Commandant Thad Allen has testified before Congress that he plans to make a number of changes to increase the Coast Guard’s focus on Marine Safety in response to criticism of the Coast Guard’s performance. The Commandant appeared before a hearing of the House Transportation Committee’s Subcommittee on the Coast Guard and Marine Transportation on August 2nd. OMSA President Ken Wells testified on the behalf of the offshore maritime sector.

The Commandant told committee members that he is working to:
• Beef up the marine inspector training and staffing;
• Reorganize the mariner licensing program;
• Improve the Coast Guard rulemaking process, which he acknowledged has a backlog of some 85 open regulatory projects and is lacks expertise;
• Create a new position, Assistant Commandant for Marine Safety, Security and Environmental Stewardship, which will be in the senior leadership circle of the Coast Guard; and
• Push Coast Guard leaders at the headquarters, district and sector levels to be more responsive and accessible to industry needs.

The hearing was prompted by dissatisfaction from both the maritime industry and members of Congress over the whether the Coast Guard has allowed its Marine Safety mission to suffer now that it has taken on new security responsibilities. In particular, Transportation and Infrastructure Chairman James Oberstar has argued that the Marine Safety program should be taken away form the Coast Guard and given to a new agency within the Transportation Department. At the Hearing, Chairman Oberstar was particularly critical of the Coast Guard’s handling of Marine Safety programs and warned the Commandant that without a change in course the Coast Guard was in danger of repeating the mistakes of FEMA, which he said focused so much on security that it lost the ability to respond to natural disasters like hurricane Katrina.

In testimony before the committee, OMSA President Ken Wells raised a number of concerns over the loss of experience and expertise within the Coast Guard, especially as it related to the inspection program, policymaking and working in partnership with industry. He quoted OMSA safety statistics, showing that offshore vessels had fewer recordable injuries than the general workplace in American, and stressed that the industry had achieved that by working in partnership with Coast Guard Marine Safety professionals. He stressed that the industry was concerned that that approach was at risk under the current Coast Guard approach.

The quality of inspectors and their length of service were raised repeatedly at the hearing. Chairman Oberstar recommended that the Coast Guard hire knowledgeable mariners to serve as civilian inspectors, as was done after World War Two. The committee requested that the Coast Guard come back with a formal plan within two months that will outline what resources it would need to fulfill its Marine Safety responsibilities.

The Transportation Worker Identification Credential (TWIC) program is overly complex and could create the same delays for the maritime industry that recent changes in passport rules caused for American travelers, according to testimony by OMSA Vice Chairman Otto Candies, III, at a July 12 Congressional hearing. The hearing was held by the Coast Guard and Marine Transportation Subcommittee of the House Transportation and Infrastructure Committee to assess the progress on the TWIC Program. At the hearing, witnesses from the Transportation Security Agency and the Coast Guard acknowledged that the program is roughly six months behind schedule. The first TWIC card processing site at the port in Wilmington, Delaware has been delayed until sometime this fall and only half the port sites will be up and running within six months of the Delaware site. Despite that, they still plan to require all mariners to have TWIC cards by September of 2008.

Testifying on behalf of OMSA, Mr. Candies said that mariners already undergo a thorough background check to receive their licenses and z-cards. He warned that an overly cumbersome process that discourages Americans from wanting to work offshore could hurt rather than help security. He cited the example of passports, where new requirements and unrealistic deadlines resulted in processing of passports for thousands of Americans being delayed. He also said that OMSA was strongly opposed to requiring TWIC reader devices on vessels.

At least two Congressmen at the hearing said the TWIC program appeared to have so many problems that it may be necessary to scrap the project and start over from scratch, but there does not appear to be a will in Congress to take that sort of drastic action.

The Coast Guard is now requiring all security plans for new vessels and facilities, as well as plans submitted for re-approval, to include procedures for complying with Transportation Worker Identity Card regulations. The requirement comes even though no TWIC cards have been issued to date and there is no published schedule for issuing TWIC cards. Vessel or facility operators who submit a new plan for Coast Guard approval or an existing plan for re-approval must now include the TWIC enforcement requirements in their plan. Holders of currently approved security plans are not required to resubmit their security plans until the plan expires.

Plans submitted without TWIC enforcement will receive a provisional approval with a requirement to resubmit the plan within 60 days incorporating TWIC enforcement provisions. OMSA raised concerns over the requirement since it would force vessel operators to write requirements for the use of a card months before the cards may become available. Based on OMSA’s questions, Coast Guard officials have indicated that they will accept provisional plan language to the effect of “When TWIC cards are issued the following requirements apply…” to meet this regulatory requirement.

TSA is reporting that TWIC enrollment will begin “Sometime in the Fall.” OMSA will inform members as soon as enrollment begins. The Coast Guard recently published NVIC 03-07 giving vessel and facility owners guidance on how to implement the new TWIC regulations. The OMSA security committee will meet on Wednesday August 22nd to discuss suggested language to meet this new requirement and update the OMSA ISPS plan.

USCG TWIC NVIC
http://homeport.uscg.mil/mycg/portal/ep/home.do

TSA TWIC Final Rule
http://www.tsa.gov/assets/pdf/1652-AA41_twic_fr.pdf

OMSA members recently met with EPA rule makers in New Orleans and Amelia to learn the details of the new engine installation regulations and inform EPA of potential pitfalls in the proposed rules.

OMSA staff believed that, for the EPA to understand the offshore industry and the potential effects of their rulemaking, it was crucial for the EPA staff to meet with vessel operators and physically visit offshore support vessels.

At OMSA’s invitation the EPA staff responsible for drafting the new Tier 3 and Tier 4 engine exhaust emissions rules met with OMSA members during the July 19th membership meeting. OMSA members were given the opportunity to hear details of the new engine exhaust proposals directly from the responsible staff and give industry opinions and input to the proposal directly to the responsible staff.

On July 20th the EPA staff was hosted by Tidewater and Seacor in Amelia, LA. The EPA staff was able to board and physically see vessels of the type affected by the proposed rules and see how various proposals may not be feasible. Based on their visit the EPA staff stated that they would have additional industry related questions. OMSA will distribute the questions to members when they are received.

The Environmental Protection Administration (EPA) is in the early stages of preparing regulations that would require vessels to have EPA permits for discharges that result from normal operations. As the result of a court order, the EPA has issued a Notice of Proposed Rulemaking seeking information on types of discharges from vessels. Comments are due by August 6th.

Ballast water and other vessel discharges, such as wastewater discharges known as grey water, have been exempted from National Pollution Discharge Elimination System (NPDES) permit requirements under the Clean Water Act. A lawsuit filed in California challenged the EPA exemption.

EPA lost its fight to continue the exemption and subsequent to the Federal Court ruling has begun the process to issue regulations controlling all vessel water discharges under the Clean Water Act. The court has ordered EPA issue rules by September 2008. Potentially, this could mean that all vessels would be required to obtain NPDES permits or the EPA could write a blanket general permit, similar to the kind used by offshore oil and gas facilities. The court ruling may also allow states to block vessel discharges in their waters or open vessel operators to state control or even private lawsuits.

OMSA is working closely with other trade associations to respond to the EPA initiative and has filed comments with the EPA. The initial request from the EPA has been for information categorizing potential vessel discharges and requesting sources of information on vessel data and statistics. While OMSA did provide the requested information the association has stressed to the EPA that any regulation of this magnitude must be conducted in a thoughtful manner and not in order to meet some unrealistic deadline. OMSA will continue to engage the EPA in the further development of any NPDES rules for vessels. To review comments, go to: www.regulations/gov/fdmspublic/component/main and enter Document ID EPA-HQ-OW-2007-0483.

The Coast Guard plans to expand its Alternate Compliance Program (ACP) which allows vessel operators to use private-sector third parties to perform most inspections. However, in comments to the docket on the ACP rulemaking, OMSA argued that the Coast Guard was not going far enough and should include all offshore supply vessels.

The lack of qualified marine inspectors has been a serious concern to industry for several years. During that time OMSA has been attempting to assist the Coast Guard and develop innovative ways to add efficiency to the process of marine inspections. One of those suggestions has been to use the ACP, which is currently limited to vessels that meet SOLAS requirements and expand it to vessels that have load lines and are classed.

The Coast Guard recently published a Notice of Proposed Rulemaking proposing to expand the ACP to include issuing Passenger Ship Safety Certificates to large passenger vessels and High-Speed Passenger Vessels and certificates to Oceanographic Research Vessels.

In its comment to the docket OMSA suggested the Coast Guard had not gone far enough with its simple proposal to add to the number of documents that ABS and others could issue to SOLAS vessels. OMSA recommended to the Coast Guard that it could improve the availability of inspections resources by expanding the ACP to include vessels in domestic service that have a loadline and are classed.

On July 24th Ken Parris of the OMSA staff traveled to West Virginia to meet with the senior National Maritime Center staff giving them industry’s perspective on the Coast Guard licensing system.

The Coast Guard is currently reorganizing its mariner credentialing programs into a centralized processing center located in Martinsburg, West Virginia. As it currently stands all mariner documents submitted to New Orleans, Anchorage or Juneau are shipped directly to Martinsburg for processing. Within the next year all of the Coast Guard Regional Exam Centers will be storefront operations with all license or document processing being conducted at the West Virginia office.

So far the Coast Guard has reduced the processing time New Orleans mariners were experiencing and is working to develop consistent document processing. One of the improvements the Coast Guard has made with the reorganization is the ability of a mariner to check the status of an application online with the capability for mariners to check the status of their credential application via http://homeport.uscg.mil. (From the left side of the home page, select Missions > Merchant Mariners > Merchant Mariner Application Status).

While OMSA supports the Coast Guard efforts to make the system more efficient, this is just the beginning with the association suggesting a number of changes needed to radically streamline the mariner licensing process.

Sarah Hufford of OMSA and Captain James Sandidge of Otto Candies, LLC, gave presentations about working in the offshore industry at the South Louisiana Young Adult Conference held at the Cajundome. Targeted towards disconnected youth in the Acadiana area, the conference was held on July 31st and was sponsored by Louisiana Works, Louisiana Department of Labor and the Louisiana Community & Technical College System. Ms. Hufford’s presentation included information about OMSA, different OMSA member companies, vessels of the offshore community, mariner requirements, qualifications and the lifestyle of working in the offshore industry. Captain Sandidge talked about the rewards and career progression of working offshore.

OMSA was well represented at the conference. Stephanie Edwards, the OJT Coordinator for Edison Chouest also gave a presentation on offshore employment. The conference also allowed them to sit down and provide one-on-one guidance to a few attendees who were interested in finding out more information on working in the offshore community.

The Maritime Advisory Committee for Occupational Safety and Health met in Oakland, CA on July 31st and August 1st and received a brief by NTSB on their final report regarding the Barge Athena 106 accident. The committee also voted on whether OSHA should take action on the recommendations made by NTSB.

OMSA sent in comments to the committee requesting to participate in any workgroups that will be responsible for the development and distribution of fact sheets to the marine industry. We also requested to remain informed of and have an active contribution in any action that OSHA takes in amending or updating its Memorandum of Understanding with the Coast Guard.

The transcript of the MACOSH meeting should be available within the next week and we will keep you informed of any actions taken by the committee.

The OMSA Golf Tournament will be held on Monday, October 15th, 2007 at Squirrel Run, New Iberia, LA. The tournament is being held in conjunction with the General Business Meeting on Tuesday, October 16th at the Hilton, Lafayette, LA.

To sponsor or register, please contact Lillie Licciardi at (504) 734-7622 or at lillie@offshoremarine.org.

Since this is the first year that OMSA has held a golf tournament at Squirrel Run in New Iberia OMSA is currently looking for tournament sponsors. Please note that sponsors will be given the first opportunity to register golfers.

OMSA members should be aware that watercraft assessments may increase substantially this year to reflect higher rates in 2006. Unfairly high assessments can be challenged, but the time-frame to do that is limited. Once a final tax roll is submitted to the State no changes can be made to the property value tax assessments. By law each year parish assessors must open their property tax books for review. Assessed property tax values must be submitted to the State no later than November 15th, but some parishes submit their data as early as mid-September. Vessel owners (or homeowners for that matter) should contact their parish assessor by mid-August to determine the taxable value assessed. The tax rolls must be examined during the public viewing period and any dispute to the taxable value must be made prior to the roll’s submission to the State.

The Merchant Personnel Advisory Committee will meet on September 11th and 12th at the Calhoun MEBA Engineering School in Easton, MD. The school is located on the Maryland Eastern Shore about one hour’s drive from BWI airport. The committee advises the Coast Guard on mariner licensing issues. Two critical issues on the agenda will be the continuing work on the Coast Guard’s new medical fitness for duty standards policy and work developing the Coast Guard position at the next IMO meeting where the overhaul of the STCW convention is on the agenda. OMSA is looking for a cadre of members to attend the meeting to support issues important to the offshore industry. A great turnout like that at the last STCW review meeting and medical NVIC meeting will go a long way in ensuring that the offshore industry position is acted on. Please contact the OMSA staff if you can attend.

The Towing Safety Advisory Committee will meet on September 18th and 19th at the Hilton Garden Inn in Columbia, Maryland. The hotel is about eight miles west of the BWI airport. Continuing work on the towing vessel inspection standards will be the main agenda item. OMSA is looking for towing vessel operators to attend the meeting to ensure that the position of the offshore towing vessel operators is heard. Active participation is the only way to continue to show the Coast Guard the offshore industry’s continued concern for the outcome of this process. Please contact the OMSA staff if you can attend.

The fall National Offshore Safety Advisory Committee will be held November 16th at the Tremont Hotel in Galveston, Texas. Additional information will be provided to the members as the agenda is developed.

General Business Meetings

October 16th, 2007 – Hilton, Lafayette, LA
January 15th, 2008 – Hilton New Orleans Riverside

Special Events

August 22nd, 2007 – OMSA Security Committee Meeting, OMSA Office, Harahan, LA
September 20th, 2007 – OMSA Personnel Shortage Solutions Seminar, Radisson New Orleans Airport
October 15th, 2007 – Golf Tournament, Squirrel Run, New Iberia, LA
November 15th, 2007 – 2nd Annual Legal Forum, Hilton New Orleans/St. Charles
December 7th, 2007 – OMSA Christmas Dinner Dance, Hilton New Orleans Riverside

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Contact Dave Alston:
125 Hwy 332 West, Suite A
Lake Jackson, TX 77566
(979) 297-1111
dave@signalelectronics.ws