Table of contents
- Executive summary
- 1. Introduction
- 2. Operating context
- 3. Risks and planning assumptions
- 4. Considerations
- 5. Initiatives to strengthen oversight
- 6. Oversight delivery in 2018 to 2019
- 7. Organizational contact information
- Annex A: Definitions
- Annex B: Marine Safety and Security Program oversight activities and descriptions
Executive summary
This report describes Transport Canada’s oversight activities in the Marine Safety and Security Program for the 2018 to 2019 fiscal year.
The Marine Safety and Security Program develops, administers and enforces national and international laws and policies governing marine safety and security, and the marine environment.
The Program:
- promotes safe and secure practices and procedures
- develops and maintains regulations
- conducts examinations, and upholds training standards for people in the industry
Oversight in the Marine Safety and Security context includes a variety of activities, namely:
- inspections
- audits
- follow-up to inspections
- investigations
- enforcement
- training
- outreach
Key areas for 2018 to 2019
- Updating legislation and regulations to strengthen the polluter-pay principle. This included updating the Ship-Source Pollution Fund to include fair compensation and other shipping regulations
- Continuing to develop regulations to make sure the Canadian marine transportation system stays safe, secure and efficient, and respects Canadian values
- Updating our technology to improve how we do business
1. Introduction
The Marine Safety and Security Oversight Program has a broad scope. Transport Canada defines oversight as:
“Activities that support the systematic promotion, monitoring, or enforcement with Transport Canada requirements governing safety or security and that contribute to departmental strategic outcomes”.
We oversee the regulatory requirements for four programs: Marine Safety, Marine Security, Clean Air and Clean Water. For a list of general oversight activities and definitions, see Annex A.
In total, the Program has over 700 full-time employees, 350 of which are designated inspectors who do inspections and audits. They also help with management and quality control, act as technical experts, and complete training and research.
To meet our goals, we oversee five key areas:
- Vessels: control of foreign and domestic vessels
- Personnel: qualification and protection
- Infrastructure and navigation: ports and facilities
- Environment: clean air and water
- Operational systems: surveillance, incident management and enforcement
These areas help meet two of Transport Canada’s core responsibilities: a safe and secure transportation system, and a green and innovative transportation system.
Highlights of the five key oversight areas are included below. For a more detailed list of our oversight activities and descriptions, see Annex B.
Vessels: Control of foreign and domestic vessels
Under this area, we:
- register and inspect Canadian-flag vessels as per Canadian and international regulations
- make sure Canadian-flag vessels are inspected according to:
- Canadian regulations, and
- for vessels on international voyages, the appropriate international memoranda, conventions and protocols that Canada ratified, adopted or acceded to, and implemented into domestic legislation
- oversee manufacturers and importers to make sure vessels follow construction requirements
- license vessels used for pleasure (non-passenger), and give recreational boaters information on regulations, equipment, publications, licensing and courses
- check inflatable survival equipment to make sure it meets standards, and accredit service providers for life-saving equipment
Personnel: Qualification and protection
Under this area, we:
- issue marine medical certificates and supporting letters to seafarers
- make sure anyone recruiting and placing seafarers in Canada has a valid Seafarer Recruitment and Placement Service licence
- maintain a system that makes sure Canadian seafarers comply internationally, and prevents Canadian vessels under Port State Control to be detained in foreign countries
- accredit, monitor and audit third-party organizations and businesses that deliver services to members of the public who want a Pleasure Craft Operator Card
- inspect and investigate labour standards in the marine industry, including issues in:
- marine occupational health and safety
- the Hazard Identification and Prevention Program
- applying the Canada Labour Code
Infrastructure and navigation: Ports and facilities
Under this area, we:
- oversee security-related assessments, plans and procedures
- carry out on-site security inspections of Canadian marine facilities and ports
Environment: Clean air and water
Under this area, we:
- review and inspect environmental response plans for vessels and oil-handling facilities
- inspect Canadian and foreign vessels travelling outside Great Lake waters who must follow the Ballast Water Control and Management Regulations
- test and inspect vessels to check that their bunker fuel oil follows sulphur-in-fuel oil standards
- track the number of hours flown by National Aerial Surveillance Program aircraft, and work with the Canadian Coast Guard on oil spills
Operational systems: Surveillance, incident management and enforcement
Under this area, we:
- inspect and review Canadian vessel security plans
- conduct risk-based vessel security inspections
- carry out inspections that are:
- based on risk assessments of foreign vessels
- regulatory, on-site Port State Control, International Ship and Port Facility Security inspections of foreign vessels
- conduct enforcement and investigations of safety and security requirements to force compliance
- generally, violations happen when vessels don’t follow the Canada Shipping Act, 2001, its regulations, or the Arctic Waters Pollution Prevention Act (AWPPA), such as for vessel certificates, collisions or pollution
- issue:
- letters of suspension or reinstatement
- assurances of compliance
- notices of violation
- verbal and written warnings
- notices of corrective action/safety deficiencies
- administrative monetary penalties
- detention orders
Additional oversight activities
Safety management audits
-
- These include technical inspections, and audits of industry (including classification societies) and safety management regulations
- Current Safety Management Regulations require all Canadian convention vessels to follow the International Convention for the Safety of Life at Sea of 1974 (SOLAS) Chapter IX, and meet the International Safety Management Code
- We conduct and oversee audits on a regular basis
Education, outreach and awareness
-
- We run targeted education and awareness campaigns for external stakeholders, like private industry and Indigenous groups
- This encourages others to comply with regulations, and can help us manage the risk for a specific safety or security issue
Program budget
For fiscal year 2018 to 2019, project costs for marine safety and security oversight activities were $55.1 million. Actual costs were nearly the same at $55.1 million, 100% of planned spending. This was due to all Regions and Directorates in Headquarters each spending close to their planned budgeted numbers, and in the range of 96% and 104%.
2. Operating context
As a trading nation, Canada relies on a safe, secure, and environmentally responsible marine transportation system to support sustainable economic growth. To achieve this, Canada works with other coastal nations to agree on international standards for safety, security and the environment.
Vessels and crew, whether foreign or domestic, must comply with the following laws and regulations:
- Canada Shipping Act, 2001
- Marine Transportation Security Act
- Arctic Waters Pollution Prevention Act
- international conventions likeSOLAS and International Convention for the Prevention of Pollution from Ships (MARPOL)
Canada’s domestic fleet and foreign vessels transported over $200 billion in international traded goods. There are now over 50,000 commercial vessels trading internationally, transporting every kind of cargo. The world fleet is registered in over 150 nations and crewed by over one million seafarers of almost every nationality. This affects how we regulate marine transportation in Canada.
As well, Canadian ports and harbours are vital connections to economic activity. As of December 2018, Canada had 557 port facilities, 883 fishing harbours and 127 recreational harbours.
The marine industry is always evolving as a result of:
- rapidly changing technology, shipping routes, vessel size and customization
- for example, most commercial vessels over 15 gross tonnes are custom built and vary based on use
- customization makes vessels more efficient, but they also need more oversight
- a need for more trade agreements as shipping volumes increase
- more international transportation through the Arctic
- earlier thawing and later freezing are making the ice-free open-water season longer, which means we need to invest more in infrastructure like ports, roads and rail lines
- more use and dependence on technology is increasing cyber risk in the sector
- rising demand for travel and supply to remote locations, which increases safety and security risks
- growing environmental issues
In 2018 to 2019, the Program responded to several changes in the international and domestic marine sectors. We worked hard to draft legislative amendments and regulations to make sure Canada complied with international laws and conventions of the International Maritime Organization (IMO).
Some of this work included:
Modernizing legislation and regulations to strengthen the polluter-pay principle. This included amending the Ship-Source Pollution Fund to include fair compensation and other shipping regulations.
Amending the Canada Shipping Act, 2001 which received Royal Assent in December 2018. We improved the way the Act protects marine safety and the environment by strengthening government ability to regulate marine vessels and navigation and help protect the marine environment, including endangered whale populations. The proposed amendments will revise sewage, garbage, and water and air pollution requirements to bring them in line with current International Maritime Organization (IMO) practices.
Implementing new Arctic Shipping Safety and Pollution Prevention Regulations.
Completing work on the Transportation Modernization Act, which included amendments to the Coasting Trade Act and the Canada Marine Act, and received Royal Assent May 23, 2018.
Amending the Canadian Navigable Waters Act (previously referred to as the Navigation Protection Act), which received Royal Assent on June 21, 2019. Now, a greater number of passenger vesselsmust carry an Automatic Identification System in Canadian waters. Key goals of this project are to support the protection and recovery of Southern Resident Killer Whales and other endangered species, like the North Atlantic Right Whale, and to further improve navigation safety in terms of search and rescue efforts and avoiding collisions.
Strengthening education and outreach activities with owners and operators of vessels to help them understand and follow the regulatory requirements of the Small Vessel Compliance Program and Concentrated Inspection Campaigns.
We also worked with Transport Canada’s two-year action plan to make sure we are correctly addressing the Transportation Safety Board’s watch list of issues and recommendations. For instance, commercial fishing safety, safety management and fatigue management remain issues of deep concern, and we continue to develop our regulatory framework with these in mind.
In addition to marine safety, marine security remains a key priority for the Program. As a core member of the Marine Security Operations Centres, we:
- continued to work with other federal departments and agencies to use our combined abilities and authorities to improve Canada’s marine security
- planned and conducted exercises under the Marine Emergency Response Protocol to make sure that the various departments with marine jurisdictions can coordinate responses to a significant marine event
- developed and signed a strategic arrangement for sharing maritime response information with the United Kingdom, Australia, New Zealand, and the United States as well as with States and Territories involved in the Arctic area activities and development
Finally, we improved our oversight work on a number of environmental initiatives by:
- training our inspectors on Vessel Pollution and Dangerous Chemical Regulations
- clarifying the requirements for marine diesel engines in small vessels
- working with various partners on the issues of black carbon as well as gasification (i.e. converting fossil fuels into carbon dioxide)
- proposing new regulations to reduce the chances of more non-native species arriving in Canada through ballast water
3. Risks and planning assumptions
Marine Safety and Security mainly goes two types of work: regulatory authorizations and accident-incident surveillance:
- Regulatory authorizations: We run certification activities that allow Canadian vessel owners, seafarers, shippers, ports and marine facilities to operate. Most of these certifications have fixed schedules and are cyclical. These activities are driven by stakeholder requests for service and many of the marine safety authorizations also have fees and service standards.
- Accident-incident surveillance and follow-up: This also represents a significant operational role for the Program. For example, many resources were devoted to protecting whales in 2018 to 2019, as is the case with other sensitive incidents. After examining the National Situation Centre (SitCen) data to better understand and measure impacts, we found that 50% of all National SitCen’s notifications to Transport Canada relate to marine transportation. A total of nearly 40 reports per day.
Over the past 10 years, carrying out conducting regulatory authorizations has spent more and more of the Program’s budget. As about 90% of our budget is slated for regulatory oversight, a smaller part of our resources are left for risk-based oversight activities. This poses a challenge to how well we can follow a risk-based method when distributing planning and resource.
As per the 2018 to 2019 oversight activities (Figure 1), the majority of our efforts were dedicated to regulatory authorizations (81%), and 18% of oversight activities were focused on reactive and planned risk-based activities and others, like enforcement.
We are developing a new risk assessment method that also makes it easier to make comparisons across transportation modes. It also helps identify and use cost-effective data collection and analysis methods to strengthen risk assessment processes.
4. Considerations
We must always consider different operating environments and geography in regions across Canada. For example: eastern and northern operations must adjust their activities to respond to extreme weather conditions and seasonal changes; the Atlantic and Quebec regions continue to have a significant number of fishing vessels, whereas the Pacific region deals with higher levels of foreign vessel visits compared to any other region.
Looking ahead, there are a number of new or emerging challenges that we need to consider:
- Keeping up with innovation and evolving technologies. We need to keep up with the rapid pace of advancements in the marine industry in order to manage risks to the transportation system as well as allow us the chance to take advantage of these new technologies.
- Retaining and recruiting staff. Marine safety and security requires specific skills, expertise and knowledge to serve Canadians and the marine industry in an efficient and cost effective manner. In order to carry out our obligations, we’re always looking for innovative approaches to attract and retain employees to meet current and future organizational needs.
- Managing the use of the change/transformation agenda. We continue to looks for ways to modernize through continuous innovation focused on improving services, maximizing efficiencies, and maintaining program integrity.
5. Initiatives to strengthen oversight
Modernization initiatives
- Seafarer credentials. We updated examination questions for the Astronavigation, Navigational Safety and Instruments, and Ship Management, as well as Chart work and Pilotage Level II. Modernizing our educational resources and working with training partners and institutions to build competencies for seafarers makes sure that Canada will continue to have a world class marine workforce.
- Modernization of service fees. Transport Canada provides services to the marine transportation sector. Several services have been provided for free while other services have fees that haven’t been updated in over 20 years. These fees need to reflect the actual cost of delivering services. We continue to modernize existing fees or introduce new fees that will reduce the amount paid by taxpayers for these services. The Service Fees Act, which received Royal Assent on June 22, 2017, introduced a modern legislative framework that requires departments to:
- report on costs of services we deliver
- publish fee revenues
- issue fee remissions and report on them
- establish service standards and make them accessible to the public
- track and report on performance results
- adjust fees for inflation, per the Consumer Price Index
- The modernization of service fees will enable cost-effective delivery of existing or new fees for over 24 service areas in Transport Canada. The expected results include:
- Increased equity: Service fees better reflect benefits for users
- More transparency: Stakeholders and government become more aware of actual costs of delivering services
- Increased sustainability: Updated service fees help keep Transport Canada financial stable
- Greater accountability: More fee information reported to Parliament and Canadians
- Cyber-security. We worked to improve the cyber elements of the Security Assessment Program. This included building on inspector’s cyber-security competency by updating how the Security Assessment course is delivered.
- Marine personnel documentation issuance system. With approximately 15,000 medical certificates being issued to seafarers every year, the marine medicine certification process has been modernized to provide better service to seafarers. The aim is to continue making the application process straight-forward for clients, providing quality products, responding in a timely manner and improving online resources.
- Small vessel oversight. In 2017 to 2018, we received funding to increase compliance monitoring of the domestic small vessel fleet. The launch of this five-year oversight program allowed us a chance to begin on-site audits of small vessel manufacturers versus our historical practice of completing paper-based reviews. This helps align Canada with the Unites States as per Regulatory Cooperation Council commitments. We were also able to increase compliance monitoring of the small vessel fleet.
Evaluating effectiveness/efficiency of oversight strategies
- Concentrated inspection campaign. We spent time focusing on the compliance review for safety and maintenance procedures for domestic vessels. This was also a chance for us to better understand the status of the domestic fleet, which includes all vessel types including delegated vessels. As per Canada’s international commitments, we also conducted a concentrated inspection campaign on foreign vessels this year.
- Inflatable safety and survival equipment serving stations oversight. In 2018 to 2019 we carried out more compliance monitoring of approved stations. Under the regulations, vessel owners must have their life-saving appliances serviced regularly at an approved station.
Innovation solutions
- Data integrity. We continued to update our systems to improve reporting on our results, tracking emerging risks and issues, and building applications to perform trend analysis. Innovation can bring many opportunities and challenges, but we believe our systems development initiatives will improve results in the near future.
6. Oversight delivery in 2018 to 2019
As per Transport Canada’s Oversight Transparency Integration Plan, we will report the results of all oversight activities, including planned and actual results and variance explanations where needed, through the Canadian Centre on Transportation Data (CCTD).
7. Organizational contact information
We welcome your comments on this report. Please send your feedback to:
TC.MSSQuestions-QuestionsSSM.TC@tc.gc.ca.
Annex A: Definitions
Required field |
Description |
---|---|
Oversight |
How Transport Canada promotes, monitors or enforces compliance with our safety and security requirements. |
Regulatory authorizations |
Given when a regulated party (for example, a railway company or vehicle manufacturer) applies for permission to do a regulated activity, or be exempt from it. We may give permission in various forms, including a permit, licence or certification. Transport Canada does not control the number of regulatory authorizations per planning cycle. |
Inspection |
A documented, formal examination of industry compliance with Canadian transportation safety and security rules, regulations and requirements. Authorized Transport Canada officials record the results of each inspection. For the purposes of this document, audits are a type of inspection. *Includes pre-site, on-site, and post-site inspection and oversight activities. Is complete when the inspector submits an approved inspection or oversight activities report. Does not include follow-up action, quality control checks or outreach activities. |
Planned, risk-based inspections |
All inspections Transport Canada initially commits to doing in a given planning cycle. The SO3 Management Board may authorize updates as needed. *Include inspections that are announced (and expected), and those that are unannounced. Does not include:
|
Follow-up activities |
Arise from findings of an initial inspection. May include an on-site inspection, requests for more information, or enhanced monitoring.
|
Other activities |
Oversight activities that Transport Canada did not initially commit to in a planning cycle, and are not a follow-up to an inspection or audit. |
Enforcement |
Measures we use to enforce requirements and compel compliance. For example:
|
Education, outreach and awareness |
How we educate the public, and encourage people and companies to comply with the law (for example: industry conferences, air shows, training, web portal) |
Quality control |
How we make sure inspectors follow policies and procedures, and complete required documentation. Applies to an entire oversight activity, from inspection, to follow-up, to resolving non-compliance.Supervisors and managers are responsible for quality control. Each program must have:
|
Annex B: Marine Safety and Security Program oversight activities and descriptions
Oversight category / Activity name |
Description of oversight activity |
---|---|
Marine vessels: control of foreign and domestic vessels |
|
Manufacturers and Importers Compliance Program |
The Marine Safety and Security Program oversees the requirements for manufacturers and importers to make sure that vessels are built in compliance with the Canadian construction requirements, which are set in Parts 7, 8 and 9 of the Small Vessel Regulations (SVR), made pursuant to the Canada Shipping Act, 2001. |
Safe design and construction of large vessels |
Ship construction plans must be reviewed and approved according to requirements specified in several regulations including the Hull Construction Regulations, Hull Inspection Regulations, Marine Machinery Regulations, and Life Saving Equipment Regulations, all made pursuant to the Canada Shipping Act, 2001. |
Vessel registrations |
Transport Canada registers vessels in Canada as set out in Part 2 of the Canada Shipping Act, 2001 (CSA 2001). All non-pleasure vessel powered by an engine of 10hp (7.5kw) or more, or commercial river rafts in Canada, must be registered with Transport Canada’s Canadian Register of Vessels. |
Pleasure craft licensing |
The Program conducts licensing for vessels that are used for pleasure. |
Office of Boating Safety |
The Office of Boating Safety provides information to recreational boaters on regulations, equipment, publications, vessel licensing and courses. |
Small vessel oversight |
The Small Vessel Compliance Program (SVCP) is an optional program that provides an easy-to-use tool to help meet all legal requirements to operate small non-pleasure vessels. While enrolment in the program is voluntary, compliance with the regulations is mandatory. |
Flag state certification by TC (including delegated statutory inspection program enrolments, exemptions and ship radio inspections) |
All large commercial marine vessels of 24 metres and above must be inspected and certified which is done through the Delegated Statutory Inspection Program (DSIP). Third-party organizations, known as “recognized organizations” conduct the inspections under the authority of Transport Canada. |
Flag state compliance monitoring (TC-certificated and delegated vessels) |
Flag State Control is responsible for ensuring that Canadian-flag vessels are inspected in accordance with both Canadian regulations and, for vessels on international voyages, the appropriate international memoranda, conventions and protocols. It is also responsible for taking all steps to make sure that, from a point of view of safety of life and environmental protection, a Canadian ship is fit for the service intended. |
Safety equipment oversight |
The Program carries out compliance monitoring for inflatable survival equipment, including prototype approvals, as well as the monitoring and accreditation of service providers for life saving equipment. |
Recognized organization (classification society) oversight |
A recognized organization is a classification society that has an authorization agreement with Transport Canada. The Canada Shipping Act, 2001 provides Transport Canada to authorize classification societies or other organizations to issue Canadian maritime documents. As part of this approach, the Program monitors and audits these organizations on a regular basis. |
Foreign vessel safety oversight: Port State Control and tanker inspections |
Port State Control (PSC) is a ship inspection program where foreign vessels entering a sovereign State’s waters are boarded and inspected. This makes sure that compliance with various major international maritime conventions is done. |
Cargo oversight: Port Warden and dangerous goods |
The Program inspects cargo vessel loading processes, including:
|
Marine insurance liability certificates |
The Program tracks and issues marine pollution insurance liability certificates. These include:
|
Marine personnel: qualification and protection |
|
Marine Medical Program |
The Program issues marine medical certificates and supporting letters to seafarers who have applied, and who are fit for sea service (with or without limitations) or are unfit, in accordance with Marine Personnel Regulations. |
Seafarer examinations, certifications and services |
The Program develops and maintains regulations, examinations and training standards for the certification of seafarers. It also issues certificates of competency to seafarers after they successfully complete all prerequisites and examinations for the level of certification. |
Recruitment and placement agencies, marine training institutions |
As a result of being signatory to the International Maritime Organization’s International Convention on Standards of Training, Certification and Watch-keeping for Seafarers, 1978 Convention, the Program is required to use a quality assurance system for the certification and training of Canadian seafarers. We must implement this system in order to make sure Canadian seafarers internationally comply, and to prevent detentions of Canadian vessels under Port State Control in foreign countries. |
Pleasure Craft Operator Competency Program |
The Program accredits and monitors third party organizations and businesses, which deliver services to the public so they can obtain their Pleasure Craft Operator Card (PCOC). |
Maritime labour standards (including Canada Labour Code, Maritime Occupational Health and Safety inspections) |
The Program carries out inspections and investigations of labour standards in the marine industry. This includes Marine Occupational Health and Safety (MOHS), the Hazard Identification and Prevention Program (HIPP) and the application of the Canadian Labour Code. |
Marine infrastructure and navigation: ports and facilities |
|
Ports and marine facility security certification |
The Program assesses security, procedures and plans approved for a Canadian Marine Facility or an Occasional Use Marine Facility (OUMF). |
Ports and marine facility security compliance monitoring |
The Program conducts on-site inspections and monitoring of Canadian Marine Facilities, Ports and Occasional Use Marine Facilities (OUMF). |
Technical Review Process of Marine Terminal Systems and Transshipment Sites (TERMPOL) review (non-OPP) |
The Program oversees the cost-recovered technical review of:
|
Protection of the marine environment from the impacts of navigation and shipping activities |
|
Oil handling facility oversight |
Under the Canada Shipping Act, 2001, the Response Organizations and Oil Handling Facilities Regulations outline the procedures, equipment and resources of response organizations and oil handling facilities for use in respect of an oil pollution incident. The Program reviews and inspects Oil Handling Facilities (OHF) plans for regulatory compliance. |
Ballast Water Program |
Every vessel entering waters under Canada’s jurisdiction must manage its ballast water properly. Discharging ballast water properly prevents non-native bacteria, plants and animal species from being released into Canada’s waters. As per the Canada Shipping Act, 2001, the Program inspects Canadian and foreign vessels (travelling outside the Great-Lakes waters) subject to the Ballast Water Control and Management Regulations. |
Environmental response organization oversight |
Ships that transit Canadian waters must have a shipboard oil pollution emergency plan, as well as an arrangement with a certified response organization that would respond to a spill on the polluter’s behalf. Response organizations are certified every 3 years by Transport Canada. |
Clean air compliance monitoring |
The Program tracks reports received from vessel owners (mostly foreign-flagged), travelling to Canadian ports situated within the North American Emission Control Area (ECA), who were not able to obtain compliant fuel, or enough compliant fuel to operate for the duration of their time in the ECA. These tests are conducted by inspectors during a vessel inspection to verify that the vessel’s bunker fuel oil complies with sulphur in fuel oil standards. |
National Aerial Surveillance Program |
The Program tracks the number of hours flown by the National Aerial Surveillance Program (NASP) aircraft. Data is compiled through daily flight reporting. |
Incident management and response |
The Program:
|
Marine operational systems: surveillance, incident management and enforcement |
|
Vessel security certification Canadian flag (SOLAS and domestic ferries) |
The Program oversees:
We certify a number of activities related to requirements of the Marine Transportation Security Act and its regulations, which capture security-related international conventions and codes. |
Vessel security compliance monitoring Canadian flag (SOLAS and domestic ferries) |
The Program collaborates with industry stakeholders to make sure a common understanding of the requirements of the Marine Transportation Security Act (MTSA) and its regulations. As part of the compliance monitoring process, we inspect regulated vessels. |
Foreign vessel security compliance monitoring |
The Program inspects foreign vessels to make sure they comply with the Marine Transportation Security Act and its regulations. |
Marine safety enforcement (vessels and seafarers) |
When faced with cases of non-compliance, the Program determines the appropriate response as per Transport Canada’s enforcement policy. This makes sure the safety of vessels, their crew and passengers, and the marine environment. The Program may:
|
Marine security enforcement |
The Program has a number of enforcement tools to encourage industry to meet the requirements of the Marine Transportation Security Act and its regulations. As noted above, the Program may give verbal or written warnings, notices of corrective action, or administrative monetary penalties. |