Targeted Review Finds Deficiencies on Dozens of U.S.-Flag Ships

In the wake of the loss of the con/ro El Faro in 2015, the U.S. Coast Guard undertook a review of its flag state marine inspection policies. It stood up a new Flag State Control Division at its Washington headquarters to oversee class society performance, and it conducted a risk assessment of all deep draft vessels in the U.S.-flagged fleet. According to Rear Adm. John Nadeau, the assistant commandant for prevention policy, this assessment has produced results. 

Speaking at the CMA 2019 conference last week, Nadeau said that 53 ships - nearly 30 percent of the U.S.-flagged fleet - were designated as "high risk" during a review last year and "targeted for additional oversight," meaning additional Coast Guard inspections.

"We sent some of our most experienced inspectors to examine these vessels and identified 661 deficiencies, including 86 detainable deficiencies," said Nadeau. "In the end . . . six vessels had their Certificates of Inspection revoked, prohibiting the vessels from operating until the matters were addressed."

The bar for revoking a COI is generally high, and it is often used to enforce a previous order for corrective action. Under federal law, the certificate "shall be revoked if a condition unsafe to life that is ordered to be corrected . . .  is not corrected at once." 

The names of the vessels and operators covered by the high-risk inspection program were not disclosed, and detailed ship-level data on deficiencies are limited in the Coast Guard's public-access database. However, Adm. Nadeau's office produces an annual report of aggregated statistics on the fleet's flag state performance using the same metrics that it uses for port state control. USCG marine inspectors are now using a revised inspection form that reflects international PSC standards, making head-to-head statistical comparison more straightforward.

"Last year, we started issuing detainable deficiencies to U.S. flagged vessels as a way to better track the health of the U.S. fleet, just as we do under Port State Control," Nadeau said. "We are finding that many of these detainable deficiencies are tied to the ship’s Safety Management System."

Inspectors also have a new tool: guidance on how to initiate “quality cases” in situations where the third party or class society may not be performing its delegated functions well enough. The USCG delegates many of its marine inspection and certification functions to class under the Alternate Compliance Program (ACP).