Final Rule on Inspection of Towing Vessels Published After 12 Years in the Making

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

 

 

 

Action Item: The recently published Subchapter M Final Rule establishes a comprehensive safety system and inspection program for towing vessels.  Stakeholders involved in the operation or ownership of towing vessels should carefully evaluate the new measures, review safety procedures, and develop plans to comply with the timeframes mandated by the new regulations. Continue reading “Final Rule on Inspection of Towing Vessels Published After 12 Years in the Making”

SOLAS Verified Gross Mass (“VGM”) Countdown: Will You Be Ready On July 1, 2016?

Jeanne M. Grasso, Dana S. Merkel, and Jonathan K. Waldron

Action Item: With less than 30 days remaining before the July 1, 2016, effective date of the new International Convention for the Safety of Life at Sea (“SOLAS”) Regulation VI/2 amendments, the International Maritime Organization (“IMO”), Administrations, and industry continue to tackle unanswered compliance questions and concerns.

Below, we discuss the most recent guidance and developments from the U.S. Coast Guard, IMO, and industry organizations, as well as our assessment and views on enforcement, to assist stakeholders in preparing for the July 1 deadline, while taking into account the unique characteristics of various operations and ports. Continue reading “SOLAS Verified Gross Mass (“VGM”) Countdown: Will You Be Ready On July 1, 2016?”

The Well Control Final Rule Is Here, Finally

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

Action Item: The recently published Well Control Rule will require significant changes to Blow-Out Preventer (“BOP”) systems and well operations. Stakeholders in offshore oil and gas operations should carefully evaluate the new measures, review safety procedures, and develop plans to come into compliance within the time frames mandated by the regulations. Continue reading “The Well Control Final Rule Is Here, Finally”

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”

Heavy Lifting: U.S. Coast Guard Confirms Container Verified Gross Mass Requirement Will Not Be Delayed

Jeanna M. Grasso, Jonathan K. Waldron, and Dana S. Merkel

Action Item: A recent amendment to the International Convention for the Safety of Life at Sea (“SOLAS”) regarding requirements for providing certain cargo information, including weight, prior to loading has caused industry confusion and consternation. As the implementation date is July 1, 2016, stakeholders should work together to develop procedures to meet this implementation date because the U.S. Coast Guard has made it clear that it does not intend to delay implementation. Continue reading “Heavy Lifting: U.S. Coast Guard Confirms Container Verified Gross Mass Requirement Will Not Be Delayed”

January 16th Marked Changes in U.S. Sanctions on Iran

Matthew J. Thomas, Jonathan K. Waldron, and Dana S. Merkel

Action Item: January 16, 2016, marked Implementation Day under the Joint Comprehensive Plan of Action (“JCPOA”), an agreement between Iran and the EU3+3 nations (the United Kingdom, France, Germany, Russia, China, and the United States) to ease international trade sanctions in exchange for constraints on Iran’s nuclear capabilities. As of January 16, the United States lifted a number of nuclear-related sanctions on Iran, particularly the so-called “secondary sanctions” related to non-U.S. persons. With limited exceptions, U.S. persons and companies continue to be broadly prohibited from engaging in transactions with Iran, but a limited exception has been implemented to permit foreign subsidiaries of U.S. entities to do business with Iran in some circumstances. Continue reading “January 16th Marked Changes in U.S. Sanctions on Iran”

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