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10/1/2018: Remembering El Faro

From the desk of Rear Adm. John Nadeau, Assistant Commandant for Prevention Policy

Today, we mark the somber anniversary of the sinking of the SS El Faro and the loss of the 33 men and women on board on October 1, 2015. It is appropriate to pause and reflect on this tragic and preventable accident, and challenge ourselves to ensure we are all taking action needed to prevent future casualties.

The Coast Guard Marine Board of Investigation (MBI) completed its Report of Investigation one year ago. The Coast Guard immediately published the report and shared it with the families, maritime industry, and the public. The Commandant solicited input from families of the crew and Parties in Interest, carefully evaluated each of the MBI’s 36 recommendations, and subsequently released the Final Action Memo  on December 22, 2017. In the Final Action Memo, the Commandant stated this casualty was a call to action for the entire maritime community and urged us all to “move with a sense of urgency.”

The Coast Guard is moving swiftly to drive change. I group our actions along four lines of effort.

First, the Coast Guard has continued to look more closely at third parties and vessels they examine on our behalf. Last October, we assessed U.S. flag vessels enrolled in the Alternate Compliance Program and similar programs where we delegate inspection functions to classification societies. We selected 44 vessels for additional oversight, including some government-owned Military Sealift Command and MARAD ships, a subset of the vessels enrolled in the Maritime Security Program, and some deep draft commercial ships that operate between Puerto Rico, Hawaii, Alaska and the continental U.S. These vessels had valid Certificates of Inspection and statutory certificates, and were generally up to date on all required exams and surveys. Unlike previous years, every vessel we selected was subjected to at least one additional oversight examination and our Traveling Inspectors from Coast Guard Headquarters attended these examinations with the local Coast Guard marine inspectors to ensure consistency.

We found that some operators are being proactive and making necessary repairs and process improvements. It is especially encouraging to see responsible operators replacing open lifeboats with new enclosed lifeboats, even though the existing boats are still “serviceable” and technically acceptable under SOLAS and U.S. regulations. However, despite these positive efforts, our findings also confirmed more must be done.

During our oversight examinations of the 44 selected vessels, we issued over 650 deficiencies for inoperable watertight fittings, load line discrepancies, problems involving firefighting systems and lifesaving appliances, and other areas of non-compliance. Most of the problems involve the basics and should have been addressed by the crew and operating company through proper preventative maintenance under a healthy safety culture. Based on these findings, seven vessels were required to undergo an additional Safety Management System (SMS) audit and the inspection certificates were removed from five vessels for failure to meet the minimum safety standards. We will continue to conduct risk-based, targeted oversight and increase our evaluation and scrutiny of each vessel’s SMS to determine if the operator has an effective system in place.

The second line of effort is directed at improving our oversight system for classification societies that perform delegated work. I chartered the Third Party Oversight Review Team (T-PORT) in January to initiate these reforms. T-PORT successfully implemented immediate and substantive changes, including the development of more rigorous procedures and detailed policy for both third parties and our local Coast Guard marine inspectors, a substantial increase in auditor training to improve the proficiency of Coast Guard personnel, and establishment of metrics and key performance indicators to monitor third party performance. We also made significant progress toward a single U.S. Supplement to the classification society rules and SOLAS, and created a new office to continue driving improvements necessary to provide robust oversight of third parties and delegated functions.

Third, we launched actions to make improvements to our marine inspector training program, increase accessions of Maritime Academy graduates, and prioritize the hiring of civilians to fill vacant marine inspector positions. These were immediately initiated by the new Commandant, Adm. Karl Schultz, when he assumed command to ensure we are a “Ready, Relevant, and Responsive” Coast Guard.

Lastly, the Final Action Memo outlines a dozen standards that we seek to modify or develop. To support this line of effort, several proposals have already been submitted to the appropriate body at International Maritime Organization (IMO) and more are currently under development. We will work with other IMO Member States to make safety improvements as these topics are added to the agendas of the various IMO working bodies. Updates and modifications to U.S. regulations will follow.

We are making substantial progress. But we are not done. A strong and enduring commitment is needed at all levels of the safety framework. Every crew and operator must commit to safety and embrace their responsibilities under the ISM Code. Classification societies must fully and effectively perform their duties. And the Coast Guard must sustain its efforts, deliver needed improvements, increase accountability, and ensure safety standards are upheld.

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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