Helping your company ‘Walk the Walk’ in response readiness

As a management consulting firm, Meridian assists our clients’ compliance with safety, environmental and quality management system standards. For example, we recently conducted an external review to verify that an organization’s internal quality system is based on ISO 9001:2015. Similarly, in enhancing our clients’ contingency preparedness, our Response Services Division provides Incident Command System (ICS) training and facilitates drills and exercises.  

In “Walking the Walk,” Meridian uses ISO 9001 and ICS processes and tools in managing our tactical operations.  Potential tactical operations, which Meridian may be asked to provide, include:

  • Armed Vessel Security
  • Direct Asset Response Team
  • Event Management
  • Executive Protection
  • Fixed Site Security
  • Oil / Hazardous Material Spill Response
  • Route/Convoy Security

The ISO-ICS integrated process starts with Meridian’s standard operating procedures and policies, which creates our framework. From there, Meridian has ensured its personnel have the required training and experience for the position they are assigned to. This includes becoming familiar with the Meridian Incident Management Handbook (MIMH), as well as completing our position-specific qualification requirements.

There are numerous moving parts when it comes to managing tactical operations. There is a constant flow of information. To ensure our readiness to respond, Meridian proactively developed Incident Action Plan (IAP) templates for various types of tactical operations. These templates incorporate lessons learned and best practices.  They serve as a 70% solution, which enables Meridian to respond to the needs of a client quickly and effectively.

From the moment a client requests our services, Meridian begins updating the appropriate template with the client’s specific information.  We assess and track the current situation.  We document the client’s objectives and priorities.  We identify resources and develop assignments.

By using ICS processes and tools, Meridian can make a seamless transition from managing routine activities to supporting crisis management while  easily assimilating into the client’s response management organization.

By having things well-organized and documented, it ensures continuity of operation.  Meridian upper management can quickly step in and effectively and efficiently complete the operation if an emergency arises and the project manager is unavailable.

Once an operation is complete, Meridian electronically archives the IAPs, so they can be referenced at a later point in time if needed. We update our IAP template.  This procedure is not only ISO compliant, but it also allows us to reference the documents as needed.  

Meridian Operational Planning Cycle for Managing Tactical Operations

 

Meridian.US Announces New Designated Person Services

Regulations, including International Safety Management Code and Towing Safety Management System, require a vessel operator to appoint Designated Person(s) that have the following responsibilities:
  • Ensuring the safety management system is implemented and continuously functions throughout management and the fleet.
  • Ensuring the safe operation of each vessel.
  • Providing a link between the Company and those on board.
  • Monitoring the safety and pollution-prevention aspects of the operation of each vessel and ensuring that adequate resources and shore-based support are applied, as required.
For companies looking for highly experienced contractors to supplement their staff, Meridian.us has senior-level personnel who can serve effectively as Designated Person(s).
For more information on Meridian’s Designated Person services, please contact Captain Hung Nguyen at (808) 282-4981 or hnguyen@meridian.us.

ISM Code and Risk Management

December 2012 – Grounding of MODU KULLUK in Alaska (courtesy of nytimes.com)

On December 31, 2012, the Noble Drilling-operated Mobile Offshore Drilling Unit (MODU) KULLUK went aground on the eastern coast of Sitkalidak Island, Alaska. Amid winds as high as 50 miles per hour and seas as high as 18 feet, 18-member crew had to be rescued by the U.S. Coast Guard (USCG). The USCG and the National Transportation Safety Board (NTSB) investigated the casualty. The USCG determined the most significant factor being the inadequate assessment and management of risks associated with a complex vessel movement during the winter in the unique and challenging operating environment of Alaska. The NTSB concurred with the USCG that the inadequate assessment of the risk for the planned tow resulted in implementation of a tow plan insufficient to mitigate that risk.

August 2016 – Grounding of TRANSOCEAN WINNER in western Scotland
(courtesy of bbc.com)

Almost four years later, we saw similar images of Coast Guard helicopter flying over the TRANSOCEAN WINNER, which was grounded in western Scotland. The casualty released approximately 12,000 gallons of diesel oil into the ocean. The UK Marine Accident Investigation Branch (MAIB) investigation into the grounding highlighted the lack of a contingency plan.

Both vessel operators are required to comply with the International Safety Management (ISM) Code. Section 1.2.2.2 requires a company to assess all identified risks to its ships, personnel and the environment and establish appropriate safeguards. Inadequate assessment and management of risks would be considered a Major Non-conformity under the Code. Per Section 13.5, this may result in the issuing government’s withdrawal of the company’s Document of Compliance, i.e., its ISM-compliant vessels can no longer operate until the identified discrepancies are corrected.

Meridian.us has certified and experienced ISM Code Lead Auditors, who can assist your company with their internal audits and management review. For additional information, please contact Captain Hung Nguyen at (808) 282-4981 or hnguyen@meridian.us.

REGULATORY ADVISORY: Maritime Transportation Security Act (MTSA) Facility Access Control Discrepancy on the Rise

On May 4 the Coast Guard Office of Port & Facility Compliance released its 2016 Year in Review.

In 2016, the Coast Guard completed 6,002 MTSA annual and spot check examination activities. About a third of the enforcement actions are related to access control—a category that has doubled in two years.

Per Title 33 Code of Federal Regulations (CFR) 105.255, the facility owner or operator must ensure the implementation of security measures to:

(1) Deter the unauthorized introduction of dangerous substances and devices, including any device intended to damage or destroy persons, vessels, facilities, or ports;

(2) Secure dangerous substances and devices that are authorized by the owner or operator to be on the facility;

(3) Control access to the facility; and

(4) Prevent an unescorted individual from entering an area of the facility that is designated as a secure area unless the individual holds a duly issued TWIC and is authorized to be in the area.

For assistance with MTSA compliance, please contact Meridian.us at (251) 345-6776 or info@meridian.us.

REGULATORY ADVISORY: Proposed Manning Changes for Mobile Offshore Drilling Unit

Nearly seven years ago, on April 20, 2010, while conducting temporary well-abandonment activities in the U.S. Gulf of Mexico, the mobile offshore drilling unit (MODU) Deepwater Horizon experienced a series of events that resulted in explosions, fire, loss of eleven lives, sinking of the vessel, and the largest oil spill in the U.S. history.

There were many investigations in the aftermath of the disaster to determine causal factors and identify potential safety improvements to offshore oil and gas drilling. The Department of Homeland Security and The Department of the Interior conducted a joint investigation. All told, the Joint Investigation Team (JIT) held seven public hearings, called over 80 witnesses, issued more than 90 subpoenas, and collected over 400,000 pages of evidence.

Within the U.S. Coast Guard jurisdiction, the JIT recommended 52 safety improvements, on 80 percent of which the Commandant agreed to take action. One major recommendation was to implement regulatory changes that provide clear designation of the person in charge under both operating and emergency situations for all MODUs operating on the U.S. Outer Continental Shelf.

Additionally, in March 2013, the International Maritime Organization (IMO) began its investigation into the Deepwater Horizon casualty.  A proposed amendment to the MODU Code under consideration is “For units that use dynamic positioning systems as a sole means of position-keeping, the master should be designated as the person in charge at all times.”

On November 28, 2014, the Coast Guard published the Proposed Rules on Requirements for MODUs and Other Vessels Conducting Outer Continental Shelf Activities with Dynamic Positioning Systems, which requires all MODUs be under the command of an individual holding an appropriate certificate of competency as a master issued by the Flag State authority.

For assistance with regulatory compliance, please contact Meridian Global Consulting at (251) 345-6776 or info@meridian.us.

  1. International Maritime Organization, Review the MODU CODE, LSA CODE and MSC.1/CIRC.1206/ REV.1, SSE 2/12 19 December 2014

  2. Federal Register, Requirements for MODUs and Other Vessels Conducting Outer Continental Shelf Activities with Dynamic Positioning Systems; Proposed Rule, Vol. 79, No. 229, November 28, 2014

For more information please contact Meridian.us at (251) 345-6776 or info@meridian.us.

Oil Spills and Emergency Preparedness on the 28th Anniversary of the Exxon Valdez

On March 24, 1989 at approximately 12:04 AM, the single-hull tanker EXXON VALDEZ with a full load of crude oil grounded on Bligh Reef in Prince William Sound, Alaska. Approximately 11 million gallons of oil were spilled into the pristine waters of Prince William Sound.

In terms of volume released, the spill is the second largest in U.S. waters, after the 2010 Deepwater Horizon incident. Prince William Sound’s remote location, accessible only by helicopter, plane, or boat, made response efforts difficult and severely taxed existing plans for response.

The EXXON VALDEZ spill led to enactment of the Oil Pollution Act of 1990 (OPA 90), which improved oil spill prevention, response, and restoration by providing greater environmental safeguards by mandating contingency planning.

Meridian has many technical experts and experienced responders who successfully implement OPA 90. Depending on the needs of your organization, our regulatory planning staff can assist with development of all or partial plans, including:

  • Facility and Vessel Response Plans
  • Integrated Contingency Plans
  • Spill Prevention Control and Countermeasure Plans
  • Emergency Response Plans
  • Tactical Response Plans

We provide training in the following areas:

  • NIMS ICS 100b/200b, ICS 300, 320, 400, 410, 420, 440, Executive Level and Section Specific
  • HAZWOPER (8HR Refreshers)
  • USCG, EPA, BSEE, and DOT Qualified Individual

We offer a wide range of drill and exercise programs to meet your organization’s preparation and training needs.  These include:

  • Tabletops
  • Worst Case Scenario Equipment Deployment
  • National Preparedness for Response Exercise Program
  • Qualified Individual Notification

Our team can also provide response expertise to oil spills across the U.S. and Canada with:

  • Spill Management Team Partial Team Augmentation or Full Team Deployment
  • Qualified Individuals
  • Operations/Planning/Finance/Auditing/Documentation
  • Government Liaison/Public Information/Safety
  • GIS Services and Trajectories

For additional information on our response services, please contact Meridian.us at (251) 345-6776 or info@meridian.usMeridian will make sure you are ready.

ISM Code Compliance Service

March 6, 2017 marked the 30th anniversary of the capsizing of the roll-on/roll-off ferry MS Herald of Free Enterprise, which resulted in the tragic deaths of 193 passengers and crew. In response to this catastrophe, and in the interest of enhancing vessel safety management, the International Maritime Organization implemented the International Safety Management (ISM) Code.

The Code went into effect for certain types of vessels on July 1, 1998, but since then has been amended five times. For instance, the new requirement “12.2 The Company should periodically verify whether all those undertaking delegated ISM-related tasks are acting in conformity with the Company’s responsibilities under the Code” went into effect just over two years ago on January 1, 2015.

Compliance with the ISM Code continues to be an issue for some vessel operators.  For example, in the U.S. Coast Guard’s 2015 Port State Control Annual Report, the Agency reported ISM related items as the second most common deficiencies.

In promoting compliance with the ISM Code, Meridian.us offers the following services to our clients:

  • Safety and Environmental Management System Assessment and Development,
  • Internal Audit,
  • Emergency Preparedness,
  • Incident Investigation,
  • Management Review Support,
  • Master Review Support, and
  • Designated Person Ashore.

 

Complying with the ISM code can be complex, but if doesn’t have to be difficult. Contact Meridian.us today by replying to this email if your company could benefit from our expertise.

 

Meridian.us is an ISO 28007:2015 and ISO 9001:2015 certified company. For more information please contact Meridian.us at (251) 345-6776 or info@meridian.us.

Subchapter M: Addressing the New Towboat Standards

The final rule requiring Towing vessels to meet specific regulatory requirements under Title 46, Code of Federal Regulations, Subchapter M, was published in June of 2016, and at Meridian.us we are dedicated to helping you both understand and execute the new rules.  

The new regulation applies to all companies with towing vessels greater than 26 feet, as well as those under 26 feet moving barges carrying oil or hazardous materials.  According to the U.S. Coast Guard, a fully implemented Towing Safety Management System (TSMS) establishes a comprehensive quality control system throughout the company, which increases the safety and efficiency of all towing vessel operations. Across the maritime industry, vessel operators have told the Coast Guard that a proper TSMS increases safety while cutting overall operating costs. A proper TSMS will reduce accidents and equipment failures, and decrease or possibly completely undo delays.

 

Two options for towboat companies

The Coast Guard essentially gives towboat companies two options: either implement a safety management system or be inspected annually by the Coast Guard.

The benefits to implementing a TSMS are:

  • Greater flexibility in scheduling required surveys and audits,
  • Less vessel downtime,
  • No requirement for USCG presence for drydock and internal exams,
  • Greater flexibility in correcting discrepancies, and
  • Significantly less USCG intrusion on operations.

 

For those companies choosing the USCG inspection route, Coast Guard inspectors will visit the vessel at least annually and in some cases more frequently, possibly stopping operations until a Coast Guard inspector can visit the vessel.

The new rule will not apply to all towing vessels in your fleet all at once—there are specific phase-in requirements for the TSMS program. But regardless of the route your company decides to take, each towing vessel will eventually be required to have on board a Certificate of Inspection (COI).

For companies with more than one tow vessel:

  • By July 22, 2019, at least 25 percent of the towing vessels must have valid COIs on board;
  • By July 20, 2020, at least 50 percent of the towing vessels must have valid COIs on board;
  • By July 19, 2021, at least 75 percent of the towing vessels must have valid COIs on board; and
  • By July 19, 2022, 100 percent of the towing vessels must have valid COIs on board.
  • All owners or managing operators of only one existing towing vessel required to have a COI by this subchapter must ensure the vessel has an onboard, valid COI by July 20, 2020.

 

How opting for a TSMS can help your towing company

There are two aspects to a TSMS: Surveys and Audits. Surveys are the actual inspection of a ship’s systems, e.g., show me your emergency fire pump is properly installed. Surveys by companies using a TSMS (as opposed to the opting for the annual Coast Guard inspections) may be conducted by either someone in the towboat company or a Third-Party Organization (TPO). Audits focus on whether companies are following the processes and procedures of their TSMS.

Key take away – do not use the term “inspection” instead of “survey” when speaking with people in the industry—“survey” is a term of art in the towing vessel world.

Any TSMS must be compliant with the ISO 9001:2000 or ISO 9001:2008 standard. Reportedly, the Coast Guard will also consider approving standard like ISO 9001.

 

Where we come in

Meridian.us is offering the Audit and Survey programs as a service to our clients. Meridian will provide the highest levels of service at reasonable rates to ensure our clients receive the most for their money.  Meridian is a fully compliant third-party organization approved by the U.S. Coast Guard. Meridian is compliant with ISO 9001:2015 and ISO 28001:2015 standards as well as OSHA safe work practices.

Navigating federal rules and regulations can be one of the most difficult aspects of your job, let Meridian.us help you through the compliance process. Please contact Meridian.us at (251) 345-6776 or info@meridian.us.