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INTERTANKO North American Panel 17 March 2008. Jeff Lantz Director of Commercial Vessel Regulations and Standards. United States Coast Guard. Rate of Detention by Vessel Type. Rates of Vessel Arrivals vs. Detentions by Age of Vessel. Detainable Deficiencies.
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INTERTANKO North American Panel17 March 2008 Jeff LantzDirector of Commercial Vessel Regulations and Standards United States Coast Guard
Detainable Deficiencies • Despite required compliance dates of more than 5 years ago, the U.S. continues to find that ISM related deficiencies constitute a very large proportion of detainable items. • One of the largest increases in detainable deficiencies this year was in the area of crew competency.
United States Coast Guard Summary of PSC Performance Safety Rolling Detention Ratio 2006: 1.78% Safety Rolling Detention Ratio 2007: 1.60% 1 Security Major Control Action Ratio 2006: 0.43% 2 Security Major Control Action Ratio 2007: 0.53 1 & 2 Note 1: 2007 preliminary data, subject to change Note 2: In 2006, the CAR targeting level was fixed at 1.50% for all flag registries.
QUALSHIP 21- “Quality Shipping for the 21st Century” • Qualifying Registries for 2007: Barbados China Marshall IslandsBelize Greece PhilippinesBermuda Hong Kong Republic of Korea Canada Israel United Kingdom Cayman Islands • Qualifying Registries for 2008 will be announced in May 2008 and vessel flying their flag will be eligible until May 2009. • Due to excellent performance from certain flag States, there will likely be additions to the current qualified flag States.
Positive Policy Impact • HIV - revised (June 07) • decreased boardings by 50% • 1st time US arrivals not automatic HIV • No double jeopardy for Certain Dangerous Cargoes (CDC) vessels • COTP flexibility to downgrade • PSC - revised (June 07) • Smarter targeting = Fewer random *(how much…50%...what are the numbers) • Modification to targeting rules = less redundancy (LPOC rules) 135,240 Vessel Arrivals
Conditions of Entry • Additional security measures may be imposed on ships arriving to U.S. ports from countries not maintaining effective anti-terrorism measures as a Condition of Entry • Concerns are discussed with country • Conditions of Entry are a last resort • Advance public notice given • Specific facilities or ports in a country may be exempted if adequate security is found in that particular facility • Countries for which Conditions of Entry are imposed Cameroon Liberia Equatorial Guinea Mauritania Guinea-Bissau Syria Indonesia
While in the foreign port with inadequate anti-terrorism measures: Implement measures per the ship’s security plan equivalent to Security Level 2; Ensure that each access point to the ship is guarded and that the guards have total visibility of the exterior (both landside and waterside) of the vessel. Attempt to execute a Declaration of Security; Log all security actions in the ship’s log; and Report actions taken to the cognizant U.S. Coast Guard Sector Commander prior to arrival in the U.S. While in U.S. ports, after arriving from a foreign port with inadequate anti-terrorism measures: Ensure that each access point to the ship is guarded by armed security guards and that they have total visibility of the exterior (both landside and waterside) of the vessel. The number and location of the guards must be acceptable to the cognizant U.S. Coast Guard Captain of the Port. Conditions of Entry Requirements – Vessels must…
Interaction with marine industry ALCOAST 108/08, 6 March 2008 • Restore professionalism, respect and trust • Openness and transparency will be our hallmarks • Boarding members, marine inspectors, PSCOs will encourage open communication with mariners • Senior leadership contact information will be provided • Resolve issues at lowest level possible – encourage, facilitate and expedite appeals • Identify and resolve pending issues, identify best practices and recommendations • Actions that restrict vessel movement will be affirmed
HOMEPORT - http://homeport.uscg.mil CFR - http://www.access.gpo.gov/nara/cfr/cfr-table-search.html NVIC – http://www.uscg.mil/hq/g-m/nvic/index.htm E-NOA - www.nvmc.uscg.gov COFR - http://www.uscg.mil/npfc/COFRs/index.htm VRP Info - http://www.uscg.mil/vrp/ E-VRP Database –http://www.e-vrp.com Ballast Water - http://invasions.si.edu/nbic/submit.html PSIX - http://cgmix.uscg.mil/psix/ USEFUL SITES
USCG Port State Control Exams • Conduct Navigation Safety Checks • Evaluate the Safety Management System • Evaluate the Vessel’s Security System • Conduct a Deck Walk and Evaluate the Vessel’s Structure • Conduct Steering Gear Tests • Test the Oily Water Separator and Bilge Monitor • Test the Fire Detection System • Test the Fixed Deck Foam System (Oil Tankers Only, use water) • Operate the Main and Emergency Fire Pump • Examine Emergency Lighting • Test the Emergency Generator • Witness Fire & Boat Drills • Evaluate ILO Conditions That May Be Unacceptable
MARPOL Annex I Enforcement • U.S. Coast Guard enforcement of MARPOL Annex I has been enhanced by issuance of policy guidance, G-PCV Policy Letter 06-01. • U.S. Government criminal investigations into MARPOL Annex I violations show vessel and crew concealment of pollution discharge caused by poorly maintained or faulty equipment, or by vessels taking short cuts to save money. • U.S. Coast Guard continues to partner with IMO and other Port State Control regimes to ensure consistent enforcement of MARPOL Annex I requirements. 18
QUALSHIP 21- “Quality Shipping for the 21st Century” Eligibility Requirements: • Must not have an IMO Detention in U.S. waters within the previous 36-months • Must not have any marine violations (civil or criminal) and no more than one paid Notice of Violation (ticket) case, within the previous 36-month period • Must not have a reportable marine casualty that meets the criteria of a serious marine incident (46CFR4.03-2) in U.S. waters within the previous 36-months. • Must have completed a successful, U.S. Port State Control exam within the previous 12-month period. • Must not be classed by or have their statutory Convention Certificates issued by a targeted class society. 19
QUALSHIP 21- “Quality Shipping for the 21st Century” • Eligibility Requirements (Cont): • Must not be registered with a Flag State that has an overall U.S. IMO detention percentage of more than 1% over the previous three-year period. Also, the vessel’s Flag State must have at least 10 distinct arrivals in each of the previous 3 years. • Vessel’s Flag State must have submitted their Self-Assessment of Flag State Performance to the IMO and provided a copy to the USCG. • Qualship 21 Certificates: - Qualship 21 certificates are good for 2 years and the issue date is based on the vessel’s last successful U.S. PSC exam. 20
ISPS/MTSA Security Compliance Vessel Security Level Verify ISSC Verify Ship Security Performance Review the CSR and other Records Ship ID (IMO number) Manning Non-Convention Vessel Security Compliance Examination • Objective - determine whether vessel meets International Conventions and U.S. Domestic Law 21
Verify Ship Security Performance Verify Ship Security Plan (SSP) is onboard and safeguarded SSP not subject to direct inspection If clear grounds exist that required security procedures are not in place, the PSCO will investigate. PSCO may examine the relevant sections of the plan after exhausting other means to determine compliance. PSCO must obtain the consent of the vessel’s flag State, or the master of the vessel as specified in ISPS Code Part A, 9.8.1 before examining relevant portions of the SSP. 22
Security Records Training, drills, & exercises Reports of security incidents/breaches Changes in Security levels External communications related to Ship Security Internal audits/reviews Periodic reviews of ship security assessments/plans Maintenance, calibration, & testing of security equipment 23
While in the foreign port with inadequate anti-terrorism measures: Implement measures per the ship’s security plan equivalent to Security Level 2; Ensure that each access point to the ship is guarded and that the guards have total visibility of the exterior (both landside and waterside) of the vessel. Attempt to execute a Declaration of Security; Log all security actions in the ship’s log; and Report actions taken to the cognizant U.S. Coast Guard Sector Commander prior to arrival in the U.S. While in U.S. ports, after arriving from a foreign port with inadequate anti-terrorism measures: Ensure that each access point to the ship is guarded by armed security guards and that they have total visibility of the exterior (both landside and waterside) of the vessel. The number and location of the guards must be acceptable to the cognizant U.S. Coast Guard Captain of the Port. Conditions of Entry Requirements – Vessels must…