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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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Public Forum on New Towing Vessel Regulations

The public forum sponsored by Maritime Compliance International, LLC held in New Orleans on September 9 was intended to inform the industry, not just on the contents of the NPRM, but also to discuss the implications and the intent of it all. The forum provided industry stakeholders with an overview of the regulations along with some insights, based on my past experience as a Coast Guard marine inspector, as to what it all might look like when fully implemented. This spurred some interesting discussions and some great comments which will be posted to the docket.

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Public Forum - Towing Vessel Regulations - Update

New Orleans Riverside Hilton – Friday September 9, 2011
Forum is free. Please let us know if you plan on attending by This email address is being protected from spambots. You need JavaScript enabled to view it.

I’m on my second reading of the 76 page Notice of Proposed Rule Making (NPRM). As a retired Coast Guard marine inspector who has issued many COIs, much of it looks very familiar, but it also leaves many questions unanswered. I spoke with the program manager at Coast Guard headquarters about many of the issues and he stressed the importance of raising all of these questions by posting them to the docket so the Coast Guard has the opportunity to consider them and respond to them before the final rule is published.

 

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Public Forum on Proposed Towing Vessel Inspection Regulations

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

 
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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

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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.

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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?”

 

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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....

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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.

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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).
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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.

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