Ecm maritime ecm europe - 09 nov 2011

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Introduction to ECM Maritime Services, LLC ECM Maritime Services, LLC and and 09 Novembre 2011 and and ECM Europe Srl Organization & Services Organization & Services

Transcript of Ecm maritime ecm europe - 09 nov 2011

Page 1: Ecm maritime   ecm europe - 09 nov 2011

Introduction toECM Maritime Services, LLCECM Maritime Services, LLC

andandECM Europe Srl

Organization & ServicesOrganization & Services

09 Novembre 2011

Introduction toECM Maritime Services, LLCECM Maritime Services, LLC

andandECM Europe Srl

Organization & ServicesOrganization & Services

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ECM Three pillars

1. Maritime regulatory compliance

2. Emergency preparedness

3. Environmental and responsemanagement

1. Maritime regulatory compliance

2. Emergency preparedness

3. Environmental and responsemanagement

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ECM Europe’s Main Services

1. Integration of Management Systems *2. Ship Management Consultancy *3. Security Management

* From January 2012 these servicesWill be rendered with main partner

1. Integration of Management Systems *2. Ship Management Consultancy *3. Security Management

* From January 2012 these servicesWill be rendered with main partner

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ECM Japan

POLARIS / Agent in Japan

607 B's Tower, 6-2-2 Hashimoto

Midori-Ku, Sagamihara-City

252-0143 Japan

Office Locations

ECM Norwalk, Connecticut

(Headquarters)

1 Selleck Street

Suite 511

Norwalk, CT 06855

ECM Houston, Texas

11550 Fuqua StreetSuite 315Houston, TX 77034

ECM Roanoke, Virginia

3959 Electric Road SW

Suite 200

Roanoke, VA 24018

ECM Seattle, Washington

900 Winslow Way EastSuite 250Bainbridge Island, WA 98110

ECM EuropeAgent in EuropePorto Turistico di Roma

Lungomare Duca Degli Abruzzi, 872

Rome 00121 Italy

Tel: +39 06 9760 6135

Fax: +39 06 9725 6010

Email: [email protected]

ECM Roanoke, Virginia

3959 Electric Road SW

Suite 200

Roanoke, VA 24018

ECM Irvine, California

320 Goddard

Suite 100

Irvine, CA 92618

ECM Seattle, Washington

900 Winslow Way EastSuite 250Bainbridge Island, WA 98110

ECM Panama

ECM (Panama) S.A.

P.O. Box 2007

Balboa, Ancon

Panama

ECM EuropeAgent in EuropePorto Turistico di Roma

Lungomare Duca Degli Abruzzi, 872

Rome 00121 Italy

Tel: +39 06 9760 6135

Fax: +39 06 9725 6010

Email: [email protected]

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ECM EuropePorto Turistico di Roma (Lido di Ostia)

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ECM provide Response Services in USA: Qualified Individual (QI) services as required under OPA 90

and California Law Spill Management Team (SMT) services USCG, California and Alaska Certificate of Financial

Responsibility arrangements Plan Writing

USCG Tank and Nontank Plans SOPEPs SMPEPs PCSOPEPs (Panama Canal SOPEP) OSRO and SMFF Vetting and Contracting AMPD Coverage Arrangements

Full Service Maritime RegulatoryCompliance Provider

ECM provide Response Services in USA: Qualified Individual (QI) services as required under OPA 90

and California Law Spill Management Team (SMT) services USCG, California and Alaska Certificate of Financial

Responsibility arrangements Plan Writing

USCG Tank and Nontank Plans SOPEPs SMPEPs PCSOPEPs (Panama Canal SOPEP) OSRO and SMFF Vetting and Contracting AMPD Coverage Arrangements

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Additional Plan Writing California Tank and Nontank Alaska Nontank Washington VBAP and ECOPRO Ballast Water Management Plan (BWMP) Garbage Plans Security Plans (vessels and Facilities) Ship to Ship (STS) Transfer Plan All plans may be Class approved

Full Service Maritime RegulatoryCompliance Provider

Additional Plan Writing California Tank and Nontank Alaska Nontank Washington VBAP and ECOPRO Ballast Water Management Plan (BWMP) Garbage Plans Security Plans (vessels and Facilities) Ship to Ship (STS) Transfer Plan All plans may be Class approved

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Inspections/Audits Assistance with USCG COC exams in USand/or Europe

World Wide assistance with Port State Control (PSC) On Board Attendance (Port Captain) Inspections / Audits (i.e. Navigational, etc) Leading provider to US Dept of Justice Environmental Crimes

Section of Auditing Services• External Audit Group/Independent Environmental Compliance

Program Consultant• Court Appointed Monitor• Third Party Auditor• Environmental Management System Manuals• Over 40 ECP cases

Full Service Maritime RegulatoryCompliance Provider

Inspections/Audits Assistance with USCG COC exams in USand/or Europe

World Wide assistance with Port State Control (PSC) On Board Attendance (Port Captain) Inspections / Audits (i.e. Navigational, etc) Leading provider to US Dept of Justice Environmental Crimes

Section of Auditing Services• External Audit Group/Independent Environmental Compliance

Program Consultant• Court Appointed Monitor• Third Party Auditor• Environmental Management System Manuals• Over 40 ECP cases

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Drills & Exercises Quarterly QI Notification Annual SMT TTX AP Notification in Panama SMFF Annual TTX Facilitation

Training HAZWOPER Incident Command System (ICS) National Pollution Discharge

Elimination System/ Vessel GeneralPermit (NPDES/VGP)

Security Officer

Emergency Preparedness Drills & Exercises

Quarterly QI Notification Annual SMT TTX AP Notification in Panama SMFF Annual TTX Facilitation

Training HAZWOPER Incident Command System (ICS) National Pollution Discharge

Elimination System/ Vessel GeneralPermit (NPDES/VGP)

Security Officer

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Preventing Environmental Violation

The prevalence of a highly focused and punitive regime inthe U.S. against MARPOL violators is not news.

Nor is the quantum of fines and penalties (financial andregulatory) levied upon operators

This has been the case since 1999/2000, when the firstcompanies were investigated and prosecuted

The prevalence of a highly focused and punitive regime inthe U.S. against MARPOL violators is not news.

Nor is the quantum of fines and penalties (financial andregulatory) levied upon operators

This has been the case since 1999/2000, when the firstcompanies were investigated and prosecuted

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Preventing Environmental Violation

Dept. of Justice enforcement : PleaAgreement/ Environmental ComplianceProgram (ECP) cases:

2005 --- 15 ECP cases 2006 --- 6 ECP cases 2007 --- 15 ECP cases 2008 --- 14 ECP cases 2009 --- 9 ECP cases 2010 --- 7 ECP cases 2011 --- 5 ECP cases (that we are aware of)

Dept. of Justice enforcement : PleaAgreement/ Environmental ComplianceProgram (ECP) cases:

2005 --- 15 ECP cases 2006 --- 6 ECP cases 2007 --- 15 ECP cases 2008 --- 14 ECP cases 2009 --- 9 ECP cases 2010 --- 7 ECP cases 2011 --- 5 ECP cases (that we are aware of)

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Preventing Environmental Violation

Even the U.S. Department of Justice (DoJ)recently expressed surprise over thefrequency and recurrence of APPS/MARPOLviolation.

They had (logically) assumed that suchcases would die a natural death over aperiod of a few years, once the message ofenforcement spread.

Yet, news of more violations keeps oncoming…

Even the U.S. Department of Justice (DoJ)recently expressed surprise over thefrequency and recurrence of APPS/MARPOLviolation.

They had (logically) assumed that suchcases would die a natural death over aperiod of a few years, once the message ofenforcement spread.

Yet, news of more violations keeps oncoming…

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Escrow Fund established to pay for thisprogram

Vessel owner on probation with thisprogram for three (3) to five (5) years

Independent EMS Consultant retained toaudit office / all vessels

Court Appointed Monitor to be retained tosupervise Consultant

A strict Environmental ManagementSystem (EMS) to be implemented. EMSManual to be approved by USCG

General Plea Agreement Requirements

Escrow Fund established to pay for thisprogram

Vessel owner on probation with thisprogram for three (3) to five (5) years

Independent EMS Consultant retained toaudit office / all vessels

Court Appointed Monitor to be retained tosupervise Consultant

A strict Environmental ManagementSystem (EMS) to be implemented. EMSManual to be approved by USCG

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In the majority of cases, a PleaAgreement is negotiated by the lawyers

For our part, the single most importantconstituent of the Plea Agreement is theEnvironmental ComplianceProgram/Plan (ECP), in MARPOL/APPScases

General Plea Agreement Requirements

In the majority of cases, a PleaAgreement is negotiated by the lawyers

For our part, the single most importantconstituent of the Plea Agreement is theEnvironmental ComplianceProgram/Plan (ECP), in MARPOL/APPScases

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Environmental Compliance Program (ECP)

The EMS will include and address thefollowing:

environmental policy environmental requirements and voluntary

undertakings objectives and targets structure, responsibility and resources operational controls corrective, preventative action and emergency

procedures training, awareness and competence organizational decision making and planning document control continuous evaluation and improvement

The EMS will include and address thefollowing:

environmental policy environmental requirements and voluntary

undertakings objectives and targets structure, responsibility and resources operational controls corrective, preventative action and emergency

procedures training, awareness and competence organizational decision making and planning document control continuous evaluation and improvement

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The “E” in ECP no longer stands for just “Environmental” Following an allision between a container vessel and the San

Francisco Bay Bridge during 2007, a large ship managementcompany has been placed on probation under an “Enhanced”Compliance Program, after being fined $10 Million.

This “ECP” requires fleetwide and training center audits of theCompany to promote navigation safety

Preventing Environmental Violation

The “E” in ECP no longer stands for just “Environmental” Following an allision between a container vessel and the San

Francisco Bay Bridge during 2007, a large ship managementcompany has been placed on probation under an “Enhanced”Compliance Program, after being fined $10 Million.

This “ECP” requires fleetwide and training center audits of theCompany to promote navigation safety

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The upcoming scenario

31th December 2010 - Penalties for ship-source pollution arenow effective in Europe, EU Directive 2009/123/EC.

07th July 2011 - Penalties for ship-source pollution are noweffective in Italy, when the Italian Government implemented theduties imposed by above Directive. The Italian Decree 231/01 hasbeen amended accordingly.

Oct 2011 – ECM Europe launch the Voluntary EnvironmentalCompliance Program (VECP)

2012 - ?

31th December 2010 - Penalties for ship-source pollution arenow effective in Europe, EU Directive 2009/123/EC.

07th July 2011 - Penalties for ship-source pollution are noweffective in Italy, when the Italian Government implemented theduties imposed by above Directive. The Italian Decree 231/01 hasbeen amended accordingly.

Oct 2011 – ECM Europe launch the Voluntary EnvironmentalCompliance Program (VECP)

2012 - ?

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Conclusion

Shipowners should protect to the maximum possible extenttheir assets against possible violations of environmentalrequirements by ships, office and shipboard personnelparticularly in the US waters;

One single violation could lead to : criminal prosecution of crewmembers and of the Company; to serious financial losses due to fines, legal expenses,

preparation and implementation of the ECP and initial andthird part audits as established in the Plea Agreement withthe US DoJ.

Protection may be achieved by implementing the USCG“Voluntary disclosure of Marpol violations” policy and VECP.

Shipowners should protect to the maximum possible extenttheir assets against possible violations of environmentalrequirements by ships, office and shipboard personnelparticularly in the US waters;

One single violation could lead to : criminal prosecution of crewmembers and of the Company; to serious financial losses due to fines, legal expenses,

preparation and implementation of the ECP and initial andthird part audits as established in the Plea Agreement withthe US DoJ.

Protection may be achieved by implementing the USCG“Voluntary disclosure of Marpol violations” policy and VECP.

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ECM Europe’s Services

Our services acting as ECM’s EuropeanRepresentative

1. Environmental Compliance Program (ECP)2. In-office exercise based on VRP or SOPEP3. USCG Assistance

Training OPA’90 and other US Regulations NPDES Training ECP Training Incident Command System (ICS)

Our services acting as ECM’s EuropeanRepresentative

1. Environmental Compliance Program (ECP)2. In-office exercise based on VRP or SOPEP3. USCG Assistance

Training OPA’90 and other US Regulations NPDES Training ECP Training Incident Command System (ICS)

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Our Team

Managing DirectorBruno Di Lascio

ECP Team

John BalaiGeorge Papoutsoglou

Davor BakotaMauro Castagnola

Safety Team

Carlo TrombettaJohn Bussells

Brian Vanderberghe

Quality Team

Andrea MonniAlina Zawadzka

Executive Senior Coach

Alessandro Palumbo

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Lungomare Duca Degli Abruzzi, 87200121 Porto di Roma (Ostia)

RomaTel. 06.97.60.61.35Fax. 06.97.25.60.10www.ecmeurope.net

Lungomare Duca Degli Abruzzi, 87200121 Porto di Roma (Ostia)

RomaTel. 06.97.60.61.35Fax. 06.97.25.60.10www.ecmeurope.net