Here is some background on the pilot waivers etc (the occurrence being the Nathan Stewart.
4.1.1 Pacific Pilotage Authority Canada
On 16 October 2016, 3 days after the occurrence, the Pacific Pilotage Authority Canada (PPA) informed the authorized representative that, effective immediately, all British Columbia coast pilotage waivers held by all Kirby Offshore Marine Operating LLC vessels and marine officers were being revoked.
Following the occurrence, the PPA began to monitor vessel traffic entering the pilotage area. The traffic monitoring resulted in the identification of 17 companies operating in compulsory pilotage waters without a pilot or the required PPA pilotage waiver.
On 24 October, 11 days after the occurrence, the PPA issued a letter explaining amendments to its waiver system to companies that held a pilotage waiver. These amendments stated that all vessels must have 2 people on the bridge at all times while operating in confined waters, and that 1 of those must be the waiver holder. The amendments also indicated that vessels carrying petroleum products as cargo but not delivering fuel to local communities
- are no longer allowed to transit the northern section of the Inside Passage;
- are to follow a route between mainland British Columbia and Haida Gwaii; and
- in adverse weather conditions, and after clearance with vessel traffic, can proceed through Laredo Channel and Principe Channel by entering via Laredo Sound or Browning Entrance (Appendix C, route B).
These additional requirements were immediately implemented on an interim basis, until a full risk assessment was conducted.
From November 2016 to May 2017, a risk assessment project was undertaken to assess the interim amendments for their net impact on safety, identify any inherent safety gaps, and make recommendations for further improvements to the safety of vessels operating under pilotage waivers on British Columbia’s northern coast. The project’s risk management team was composed of the PPA, Transport Canada (TC), the Canadian Coast Guard (CCG), the United States Coast Guard, BC Coast Pilots, the Council of Marine Carriers, First Nations groups, and Canadian and U.S. company pilot waiver holders.
The project concluded that the interim measures implemented by the PPA in October 2016 were effective in reducing the navigational risk to pilotage-waiver traffic on the north coast of British Columbia. On 23 May 2017, the PPA released the project report, entitled A Risk Assessment of the Pacific Pilotage Authority’s Process for Granting Waivers from Compulsory Pilotage of the BC Coast . The report recommendations are incorporated within the PPA’s “Standard of Care” Implementation Guidelines.Footnote 127 Although these guidelines do not have the force of law, they include the conditions under which the PPA will consent to granting waivers to qualified applicants.
On 14 August 2017, after further consultation with TC, the PPA proposed amendments to its guidelines for granting future pilotage waivers, eliminating the option of a 1-person bridge watch during the hours of darkness, by clarifying "that the relaxation of the requirement for two persons on the bridge should only be considered available in conditions of daylight and good visibility."Footnote 128