Summary of remarks by Asst Commandant for Prevention Policy

Adam Foster
Adam Foster

15 March 2018

Rear Adm. John Nadeau, assistant commandant for prevention policy, addressed leaders from the maritime shipping industry during a morning panel session hosted by INTERTANKO, during Connecticut Maritime Association’s Shipping 2018, in Stamford, Connecticut, March 12, 2018. INTERTANKO, the International Association of Independent Oil Tankers, represents 205 independent tanker owners and operators of oil, chemical and gas tankers, and non-state controlled tanker owners. “It is an honor to be here to speak with you today,” Nadeau said. “You are the representatives of the world’s shipping industry and I always look forward to meeting with you face-to-face so that we can talk about some of things that are of great importance to both of us.” Nadeau gave attendees a snapshot of the most recent Port State Control statistics, in advance of the annual PSC report, which is due out in the coming weeks. More than 10,000 foreign ships made port calls to a U.S. port last year, representing 84 different flag administrations – an 8 percent increase in the number of foreign vessels arriving in the U.S. Despite the increase in arrivals, the detention rate was less than 1 percent, which Nadeau said is the lowest rate in recent history. The three leading causes for detentions over the last year were deficiencies in firefighting appliances, lifesaving equipment, and safety management systems. “The shipping industry should be proud of the 1 percent detention rate,” Nadeau said. “The Coast Guard tries to be as transparent as possible about its expectations for ship owners and operators, because it’s in everyone’s interest that operations run smoothly and efficiently, all the while ensuring the regulatory and Port State Control requirements are met.” Nadeau briefly discussed the E-Zero program, which rewards those foreign ships that have consistently adhered to environmental compliance, while also demonstrating an immense commitment to environmental stewardship. Since the program’s inception in 2017, 48 ships have been awarded an E-Zero certificate. Nadeau added that approximately 100 others would be eligible, if not for the existence of BWMS extension letters. During a discussion on the latest regarding ballast water management system extensions, Nadeau heard from attendees about some of the challenges they face as they work toward compliance:
  • Harmonisation of enforcement of EPA and USCG BWMS regulations
  • Operability of existing type-approved BWM systems
  • Dynamic nature of vessel operations and scheduling, and the effects of dry-dock slippage on BWMS compliance
The number of exams rose by 2 percent in 2016/2017, but the number of BWMS deficiencies more than doubled. Nadeau attributed this to increased enforcement and awareness on the part of OCMIs since the regulations went in effect, not necessarily to any negative actions on the part of industry. Nadeau further stated that the Coast Guard instituted operational controls in just 17 cases, which equates to roughly .2 percent of the total number of exams performed. None of the PSC detentions were BWMS-related. “We want to work with companies to help them come into compliance, because we recognize the challenges you face and want to understand what you’re up against,” Nadeau said. “However, we’re seeing that in many cases operators have never even turned on their system before attempting to arrive in a U.S. port, and either don’t know how to use it or find that it doesn’t work. Neither of these is a valid reason to be non-compliant; your ballast water management plan should spell out how you’re going to meet requirements when faced with any contingency.” Nadeau said the Coast Guard has granted over 12,000 extensions to date, but emphasized that extensions should not be considered a strategy to comply. “We’re still issuing extensions, but we’re just being more selective and restrictive now that there are six type approved systems available, and three more under review.” To close, Nadeau said his goal is to ensure a safe, secure, and efficient Marine Transportation System by focusing on oversight of recognized organizations, SMS effectiveness, cyber risk management, and future implications of autonomous vessels. “We must seek a unified global approach and practical implementations, coupled with measured enforcement,” Nadeau said.