Interview: Rear Admiral Paul Thomas, USCG

Rear Admiral Paul Thomas (Photo: USCG)

By Joseph Keefe

Rear Admiral Paul Thomas develops and maintains policy, standards
and program alignment for waterways management, navigation
safety, boating, commercial vessels, ports and facilities,
merchant mariner credentialing, vessel documentation, marine
casualty investigation, inspection and port state control
activities. He serves as the Assistant Commandant for Prevention
Policy overseeing three Coast Guard directorates: Inspections and
Compliance, Marine Transportation Systems, and Commercial
Regulations and Standards. A specialist in Marine Safety,
Security and Environmental Protection, he has served at the
Marine Safety Center in Washington, DC and many others before
that. His other tours include, among others, service as
Commanding Officer of USCGC CAPE ROMAIN. He is a graduate of the
US Coast Guard Academy and the Massachusetts Institute of
Technology. In 2005 he completed a National Security Fellowship
at Harvard University's John F. Kennedy School of Government, and
in 2010 he served as a Senior Fellow to the Chief of Naval
Operations Strategic Studies Group. This month, he weighs in on
the entire spectrum of Coast Guard safety and regulatory issues.
It is an exciting time in this regard, and the buck stops at his
desk. Listen in as he brings us up to speed:

With the first BWTS approval out of the way, how many
more are in the pipeline and is there a sense of how soon you
might be acting on additional applications?

We now have three systems with USCG Type Approval. Two are UV and
one is EC. To date, we've received 45 letters of intent from
manufacturers who plan to conduct testing. We understand that the
independent laboratories are currently working with several
manufacturers to complete testing and evaluation of additional
systems. Based on this ongoing activity, we anticipate that we
will receive additional applications for type approval throughout
the upcoming year. Vessels owners and operators should study
these type approvals carefully and fully understand the technical
constraints associated with each. The Coast Guard recognizes that
"one size does not fit all" for BWMS. As such, it will take a
variety of type approved systems to meet the needs of the global
fleet. We'll continue to work toward additional type approvals
and to provide guidance to industry on future compliance date
extension requests as appropriate.

The Subchapter M towboat rules are 'settled law' at this
point, but companies still must decide which route that they will
take to compliance. What's your sense on the numbers of firms
that will opt for 'the Coast Guard' option?

The Coast Guard recently issued the "Third Party Organization
(TPO) Guidebook." This document intends to help organizations who
want to provide third party services and vessels operators
considering the use of Third Parties as a compliance strategy. We
know the industry is studying the options, but we do not know how
many TPOs will enter the market, or how many operators will chose
the TPO option. There are many advantages to the TPO option over
the Coast Guard option. Operators who chose the TPO option will
have much greater flexibility with regard to scheduling
inspections, clearing deficiencies, making repairs and managing
their fleet wide compliance dates. Any operator who desires to
certify more than 25% of their fleet in any given year will have
to use a TPO. In addition, there are inherent advantages to the
implementation of a Towing Vessel Safety Management System (TSMS)
as a means of consistently engaging the entire workforce to
ensure compliance with the regulations.

The Coast Guard has delegated more and more statutory
inspection work to quality third party groups. How much
inspection work does the Coast Guard still do, and do you feel
the internal knowledge is still there and being grown in-house to
support these missions going forward?

Third parties have been and will continue to be an important part
of the system we use to ensure the US Fleet is safe, secure and
environmentally sound. In fact, we use more than 300 Third
Parties for everything from the development of standards, to
testing of equipment, type approvals and compliance activities.
Subchapter M is the first time we have codified the use of Third
Party as a compliance strategy in regulations, but we expect to
take that approach more often in the future. All of our Third
Party options are designed to improve, rather than remove, Coast
Guard oversight while reducing burden and increasing flexibility
for the industry. We still do a lot of inspection work "in
house," both as part of our Third Party oversight
responsibilities and in cases where Third Parties are not an
option or are not employed. Third Parties actually increase Coast
Guard ability to maintain proficiency where we need to because
they can free us from the tyranny of scheduled inspections and
allow our inspectors to focus on the most critical fleets,
vessels and systems. As this industry continues to grow in terms
of complexity and diversity we expect more and different Third
Parties to play important roles in the overall safety net. Cyber
Risk management is an emerging area with great potential for
Third party standards and compliance.

The centralization to WV of the 17 REC's now seems like
ancient history. That said; it was not without its teething
issues, but today, the general sense is that the National
Maritime Center is doing a good job. Give us some real metrics
and benchmark numbers to support that point of view.

In 2009, the Coast Guard's set a performance goal for the time it
takes to issue a merchant mariner credential from application to
issuance at 30 days net processing time. Since that time, the
overall net processing time has averaged 28.6 days. While it is
clear that the National Maritime Center meets the net processing
goal for a majority of mariners, we know that isn't the case 100%
of the time. In 2016, the NMC issued 70,023 merchant mariner
credentials with 78 percent being issued within our goal of 30
days net processing time. It is currently taking longer than 30
days net processing time due to an increase in applications that
are linked to STCW "gap closing" requirements. We usually see
fluctuations in our net processing time throughout the year due
to increases in applications in the spring when graduates from
the maritime academies apply for their credentials, and in the
summer when there is an uptick in seasonal work in the domestic
maritime industry. In the past, singular events such as the
government furlough in 2013 or changes in CG regulations or
international standards have contributed to short-term growth in
our application inventory. Centralization was completed in late
2008. Following that event, our average processing time peaked at
slightly over 60 days in 2009 but has remained consistently lower
than that since, giving us some quantitative assurance that the
decision to centralize was a good one. For more detailed
information on the NMC's performance and customer satisfaction
reports, please go to
http://www.uscg.mil/nmc/reports/default.asp.

The Coast Guard, in recent years has made a real effort
to recruit maritime industry and maritime academy professionals
into the marine safety mission set. How has that been going and
just as importantly, are you retaining these personnel?

We understand that the Coast Guard is competing for the same
talented professionals as is the industry, Class Societies and
others. We do lose highly qualified people to the industry,
particularly on the up cycles. Right now, our retention of
Maritime Prevention Professionals is high. Nevertheless, we are
constantly focused on making the Coast Guard the employer of
choice for Maritime Safety professionals. Our Commandant recently
issued the Coast Guard Human Capital Strategy. This focused the
entire Coast Guard on ensuring our Human Capital System meets
mission, service and people needs. The implementation plan for
the strategy specifically addresses the Marine Safety workforce.
We are looking at how we recruit, train, retain, assign and pay
our people. We know that the Maritime Prevention professional of
the future will need the skills and enabling technology to keep
pace with this industry and we've initiated programs to do just
that. We will continue to seek out Maritime industry and Maritime
Academy professionals as part of our workforce. The Coast Guard
provides tremendous opportunity to work in the maritime industry
on an outstanding team who makes a positive impact on our nation.

What is the biggest issue on the plate of the marine
safety group at this moment? What are you doing to solve
it?

The maritime industry faces the triple challenge over the next
several decades of increasing the capacity of the Marine
Transportation system (MTS), while reducing the environmental
footprint in the face of every increasing complexity. This triple
challenge drives Coast Guard maritime prevention priorities as
well. We are focused on increasing capacity of the MTS through
our Future of Navigation initiative even while we increase our
internal capacity to provide governance through the workforce and
third party initiatives I've already mentioned. Another focus
area of the Coast Guard is providing effective and reasonable
environmental standards and compliance strategies in order to
reduce the environmental footprint of the MTS. You see this today
in air emissions, ballast water and other waste streams. We
strive to put standards in pace that drive the innovation
required to meet this environmental challenge, and to develop
compliance processes that provide the level playing field the
industry demands and deserves. And finally, with regard to
complexity, the two biggest issues on our plate our implementing
effective safety management systems and managing operational risk
associated with cyber systems. We are working hard to update SMS
and ISM requirements in both regulation and NVIC, and to put in
place basic cyber risk management requirements for both vessels
and port facilities.

In terms of regulatory issues, SubM, the Ballast Water
issue and VGP seem to be 'answered policy.' What's looming large
in the porthole next, when can we expect it, and what will it
mean for the commercial sector?

Our next big regulatory initiative is an update to Sub N, which
governs Outer Continental Shelf Activity. These regulations have
not been update in decades, and they have not kept pace with the
types of activities and technologies on the OSC today. Our goal
is to provide flexible performance based requirements that level
the playing field for US and foreign operators on the OSC. We
look forward to robust industry participation in the finalization
of these regulations.

In terms of policing the offshore oil & gas sector,
where does the Coast Guard and the BSEE intersect in terms of
jurisdiction and where do they have strict separation of
powers?

The Coast Guard and BSEE understand that the most effective
oversight of offshore oil and gas doesn't come about from strict
adherence to agency jurisdictional boundaries or separation of
powers. Instead, we have focused on leveraging the authorities
and capabilities of both agencies to provide seamless oversight
in a manner that improves safety and environmental performance
and simplifies compliance for the industry. That is why the CG
and BSEE meet regularly at both the national and regional levels,
we conduct joint training and operations, we coordinate on
policy, regulations, investigations and corrective actions, and
we meet jointly with the regulated industry. We have established
a joint "scorecard" to help us gauge safety and environmental
performance on the OCS, and we are working on better procedures
to "hand off" issues from one agency to the other when
jurisdictional boundaries are encountered. This year the CG and
BSEE will issue our first joint report on the State of the US OCS
Regulated Activity.

Dynamic Positioning (DP) training and certification is a
hot issue. Where does the Coast guard get involved with
certification of both the training facilities and then, with
Coast Guard credentialing and/or STCW requirements - if at all?

The U.S. Coast Guard does not currently approve courses for
dynamic positioning training. However, we note the potential for
a loss of position on a MODU or other vessel engaged in Outer
Continental Shelf activities that could result in serious
consequences for human safety and the environment during certain
critical operations. Taking into account these and other factors,
including the increasing complexity of these systems, we are
developing regulations (see 79 FR 70943) to establish minimum
training standards in order to improve the safety level of people
and the property involved in such operations and ensure the
protection of the environment in which they operate.

In a down maritime economy, one of the first things to
"go" tends to be spending on safety. What has the Coast Guard
seen in terms of measurable changes in the rate of accidents, oil
spills, etc?

Overall, major marine casualty rates have remained consistent
over the last 10 years. However, reportable marine casualties
have actually been trending downward since 2015. We believe that
the publication of the Marine Casualty Navigation and Vessel
Inspection Circular had an impact on both the reporting of marine
casualties by industry and the investigation of marine casualties
by investigating officers.

What is the Coast Guard's marine safety division doing
best, in your opinion, at moment? Give us an example of that in
play. And, what could you be doing better?

There is no doubt the best part of the Coast Guard Prevention
program is our workforce at the Sector, MSU and MSD levels. What
we do best, and have always done very well, is provide a
geographically distributed workforce in the port who know the
industry, the area and the issues. Better than any other Federal
regulator we are able to bring local knowledge and common sense
to bear on operational decisions that happen at the port level.
We will always cherish and nurture our relationship with the
maritime community at all levels, but particularly at the port
level where the most important work gets done every day. Of
course, an empowered, decentralized workforce brings challenges
associated with ensuring consistency across the nation. We will
always be working on improving our consistency in a way that
preserves the advantage of local flexibility. We rely on industry
feedback to help us identify areas where additional guidance is
needed to ensure the proper degree of consistency.

Looking at the domestic commercial waterfront today, what
one thing would you change were it in your immediate power to do
so?

If I could change anything it would be to increase the public
awareness of and appreciation for the significance of the
commercial waterfront in terms of our national security and
prosperity. Our nation relays on our ports and waterways and on
the maritime industry; but most of us don't realize that. The
Coast Guard is committed to ensuring this vital MTS remains safe,
secure, environmentally sound, productive and efficient.

(As published in the February 2017 edition of
Marine News
)

Mar 8, 2017

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