Category: Environmental Compliance

The Latest on the Ballast Water Conundrum

Mainbrace | March 2016 (No. 2)

Jeanne M. Grasso and Dana S. Merkel

The challenges faced by the maritime industry in implementing international and domestic ballast water requirements continue unabated. These challenges may be getting even more challenging in the next year or so.

Internationally, new ratifications to the International Maritime Organization’s (“IMO”) International  Convention for the Control and Management of Ships’ Ballast Water and Sediments (“Convention”) mean the Convention is very close to entering into force. In the United States, which is not party to the Convention, the U.S. Coast Guard (“USCG”) issued a revised policy addressing extensions for the installation of ballast water treatment systems and, shortly thereafter, rejected an “equivalency request” from four ballast water treatment system manufacturers, which would have helped alleviate the need for these extensions, which now number more than 4,000. In addition, the U.S. Second Circuit Court of Appeals ruled that the U.S. Environmental Protection Agency (“EPA”) acted arbitrarily and capriciously in drafting the ballast water provisions of its Vessel General Permit for Discharges Incidental to the Normal Operation of Vessels (“VGP”), thus creating more uncertainty. Continue reading “The Latest on the Ballast Water Conundrum”

Risk-Management Tools for Maritime Companies

Mainbrace | March 2016 (No. 2)

Compliance Review Program

Blank Rome Maritime has developed a flexible, fixed-fee Compliance Review Program to help maritime companies mitigate the escalating risks in the maritime regulatory environment. The program provides concrete, practical guidance tailored to your operations to strengthen your regulatory compliance systems and minimize the risk of your company becoming an enforcement statistic. To learn how the Compliance Review Program can help your company, please visit www.blankrome.com/  compliancereviewprogram.

Maritime Cybersecurity Review Program

Blank Rome provides a comprehensive solution for protecting your company’s property and reputation from the unprecedented cybersecurity challenges present in today’s global digital economy. Our multidisciplinary team of leading cybersecurity and data privacy professionals advises clients on the potential consequences of cybersecurity threats and how to implement comprehensive measures for mitigating cyber risks, prepare customized strategy and action plans, and provide ongoing support and maintenance to promote cybersecurity awareness. Blank Rome’s maritime cybersecurity team has the capability to address cybersecurity issues associated with both land-based systems and systems onboard ships, including the implementation of the BIMCO Guidelines on Cyber Security Onboard Ships. To learn how the Maritime Cybersecurity Review Program can help your company, please visit www.blankrome.com/cybersecurity or contact Kate B. Belmont (KBelmont@BlankRome.com, 212.885.5075) or Steven L. Caponi (Caponi@BlankRome.com, 302.425.6408).

Trade Sanctions And Export Compliance Review Program

Blank Rome’s Trade Sanctions and Export Compliance Review Program ensures that companies in the maritime, transportation, offshore, and commodities fields do not fall afoul of U.S. trade law requirements. U.S. requirements for trading with Iran, Cuba, Russia, Syria, and other hotspots change rapidly, and U.S. limits on banking and financial services, and restrictions on exports of U.S. goods, software, and technology, impact our shipping and energy clients daily. Our team will review and update our clients’ internal policies and procedures for complying with these rules on a fixed-fee basis. When needed, our trade team brings extensive experience in compliance audits and planning, investigations and enforcement matters, and government relations, tailored to provide practical and businesslike solutions for shipping, trading, and energy clients worldwide. To learn how the Trade Sanctions and Export Compliance Review Program can help your company, please visit www.blankromemaritime.com or contact Matthew J. Thomas (MThomas@BlankRome.com, 202.772.5971).

Critical Habitat for Right Whales Expanded

Jeanne M. Grasso, Jonathan K. Waldron, and Stefanos N. Roulakis

Action Item: The National Marine Fisheries Services (“NMFS”) promulgated a final rule identifying critical habitats for the endangered Northern Atlantic Right Whale. Stakeholders involved in spill response, ocean and offshore energy (including renewable energy), fisheries, and other activities requiring federal permits or permission should examine the final rule to determine current possible impacts to activities in the Atlantic Ocean. Additionally, stakeholders involved in industries in the Atlantic Ocean, particularly in the South Atlantic, should consider engaging early with NMFS to minimize permitting delays and costly modifications to plans. Continue reading “Critical Habitat for Right Whales Expanded”

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