Thursday, March 20th, 2008

The growing pains associated with the U.S. Coast Guard's transformation over the past few years are being felt both inside and outside of the organization, especially when it comes to the Coast Guard's interaction with the maritime industry through its marine safety program. As a result of policies implemented due to shifting national priorities, many maritime industry personnel do not find the Coast Guard to be the helpful advocates that they once were. While the Coast Guard is working hard to make improvements, there are some practices that maritime industry managers can implement in the interim to ensure a smooth and effective operation.

Since September 11, 2001 and the subsequent formation of the Department of Homeland Security in 2003, the Coast Guard has shifted its focus towards maritime security. While there is plenty of justification for this shift, the importance of marine safety has not diminished, and in fact, the demands of the marine safety program have increased. An unfortunate consequence of this shift in priorities is that many in the industry find Coast Guard inspectors to be less knowledgeable and less customer-focused than in the past. Last year, industry concerns resulted in congressional hearings on these issues and a proposal to transfer the marine safety mission out of the Coast Guard and into another government agency.

The Commandant of the Coast Guard has reacted swiftly to these concerns and has come up with a plan of action to rectify the situation. As part of that plan of action, the Commandant asked retired Vice Admiral James Card to conduct an overall analysis of the Coast Guard's marine safety program. Vice Admiral Card's analysis, entitled "Coast Guard Marine Safety Analysis: An Independent Assessment and Suggestion for Improvement," has been published on the Coast Guard's Homeport website and is an excellent and honest assessment of the current situation. The report does not pull punches and all industry personnel who have a vested interest in the Coast Guard's marine safety program should find this report extremely encouraging.

While the picture painted by Vice Admiral Card is not a pretty one, it is the honesty and forthrightness of the report that is encouraging, as the first step towards correcting the problem is to recognize that it exists and to understand its depth. Vice Admiral Card not only describes the problems in detail, he also lays out detailed plans for improving the current situation. Both the Commandant and Vice Admiral Card should be commended for their efforts and this excellent report.

The good news is there is light at the end of the tunnel. The bad news is in dealing with government, no matter how well intentioned, sometimes the tunnels can be very long. While the Coast Guard continues with its course correction, the industry will continue to feel the impact of this transformation for quite some time. Therefore, in order to ensure a smooth and effective operation, industry managers should consider the following practices:

Understand and accept that the current situation will not get fixed overnight. It will take a great deal of time, money and training on the part of the Coast Guard, and patience and cooperation on the part of industry;

Stay in compliance with written regulations, guidance and policy memos instead of relying on individual Coast Guard inspector's opinions. Also, don't shop around to different Coast Guard personnel until you get the answer you want to hear. The correct answer is available in writing;

When it comes to performance based regulations, such as maritime security regulations or the impending towing vessel safety management system, make sure you have the best possible plan for your company; you are able to demonstrate that it is fully implemented and you can defend your plan and practices to any inspector who may question them. Don't get caught in the cycle of having to make adjustments to your operation after each Coast Guard inspection.

Don't be afraid to get a second opinion. The majority of Coast Guard inspectors are conscientious professionals who want to make the best possible decisions regarding inspection issues. They understand they can't know everything. The Coast Guard's official policy is that it encourages you to question its policies and actions without fear of retaliation.

By following these practices you will save money on costly compliance errors and, perhaps more importantly, you will gain the confidence and peace of mind that comes with knowing you are running a truly compliant program.