By Dean Shoultz
The United States Coast Guard often appears behind schedule when it comes to crafting rules involving technological advancements on board ships. Often by the time the USCG gets a final rule approved for publication in the Code of Federal Regulations, the technology that that final rule was supposed to address has been replaced by a new form of technology. This is not the case, however, with electronic record keeping (electronic journals) and software as a service (SaaS).
Currently, the USCG provides the âOfficial Logbook 706-Bâ in manual form free of charge to any marine operator who requests it. The 706-B is the basic pen and ink logbook. The USCG also generally accepts “in-house” or commercially published formatted logbooks as long as the captain, journeymen, and engineers make appropriate entries. There are other commercially available pen and ink logbooks, GMDSS, Oil Record Book, Garbage Log, and Cargo Log that the USCG also accepts for inspection and recording purposes.
Many players in the towing industry have followed the progress of Subchapter M since 2004 and especially since the publication of the Notice of Proposed Regulatory Proposal (NPRM) in August 2011. However, few maritime observers have understood the The impact that the NPRM will likely have on other sub-chapters that regulate the balance of US-flagged vessels. Although it is expected that there will be differences between Subchapter M of the NPRM and the Final Rule of Subchapter M, one element that has received little attention will likely remain in the Final Rule as it is. was published in the NPRM.
The USCG has defined a towing vessel record as “a book, log or electronic record used to document the events required by this subchapter”. Of course, a towing vessel log is nothing more than a vessel’s logbook for prohibited commercial and regulatory entries. Uniquely, the NPRM Sub-M and, without a doubt, the Final Rule Sub-M allow the use of an “electronic record” to meet the same legal requirements for on-board record keeping. So, with the publication of the Sub-M Final Rule, the towing industry will have an advantage overnight that Sub-Chapters I, K, P, T and others are currently denied, authorization to use electronic record keeping on board as the primary means of daily log functions. It is clear that the USCG was forward thinking when this specific language was drafted into the Sub-M NPRM language and it should be applauded for its foresight. While it is not enough that a single segment of U.S. flagged vessels has the ability to tackle the overwhelming burden of record keeping using software solutions, it is reassuring that the USCG has introduced a such measure in the elaboration of the rules which will probably follow in the other sub-chapters.
Historically, the USCG provided the overall regulatory framework for record keeping on board ships in the Code of Federal Regulations, various NVICs, and Commanding Officer’s Instructions, but left to the shipping industry the development of detailed means on the manner of accomplishing the maintenance of regulatory and commercial registers of marine operators. requirements. From now on, with the Sub-M language, a vast and unregulated environment will exist for on-board electronic archiving solutions.
Software as a service, or SaaS, had just emerged in the general software market in 2004 when Congress passed legislation that would become Subchapter M. SaaS is a web-based or remote solution. cloud that cuts IT costs all the way. the user by contracting the deployment, maintenance and technical support of a software solution to the software developer. Since the introduction of SaaS, thousands of companies have made the transition from high-cost, high-maintenance software solutions to lower-cost SaaS solutions. Although the domestic shipping industry has been reluctant to embrace the SaaS transition due to long-standing regulatory constraints on record keeping, the push from Subchapter M regulation opens the door to SaaS to the larger segment. of the US national fleet in terms of number of ships and vessels. the operators.
The ability for shipping operators to streamline all of their on-board and ashore record-keeping processes into a single, consistent electronic solution without having to incur the ongoing expense of sophisticated IT and communications equipment or permanent IT staff has become an unexpected result of the USCG’s Sub-M regulations. Throughout rule development, the USCG has encouraged marine service providers, in this case marine software companies, to create easy-to-implement, affordable, and scalable solutions to support the Sub transition. -Mr. Major players in the marine software industry have taken the challenge to heart and the result has created a responsive market beyond the simple requirements of Sub-M electronic record keeping, but the prospect of transforming the way shipping operators are conducted. via SaaS.
While the savings and efficiencies generated by electronic logbooks and SaaS are tantalizing, shipping operators interested in hiring software companies offering these solutions should exercise caution. First, there are serious security concerns associated with the storage of regulatory and commercial electronic data that would make it almost impossible to consider any foreign maritime software vendor. Second, a qualified marine software vendor should be well versed in the details, not only of maintaining U.S. regulatory shipping records, but also of business and commercial record keeping requirements that impact internal and external business relationships. of a maritime operator. Third, reputable companies located in the United States with verifiable financial standing, sufficient and successful marine software deployments, advanced software support systems, and staff including deck officers, marine engineers, or former USCG officers under license should be preferred over foreign software vendors. . Fourth, and most importantly, a marine operator is best advised to select an experienced software partner company sensitive to the on-board dynamics created by the shift from âold schoolâ techniques to electronic record keeping. Fortunately, the savvy marine operator only has to look to Texas, Louisiana, Georgia, New York, Maryland or California to find marine software vendors experienced in electronic logbooks and SaaS. .
The USCG appears to be ahead of the technology curve when it comes to Sub-M rule-making, but the effort won’t be over until all U.S.-flagged ships have the same advantage. It’s a good start.
About the Author
Dean Shoultz is Chief Technology Officer at MarineCFO, a leading provider of marine software, including onboard software solutions, marine operations, personnel, fleet maintenance and financial management for the marine industry. maritime transport. MarineCFO solutions are scalable, from the biggest players in the industry to small family businesses. MarineCFO provides MarineCFO Enterprise, a complete behind-the-firewall solution, and Endurance, a web-on-demand solution.
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