Page 25: of Maritime Reporter Magazine (January 2015)

POSH Xanadu is a new generation DP3 Semisubmersible Accommodation

Vessel (SSAV) for PACC Offshore Services Holdings Limited (POSH).

(Photo courtesy of PACC Offshore Services Holdings Limited) lines, as well as several others found to maintained with regard to covered vessels be relevant. The NPRM, on page 70946, with DP systems. It is assumed that most states, for example: are maintained properly now, but there [W]e propose to incorporate IMO may be exceptions. In the future, excep-

MSC/Circ.645 into regulations as manda- tions may have consequences, even when tory provisions. We also propose to adopt no casualty results therefrom. One of the in regulations DP guidance issued by the sets of records to be maintained involves

Marine Technology Society (MTS) as the resumes and vessel-speci? c work re- mandatory provisions to provide owners cords of all key DP personnel. Let’s as- or operators of DP MODUs and other sume that one of those persons materially vessels essential information on how to fudged his or her resume at some time in meet some of the requirements of this the past – perhaps by falsely claiming to notice of proposed rulemaking (NPRM). have taken a particular training course. If

In other words, a goal of the rulemak- the Coast Guard proposal is adopted, that ing is to mandate that all participants old but fraudulent entry in a resume may adopt proven best practices. In analyz- have severe legal consequences.

ing the costs of this proposal, the Coast For the most part, I heartedly endorse

Guard notes that costs should be minimal the Coast Guard approach to regulation because, for the most part, the regulated of this important and expanding technol- entities already are or should be taking ac- ogy. By adopting industry standards, the tions that incur these costs, thus the added Coast Guard is minimizing the burden on expense in many instances is almost zero. good operators while working to bring

The major difference between the cur- others up to the accepted mark. Any bad rent process of voluntary guidelines and apples should be weeded out. The legal the proposed US Coast Guard rulemak- impacts of mandating previously volun- ing is that, when and if implemented, the tary records and reports are an unfortu-

USCG regulations will mandate certain nate but natural secondary consequence. operational procedures, reporting, and Your view may differ. Either way, your recordkeeping. While not creating many comments should be submitted to the new provisions in this regard, there is a Coast Guard by February 26.

major paradigm shift that deserves atten- tion. Failure to comply with those opera- tional procedures and reporting require- ments, as subsumed by the Coast Guard

The Author rulemaking, could result in civil penal-

Dennis L. Bryant is with Maritime Regu- ties. Intentional failure to comply with latory Consulting, and a regular contribu- the recordkeeping and reporting require- tor to Maritime Reporter & Engineering ments could result in criminal charges

News as well as online at MaritimePro- against both the individual and the vessel fessional.com. owner and operator.

t: 1 352 692 5493

By rough count, there are at least 15 e: [email protected] different reports and records that are to be www.marinelink.com 25

MR #1 (18-25).indd 25 MR #1 (18-25).indd 25 1/7/2015 4:22:24 PM1/7/2015 4:22:24 PM