Page 11: of Maritime Reporter Magazine (January 2018)

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According to Dr. Tamburri, the Coast Guard personnel involved in the program have formally and informally provided different answers to different laboratories via ex parte meetings, telephone calls, emails, and written letters, resulting in dramatically inconsistent approaches at the various laboratories. Because this guidance has not been shared with all of the approved ILs, the process is no longer rigorous, consistent and transparent.

tion or guidance in house; and then share ent Coast Guard individual (possibly a This fundamental issue arises on a reg- Guard will view a particular matter. This that direction or guidance with all par- marine chemist) about the same issue ular basis in the Coast Guard. It has ? eld is somewhat similar to a notice and com- ticipants equally, thereby maintaining a but approaching it differently, asking “as of? ces all around the country. Mariners ment rulemaking. level playing ? eld. regards ______, is it OK if we do this?” and other stakeholders contact those ? eld The sooner a difference of approach

I can envision how this situation, if it This second individual also answers the of? ces on an almost daily basis seeking between two or more Coast Guard ? eld exists, could have happened. This is a question, but the answer is not the same guidance. Eventually, it happens that the of? ces or individuals on a substantive complex program with many moving as it was to the ? rst question because the answer received from one ? eld of? ce is matter is discovered, the sooner a uni? ed parts and many participants within the questions were presented differently and not the same as received from another approach can be developed. Assuming agency. Someone calls from one of the the individuals answering the questions ? eld of? ce. When the issue is inevitably that this is what has occurred with re-

ILs and asks “what does it mean in the approached the issue from their own elevated to Headquarters, it gets staffed gard to BWMS certi? cation testing pro- regulation where it says _____?” The re- perspectives. Neither Coast Guard in- and researched. cedures, it appears to be time to match cipient of the call (possibly a mechanical dividual tried to mislead the questioner A considered approach is developed pointers and develop an agreed and uni- engineer), trying to be helpful and un- and the answers were correct within the and approved. At that point guidance ? ed approach going forward. This is too derstanding the issue from that person’s bounds of the Coast Guard individual’s put in the form of perhaps a policy let- important an issue to be left to chance. perspective, answers the question and understanding of the issue. The prob- ter or Navigation and Vessel Inspection As I said above, Dr. Tamburri is a re- then turns his or her attention to a totally lem is that the recipients of the answers Circular (NVIC) is disseminated to all spected scientist and has raised issues different matter, not recording the ques- could now innocently adopt different ? eld of? ces and shared with the pub- that must be taken seriously by both the tion or the answer. Later, someone from methodologies for the same portion of lic. Thereafter, all interested parties are Coast Guard and the maritime commu- a different IL sends an email to a differ- the BWMS certi? cation testing. (or should be) aware of how the Coast nity.

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