Tag: USCG

Recommended Reading

Recommended ReadingIt’s a hot summer weekend and you are heading to the <insert one> :

a. pool

b. beach

c. mountains

d. couch

Are you going to read the latest feel-good novel from the New York Time best seller list or something that might give you an idea of what is coming down the road in the maritime industry?  You know, that place where you make your living?

A few recommendations for summer reading are below.  Download them to your tablet, e-reader or phone and enjoy them as you go.

USCG Proceedings : The 21st Century Maritime Workforce

The Navigator : Issue 15 : Mentoring

Phish and Ships #7 : June 2017

IGP&I (International Group P&I) 2016/2017 Annual Review

U.S. Coast Guard 2692 Updated : What to report and when

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Had a bad day?  Maybe it wasn’t as bad as the vessel above, but you know you need to give the nearest U.S. Coast Guard OCMI (Officer in Charge of Marine Inspection) or COTP (Captain of the Port) a call.  Where do you start?

Fortunately for those who have not had to make such reports in the past, the USCG has provided guidance.  Navigation and Vessel Inspection Circular (NVIC) 01-15  lays out the requirements for reportable incidents in accordance with 46 CFR Part 4.  There are very specific reports – both immediately (generally by voice) and then written within 5 days.

Many a company has failed to adequately provide the immediate notification, which can lead to fines.  As the fines are up to $32,500, this is sure to quickly gain the attention of company management.  Vessel personnel can expect rapid modification of procedures for reporting of incidents when fines are levied.

Immediate does not mean instantaneous, however.  It means “as soon as reasonably practicable without delay.”  In other words, take care of what needs to be taken care of to ensure the safety of crew, vessel and other safety concerns before stopping to call the nearest USCG Command Center.  It is highly recommended that the command center is utilized for these notifications instead of contacting a particular inspector, as it provides the opportunity for the fastest response.

In the event that the nearest USCG OCMI or command center cannot be reached by telephone or radio, the National Response Center is certainly an option.  In a pinch, ensuring a message is left or a particular inspector IS contacted, this should fulfill the reporting requirements.  Just remember that you may be judged on how thorough your efforts were to make that initial voice report.

And the 2692 (the written report) has changed rather significantly.  There is a brief video below that describes those changes.  The current 2692, 2692A and 2692B can continue to be used until midnight on December 31st, 2016.  As many in the industry have these saved onboard or on their personal equipment, ensuring an overlap is an excellent idea.  Be aware that the changes are coming!

Having to file a USCG 2692 or make the initial voice reports is not the end of the world.  We may not relish the idea of the Coast Guard or company investigating the incident, but it is part of being a professional mariner.  Trying to sweep an incident under the rug will rarely work out well.  Check out the links below that include the guidance on required reporting both from Sector New Orleans and NVIC 01-15.

Let’s be safe out there.

Additional Reading and Links

USCG : Commercial Vessels : Reportable Marine Casualty and what to do

USCG NVIC (Navigation and Vessel Inspection Circular) No. 01-15 : Marine Casualty Reporting Procedures with Associated Standard Interpretations

2692 : Report of Marine Casualty, Commercial Diving Casualty or OCS-related Casualty

2692A : Barge Addendum

2692B : Report of Mandatory Chemical Testing Following a Serious Marine Incident

2692C : Personnel Casualty Addendum

2692D : Involved Persons and Witnesses Addendum

 

USCG Rolling Out AIS ATON : Safe AND Secure?

There are new buoys – and is some cases virtual buoys – coming to a U.S. port near you.  First seen in the port of Mombasa, Kenya almost two years ago, AIS-assisted buoys (Real AIS ATON) – physical buoys with an AIS transmitter installed – will be rolled out in select areas on an experimental basis by the U.S. Coast Guard.  These will be accompanied by both Synthetic AIS ATON – physical buoys overlaid with an AIS signal generated by a shoreside base station and Virtual AIS ATON – truly virtual buoys with no physical presence, which would be visible on an appropriately outfitted ECDIS, radar or computer.

U.S. Coast Guard to Test Automatic Identification System (AIS) Aids to Navigation (ATON)

Mariners first noted Real AIS ATON in the approaches to Mombasa, Kenya during routine transits.  The addition of the AIS transmitters – which we do not believe was announced through NAVTEX or chart updates – have allowed these buoys to stand out more when viewed on the ECDIS, while still allowing visual use.  The recent announcement by the U.S. Coast Guard highlights the chart symbols that will be in use.  It is of note that these symbols are not yet in use on the U.K. Admiralty charts for the approaches to Mombasa (please see linked chart).

KPA – Mombasa – High Performance Navigation Aids Installed

As noted, in real-life applications Real AIS ATON have proven to be beneficial.  As with all methods of navigation, redundancy is extremely important, therefore coupling the physical ATON with the virtual ATON is a great combination.  The introduction of the Virtual AIS ATON is a little more troubling.  Research by Trend Micro Inc., an internet security company based out of Tokyo as announced by gCaptain has revealed some serious security issues with the AIS system.  Being that AIS signals lack any form of encryption or authentication, they are vulnerable to hacking by outside forces.  This has been demonstrated repeatedly by Trend Micro – including the spelling of the classic hacker tag “PWNED” with a vessel’s AIS track.

gCaptain – Researchers Discover Serious Security Vulnerabilities to AIS Data

Advances in aids to navigation are welcome – anything that can make the operation of vessel’s safer is great.  However, it can be hoped that we don’t hang our hat – or the safety of vessels – entirely on the AIS system.  Yet.

Focusing On Enclosed Space Entry

As mariners, we’ve all been there, ready for us or one of our crew to go diving into one of the deep recesses of the vessel that doesn’t see light, air or crewmembers very frequently.  Hopefully, we are in the group that has done our due diligence, checked all the boxes and actually performed the tasks listed next to the boxes.  If not, we might be one of the lucky ones that pops out of the space unscathed as a port engineer at a tug company did after entering a newly opened, unventilated fuel tank.  Or, in the worst case scenario of not following procedures for enclosed space entry, we or our crew are pulled out in a body bag.  We don’t have to look too far back to see exactly such an instance on the former Pacific Princess, where two persons died after working in an unsafe atmosphere in early August 2013.

This topic is near and dear to our hearts at Madden Maritime and you can expect to hear more on it from both us and many others around the industry.  Not only are protection and indemnity insurance clubs (P&I clubs) hammering on this issue, but increasingly those who have a lot more at stake.  Just yesterday, the U.S. Coast Guard issued Safety Alert 08-13, which comments on recent incidents involving their inspectors onboard vessels.    The International Association of Classification Societies (IACS) issued Recommendation 072 Confined Space Safe Practice quite a bit ago, but illustrates the emphasis on keeping surveyors from the various class societies safe.

In the immortal words of Hill Street Blues’ Sergeant Esterhaus, “Let’s be careful out there.”

For a little more reading and enlightenment :

A Master’s Guide to : Enclosed Space Entry

MLC 2006 and Port State Control

A mere 3 weeks before the implementation of the sweeping Maritime Labor Convention (MLC 2006) from the International Labor Organization, the United States Coast Guard finally provides guidance to vessels flying the U.S. flag in international trade.  U.S. shipping companies have been scrambling during the previous months to ensure that their vessels are not detained while on foreign voyages and calling in countries that have ratified the MLC 2006.  Navigation and Vessel Inspection Circular (NVIC) 02-13, “GUIDANCE IMPLEMENTING THE MARITIME LABOUR CONVENTION, 2006,” is intended to provide guidance for Coast Guard marine inspectors, Recognized Classification Societies (RCS) that are authorized to issue international convention certificates on behalf of the Coast Guard, and U.S. vessel owners/operators on the U.S. laws and regulations, or other measures, conforming to the MLC 2006.

While the majority of U.S. vessels affected by this convention are fully compliant through existing U.S. laws, port state control (PSC) officers could easily detain them in foreign ports as the convention states they must, “…ensure that the ships that fly the flag of any State that has not ratified this Convention do not receive more favourable treatment than the ships that fly the flag of any State that has ratified it.”  The implementation of a convention of this magnitude is not without its well-meaning, but possibly misguided attempts to enforce it.  In order to remove some of the mystery, the International Chamber of Shipping has issued, “GUIDANCE FOR SHIP OPERATORS ON PORT STATE CONTROL AS FROM 20 AUGUST 2013.”  This pamphlet includes an overview of the enforcement procedures and methods of complying with the convention.  It also (on page 5) discusses three remedies that may be available in the event of PSC difficulties.

A major container ship company recently commented that the difference between profit and unprofitability might be as simple as a detained vessel.  With charter and daily operating costs running into the tens of thousands of dollars, avoiding any detentions based on MLC 2006 issues will be key.  To that end, a review of the ILO “Guidelines for port State control officers carrying out inspections under the Maritime Labour Convention, 2006” may keep you, your ship or your company out of hot water.  Forewarned is forearmed.