AUGUST 4, 2015 — Law firm Blank Rome says that vessel owners, operators and crew managers should review a recently published Coast Guard policy guidance on when a casualty report is and is not required.
On July 21, 2015, notes Blank Rome, the U.S. Coast Guard released Navigation and Vessel Inspection Circular 01-15 (NVIC 01-15), titled Marine Casualty Reporting Procedures Guide with Associated Standard Interpretations. The purpose of NVIC 01-15 is to clarify terminology and phrases within the regulatory context, draw attention to helpful regulatory citations, and provide concise policy interpretations to assist vessel owners/operators with the casualty reporting process.
NVIC 01-15 can be located HERE.
“With the publication of NVIC 01-15,” says Blank Rome, “the Coast Guard has finally set the benchmark in establishing industry-wide marine casualty reporting standards, with the goal of establishing uniformity in such reporting, as well as more consistency in Coast Guard enforcement, in an area which has been problematic for years. In short, the Coast Guard has essentially provided the marine industry with its ‘playbook’ for how it will respond to casualty-related reporting incidents or failures to report. Industry stakeholders should ensure that crew and shoreside personnel are familiar with the Coast Guard’s guidance, and heed the NVIC 01-15 recommendation to contact the Coast Guard whenever in doubt to avoid Coast Guard enforcement action for a failure to report a marine casualty in accordance with the regulations as interpreted by the Coast Guard as outlined in NVIC 01-15.