[QUOTE=KPChief;180682]Excuse me. I must have been pecking away while you were posting this. I see more where you are coming from now. However still think the USCG is sort of trapped jurisdictionally. Yes a life raft goes on a ship and a container goes on a ship but the industries involved are pretty different.
Wonder why USCG hasn’t tried harder to elaborate, then again they may just make it worse.
NYK letting their valued customers know.
Yes they are different and this underscores the CG’s problem. It’s not hard to say, hey US flag ships, get liferaft servicing at CG approved service facilities. Ok, that’s manageable, how many US ships? How many rafts? Need x number of servicing stations to meet need to service y number of rafts. Businesses will spring up and seek the appropriate CG certification. And since the ships have a year to get service, it is a manageable affair. To continue the metaphor for containers—pretend they are all liferafts, and you must only load containers ‘serviced’ by CG approved stations. You don’t have a year to do it, and the liferafts are coming from everywhere. Different story. Challenging for everyone, even the way the Brits are doing it (I posted this earlier).
the challenge of the shoreside enforcement (shippers and terminals) is the problem, partly jurisdictional, partly a case of management. but that’s the problem the CG has. At IMO everyone agreed, and has the obligation to go home and make it happen. In this case, it means passing a new regulation to regulate terminals and shippers. The coast guard can do so, it did for ISPS, another SOLAS requirement that places requirements beyond just the vessel. It was obligated to do the same, but the coast guard has ‘challenges’ actually implementing regs generally and solas ones specifically–see the ongoing regulation project for SOLAS approved cargo securing manuals–15 years and not done.