Coast Guard Cracks Down on Inspection in Sustained Follow-up to El Faro Tragedy

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In a sign that the loss of the SS El Faro is significantly toughening US Coast Guard inspections, the Commandant of the Coast Guard has ordered all Officers of Marine Inspection (OMI) to “stand down” in overseeing inspections of ships and barges until they are certain they understand new, expanded Coast Guard inspection requirements prompted by the SS El Faro loss.  

The sustained focus on marine inspections, more than a year after a Marine Board of Investigation said Coast Guard oversight of inspections failed the crew of the El Faro. appears to show the agency is taking the report seriously and checking to make certain crackdowns are implemented. One specific target of the stand down focus appears to be oversight of third parties designated to perform safety inspections.  Mostly, this is the American Bureau of Shipping. (ABS).  The stand down order also mentions expanded Coast Guard responsibility for barge and inland watercraft inspections. 

“The objective of the stand down is to ensure unit members understand and properly execute
the new Mission Management System (MMS) Work Instructions and Procedures regarding domestic
vessel inspections and Coast Guard oversight responsibilities,” the order states.

The stand down order references the SS El Faro. 

On 01OCT15, the S.S. EL FARO and her 33 crew members were lost at sea. One of the causal factors that led to this tragedy was the failure of the Coast Guard to provide effective oversight of TPOs (third party oversight) performing statutory functions on our behalf under the Alternate Compliance Program. 
“In addition, the use of TPOs is expanding. On 20JUL18, 46 C.F.R. Chapter I, Subchapter M went into force. These regulations added approximately 5,800 towing vessels to the U.S. inspected fleet and permits additional TPOs to perform statutory functions on behalf of the Coast Guard.”

The El Faro was lost in Hurricane Joaquin on October 1, 2015, with the loss of all 33 officers and crew.  The captain ought not to have navigated toward Joaquin, the Marine Board concluded, but contribution factors to the loss were poor inspections and approval of modifications that ultimately left the ship less stable. 


Said one senior officer within the Coast Guard:

“This will prompt the OCMIs to focus on marine inspections and each unit will now have new accountability protocols for inspections and third party oversight that simply didn’t exist before.”
The officer added that “stand downs” are rare in the Coast Guard.  They generally are implemented only after a vital system or crew training factor has been identified as failing.  It focuses the attention of all on the challenge. 

The stand down order issued on March 15th by Commandant of the Coast Guard Admiral Karl L. Schultz, specifically references the SS El Faro as one underlying reason for the stand down. 

U.S. Coast Guard sent this bulletin at 03/15/2019 10:40 AM EDTR 151036 MAR 19
FM COMDT COGARD WASHINGTON DC//CG-5P//
TO ALCOAST
UNCLAS //N16700//
ALCOAST 082/19
CONDTNOTE 16700
SUBJ: UNIT STAND DOWN FOR THIRD PARTY OVERSIGHT
1. Each Coast Guard Sector, Marine Safety Unit, and other unit that exercises Officer in 
Charge, Marine Inspection (OCMI) authority shall conduct a Third Party Organization (TPO)
oversight stand down within 30 days, following the procedures outlined below. The stand
down activities may be spread over several days to accommodate operational requirements.
The objective of the stand down is to ensure unit members understand and properly execute
the new Mission Management System (MMS) Work Instructions and Procedures regarding domestic
vessel inspections and Coast Guard oversight responsibilities.
2. Effective TPO oversight is crucial to ensuring all inspected vessels meet applicable
safety, security, and environmental protection standards. On 01OCT15, the S.S. EL FARO and
her 33 crewmembers were lost at sea. One of the causal factors that led to this tragedy was
the failure of the Coast Guard to provide effective oversight of TPOs performing statutory
functions on our behalf under the Alternate Compliance Program. In addition, the use of TPOs
is expanding. On 20JUL18, 46 C.F.R. Chapter I, Subchapter M went into force. These
regulations added approximately 5,800 towing vessels to the U.S. inspected fleet and permits
additional TPOs to perform statutory functions on behalf of the Coast Guard.
3. The Coast Guard is ultimately responsible to monitor the performance of TPOs. Significant
progress has been made to improve the policy framework and reform Coast Guard oversight of
TPOs. COMDT (CG-CVC) has made substantial changes to the oversight program and published Work
Instructions and Procedures that form a solid foundation for this program. However, it is
critical that OCMIs embrace and drive these changes and improvements down to the deck plates
to ensure all members of Inspections and Investigations Divisions understand and properly
execute. Units will assess current oversight functions within their OCMI zone and ensure
operations are being conducted in accordance with the revised procedures.
4. Stand down training material is available at:
https://cg.portal.uscg.mil/units/cgcvc/cvc4/TPO_Stand_Down/SitePages/Home.aspx/.
5. Training materials will be permanently posted on the COMDT (CG-CVC-4) portal site for
future participation. For questions regarding the stand down, please contact COMDT (CG-CVC-4)
at: FlagStateControl@uscg.mil.
6. As the lead agency for the U.S. Flag Administration, the Coast Guard is the final element
in the vessel safety framework and must conduct effective TPO oversight, increase focus on
improving Safety Management Systems, and promote a healthy safety culture. Thank you for your
efforts to remain “Ready, Relevant, and Responsive” and ensure commercial vessel operations
continue to be safe, secure, and environmentally responsible.
7. RADM J. P. Nadeau, Assistant Commandant for Prevention Policy, sends.
8. Internet release is authorized. 

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