Adoption of Voluntary Environmental Compliance Program (VECP)

ECM  has recently completed an ECP-related seminar entitled “MARPOL compliance and the U.S. & E.U perspective : Investigate, Criminalize & Prosecute” at Rome in partnership with P.L. Ferrari & Co., with inputs from the UK Club and Chalos, O’Connor and Duffy, LLP and Azimuth Srl.

The seminar hosted by Confitarma (Italian Shipowner Association) was attended by executives from several Italian companies at the Managerial and Departmental Head level.

This one-day seminar was provided as an additional tool to protect to the maximum possible extent Companies’ assets against violation of environmental requirements by ship, office and shipboard personnel. Since Environmental Compliance Program (ECP) ensures the company’s compliance with environmental laws and regulations, thus avoiding, to the maximum extent possible, requests for criminal prosecution by USCG, it was agreed that ECP adoption on voluntary basis will improve financial, legal and marketing benefits for shareholders and fleet managers.

ECM continues to expand its presence in the field of Environmental Management System Compliance Plan (ECP) implementation (as mandated by the U.S. Department of Justice – DoJ), following Plea Agreements between the DoJ and companies found in violation of MARPOL/APPS.

Lately, ECM has also been appointed to serve as auditors in the execution of an “Enhanced” Compliance Plan under the ISM Code (following a serious maritime incident), to audit company procedures relating to safe navigation, loss prevention and personnel awareness & training.

Following our first involvement with such Plea Agreements during 2004, ECM’s audit teams have now worked with over 40 companies in providing EMS-related audit, review, analysis and consultancy services, either on a voluntary or government-mandated basis. Our personnel have served in all three roles specified under Plea Agreements/ECPs – as the External Audit Group (EAG), Court Appointed Monitor (CAM) and Third Party Auditor (TPA).

Some of our clientele have already undergone EMS gap analysis under the general scope of a typical Environmental Compliance Plan (ECP), and used our feedback to develop and/or upgrade their SMS/EMS to reflect the requirements of such ECPs. This in turn equips them to seek protection under the U.S. Coast Guard Voluntary Disclosure Policy, in the unfortunate event that a MARPOL/APPS violation occurs/comes to light.

For further information please contact Bruno Di Lascio at


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