Since the outbreak of COVID-19, several federal and local agencies have issued requirements to lessen the threat of transmitting the disease to the Lower Mississippi River maritime community. Below is a summary of what vessel interests need to know to ensure the safety of their crew and continued, uninterrupted business operations.
On March 13, United States Coast Guard issued Marine Safety Information Bulletin (MSIB) 06-20: Vessel Reporting Requirements for Illness or Death, which imposes reporting requirements for illness or death on board a vessel both to the Coast Guard and the Centers for Disease Control and Prevention (CDC). The MSIB notes that illness of a person onboard a vessel that may adversely affect the safety of a vessel or port is a hazardous condition, per 33 CFR 160.216v. The owner, agent, master, operator or person in charge must immediately notify the nearest Coast Guard Captain of the Port (COTP). It is critical to report persons who exhibit symptoms consistent with COVID-19 or other illness to the COTP.
Additionally, as required by 42 CFR 71.21, the master of a ship destined for a U.S. port shall report the occurrence on board of any death or any ill person among passengers or crew (including those who have disembarked or have been removed) during the 15-day period preceding the date of expected arrival or during the period since departure from a U.S. port (whichever period of time is shorter). This report must be made immediately at the quarantine station at or nearest the port at which the ship will arrive. Guidance and forms to report deaths and illnesses to the CDC can be found on the CDC’s website. The CDC Houston Quarantine Station, which has jurisdiction over the Mississippi River can be reached 24 hours at 281-230-3874. In addition to notifying Coast Guard and CDC, vessel interests are advised to also notify Customs and Border Control, all three local bar pilot associations and the New Orleans Board of Trade.
On March 17, the U.S. Coast Guard issued MSIB XX Issue 035 – COVID-19 Vessel Precautions
concerning precautions to be taken by vessel’s crew prior to arrival:
Further, on March 20, the Associated Branch Pilots of the Port of New Orleans published its Coronavirus Risk Management and Safety Measures Plan, which tracks the U.S.C.G. requirements. Specifically, the Bar Pilots Dispatchers one hour prior to pilot boarding are asking whether any crew member has symptoms of Coronavirus – including a fever of 100.4 degrees or greater, cough, trouble breathing or body aches – and whether the vessel has complied with Captain of The Port, New Orleans, MSIB Volume XX issue:035, COVID-19 Vessel Precautions, Dated March 17, 2020. Notably, if these procedures are not followed, pilotage services could be denied. A similar plan was developed March 22 by Crescent River Port Pilots Association.
Additional requirements when ordering pilot services came into effect on March 23 as follows:
The following procedures will be followed when ordering a pilot for shifting, berthing or sailing in all Pilot (BAR, CRPPA, NOBRA, Federal) navigational jurisdictions:
Step 1. - Vessel agent shall contact ship’s Master to confirm the following:
1.) No crew member has symptoms of Coronavirus including:
2.) The vessel has received, read, and will comply with Captain of The Port, New Orleans, MSIB Volume XX issue:035, COVID-19 Vessel Precautions, Dated March 17, 2020.
Step 2. - Vessel agent contacts Pilot dispatch and orders a pilot and informs the pilot dispatcher of the Master’s responses to Step 1 items 1). & 2).
Step 3. – Concurrent with Step 2, the agent copies (cc) the pilot dispatch on an email from the Agent to the Master confirming Master’s representation that:
Pilot Dispatch Email Addresses:
BAR Dispatch – firstname.lastname@example.org
CRPPA Dispatch – email@example.com
NOBRA Dispatch – firstname.lastname@example.org
Federal Pilots Dispatch – email@example.com
Relatedly, on March 21, Customs and Border Protection (CBP) issued Trade Notice 20-023 — CBP New Orleans, Temporary Restrictions on Crew Shore Leave. The ruling provides that maritime crew will be remanded to their vessels until further notice and that CBP will work with carriers on a case-by-case basis on temporary shore leave requests for such reasons as but not limited to humanitarian, shore side business critical to the safe operation of the vessel, legal, medical, etc.
Lastly, the U.S. Coast Guard extended the validity of Merchant Mariner Credentials (MMC), Medical Certificates (National Endorsements only) and STCW credentials set to soon expire through October, 31, 2020 and STCW medical credentials for three months past their expiration date pursuant to MSIB 08-20: Extension of Merchant Credential Endorsements and Medical Certificates.
This is a fluid situation and our Marine and Energy group will continue monitoring it to keep our clients abreast of developments.