 Hits
  0 Comments
2782 Hits
0 Comments

RCP v. Subchapter M

The proposed rule containing regulations for the inspection of towing vessels, known as Subchapter M, is due to be published in a few months.  It is expected that these regulations will include a towing vessel safety management systems. Many towing vessel companies currently have a safety management system (SMS) in place known as the American Waterways Operators (AWO) Responsible Carrier Program (RCP).  Having been both a U.S. Coast Guard marine inspector and an AWO RCP auditor, I have noticed a different expectation regarding the level of implementation required between inspected vessel's SMS and RCP. I suspect that some RCP companies might have a difficult time with Subchapter M enforcement if they don't step up the level of implementation.

Continue reading
  3472 Hits
  0 Comments
3472 Hits
0 Comments

New Safety Management System Workbook Available

A common practice throughout the maritime industry, despite elaborate safety management systems (SMS) which have been put in place, is to simply rely on the credentials and experience of mariners to operate safely. But the expectation with Safety Management Systems (SMS) is that written policies and procedures are to be followed by employees, both ashore and afloat.   Just ask anyone who has been involved in a serious accident investigation, or litigation. 

The hard truth is, best way to learn the company’s policies and procedures is to “hit the books” and actually look up the information and apply it to real-life situations.  The best way to ensure this is done is to provide a tool to shipboard and shore-side employees which will help them do the work.

 

Continue reading
  2741 Hits
  0 Comments
2741 Hits
0 Comments

What's the best way to get captains and crews to learn company policies and procedures?

These days there are many policies and procedures for crews to follow. As we have discussed in the past, many policies and procedures may be unreasonable or unrealistic, but once they have been customized and refined, what's the best way to get captains and crews to learn and follow them? Unfortunately, the answer is to "crack the books" which not too many people enjoy.  This is a true leadership challenge, but with the right skills and tools it can be done.

Please join us in New Orleans on April 29th for an important seminar on the proper implemenation of safety management systems.  Please follow the link below for further details:
http://www.marcomint.com/index.php?option=com_content&view=article&id=24&Itemid=16

  2578 Hits
  0 Comments
2578 Hits
0 Comments

USCG to “Evaluate Compliance” of EPA VGP March 11, 2011

Beginning March 11, 2011 during vessel boardings and inspections, the U.S. Coast Guard will begin evaluating compliance with the U.S. Environmental Protection Agency (EPA) Vessel General Permit (VGP).  A Memorandum of Understanding (MOU) was recently signed between the two agencies, and a USCG policy letter was published, requiring Coast Guard inspectors to use a job aid to evaluate the level of compliance on a particular vessel, document any discrepancies, and pass them along to the EPA.  The EPA retains enforcement authority and will take enforcement action based upon the information gathered by the USCG.

Continue reading
  3203 Hits
  0 Comments
3203 Hits
0 Comments

Important SMS information for 2011

Please watch this brief, but important video message...

  2088 Hits
  0 Comments
2088 Hits
0 Comments

EPA VGP Compliance – Do You Have All the Facts?

Each vessel owner/operator I ask about EPA VGP compliance gives me a different response:  “Oh yeah, I heard about that…We’ve got it covered we just log how much graywater we discharge and try not to wash any oil over the side…I asked the Coast Guard and they don’t know anything about it…Is that for real..?” 

This year I was selected to do a session on EPA VGP compliance at the International WorkBoat Show Professional Series being held in New Orleans from December 1-3.  In preparation for my presentation, I just concluded a meeting in Houston with EPA officials who are responsible for the EPA VGP in EPA Region 6.

Continue reading
  3179 Hits
  0 Comments
3179 Hits
0 Comments

Contact Us

This email address is being protected from spambots. You need JavaScript enabled to view it.
Phone: 504.249.5291 | Fax: 504.367.3308

Copyright ©
Maritime Compliance International
All rights reserved | Privacy Policy

Maritime Compliance Report Sign-Up

Click here to subscribe to the Maritime Compliance Report blog for critical email updates on compliance issues.