Page 13: of Maritime Logistics Professional Magazine (Nov/Dec 2017)
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M c a l f
President & CEO,
Chamber of Shipping of America dling and storage requirements to name a few. Narrowing CSA A dvocacy extends to foreign fag and domestic op- down systems suitable to a particular vessel confguration is erators and membership. What is the common glue that the most important frst step. The next step is to determine if a holds this unique group together and what one issue – if particular system has a type approval, whether it is issued by you can distill it down to that – do they share that concerns the United States or another country. If it does not have a US all of them?
type approval, it is critically important for the shipowner to The primary goal of our members is to assure that they are determine if the manufacturer is engaged in seeking a US type compliant with all legal requirements in all locations to which approval. If not, cross that system off your list. they trade. As a membership based organization, our primary
Taking all of the above into consideration, it’s time to en- goal is their primary goal and much of our communications gage in negotiations with manufacturers that produce systems with members relate to implementation requirements for ex- that meet the operational needs of the vessel in question. isting regulations and providing compliance advice for a par-
These negotiations obviously will include price, but equally ticular issue in general but also from time to time, providing as important should include discussions on availability of the customized compliance advice on a specifc issue unique to system and traditional contract terms relating to warranty, a situation encountered by one member. A secondary goal is service and maintenance. From the shipowner’s perspective, to provide “heads up” briefngs to our members on new re- planning for preparation of the ballast water management quirements which we see coming down the road and develop plan is critical including contingency planning if the system, a Chamber position on how we can infuence the development once installed, fails to operate while a vessel is in transit. of these new requirements so the fnal result is economically
Once a system is selected, the shipowner needs to prepare a feasible, operationally practical and takes into account the timeline for installation presumably during a regularly sched- most important issues of vessel and crew safety and environ- uled drydocking and determine if the vessel’s implementa- mentally responsible operations.
tion deadline can be met. If not, the vessel owner will need to apply for an extension although it is worth noting that exten- CSA in A ction: If you had to choose one mission of your sions are harder to come by these days given the fact that a many da ily tasks, where do you provide the most value number of systems have received US type approval. A suc- for y our membership? Why, how and can you give us spe- cessful extension application must show why none of the cur- cifc examples?
rent systems with U.S. type approval can be used and provide CSA’s goal is to ensure that our members know what they a timeline for how the vessel owner will assure compliance have to do to remain compliant today, and what they may have by the implementation deadline. to do in the future. With the avalanche of new requirements
A well-informed colleague, Debra DiCianna from Choice both internationally and here in the US, it is critical that they
Ballast Solutions has put together a simple list of generic con- have the necessary information to make informed business de- siderations and advice. In her words, vessel owners should (1) cisions. For us to be successful in this mission requires CSA expect the unexpected (2) develop a compliance strategy in- to be at the forefront of all discussions relating to international cluding considerations for system design and installation and deliberations (IMO) and U.S. state legislative and regulatory contingency planning (3) document all discussions with sys- initiatives. CSA staff work very hard at maintaining the critical tem manufacturers, engineering frms and drydocks including network and interfaces with Congress, USCG, EPA, NOAA any operational issues noted (4) keep up to date with all devel- and the State Department. In this role, our primary aim is to be opments and (5) team with trusted partners. seen as a trusted industry advisor capable of providing the in- www.maritimelogisticsprofessional.com 13
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