Page 12: of Marine News Magazine (November 2013)

INSIGHTSDennis L. Bryant retired from the U.S. Coast Guard with the rank of Captain after 27 years active duty. His billets included serving on the icebreaker NORTHWIND for several years including in 1969 when it escorted the tanker MANHATTAN through the Northwest Passage (this was back in the old days, when there was real ice in the Arctic). He also spent various tours as a law specialist, including an assignment as the Coast Guard?s Law of the Sea of cer. He also served a tour in the Of ce of Interna- tional Affairs and  nished his career supervising the staff charged with implementing the Oil Pollution Act of 1990 (OPA 90). After leaving the Coast Guard, he was with a major maritime law  rm for 13 years. Now an indepen- dent consultant, and when not guiding his clients in navi-gating the complicated world of regulatory compliance, he also speaks at various forums, both domestically and internationally. His blog on recent maritime developments is always well received on the Maritime Professional web site as well as his own venue. Dennis also frequently writes maritime-related articles for various trade magazines and his work is frequently quoted by the trade press. This month in MarineNews , we explore the current regulatory and compliance environment facing domestic maritime industry, as well as every foreign-based marine entity that hopes to do business with a country that trans- ports 95 percent of what it consumes on the water. To that end, there is arguably no better quali ed expert on the full breadth of maritime regulatory issues than is Den- nis Bryant. He weighs in this month on a raft of different questions and quickly distills down to the lowest common denominator, some of the prickliest challenges facing both the commercial sectors and also the regulators themselves. We started out by asking him to comment on  ve speci c rulemaking efforts. Listen in as he gives his unvarnished take on all of it:Subchapter M (The Coast Guard?s effort to establish safety regulations governing the inspection, standards, and safety management systems of towing vessels):The move to convert the U.S. towboat sector from unin- spected to inspected was initiated by the towboat sector it- self, which wanted to get out from under the thumb of the Occupational Safety & Health Administration (OSHA). The conversion turned out to be more complex than they envisioned. In addition, it quickly became clear that the Coast Guard lacked the manpower to conduct all these in- spections in the same manner as it did with the blue-water  eet. Thus, a new paradigm has been crafted with private sector inspectors working under USCG standards. The  nal regulation is expected to be promulgated in 2014. Only time will tell how this new system works out. Dennis L. BryantBryant?s Maritime Consulting November 201312 MNMN November2013 Layout 1-17.indd 12MN November2013 Layout 1-17.indd 1210/28/2013 3:12:10 PM10/28/2013 3:12:10 PM