On the occasion of USCG participation at Posidonia this month, Rear Adm. John Nadeau, assistant commandant for prevention policy, shares his view on at the role of the regulator in the maritime industry’s environmental footprint, mostly in the context of ballast water management regulations. Mr. Nadeau noted that regulators must always be mindful of the need to facilitate commerce, and do their best not to impede it.
Regulations are in response to mandates from our publicly elected officials, international obligations, and demands from industry and the public. They provide the certainty needed for investment and innovation, and level the playing field to promote fair competition and free market solutions.
- Regulators must work in coordination with industry, academia and science, interagency partners, and public and international counterparts to develop risk-based performance standards that provide industry flexibility in compliance strategies.
- Regulators must focus on practical implementation and measured enforcement, particularly for new regulations.
- Regulators must have a fully informed common sense approach to development and implementation to manage risk in an increasingly complex Marine Transportation System.
With respect to BWM, as an area of intense focus in the industry over the last months, Mr. Nadeau noted that vessel owners and operators must focus on compliance.
In the past, we were more generous about issuing extensions because we were aware that the availability of these systems was limited. However, we now have 7 type approved systems, with more on the way, that we believe address a range of vessel needs and operations. For that reason, the issuance of extensions will be much more limited to only those cases where despite the best efforts of the owner or operator, compliance is not yet possible but a strategy has been developed to meet the requirements. Extension requests must demonstrate that the owner or operator has thoroughly evaluated the existing type approved systems and other compliance methods and found them to be inadequate.
In 2017, he added, Port State Control examiners documented 220 BWM deficiencies, mostly related to incomplete record keeping, lack of a sufficient ballast water management plan, or discharge of untreated ballast water.
We are fully aware that ballast water management has been and will continue to be a tough pill to swallow. However, we have tried to maintain flexibility while ensuring compliance with the regulations, and we will continue to do so.
Concluding, Mr. Nadeau stressed that, as the industry is by far the most efficient means of transporting goods, this trend of increasing focus on environmental standards is not going to subside soon.
We have been working on reducing air emissions and managing ballast water for three decades, but we are not done. Increasing stakeholder expectations will continue to place pressure on flag states and the maritime industry to reduce the environmental footprint of shipping…We should all recall that the cornerstone of environmental compliance is a good safety management system. There must be procedures, planning, and training in place to ensure success and compliance.
