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Pages 47-66

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From page 47...
... 47 The investigations of the El Faro sinking identified a number of factors causing and contributing to the casualty and its severity. In responding to the Marine Board of Investigation's report, the Commandant of the U.S.
From page 48...
... 48 STRENGTHENING U.S. COAST GUARD OVERSIGHT AND SUPPORT OF ROs The Statement of Task calls for the study committee to examine the actions planned and taken by the Coast Guard since the El Faro casualty in response to the findings and recommendations from the investigations pertaining to the Coast Guard's oversight of recognized organizations (ROs)
From page 49...
... COAST GUARD ACTIONS TO SUPPORT AND OVERSEE ROs AND ACP 49 performance and to make appropriate changes to the frequency and scope of oversight examinations of ACP vessels. Investigators noted that the Coast Guard had estab lished a process for targeting certain ACP vessels for more frequent and extensive oversight examinations.
From page 50...
... 50 STRENGTHENING U.S. COAST GUARD OVERSIGHT AND SUPPORT OF ROs two data systems, MISLE and the RO's records.
From page 51...
... COAST GUARD ACTIONS TO SUPPORT AND OVERSEE ROs AND ACP 51 The investigators also found shortcomings in coordination among Coast Guard marine safety personnel and the ROs. According to Coast Guard policy, a Coast Guard officer was supposed to serve as a liaison to each RO, thereby providing a centralized point of contact for RO surveyors and Coast Guard inspectors.
From page 52...
... 52 STRENGTHENING U.S. COAST GUARD OVERSIGHT AND SUPPORT OF ROs targeted oversight of ROs and other third-party organizations (TPOs)
From page 53...
... COAST GUARD ACTIONS TO SUPPORT AND OVERSEE ROs AND ACP 53 Marine Inspector and Recognized Organization Surveyor Guidance, Competencies, Qualifications, and Communications The Marine Board of Investigation made the following five additional recommendations pertaining to workforce and communication issues: • The Coast Guard should require RO surveyors to complete an assess ment process for each type of delegated activity to ensure that surveys and audits meet Coast Guard standards (Safety Recommendation 24)
From page 54...
... 54 STRENGTHENING U.S. COAST GUARD OVERSIGHT AND SUPPORT OF ROs IMPLEMENTATION OF AGREED-TO OVERSIGHT ACTIONS The Commandant's final action memorandum was issued on December 19, 2017, shortly after the Marine Board of Investigation and the NTSB issued their recommendations.
From page 55...
... COAST GUARD ACTIONS TO SUPPORT AND OVERSEE ROs AND ACP 55 • Provide liaison direction to all ROs in support of the ACP and other vessel compliance programs that require oversight of TPOs (in addition to providing oversight of ACP, CVC-4 provides oversight of other programs in which TPOs perform delegated functions)
From page 56...
... 56 STRENGTHENING U.S. COAST GUARD OVERSIGHT AND SUPPORT OF ROs intended to be a consolidated source of guidance for Coast Guard personnel conducting ACP examinations, to promote understanding and consistency of interpretation and implementation.6 Notably, the TPP provides guidance on the following activities for compliance verifications and oversight by marine inspectors with respect to vessels enrolled in ACP: • Preexamination activities, including vessel record reviews (consulting compliance history in MISLE, RO findings and observations from surveys, and RO records related to ISM audits)
From page 57...
... COAST GUARD ACTIONS TO SUPPORT AND OVERSEE ROs AND ACP 57 require the RO to conduct an internal review of its QMS to determine appropriate corrective action. • CVC-WI-008: "Vertical Contract Audits." This instruction sets up the protocols and criteria for Coast Guard personnel to conduct audits to independently verify that ROs have established and are faithfully following a QMS when performing functions on behalf of the Coast Guard.
From page 58...
... 58 STRENGTHENING U.S. COAST GUARD OVERSIGHT AND SUPPORT OF ROs New Data Tools and Metrics for Recognized Organization Oversight CVC-4 has many responsibilities related to data metrics and tools, including the publication of the annual report containing flag-state control performance statistics, the development of KPIs for RO performance, and the establishment of the fleet risk index for the prioritization of inspections and to determine whether special inspection campaigns are warranted.
From page 59...
... COAST GUARD ACTIONS TO SUPPORT AND OVERSEE ROs AND ACP 59 of such a marker does not necessarily mean a vessel is not in compliance or substandard. Although all of the risk criteria and weightings used to develop the Fleet Risk Assessment List could not be verified by the committee due to certain sensitive information, they are known to include vessel age and records of deficiencies, marine casualties, and port-state control detentions.
From page 60...
... 60 STRENGTHENING U.S. COAST GUARD OVERSIGHT AND SUPPORT OF ROs for reviewing U.S.
From page 61...
... COAST GUARD ACTIONS TO SUPPORT AND OVERSEE ROs AND ACP 61 MISLE's shortcomings also hinder the Coast Guard's oversight of vessel compliance and RO performance in other ways. For instance, because of their absence from MISLE, records of vessel compliance from foreign port-state control inspections must be obtained by Coast Guard personnel on external data systems (e.g., the Paris Memorandum of Understanding [MOU]
From page 62...
... 62 STRENGTHENING U.S. COAST GUARD OVERSIGHT AND SUPPORT OF ROs was added to MISLE, and in March 2021, the Coast Guard established a single U.S.
From page 63...
... COAST GUARD ACTIONS TO SUPPORT AND OVERSEE ROs AND ACP 63 inspection content to include the ACP. In 2019, the course added 2 additional days to discuss OCMI and vessel inspection content that included third-party oversight and risk-based inspection prioritization.
From page 64...
... 64 FI G U R E 3 -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 lte rn at e C om pl ia nc e Pr og ra m a nd t hi rd -p ar ty o ve rs ig ht .
From page 65...
... COAST GUARD ACTIONS TO SUPPORT AND OVERSEE ROs AND ACP 65 systems. The Coast Guard's marine inspection workforce is large and has a varied set of responsibilities that requires balancing inspector deployments and investments in their training and competency development.

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