Mandatory Environmental

Compliance Auditing

IMC delivers (as a Third Party Auditor or Court Appointed Monitor) environmental compliance audit services meeting Department of Justice requirements for owners/operators obliged to comply with an Environmental Compliance Program mandated by a US court.

The US law implementing the IMO’s MARPOL Annex I Code is called the Act to Prevent Pollution from Ships (APPS). Owners and operators of vessels who are convicted in US court for violating the APPS are often required to implement an Environmental Compliance Plan (ECP). Vessels owned and/or managed are monitored by court-appointed monitors, or auditors, who are typically required to ride the vessels in between ports in order to perform an in-depth inspection of the vessel’s equipment for processing oily waste while the vessel in operation. These teams must also interview and audit relevant crew members to ensure they are operating the equipment properly and possess the necessary understanding of the equipment and APPS requirements. Auditors will also review company and vessel record keeping to ensure it meets US laws and regulations.

Maintaining an ECP, which typically lasts 3-5 years, is paid for by the vessel owners and operators and can be extremely costly. Owners and operators are often required to provide the DOJ with a proposed list of 2-3 independent firms who have the knowledge and experience to conduct the monitoring and auditing process. The DOJ will select one of the firms proposed by the owners. The DOJ has a preference for auditors with marine engineering backgrounds and extensive seagoing experience and will verify that the firms proposed by the owners have the necessary resources and auditing qualifications; including ISO 14001 lead auditor certification, to perform the tasks required, as well as in-depth knowledge of applicable laws and regulations. Audit reports are sent directly to the DOJ by the Court Appointed Monitor.

Independent Maritime Consulting (IMC) has a very strong team of well qualified marine consultants, with extensive seagoing experience as chief engineers or masters on ocean going vessels. This practical experience, coupled with training and experience as ISO 14001 lead auditors, enables us to assist vessel owners and operators comply with the stringent requirements of an Environmental Compliance Program. The management of our monitoring and auditing services is in the trusted hands of a small team of professionals who have worked within the Unites States Coast Guard (USCG) in senior level positions for many decades. Their experience in the enforcement and interpretation of the MARPOL regulations is invaluable to our clients and the IMC auditing team.

IMC has served the shipping community, as an independent marine consulting firm, for two decades. The blend of team members with strong sea going and USCG backgrounds makes us uniquely qualified to work with vessel owners, operators, and the DOJ to effectively deal with the requirements of Environmental Compliance Programs.

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© 2019 by Independent Maritime Consulting LLC

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