The dawn of the age of the onboard ‘Compliance Officer’?

It might seem daft to even suggest it, but the day could be approaching when every ship will have to employ, as an important member of her crew, a “Compliance Officer”. Every year brings with it a shoal of new regulations, many of which will not be simple to implement, but will be subject to interpretation, or, in the weasel words of the regulator - “to the satisfaction of the administration”.

There are now umpteen items of equipment aboard a modern ship, which, first of all, are mandatory, but which if they happen to be non-functioning, will render the ship effectively unseaworthy, or if the authorities are appraised of the matter, will be deemed deficiencies worthy of detention. As just one example, a large ship must leave port with at least two functioning radars and if one breaks down, there will be a terrible panic getting somebody down to the ship to fix it. Not that long ago a radar was regarded as a mere “aid” to navigation and an auxiliary to the “lead, log and look-out” which represented the essentials.

But regulation rushes on apace and we now have precious few months available for the purchase and fitting of ballast water treatment equipment, which may, or may not, comply with the moving targets of environmental authorities around the world. One can become over-analytical about these matters, but it is not for the first time that the industry has got in a terrible mess, with regulation that prescribes equipment that has yet to be developed.

Once such a policy would have been regarded as complete madness, but since the dreadful precedent of oily water separators that were demanded last century, it is sort of assumed that if regulators prescribe, manufacturers will bend over backwards to do their bidding. As a great deal of duff equipment has shown us over the years, life doesn’t work like that, especially in an industry where equipment volumes may be small and the incentives to research and develop are often questionable.

Regulations sometimes emerge over the horizon that are downright impractical and appear to be driven by a desire to force shipping off the seas. Shipping people are anxious to be seen as environmentally conscious and their business “sustainable” in every respect, but in their private moments will be forced to concede that regulatory pressures sometimes emerge from an anti-trade green agenda.

It is also an interesting exercise to compare the task of the present day port state control (PSC) inspector with that of his predecessor when PSC first emerged nearly 40 years ago. Then, the inspector, after an initial visual assessment of the state of the ship, would inspect the vessel’s certificates, possibly look at the date of chart corrections, check on the frequency of boat and fire drills and, if the inspector was particularly zealous, ask a few questions of crew members.

Such inspections now cover very many more fields, from the contracts with the crew to the state of the cold stores, the familiarity of crew members with their equipment and the fuel which has been burned in the engine and auxiliaries. In some parts of the world they will be poring over the ballast exchange arrangements and scrutinising the oil records in the utmost detail. They may be prising off flakes of paint to ensure that it is non-toxic, even checking up that the mud in the cable locker does not harbour pathogens or alien species. Enormous attention will be paid to the ship’s garbage disposal system. Soon, similar scrutiny will be focussed on the vessel’s exhausts, which, linked to the efficiency of the machinery and the practical work done by the ship in hauling cargo around, may well determine where the ship sits in a scale of emission taxation.

And so it goes on, with very little attention ever paid to the ability of the ship to earn sufficient money to pay for regulations, often applied retrospectively and indiscriminately, under a “one size fits all” basis. It was just a couple of years ago that the then Bimco president John Denholm complained of a “perfect storm” of regulations. Today, it might appear to be more of a hurricane, but with the industry’s ability to financially weather it, rather more problematical.

Posted 19 September 2016

© Copyright 2019 Seatrade (UBM (UK) Ltd). Replication or redistribution in whole or in part is expressly prohibited without the prior written consent of Seatrade.

Michael Grey

Columnist and correspondent

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