5/14/2018: Marine Safety Alert – Implementing an internal reporting system may reduce risks

The Office of Investigations and Casualty Analysis issued Marine Safety Alert 05-18, “Seeking What You Don’t Know May Reduce your Risks: Consider implementing an internal reporting system,” to remind owners and operators of all commercial vessels of the importance of developing and maintaining organizational-wide internal reporting systems.

The purpose of such a reporting system is to allow vessel employees at any level to anonymously report, when desired, issues related to vessel material safety, operational safety, and environmental compliance. The reporting systems must operate with a non-retaliation policy, which explains that the organization will not retaliate against any employee who, in good faith, reports a potential violation. Reporting policy should dictate that all company officials know that any attempt at retaliation against an employee who uses the reporting system or engages in any kind of whistleblowing would result in immediate disciplinary action. Without such a policy, employees and others will likely be hesitant to report potential problems internally. This non-retaliation policy is critical if your reporting system is to be effective.

Organizational reporting systems are managed internally or by a third party. They may use email, web based, telephone hotline and other reporting methods or combinations thereof to facilitate submission of reports from a vessel or fleet. Essential to the success of such systems is employee training on the hotline process; what happens after the complaint; retaliation and its handling; when to use the hotline; and types of issues to report. Senior vessel personnel and shore side managers have to be trained on handling reports raised directly to them and on the prohibition against retaliation.

Occasionally, such reporting systems fail and are underutilized. Reasons for why such system fail are associated with the following:

• Employee lack of awareness of the resource or how to contact it
• Fear of reprisal if they use it
• A lack of faith that something will be done with a report
• Fear due to lack of understanding of the hotline process
• Preference to use management as the resource for raising issues and asking questions

The Coast Guard strongly recommends that owners and operators consider the value of implementing reporting systems recognizing that such reporting can assist them in remaining compliant with various domestic and international requirements. Reporting will allow the owner and operator to become knowledgeable of issues related vessel material safety, operational safety and environmental concerns. This additional awareness allows management control and may reduce the impact of costs associated with repairs, environmental penalties, injuries and other circumstances before they become problematic to the owner and operator.

This safety alert is provided for informational purposes only and does not relieve any domestic or international safety, operational or material requirement. Questions may be sent to HQS-PF-fldr-CG-INV@uscg.mil.

This blog is not a replacement or substitute for the formal posting of regulations and updates or existing processes for receiving formal feedback of the same. Links provided on this blog will direct the reader to official source documents, such as the Federal Register, Homeport and the Code of Federal Regulations. These documents remain the official source for regulatory information published by the Coast Guard.

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