Assisting the maritime industry in regulatory compliance

Bryant's Maritime Consulting

December 26th, 2018 at 11:24 am

Bryant’s Maritime Blog – 26 December 2018


USCG – electronic visual distress signal devices;

USCG – recreational boating safety projects;

STB – water carriers in the noncontiguous domestic trade;

FCC – maritime mobile & maritime mobile-satellite radio services;

CMTS – 2018 hurricane season report; and

Paris & Tokyo MOUs – early warning on global 2020 sulphur cap.

December 26, 2018

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Note: This blog is one section of the Bryant’s Maritime Consulting website. Visit the site for more extensive maritime regulatory information. Individual concerns may be addressed by retaining Dennis Bryant directly. Much of the highlighted text in this newsletter constitutes links to Internet sites providing more detailed information. Links on this page may be in PDF format, requiring use of Adobe Acrobat Reader. Comments on these postings are encouraged and may be made by clicking the envelope that appears at the end of each posting. Be aware that the daily blog entry is a single posting, even though it contains a number of individual items. The proposal is all very well in practice, but it will never work in theory.

USCG – electronic visual distress signal devices

clip_image004 The US Coast Guard issued a policy letter providing guidance for acceptance of electronic visual distress signal devices (eVDSDs) that are evaluated as meeting the design and performance requirements of RTCM Standard 13200.0 as equivalent to electric distress lights certified to 46 CFR § 161.013. CG-ENG Policy Letter 03-18 (12/21/18) [].

USCG – recreational boating safety projects

clip_image004[1] The US Coast Guard issued a notice publishing the recreational boating safety projects, programs, and activities funded under provisions of the Fishing America’s Surface Transportation Act during FY 2018. 83 Fed. Reg. 66291 (12/26/18) [].

STB – water carriers in the noncontiguous domestic trade

clip_image006 The Surface Transportation Board (STB) proposes to amend its regulations relating to the tariff filing procedures for water carriers operating in the noncontiguous domestic trade to allow for electronic publishing. Comments are due by 25 January 2019. 83 Fed. Reg. 66229 (12/26/18) [].

FCC – maritime mobile & maritime mobile-satellite radio services

clip_image008 The Federal Communications Commission (FCC) adopted a Report and Order regarding that transition of the functions and duties currently performed by the FCC as the ‘accounting authority of last resort’ for those customers in the maritime mobile and maritime mobile-satellite radio services that have not otherwise designated any such accounting authority to private authorities. A transition and outreach program will be developed to facilitate a smooth transition. (12/21/18) [FCC-18-186A1.pdf]. Note: This item was brought to my attention by my good friend Joe Hersey at JoeCel Engineering & Consulting, LLC. This change is expected to mostly affect users of legacy Inmarsat terminals, particularly Inmarsat C.

CMTS – 2017 hurricane season report

clip_image010 The Committee on the Marine Transportation System (CMTS) issued a bulletin announcing publication of the report, 2017 Hurricane Season: Recommendations for a Resilient Path Forward for the Marine Transportation System. The report provides an overview of the impacts to the MTS during the 2017 hurricane season and identifies best practices and lessons learned for federal agencies. Applying the recommendations in this report can help to minimize the impact from future storms and other disruptive events, enhancing the resilience of the MTS and surrounding coastal regions, as well as supporting a stronger, more resilient U.S. economy. (12/21/18) []

Paris & Tokyo MOUs – early warning on global 2020 sulphur cap

clip_image012 clip_image014 The Paris MOU issued a news release stating that it and the Tokyo MOU will start issuing letters of warning from 1 January 2019 on the sulphur content of marine fuels during inspections in order to increase awareness of and to encourage timely compliance with the new requirements that enter into effect on 1 January 2020. (12/21/18) [].

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Dennis L. Bryant

Bryant’s Maritime Consulting

4845 SW 91st Way
Gainesville, FL 32608-8135



© Dennis L. Bryant – December 2018

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    logo11 HazSub spill response plans

    In the March 2019 edition of Maritime Reporter and Engineering News, you can find my article entitled "HazSub spill response plans". The article discusses the recent decision of the US Coast Guard to withdrawal its proposed rulemakings for hazardous substance spill response plans for tank vessels and marine transportation-related facilities. In my opinion, the USCG proposals evidence a failure of imagination. I recommend that the Coast Guard meet with the marine transportation chemical sector and determine which current industry measures can be considered as providing an equivalent level of safety to measures mandated in OPA 90. The gaps identified can then be filled in a rulemaking.