Strengthening U.S. Coast Guard Oversight and Support of Recognized Organizations: The Case of the Alternate Compliance Program (2021) / Chapter Skim
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Pages 121-134
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In the Hamm Alert Maritime Safety Act of 2018, as part of the Save Our Seas Act of 2018, Congress required the U.S. Coast Guard (Coast Guard)
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122 STRENGTHENING U.S. COAST GUARD OVERSIGHT AND SUPPORT OF ROs beyond the initial stages of policy and program introduction to ensuring their increasingly effective, long-term execution.
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BUILDING AND SUSTAINING A SAFETY PARTNERSHIP 123 also providing guidance and procedures for inspectors and TPO coordinators on policy implementation. For such purposes, CVC-4 has introduced a set of work instructions for field inspectors for detecting, and referring to TPO coordinators, evidence of lapses in the quality of RO inspections and in their audits of vessel and company SMS plans.
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124 FI G U R E 7 -1 C oa st G ua rd a ct io ns i n re sp on se t o fin di ng s an d re co m m en da ti on s fr om E l Fa ro i nv es ti ga ti on s pe rt ai ni ng t o th e A lt er na te C om pl ia nc e Pr og ra m a nd t hi rd -p ar ty o ve rs ig ht .
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BUILDING AND SUSTAINING A SAFETY PARTNERSHIP 125 fulfillment of its role but within the limits of its authorities and capabilities. However, the figure also shows how the Coast Guard's progress in certain other areas has lagged.
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126 STRENGTHENING U.S. COAST GUARD OVERSIGHT AND SUPPORT OF ROs In the near term, the Coast Guard has little choice but to use the information in MISLE along with any other relevant data it can obtain from ROs and other sources (such as foreign port-state control inspection data)
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BUILDING AND SUSTAINING A SAFETY PARTNERSHIP 127 records and to add supplemental fields should not be formidable. However, it would be desirable for the Coast Guard to ensure that information from the Marine Safety Center's plan reviews is incorporated -- as this information does not currently reside in MISLE.
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128 STRENGTHENING U.S. COAST GUARD OVERSIGHT AND SUPPORT OF ROs need be kept current and regularly validated for accuracy.
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BUILDING AND SUSTAINING A SAFETY PARTNERSHIP 129 inspector competencies and experience levels for this purpose, and about the lack of marine safety personnel charged with, and capable of, overseeing ACP compliance and RO performance generally. The Coast Guard has taken important steps to address these concerns, including the introduction of new work instructions and tools (e.g., a mobile app for inspectors)
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130 STRENGTHENING U.S. COAST GUARD OVERSIGHT AND SUPPORT OF ROs Recommendation 6: The Coast Guard should review its current career path progression guidance for Operations Ashore Prevention Officers, which was introduced before the El Faro investigations, with an eye to whether the guidance is being followed by sufficient numbers of junior officers, provides opportunities to master the marine inspection specialties, and ensures that mastery of those specialties provides ample career advancement opportunities in the prevention field, including relevant leadership positions such as OCMI.
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BUILDING AND SUSTAINING A SAFETY PARTNERSHIP 131 measures the Coast Guard should pursue to capitalize on the progress that has already been made. In thinking about the end goal of positively impacting vessel compliance and safety -- which Congress has set as the measure of effectiveness -- the committee also believes it will be important for the Coast Guard to ensure that its relationship with the ROs involves more than performance monitoring and oversight.
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132 STRENGTHENING U.S. COAST GUARD OVERSIGHT AND SUPPORT OF ROs ability to work as a team and needs to be addressed.
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BUILDING AND SUSTAINING A SAFETY PARTNERSHIP 133 a culture of learning and continual improvement by not only the ROs and vessel operators, but also the Coast Guard itself. Indeed, all monitoring and oversight activities will present opportunities for the Coast Guard to be more introspective and comprehensive in thinking about where improvements are needed and how they can be made.
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