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.
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.
Compliance is something that many only think of when forced to. At the Workboat Show many representatives from good companies pass by our booth and say hello, but when asked if they have any compliance questions or issues we can help with, the response is usually, “No thanks we’ve got all that under control.” Perhaps they do, but chances are their issues just haven’t risen to the surface yet. Many good companies pass inspections and audits and assume that they are in full compliance. They may be, or they may find out at the next inspection, audit or accident that they were not as compliant as they had assumed. But an excellent company has a proactive compliance management program as part of their regular routine and does not rely upon inspectors’ and auditors’ interpretations and opinions to determine their level of compliance.
As I read the indictment of two BP officials, Robert Kaluza and Donald Vidrine, on 11 counts of seaman’s manslaughter and involuntary manslaughter, I couldn't help but think about Subchapter M and the future of the towing vessel industry. Mr. Vidrine and Kaluza were Well Sight Leaders on the Deepwater Horizon rig the day of the explosion which resulted in the deaths of 11 people. According to the indictment, these Well Sight Leaders were responsible for, among other things, “supervising the implementation of BP’s drilling plan.” To draw an analogy, under Subchapter M, should a company operate under a Towing Safety Management System (TSMS), the captain will be responsible for “supervising the implementation of the company TSMS.”
The International WorkBoat Show in New Orleans is fast approaching. It is being held in the New Orleans Convention Center from December 5-7. If you are interested in learning the latest about regulations and compliance and you are planning on investing in the conference sessions, I’d like to bring two sessions to your attention:
Wednesday December 5, 2012 from 4:00 – 5:30pm I will be participating in a conference session moderated by retired RADM Whitehead on: “Choosing a Compliance Option for Towing Vessel Regulations: What You Need to Know.”
Friday December 7, 2012 from 1:00 – 2:00pm I will be conducting an hour-long session: “Culture of Compliance” where I will go in depth on my comprehensive model for maritime compliance management.
If you have specific questions, please come by our booth: 2757 and visit with us. We look forward to seeing you all there!
On a recent visit to Greece I was invited to speak at the Safety4Sea conference in Athens to an audience of almost 400 attendees. I took the opportunity to introduce my Maritime Compliance Management Model. Click on the picture to watch the short video:
If a company hired a new captain for a new vessel, and shortly thereafter that captain was asked what challenges he faces on his new vessel, what do you think he might say? I can’t imagine him saying that the biggest hurdle he faced was that there was not enough established doctrine or written procedures for him to follow! Perhaps if International Safety Management (ISM) systems had been implemented as intended, to minimize human error by following written procedures that represent best practices, he might have said such a thing. But that culture, to my knowledge, has not been established on the civilian side of seafaring. While working with companies to implement ISM and other safety management programs, I often use the example of serving on a number of Coast Guard cutters, where there was a right way to do everything, and it was written down in manuals. There were almost no checklists used either, because everything had to be learned, practiced, memorized and drilled. From this perspective, I believe a real safety culture is one where the word “safety” is never mentioned. I can’t remember ever hearing it on any Coast Guard cutter: there was only the right way to do things. In watching Dale DuPont’s interview with LCDR Craig Allen, Commanding Officer of the USCGC William Flores, on Workboat.com recently, I was pleased to see that some things never change. Listen to what the Captain says when asked what challenges he faces on his new vessel… (Video interview) That’s right; he says that their biggest hurdle is that there is not enough established doctrine or procedures to follow. He explains they will have to make them from scratch based upon lessons learned and best practices. This is an example of what the Coast Guard’s “safety culture” looks like. The operational Coast Guard is not an excellent organization by accident. How excellent is your operation?
Time flies. It’s hard to believe that many TWICs are reaching their expiration date. Thankfully, there is an alternative process to renew a TWIC for those whose cards are now expiring. As long as you are a U.S. citizen or U.S. national and your TWIC is expiring before December 31, 2014, all you have to do is call 1-866-347-8942 and pay $60, to order a new TWIC which will be good for another three years. A client recently did this over the phone with all their employees and found it to be a very simple process. Of course, once the TWIC is ready, it will require a trip to a TWIC center to pick it up and activate it.