Does Your Safety Management System Address Cyber Risks?

At the recent Connecticut Maritime Association’s 2017 Shipping Conference, Coast Guard Rear Admiral Paul Thomas, Assistant Commandant for Prevention Policy, indicated that the U.S. has submitted a paper to International Maritime Organization (IMO) for consideration that makes the case for installation of governance over cyber risks as part of the Safety Management System (SMS) required by the IMO’s ISM Code. “ISM requires that SMS establish safeguards for all risks, and put in place procedures to ensure compliance with all requirements of the convention and domestic regulations. ISM specifically mentions computer systems, which we take to include control systems. Our paper suggests a timeline for port state control officers to verify that SMS do indeed address cyber risks.”

Soon after the Connecticut Maritime Associations Shipping Conference, the U.S. Coast Guard released its Port State Control 2106 Annual Report. Detainable deficiencies are ranked as follows:

It is interesting to note that International Safety Management (ISM) Code has risen from 10th in 1998, when it became mandatory for companies operating certain types of ships, to 2nd in 2016.  In his February 2017 interview with Marine News, Admiral Thomas indicated that the Agency is working hard to update ISM requirements in both regulation and guidance.

To mitigate the risk of critical cyber systems, new Coast Guard ISM requirements may include the following:

  • Designated person responsible for Cyber Risk Management (CRM);
  • Corporate structure to address CRM;
  • Training requirements based on access to cyber systems; and
  • Corporate and shipboard procedures for operations and maintenance of critical cyber systems.

Does your SMS have these components?  How effective is your implementation?

Meridian.us can help your organization improve the effectiveness of your ISM Code compliance and cyber risk management.

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

WILCO – What’s New from Meridian Global Consulting

WHAT’S NEW
Welcome to the inaugural edition of Meridian Global Consulting’s quarterly Newsletter.

Since our establishment in 2009, Meridian has been known as a high-quality organization that goes the extra mile to meet client expectations. The name “Wilco” reflects our values and commitment to those we serve.

In every edition of our quarterly newsletter, we will strive to provide information that facility and vessel operators can use to ensure operational readiness and regulatory compliance. We welcome any feedback or suggestions for improvement.

Jonathan McConnell
President
Meridian Global Consulting

 

Read the whole newsletter HERE.

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.

Terrorists May Be Evolving in Their Tactics, But So Are We

The bustling Brussels Airport in Zaventem, Belgium, handles more than 500 flights a day, bringing more than 27,000 passengers into the facility with approximately the same number departing. Mornings are particularly busy at the airport, and amid the flurry of activity, it is little wonder that on March 22, 2016, three men emerging from a taxi outside of the departures hall passed through unnoticed.

The trio loaded their heavy suitcases onto baggage carts and entered the flow of people heading through the doors toward the ticket desks. Shortly after they entered the departures hall, the three split up to take their places in separate ticket lines.

Three minutes later, one of the men detonated his suitcase bomb, which had been packed with nails, as he stood in one of the check-in lanes. Approximately nine seconds after that, the second man detonated his suitcase bomb in another lane. The third suitcase bomb did not detonate immediately; surveillance camera footage showed that after being thrown to the ground by the second blast, the third man, Mohamed Abrini, simply got up and walked away from the airport toward the city center.

READ MORE at asisonline.org….

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.

Cruise Ship Safety & Security

The cruise industry continues to experience significant growth, with the Cruise Lines International Association projecting that its members will serve 25.3 million passengers in 2017, compared to 17.8 million in 2009.

To meet the increasing demand, the industry is planning to build 97 new ships over the next ten years.

The cruise industry is a heavily regulated industry. All cruise ships are designed and operated in compliance with the strict requirements of the International Maritime Organization, for example, the Safety of Life at Sea (SOLAS) Convention and the International Convention for the Prevention of Pollution from Ships (MARPOL). They are subject to periodic inspections and surveys by their Flag State and Port State authorities, and classification society.

Over the last three years, the Coast Guard National Response Center annually received approximately 65 incident reports from cruise ship operators. Additionally, the Coast Guard reported that 2015 saw a substantial increase in the number of vessel detention over 2014.  The most common areas of detainable deficiencies include: (1) fire protection systems, (2) firefighting detection, (3) maintenance of ship and equipment, (4) rescue boats, and (5) oily water separating equipment.

Some of these incidents have resulted in significant enforcement action. Notably, on December 1, 2016, a major cruise line pleaded guilty to seven felony charges stemming from its deliberate pollution of the seas and intentional acts to cover it up. The company has agreed to pay a $40 million penalty and be will be under a court supervised Environmental Compliance Program for five years.

In promoting safety, security and environmental protection, Meridian.us offers the following scalable, cost-effective services for the cruise industry:

  • Safety and Environmental Management Systems Assessment and Improvement
  • Pre-Port State Control Examination Assessment
  • SOLAS Compliance Verification
    • International Safety Management Code Compliance
      • Management review
      • Internal audits
      • Incident investigation
    • International Ship and Port Facility Security Code
      • Ship Security Assessment
      • Ship Security Plan Development and Maintenance
      • Cruise Terminal Security Assessment
      • Cruise Terminal Security Plan Development and Maintenance
      • Training, Drills, and Exercises
  • MARPOL Compliance Verification
    • Oil Record Book
    • Ballast Water Management
    • Waste Stream Management
  • Port Captain Assistance
  • Emergency/Spill management Team Services
  • Environmental Compliance Plan Audits

For additional information on our services, please contact Meridian.us at (251) 345-6776 or info@meridian.us.

Somali Pirates Hijack Commercial Ship for First Time Since 2012

Somali pirates have hijacked an oil tanker off the coast of Somalia for the first time since 2012, according to a report by the Associated Press.

The Aris 13, which was manned by eight Sri Lankan sailors, was overtaken on Monday by the band of more than two dozen Somalis in two skiffs.

The company connected to the ship is being close-lipped about how they are dealing with the situation.

From the AP:

An address listed for Flair Shipping in Dubai’s high-rise neighborhood of Jumeirah Lake Towers was for a company called Flair Oil Trading DMCC. A woman who answered the door Tuesday told an AP reporter the firm wasn’t connected to the ship and directed him to another office.

When no one answered the door at that office, the AP reporter returned to find Karagiannis entering the office of Flair Oil Trading DMCC.

“We will not be releasing any information,” Karagiannis said before shutting the door.

Since being hijacked, the ship has been anchored off the coast of Alula, Somalia, where the contents and crew of the tanker will likely be ransomed.

Because of the five year hiatus in piracy off the Somali coast one of the issues law enforcement may run into is how well the response infrastructure has held up.

Negotiators, shoreside security, and money drops have been on a half-decade long vacation and we will see which tactics, techniques, and procedures are used to mitigate the crisis.

Through our nearly 8-year history, Meridian.us has successfully guarded hundreds of voyages, using our risk mitigation and deescalation techniques to prevent 100% of our serviced ships from being boarded.

Through our vessel security service, Meridian.us will provides an armed security team aboard your vessel while transiting High Risk Waters (HRW). In full compliance with ITAR, equipment will be loaded onto your vessel in a port that is outside of HRW. The Meridian personnel will meet the vessel at a time and place of the vessel’s choosing in order to transit HRW.

While onboard the Meridian Personnel will ensure that the ship is secure and in compliance with Best Management Practices 4 (BMP4). Our personnel have been trained in implementing BMP4 and will work towards ensuring that BMP4 is properly implemented, allowing the crew to continue with their jobs. Meridian personnel advise the master of areas of High Risk and recent pirate activity. In addition, our personnel are available for anti-piracy crew training and will conduct crew drills prior to transiting HRW. Once onboard, our team provides 24-hour security, keeping crew costs low and unburdened with additional watch.

To learn more about our Vessel Security program, click here.

With the reemergence of piracy off the coast of Somalia and the continued threat in several other High Risk Waters, it is more important than ever to make sure your crew and cargo are kept secure.

Contact Meridian.us today to discuss how we can help you navigate through a variety of risks.

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.