The Role of the Compliance Manger in the Voluntary Environmental Compliance Program (VECP)
Recently, ECM has issued in Europe the so called “Voluntary Environmental Compliance Program” (VECP) Project.
VECP is an operational standard that specifies requirements for an environmental management system to enable a shipping company to prevent, detect and correct environmental violations under applicable international flag state, port state and coastal state law, and the United State laws including, but not limited to, the international Convention for Prevention of Pollution from Ships (MARPOL), and all U.S. Federal and State statutes and regulations including, but not limited to the Ports and Water Safety Act (PWSA), the Act to Prevent Pollution from Ships (APPS), the Clean Water Act (CWA) and the Oil Pollution Act (OPA 90) and the EU Directive 2009/123/EC.
The organization who voluntary adopt the VECP in its organization, should designate a senior officer as the Compliance Manager (hereinafter “CM”) who should report directly to the Chief Executive Officer (CEO) and Board of Directors of the organization.
The CM position must be filled by an individual with significant maritime vessel operational background, who possesses the authority to ensure full implementation of the VECP, and who is thoroughly familiar with the requirements of the VECP, domestic and international maritime environmental laws and regulations.
The CM should be authorized to access all records, documents and facilities and vessels throughout the organization for the purpose of implementing if the VECP.
The organization my appoint the Company’s DPA to serve as the CM.
This includes oversight of compliance with the VECP as implemented by organization staff. The CM should ensure that internal audits are carried out by internal qualified auditor or other qualified auditor.
The CM should be responsible for ensuring that observations and any recommendations resulting from any audit under the VECP are appropriately documented, tracked, and resolved and that such resolutions are thoroughly documented in a format that can be readily audited. This documentation should be made available to any personnel performing audit functions under the VECP and to the external Authorities.
The CM is responsible for annually certifying in writing the adequacy of vessel operating budgets, including costs related to operation, maintenance and repair of pollution prevention equipment, use of shore side reception facilities, labour costs relating to maintenance of machinery spaces and other related costs necessary to meet the objectives of the VECP.
The certification should include a narrative summary in the aforementioned areas and explain the analysis used to determine if such budgets are adequate or not.
The CM should make periodical reports to the organization’s CEO concerning compliance with and implementation of the VECP and other maritime environmental protection requirements. Annually, the CM should provide a summary of the reports to the organization’s Board of Directors. All issues of non-compliance will be communicated, along with any corrective action taken.
The CM should be the responsible to maintain an “open reporting system”.
The CM should be responsible for developing a comprehensive budget process to ensure on an annual basis that each vessel is provided with adequate funding for shore side disposal of wastes, including bilge water, slops, sludge disposal, the minimization and management of waste streams, the maintenance and technical upgrades of environmental equipment and funding necessary to meet all the other requirements of this plan. Budgets should account for bilge water, slop and sludge disposal and include a documented methodology on the determination of quantities estimated to be sent ashore and or processed by the vessel.
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