Commercial Vessel Compliance

3/13/2018: CMA Shipping 2018 – Summary of keynote address by Deputy Commandant for Operations, Vice Adm. Charles Ray

Vice Adm. Charles Ray, deputy commandant for operations and recently nominated Vice Commandant of the Coast Guard, delivered keynote remarks to about three hundred members of the international shipping community during Connecticut Maritime Association’s Shipping 2018 in Stamford, Connecticut, March 12, 2018.

Ray began his remarks by thanking Connecticut Maritime Association’s Joseph Gross and Jim Lawrence for their dedication in organizing the event and for giving the Coast Guard the opportunity to participate.

“This is my second time at CMA and I’m always impressed by the enthusiasm of the attendees and by the advocacy, wisdom and depth of experience of those here,” Ray said.

Ray’s remarks focused on securing the alignment of safe and efficient commerce. He pointed out that 90 percent of the world trade is carried by shipping and the U.S. alone accounts for 26 percent of the world’s consumer market. The United States is the fifth largest ship-owning country by tonnage and accounts for 986,816 metric tons of goods and services, which equates to 1.47 trillion U.S. dollars.

“Shipping will continue to be the most reliable and efficient means of transporting goods, Ray said. “Our challenge is ensuring the safety of this ever-growing marine transportation system in an age of rapidly changing technology.”

Ray acknowledged this poses a challenge for the Coast Guard’s prevention program, but it is one that is not taken lightly, especially in light of the El Faro tragedy and the recommendations in the Commandant’s Final Action Memo.

“Our U.S. mariners support our Nation’s prosperity, they support our military readiness, and they support our national security,” Ray said. “We owe them excellence; we fell short of that standard and improvement is our charge.”

Ray discussed the work of Rear Adm. John Nadeau, assistant commandant for prevention policy, who is leading the Commandant’s efforts in response to the recommendations. Nadeau put together a dedicated group known as the Third-Party Oversight Reform Team (T-PORT) that will be working to implement governance, policy, and accountability reforms to the Alternate Compliance Program.

The 20th Anniversary of the ISM Code is coming up, Ray reminded attendees, and asked them to take a look at their own efforts to develop Safety Management Systems that produced real, tangible benefits, not just dusty binders to sit on a shelf.

Ray invited attendees to ask themselves three questions:

1) Have they implemented a SMS?
2) Does their company have a strong safety culture?
3) Could an accident like the El Faro tragedy happen to one of their ships?

“I hope that everyone in here has a good feeling about those questions,” Ray said. “If you don’t, then, like the Coast Guard, you may have some homework to do.”

Ray then shifted to topics directed toward the future of shipping.

Ships are becoming more technologically complex, autonomy is on the horizon, and cyber vulnerabilities abound, Ray said, and as this new paradigm unfolds, and ships become more connected, the Coast Guard sees both challenges and windows of opportunity.

Because of these changes, the Coast Guard may have to turn its attention from prescriptive regulations and rely more heavily on the SMS to address risk. Ray noted one recent example was the Coast Guard’s push to require companies to address cyber vulnerabilities in their SMS by January 2021.

Ray said he expects to see continued pressure to reduce the environmental impact of the maritime industry, but says shipping also happens to be one of the few modes of transport where international regulation is achievable, due in no small part to the efforts of the IMO.

Ray also discussed how the upcoming 2020 0.5 percent global Sulfur cap has raised concerns over fuel availability and highlighted the need for consistent verification of compliance. In response to industry concern, IMO is taking action to support consistent implementation and the U.S. is actively participating.

“The U.S. believes that without consistent global implementation and enforcement some ship owners will be afforded a competitive advantage over those companies that choose to comply,” Ray said. “As with all environmental requirements, you can expect to see a strong effort within our Port State Control program to ensure compliance with these Sulfur limits.”

Ballast water management continues to be an area of intense focus for the Coast Guard, Ray said, reminding attendees that the Coast Guard is no longer as generous when it comes to issuing extensions because of the availability of six type approved systems to address a wide range of needs and requirements.

Ray also briefly discussed a number of guidance documents published, including NVIC 01-18 that provides the latest on extensions and compliance dates, and a policy letter that outlines courses of actions when a vessel bound for the U.S. has an inoperable system.

Ray closed by reminding attendees that safety and efficiency are not mutually exclusive terms and that the Coast Guard will continue to work with industry and the international community to ensure the regulations developed are fully transparent.

“We are committed to working with all member states at IMO, and we firmly believe this global industry requires the kind of certainty, consistency, and efficiency that can only be achieved through international regulation,” Ray said. “The Coast Guard will look to leverage the IMO to address safety, security and environmental protection.”

Want to read more of our coverage from CMA Shipping 2018? Check out these other posts:

3/29/2018: CMA Shipping 2018 – The critical role of integrating new technology within the regulatory approval process

3/15/2018: CMA Shipping 2018 – IMO and environmental standards

3/12/2018: CMA Shipping 2018 – Summary of remarks by Asst Commandant for Prevention Policy Rear Adm. John Nadeau

This blog is not a replacement or substitute for the formal posting of regulations and updates or existing processes for receiving formal feedback of the same. Links provided on this blog will direct the reader to official source documents, such as the Federal Register, Homeport and the Code of Federal Regulations. These documents remain the official source for regulatory information published by the Coast Guard.

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