INSIGHTS
R
ear Admiral Paul Thomas develops and maintains
policy, standards and program alignment for wa-
terways management, navigation safety, boating,
commercial vessels, ports and facilities, merchant mariner
credentialing, vessel documentation, marine casualty in-
vestigation, inspection and port state control activities. He
serves as the Assistant Commandant for Prevention Policy
overseeing three Coast Guard directorates: Inspections and
Compliance, Marine Transportation Systems, and Com-
mercial Regulations and Standards. A specialist in Marine
Safety, Security and Environmental Protection, he has
served at the Marine Safety Center in Washington, DC and
many others before that. His other tours include, among
others, service as Commanding Offi cer of USCGC CAPE
ROMAIN. He is a graduate of the US Coast Guard Acade-
my and the Massachusetts Institute of Technology. In 2005
he completed a National Security Fellowship at Harvard
University’s John F. Kennedy School of Government, and
in 2010 he served as a Senior Fellow to the Chief of Naval
Operations Strategic Studies Group. This month, he weighs
in on the entire spectrum of Coast Guard safety and regula-
tory issues. It is an exciting time in this regard, and the buck
stops at his desk. Listen in as he brings us up to speed:With the fi rst BWTS approval out of the way, how many
more are in the pipeline and is there a sense of how
soon you might be acting on additional applications?
We now have three systems with USCG Type Approval.
Two are UV and one is EC. To date, we’ve received 45 let-
ters of intent from manufacturers who plan to conduct test-ing. We understand that the independent laboratories are
currently working with several manufacturers to complete
testing and evaluation of additional systems. Based on this
ongoing activity, we anticipate that we will receive addition-
al applications for type approval throughout the upcoming
year. Vessels owners and operators should study these type
approvals carefully and fully understand the technical con-
straints associated with each. The Coast Guard recognizes
that “one size does not fi t all” for BWMS. As such, it will
take a variety of type approved systems to meet the needs of
the global fl eet. We’ll continue to work toward additional
type approvals and to provide guidance to industry on fu-
ture compliance date extension requests as appropriate.The Subchapter M towboat rules are ‘settled law’
at this point, but companies still must decide which
route that they will take to compliance. What’s your
sense on the numbers of fi rms that will opt for ‘the
Coast Guard’ option?
The Coast Guard recently issued the “Third Party Or-
ganization (TPO) Guidebook.” This document intends to
help organizations who want to provide third party services
and vessels operators considering the use of Third Parties
as a compliance strategy. We know the industry is studying
the options, but we do not know how many TPOs will en-
ter the market, or how many operators will chose the TPO
option. There are many advantages to the TPO option
over the Coast Guard option. Operators who chose the
TPO option will have much greater fl exibility with regard
to scheduling inspections, clearing defi ciencies, making re-Rear Admiral
Paul Thomas
Assistant Commandant
for Prevention Policy,United States Coast Guard
12 MN February 2017