A New Year’s resolution: More compliance
January 8, 2013
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.”
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.
companies may simply take a wait-and-see approach. Excellent companies,
however, will not take that chance.