New USCG guidance on SASH crew safety compliance

Following on from its April Marine Safety Bulletin (MSIB) on reporting harassment on U.S.-flag vessels (see earlier story) the U.S. Coast Guard has now released further guidance on vessel operator compliance with changes to the law enacted as part of the FY 2023 National Defense Authorization Act (NDAA) to enhance crew safety and address sexual assault and sexual harassment (SASH) issues.

Key changes include mandated surveillance systems, crew training, reporting procedures, and master key controls on select vessels.

An MSIB released November 14 gives an overview of the new guidance, while four policy documents provide more specific guidances for compliance.

• CG-CVC Policy Letter 23-04 covers the statutory requirement for merchant vessels over 100 gross tons to post information regarding prohibitions on sexual assault and sexual harassment;
• CG-CVC Policy Letter 23-05 covers the statutory requirement for certain vessels (including vessels with overnight accommodations for 10 or more persons on seagoing voyages of 600 or more miles) to install and maintain video and audio surveillance systems;
• CG-CVC Policy Letter 23-06 covers the statutory requirement for inspected vessels to establish a master key control system. More information about AWO’s preliminary analysis of these policy letters can be found in our recent member alert.
• CVC-WI-004(3) is a work instruction on flag state interpretations on the ISM Code to address the statutory requirement to report harassment, sexual harassment, and sexual assault.

Some industry groups are not happy with what they see as a lack of consultation on the new SASH prevention guidances.