facebookgoogle+
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.

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.

 

Continue reading
  3029 Hits
  1 Comment
3029 Hits
1 Comment

A “Good” Inspector

In the past, I have heard many opinions from vessel operators on what they consider a “good” Coast Guard marine inspector to be. The majority opinion has been that good inspectors apply “common sense” in enforcing regulations, or that they do not necessarily, “follow the book.” I disagree.


The truth is, enforcing prescriptive regulations has very little to do with applying common sense. Enforcing performance or management based regulations if a different story altogether, but we’ll save that for future discussions.  While some regulations may seem to be drafted without “common sense,” the authority to waive them is above an inspector’s pay grade. An inspector who is not knowledgeable of the regulations he is charged with enforcing, or is not thorough or consistent in enforcing them, is not doing anyone any favors.

 

Continue reading
  2654 Hits
  0 Comments
2654 Hits
0 Comments

Unraveling Subchapter M

The level of understanding of Subchapter M runs the gamut from nonexistent to expertise. Some in the towing industry have been involved with the process for the past eight years, helping to steer the direction of the final rule. Others in the towing industry have still never heard of a TSMS or think Subchapter M is a pipe dream which will never come to fruition. So here’s a basic recap for those who may have been too busy to pay attention.

 

Continue reading
  4560 Hits
  0 Comments
4560 Hits
0 Comments

The Boy Who Cried Wolf

Sometimes I feel like the boy who cried wolf. I study all maritime related regulations and policies and warn my clients about the severe consequences of noncompliance. All too often the bark is much worse than the bite when it comes to these things due to minimal or nonexistent enforcement.  But when they do bite, it hurts. It hurts not only from the penalty, but from a sense of injustice. Vessel owners think, “Why am I being singled out? This was never an issue before? What about the company down the road?” For whatever reason, selective enforcement is a reality that we must live with. But every regulation ignored, or complied with in a half-assed manner, is a roll of the dice. To be fair, there are many companies who choose to minimize their risk by accepting responsibility and dedicate themselves to getting it right. However, there is no denying that the “wait and see” strategy works and has worked for many years.

 

Continue reading
  2170 Hits
  0 Comments
2170 Hits
0 Comments

Pressure Cooker Bombs?

Pressure cooker bombs! Who knew?


You did hopefully. That is, if you are a “Company, Vessel or Facility Security Officer.” The tragic events of this week’s Boston Marathon should have come as no surprise to those charged by federal regulations with having, “…general knowledge through training or on the job experience in… recognition of dangerous substances and devices.”


Ten years ago, when the Maritime Transportation Security Act regulations were published by the Coast Guard, I was hired by a training company as a subject matter expert to develop a course. It was during my research for this project that I first heard of the pressure cooker bomb. The information that I gathered at the time was that this type of improvised explosive device (IED) was very popular in Malaysia. I incorporated many kinds of IEDs into the course, including pressure cooker bombs.

 

Continue reading
  2287 Hits
  0 Comments
2287 Hits
0 Comments

No Deficiencies?

Many vessel operators claim that Coast Guard inspections are notoriously inconsistent. They claim such things as, “One Coast Guard guy came and told me it had to be this way, and next year another one came and told me to do something else, and the next year a third guy came back and told me to do it the way we had it in the first place.” This unfortunately is true altogether too often, especially when it comes to dealing with inexperienced inspectors or examiners.

 

Continue reading
  2271 Hits
  0 Comments
2271 Hits
0 Comments

TWIC Readers

“I thought TWICs were going away?”  I have heard this many times over the past year. They are not. Many believe TWIC is a useless program. The truth is TWIC is a very important program, but few understand it.


Basically, the most important purpose of a TWIC is to not allow anyone, unescorted, into a secure area of a vessel or facility unless we know they are not a terrorist and they have a card to prove it. This may seem like nonsense to some, but if a major terrorist organization can send a terrorist spy to the U.S. and infiltrate the CIA, FBI and Army Special Warfare command, then they can surely send some to infiltrate the maritime industry. In fact, during one joint FBI/ USCG operation, a significant number of individuals “having a nexus to terrorism matters,” were found to have U.S. merchant mariner documents and they were subsequently placed on the terrorist watch list and the no-fly list. Furthermore, officials recently uncovered a major plot to attack the maritime industry because it is viewed as a soft target by terrorists.

 

Continue reading
  2441 Hits
  0 Comments
2441 Hits
0 Comments

Subchapter M Alliances and Software

Check out this interesting article on Subchapter M alliances and software being developed:


http://www.marinelink.com/news/surfaces-chapter-finally351557.aspx
  2178 Hits
  0 Comments
2178 Hits
0 Comments

Lessons Learned from a Cruise Ship Fire

According to news sources, Coast Guard investigators have explained that the cause of the engine room fire on the Carnival Triumph was a leaking fuel return line. There is a lesson to be learned for all vessel operators, especially towing vessel operators considering adopting a towing safety management system (TSMS) under Subchapter M.

 

Continue reading
  2228 Hits
  0 Comments
2228 Hits
0 Comments

Critical Decisions for Vessel Operators and Third Parties

It seems that whenever a new rule making is in progress an entire new industry evolves. This was the case with Oil Pollution Act (OPA) of 90, as well as the Maritime Transportation Security Act (MTSA) of 2002. But both may pale in comparison to the economic opportunity provided by Subchapter M, which may be seen as a potential gold mine for some professional services companies and maritime entrepreneurs. Unfortunately, for towing vessel operators, the amount of information being levied upon them may add to their confusion and stress when trying to make the best decisions for their companies. 

 

Continue reading
  2262 Hits
  0 Comments
2262 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.

Stay Connected