ALCOAST 082/19 - MAR 2019 UNIT STAND DOWN FOR THIRD PARTY OVERSIGHT

R 151036 MAR 19
FM COMDT COGARD WASHINGTON DC//CG-5P//
TO ALCOAST
UNCLAS //N16700//
ALCOAST 082/19
CONDTNOTE 16700
SUBJ: UNIT STAND DOWN FOR THIRD PARTY OVERSIGHT
1. Each Coast Guard Sector, Marine Safety Unit, and other unit that exercises Officer in
Charge, Marine Inspection (OCMI) authority shall conduct a Third Party Organization (TPO)
oversight stand down within 30 days, following the procedures outlined below. The stand
down activities may be spread over several days to accommodate operational requirements.
The objective of the stand down is to ensure unit members understand and properly execute
the new Mission Management System (MMS) Work Instructions and Procedures regarding domestic
vessel inspections and Coast Guard oversight responsibilities.
2. Effective TPO oversight is crucial to ensuring all inspected vessels meet applicable
safety, security, and environmental protection standards. On 01OCT15, the S.S. EL FARO and
her 33 crewmembers were lost at sea. One of the causal factors that led to this tragedy was
the failure of the Coast Guard to provide effective oversight of TPOs performing statutory
functions on our behalf under the Alternate Compliance Program. In addition, the use of TPOs
is expanding. On 20JUL18, 46 C.F.R. Chapter I, Subchapter M went into force. These
regulations added approximately 5,800 towing vessels to the U.S. inspected fleet and permits
additional TPOs to perform statutory functions on behalf of the Coast Guard.
3. The Coast Guard is ultimately responsible to monitor the performance of TPOs. Significant
progress has been made to improve the policy framework and reform Coast Guard oversight of
TPOs. COMDT (CG-CVC) has made substantial changes to the oversight program and published Work
Instructions and Procedures that form a solid foundation for this program. However, it is
critical that OCMIs embrace and drive these changes and improvements down to the deck plates
to ensure all members of Inspections and Investigations Divisions understand and properly
execute. Units will assess current oversight functions within their OCMI zone and ensure
operations are being conducted in accordance with the revised procedures.
4. Stand down training material is available at:
https://cg.portal.uscg.mil/units/cgcvc/cvc4/TPO_Stand_Down/SitePages/Home.aspx/.
5. Training materials will be permanently posted on the COMDT (CG-CVC-4) portal site for
future participation. For questions regarding the stand down, please contact COMDT (CG-CVC-4)
at: FlagStateControl@uscg.mil.
6. As the lead agency for the U.S. Flag Administration, the Coast Guard is the final element
in the vessel safety framework and must conduct effective TPO oversight, increase focus on
improving Safety Management Systems, and promote a healthy safety culture. Thank you for your
efforts to remain “Ready, Relevant, and Responsive” and ensure commercial vessel operations
continue to be safe, secure, and environmentally responsible.
7. RADM J. P. Nadeau, Assistant Commandant for Prevention Policy, sends.
8. Internet release is authorized.