Mr. Elliott addressed RORC’s two main arguments in reaching these conclusions:
- US Coast Guard Verification Process
The US marine salvage industry is regularly audited by USCG, maritime industry and insurance providers. Before implementation of the regulations, hundreds of so-called salvors were listed on Vessel Response Plans. These entities included standalone surveyors with no owned assets and even companies with no salvage and marine firefighting experience.
During the regulatory implementation process, the USCG reviewed these salvage service providers, ultimately narrowing the field of qualified salvors from hundreds to just four national salvage companies and a handful of regional salvage providers.
This “verification” process did not stop there, Mr. Elliott stressed. Salvage and marine firefighting service providers are audited and verified during plan preparation, remote assessment exercises, table-top exercises and full-scale deployment exercises. Most importantly, on every US marine casualty incident, the salvage company must submit a written salvage plan that is reviewed and approved by Coast Guard master-degreed naval architects and experienced Captains of the Port.
In addition, salvage companies are also audited by insurance companies and vessel owners and operators who are ultimately responsible to ensure their Vessel Response Plan is effective and meets regulatory standards. Following implementation of this regime, hundreds of successful salvage and marine firefighting operations have been completed by ASA members.
Late last year, the salvage industry had successfully passed every verification audit since the Coast Guard began reviewing salvage and marine firefighting service providers in 2010. Additionally, when called, the salvage industry has never failed to effectively respond to a marine casualty incident.
2. Salvage Response Planning Standards
Mr. Elliott noted the US marine salvage industry has been “verified” to effectively meet the US regulatory planning standards and continues to expand capabilities both domestically and internationally.
The salvage and marine firefighting regulatory standards for the desired response timeframes are “planning standards.” To meet these standards, the US industry has spent millions of dollars to pre-position marine firefighting systems and other salvage equipment, such as dewatering and cargo transfer pumps, around the US and in remote territories to meet these planning timelines.
Additionally, the salvage industry created an innovative network of responders, including vessels of opportunity to rapidly address all 19 services required by the regulatory planning standards. Without a doubt in the past 10-years since the publication of the regulations, US salvage capacity and capabilities have grown significantly and continue to expand.
Testaments of the the industry’s capacity include the response to the historic 2017 hurricane season, simultaneously salvaging hundreds of ships, barges and boats in multiple locations following three hurricane landfalls, and the export of US salvage capacity.
In the end, while we can continuously improve our nation’s salvage and marine firefighting capabilities, the regulatory system is working and evolving. The ASA was actually created to help develop these rigorous standards and, like RORC, we encourage ship owners, insurers and regulators to be vigilant in their review of service providers. If RORC would like to provide these demanding services, we simply ask that they go through the same verification process with the Coast Guard as every other company in the salvage industry. If RORC wants to simply provide a taxi service for professional salvors, then they should be audited by those that desire to use their services and compete fairly with members of our network of responders. In this process, I am confident RORC will gain a new respect for the demands and associated costs of meeting the US standards that arguably set the international benchmark.
In the American Salvage Association meetings with the Coast Guard over the years, we have asked that the regulations and rules of engagement be fair and consistent. If the Coast Guard desires to require a marine firefighting boat in every port, then they should allow a competitive market to find the best, most cost effective solution, as opposed to granting monopolies.