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.

Public Forum on Proposed Towing Vessel Inspection Regulations

New Orleans Riverside Hilton
Friday September 9
8:45am – 1:00pm

 
  1858 Hits
  0 Comments
1858 Hits
0 Comments

EPA VGP One-Time Reports Due

At our last professional development workshop on EPA VGP and MARPOL Annex VI there was lots of concern about the EPA VGP one-time report which is currently coming due. My excellent contact at the EPA has provided some very specific and detailed information about the 30-36 month window. Below are his comments on the matter: First, EPA HQ has updated the electronic reporting page FAQ with many answers that address when one time reports are due for different scenarios. The FAQ can be found at http://cfpub.epa.gov/npdes/vessels/vesselsreporting.cfm#submit

Continue reading
  2514 Hits
  0 Comments
Tags:
2514 Hits
0 Comments

Coast Guard Set to Crack Down on Towing Industry Safety

The Coast Guard is proposing extensive new regulations for the towing industry requiring towing vessels to obtain a certificate of inspection within the next few years. According to the Coast Guard discussion of the proposed rule, on an annual basis, towing vessel accidents are associated with 23 fatalities, 146 reportable injuries, 26 oil spills and $63.5 million in property damage. 4% of major incidents were due to electrical failures, equipment failures in propulsion and steering accounted for another 30%, and human factors contributed to 54% of the major incidents. One of these major accidents happened in New Orleans in July of 2008 resulting in a $275 million a day economic impact, and was used in Coast Guard testimony to Congress to argue in favor of the new regulations.

Since the majority of accidents are related to human factors, the Coast Guard is proposing a towing safety management system with specific procedures for crewmembers and shore side personnel to follow that will most likely ensure safe operations. The safety management system will be required to be audited by third party auditors to ensure that all vessels and employees within the company follow written protocols.

Continue reading
  2605 Hits
  0 Comments
2605 Hits
0 Comments

Coast Guard Makes a Course Correction on FSPs

Apparently, based upon a recently published Coast Guard policy decision, lots of facilities will be able to throw their facility security plans (FSPs) in the trash. The policy document “Policy Advisory Council #02-11” lists 35 regulated cargos which are now exempt from maritime security regulations based upon their low risk. Most of the facilities which will be able to dispose of their FSPs are facilities that deal exclusively with barges. In general, if any of these facilities receive ships they will still be required to have an FSP due to the ships they receive, as always. However, the document is still useful for those ship-receiving facilities in deciding the appropriate level of security for the “cargo awaiting loading on ships” since the policy document clearly states these products, “have little threat of contributing to a TSI.” Some questions for those ship-receiving facilities to ask about their FSP might be, “Do the cargo areas then still need to be restricted areas, or part of the secure area?”

 

Continue reading
  2089 Hits
  0 Comments
2089 Hits
0 Comments

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....

  1786 Hits
  0 Comments
1786 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
  2213 Hits
  3 Comments
2213 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
  2042 Hits
  0 Comments
2042 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
  2620 Hits
  0 Comments
2620 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
  3279 Hits
  0 Comments
3279 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
  2529 Hits
  0 Comments
2529 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