Regulatory Roundup

Kevin Gilheany A New Year’s resolution: More compliance

January 8, 2013 Compliance is something you only think of when forced to. At the International WorkBoat Show last month, several officials from good quality companies passed by our booth and said hello. When we asked them if they had any compliance questions or issues, the answer was usually, “No thanks, we’ve got all that under control.”

Maybe they do. But it is more likely that issues simply haven’t surfaced yet. Many good companies that pass inspections and audits assume that they are in full compliance. That may be. However, at a future inspection, audit or accident they may find out that they are not as compliant as they had thought. An excellent company has a proactive compliance management program as part of its regular routine and does not rely upon interpretations and opinions from inspectors and auditors to determine their level of compliance.

The New Year is a good time to upgrade your company from “good” to “excellent” in terms of compliance. If striving for excellence is part of your company culture, here are a few things to consider in 2013:

  • TWICs are expiring en masse this year. Don’t procrastinate with renewals. Even with the new 30-day grace period, there could be serious repercussions.
  • The effective anniversary date of the EPA VGP is Feb. 19. Each year a comprehensive VGP annual inspection is required and any instances of noncompliance with the permit must be reported to the EPA. This annual inspection includes record keeping. For example, if there are not 52 weekly inspections on file, or records of all gray water discharges or any painting and deck maintenance that may constitute noncompliance with the permit. Be aware that the permit also dictates who is qualified to conduct annual VGP inspections.
  • Your uninspected towing vessel examination sticker may expire this year. You are not required to renew it. But if you do, you should be prepared for a much more knowledgeable batch of examiners who may find a number of deficiencies that were not addressed in the first round. A comprehensive regulatory compliance survey is a good way to prepare for the Coast Guard.
  • Subchapter M may be published this year and companies will be scrambling to determine the best path forward. You can get ahead of the curve by discussing compliance options for each vessel, and by getting captains and crews ready through intensive drills and training on what operating a vessel according to safety management system really means. A thorough internal audit or assessment by an objective third party is a good way to prepare.

Good companies may simply take a wait-and-see approach. Excellent companies, however, will not take that chance.

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