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Technical Alert No. 14-23 Issue Date 26 Nov 2014 TECHNICAL ALERT No.14-23 TECHNICAL ALERT No. 14-23 Page 1 of 6 Contact: [email protected] +44 20 7562 1300 Port State Control Qualship 21 1. Introduction 1.1. In recognition of ship owners who operate with a high commitment to safety and quality the United Stated Coast Guard (USCG) introduced the Quality Shipping in the Twenty First Century Program (Qualship 21) in 2001. 1.2. The Commonwealth of the Bahamas qualified for the USCG Qualship 21 Programme in 2012 and has retained Qualship 21 in the year 2014 through to June 2015. The Bahamas Maritime Authority wishes to highlight the benefits of Qualship 21 to ship owners and highlight the importance of maintaining the Qualship 21 qualification to the BMA. 1.3. This Technical Alert replaces Technical Alert 13-07, which is hereby withdrawn. 2. Qualship 21 2.1. The Qualship 21 program encourages maritime entities to participate through incentives such as certificates, name recognition and a reduction in PSC inspection frequency. Details of the Qualship 21 qualifying criteria for ships may be found in Annex 1 of this Technical Alert 1 . 1 This Technical Alert is provided by the Bahamas Maritime Authority with the aim of increasing awareness. Any queries on the content of the information provided by third parties should be referred to the party providing the information.

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Technical Alert No. 14-23

Issue Date 26 Nov 2014

TECHNICAL ALERT No.14-23

TECHNICAL ALERT No. 14-23 Page 1 of 6Contact: [email protected] +44 20 7562 1300

Port State Control – Qualship 21

1. Introduction

1.1. In recognition of ship owners who operate with a high commitment to

safety and quality the United Stated Coast Guard (USCG) introduced the

Quality Shipping in the Twenty First Century Program (Qualship 21) in

2001.

1.2. The Commonwealth of the Bahamas qualified for the USCG Qualship 21

Programme in 2012 and has retained Qualship 21 in the year 2014

through to June 2015. The Bahamas Maritime Authority wishes to

highlight the benefits of Qualship 21 to ship owners and highlight the

importance of maintaining the Qualship 21 qualification to the BMA.

1.3. This Technical Alert replaces Technical Alert 13-07, which is hereby

withdrawn.

2. Qualship 21

2.1. The Qualship 21 program encourages maritime entities to participate

through incentives such as certificates, name recognition and a

reduction in PSC inspection frequency. Details of the Qualship 21

qualifying criteria for ships may be found in Annex 1 of this Technical

Alert1.

1 This Technical Alert is provided by the Bahamas Maritime Authority with the aim of increasing awareness. Any queries on the content of

the information provided by third parties should be referred to the party providing the information.

Bahamas Maritime Authority

TECHNICAL ALERT No. 14-23 Page 2 of 6Contact: [email protected] +44 20 7562 1300

2.2. A number of owners and managers have Bahamian ships that have

qualified for Qualship 21 and these ships are already benefiting from a

reduced number of PSC inspections per year in the USA. Any companies

with Bahamian Ships that have qualified for Qualship 21 are asked to

advise the BMA.

2.3. The USCG periodically publishes a list of ship that have qualified for

Qualship 21. Based on the last USCG report (3rd February 2014), the

BMA is currently aware of the following Companies that have Bahamian

ships under their management that have qualified for Qualship 21. The

BMA wishes to congratulate these Companies on achieving their award:

Alcyon Shipping Co. Ltd.;

Bergshav Management AS;

Buena Fortuna Shipmanagement;

BW Fleet Management AS;

Campbell Shipping;

Charterwell Maritime S.A.;

Chartworld Shipping Corporation;

Chevron Shipping Co. LLC;

Chevron Transport Corp. Ltd.;

Chevron Tankers Ltd.;

Clipper Fleet Management A/S;

Dockendale Ship Management DMC Co;

Dorian LPG Ltd.;

Dorian LPG Management Corp.;

E. Nomikos Corp.;

Eide Marine Services AS;

FleetPro Ocean Inc.;

Gestmar Tehnika D.O.O.;

Grace Management S.A.;

Green Managmenet Sp. Z.o.o.;

Hoegh Fleet Services A.S.;

International Tanker Management Holding Ltd.;

KGJ Bulk Fleet Management AS;

KGJ OBO & Tankers Fleet Management AS;

Lemissoler Shipmanagement Ltd.;

Magical Cruise Company Ltd.;

Maryville Maritime Inc.;

NCL Bahamas Ltd;

Nordic Tankers Marine AS;

Nordic Tankers Marine A/S;

Salen Ship Management AB;

Samos Steamship Co.;

Bahamas Maritime Authority

TECHNICAL ALERT No. 14-23 Page 3 of 6Contact: [email protected] +44 20 7562 1300

Seatrade Groningen B.V.

SMT Shipmanagment & Transport Gdynia Ltd. Sp z.o.o.;

Stamco Ship Management Company Ltd.;

Star Reefers UK Ltd.;

Super-Eco Bulkers Management Inc.;

Teekay Shipping Limited;

Teekay Shipping Glasgow Ltd;

Thenamaris Ship Management Inc.;

Thor Dahl Shipmanagement AS;

Tide Line inc.;

Total Shipmanagement Services;

Tsakos Columbia Shipmanagmenet S.A.;

V.Ships Leisure SAM;

Valerie Ship Management LLC;

Wallem Shipmanagement Limited;

Wilhelmsen Ship Management Ltd.;

Wisby Shipmanagement AB.

2.4. In order for a ship to qualify for Qualship 21 the Flag Administration of

the ship must also qualify for Qualship 21 by fulfilling the following

criteria:

i. Not have a detention ratio greater than 1.0% and the ship’s Flag

Administration must have at least 10 distinct arrivals2 in each of the

previous 3 years.

ii. The ship’s Flag Administration must have submitted their Self-

Assessment of Flag Administration (State) Performance to the IMO

and provided a copy to the U.S. Coast Guard.

iii. The ship’s Flag Administration must submit their Executive Summary

from their Voluntary Member State Audit Scheme audit to the U.S.

Coast Guard.

2.5. Maintenance of Qualship 21 for Flag Administrations is linked to the 3

year rolling average detention ratio being no greater than 1% based on

the number of distinct arrivals versus the number of detentions3. This is

therefore a very high standard to achieve, particularly for flag

administrations with a large number of ships trading to the USA, as is

the case for The Bahamas. Therefore, the number of PSC detentions in

the USA significantly affects the ability of The Bahamas to maintain the

Qualship 21 eligibility.

2Distinct Arrival: A ship subject to the US PSC Program, which called upon at least one U.S. post during the calendar year. A ship that

called upon numerous U.S. ports in the calendar year only counts as one distinct arrival to the US PSC Program, which called upon at leastone U.S. post during the calendar year. A ship that called upon numerous U.S. ports in the calendar year only counts as one distinctarrival.3

As of 2014 the distinct arrival criteria has been revised and the ratio of number of detentions to number of inspections is used instead.

Bahamas Maritime Authority

TECHNICAL ALERT No. 14-23 Page 4 of 6Contact: [email protected] +44 20 7562 1300

3. PSC detentions in the USA

3.1. To date in 2014 there have been 7 detentions of Bahamian ships in the

USA. Any further detentions of Bahamian ships in the USA will

jeopardise the Bahamas’ Qualship 21 eligibility and therefore the ability

of Bahamian ships to achieve and maintain Qualship 21 certification will

also be jeopardised.

3.2. Investigations into all 7 detentions to date in 2014 have identified that 6

of the 7 detentions were fully avoidable and were largely attributed

to lack of maintenance, failings in the implementation of the company

Safety Management System and lack of crew training/familiarity.

3.3. In common with 2013, the most common detainable deficiencies were

inoperable Quick Closing Valves and water based local application

systems in engine rooms. Technical Alert 13-08 addresses these

particular deficiencies and the BMA’s position where such deficiencies are

identified by PSC.

3.4. Owners and Managers of Bahamian ships are urged to ensure that any

ships calling at ports in the USA are fully prepared for the possibility of a

PSC inspection by the USCG and that all lifesaving appliances, firefighting

equipment and essential equipment are tested before arrival, are in full

working order and are ready for immediate use and that crews are

adequately trained for and familiar with their duties.

4. Retention of Qualship 21

4.1. As an increasing number of owners and managers of Bahamian Ships are

benefiting from the Bahamas’ Qualship 21 qualification, it is increasingly

important to the BMA and the Board of the Bahamas Shipowners’

Association that the Bahamas retains Qualship 21. Therefore, moving

forward, the BMA aims to further improve the PSC performance of

Bahamian ships in the USA.

4.2. Where a Bahamian is subject to an IMO reportable detention by the

USCG, the detention will be fully investigated and, depending on the

outcome of the investigation, as per existing BMA policy, the ship may be

subject to a technical review for continued registration.

4.3. The applicable requirements of BMA Information Bulletin No. 120 will

also be applied to the ship and company in full.

Bahamas Maritime Authority

TECHNICAL ALERT No. 14-23 Page 5 of 6Contact: [email protected] +44 20 7562 1300

4.4. This initiative is fully endorsed by the Board of the Bahamas Shipowners’

Association.

5. Validity

5.1. This alert is valid until further notice.

6. Revision History

Rev.0 (28 November 2014) – First issue

Bahamas Maritime Authority

TECHNICAL ALERT No. 14-23 Page 6 of 6Contact: [email protected] +44 20 7562 1300

Annex 1

Qualship 21 - Frequently Asked Questions

What is QUALSHIP 21? Coast Guard efforts to eliminate substandard shipping have focused on improving methods to identify poor-quality vessels (targeting schemes). However, regardless of the score that a vessel receives in our targeting matrix, all foreign-flagged vessels are examined no less than once each year. This provides few incentives for the well run, quality ship. Hundreds, perhaps thousands, of vessels are operated responsibly, and are typically found with few or no deficiencies. Under our current policies, these vessels are boarded at similar intervals as vessels that aren’t operated responsibly. These quality vessels should be recognized and rewarded for their commitment to safety and quality. Therefore, the Coast Guard implemented an initiative to identify high-quality ships, and provide incentives to encourage quality operations. This

initiative is called Qualship 21, quality shipping for the 21st

century. Return to Page Top

What are the eligibility criteria? By closely examining Port State Control data from the previous 3 years, the characteristics of a typical "quality" vessel were identified. A quality vessel is associated with a well-run company, is classed by an organization with a quality track record, is registered with a Flag Administration with a superior Port State Control record, and has an outstanding Port State Control history in U.S. waters. Using these general criteria, approximately 10% of the foreign-flagged vessels that call in the U.S. qualify for this initiative (the specific Qualship 21 eligibility criteria is described below). Eligibility Requirements:

1. The vessel may not have been detained, and determined to be substandard, in U. S. waters within the previous 36 months;

2. The vessel may not have any marine violations, no more than 1 paid Notice of Violation cases (tickets), and no reportable marine casualties that meet the definition of a serious marine incident (46CFR4.03-2) or major marine casualty (46CFR4.40), in U.S. waters within the previous 36 months. Casualty reports of crewmember or passenger injuries that are not in conjunction with any other criteria of a serious marine incident or major marine casualty will not be considered. For the purpose of this initiative, a marine violation is any violation of a law, regulation, or order that is enforced by the Coast Guard, and results in a final assessed monetary civil penalty by a hearing officer, or a judgment by the U.S. attorney in a criminal proceeding;

3. The vessel must have completed a successful, U. S. Port State Control Safety and Environmental Protection Compliance examination within 24 months of eligibility determination. A Port State Control Safety and Environmental

Protection Compliance examination is defined as an examination of a non-U. S. flagged vessel for the purpose of assessing a vessel’s compliance with the relevant provisions of applicable international conventions, domestic laws and regulations, with a scope to the extent necessary to verify that no unsafe conditions exist. The term successful means that the vessel did not leave port with any serious, outstanding deficiencies (e.g., are considered such a serious nature that they may warrant the detention of the vessel);

4. The vessel may not be owned, operated, managed or chartered by any

company that has been associated with a substandard vessel detention in U.S. waters within 24 months. A vessel is considered to be owned, operated, managed or chartered by a company, if that company has been issued a U.S. Certificate of Financial Responsibility as the responsible operator of the vessel, and/or is listed on the vessel’s certificate of registry, and/or is the company responsible for the safe operation of the vessel as indicated on the vessel’s Safety Management Certificate and/or considered the ship manager or charterer by playing the lead role as a crew provider or chartering the majority cargo space, time or voyage;

5. The vessel may not have their statutory convention certificates issued by, a

targeted recognized organization. A recognized organization is targeted if points are assigned to them in the PSC Safety and Environmental Protection Compliance targeting matrix (refer to our Targeted Recognized Organization Page for details on the class societies that meet this criterion);

6. The vessel may not be registered with a Flag Administration that has a

detention ratio greater than or equal to 1.0%, determined on a 3-year rolling average, and the Flag Administration must have at least 10 distinct vessel arrivals in each of the last three years (refer to Flag Administration Safety Compliance Performance found in the Coast Guard’s 2013 Annual Port State Control report, for details on the Flag Administrations that meet this criterion);

7. The vessel’s Flag Administration must submit their Self-Assessment of Flag

State Performance to the IMO, and provide a copy to the Coast Guard; 8. The vessel’s Flag Administration must submit the Executive Summary from

their Voluntary Member State Audit Scheme audit to the U.S. Coast Guard or submit a letter/e-mail attesting to the fact that they have not yet undergone the audit but have submitted their request to be audited; and

9. The vessel may not be owned or operated by any company that is required by

the U.S. Department of Justice or Coast Guard to have an Environmental Compliance Plan.

10 Though not specifically mentioned in the above criteria, the Coast Guard reserves the right to restrict eligibility in the Qualship 21 initiative to any vessel because of special circumstances, including, but not limited to, significant overseas casualties or detentions, and pending criminal or civil investigations.

Return to Page Top

What incentives will Qualship 21 vessels receive? To encourage quality vessel operations, all Qualship 21 designated vessels will receive a Qualship 21 Certificate, issued by the Office of Vessel Activities (CG-CVC) staff. This certificate will have a maximum 3-year period of validity, which will correspond with the date of the COTP’s last Port State Control Safety and Environmental Protection Compliance exam of the vessel. For example, an eligible freight ship that completed a successful freight ship exam on 25 September 2014 will receive a Qualship 21 Certificate from CG-CVC that expires on 24 September 2017. Additionally, Qualship 21 vessels will have their names posted on the Qualship 21 page of the headquarters Port State Control internet web site. Qualship 21 freight ships will be eligible for a maximum of 2 years of limited Port State Control oversight. While annual exams of these vessels will be eliminated (and replaced with biennial exams), the COTP may continue to examine these ships when overriding factors are present, as described in current guidance. Qualship 21 tank ships must still be examined once a year, but the annual / "mid-period" examination of a Qualship 21 tank vessel may be reduced in scope. In general, the scope of the annual/"mid-period" examination shall be the same as for the renewal exam, but will be in less detail, unless it is determined that major changes have occurred since the last examination, or conditions warrant expanding the exam. The annual / "mid-period" examination shall be performed on these tank ships that visit U.S. waters between the tenth and fourteenth month of the period for which the Certificate of Compliance (COC) and Qualship 21 Certificates are valid. A vessel that does not visit U.S. waters, and receive an annual / "mid-period" examination, before the completion of the last day of the fourteenth month, shall receive an annual exam between the 15th and 18th month. Qualship 21 passenger vessels will not be eligible for a reduction in any Port State Control exams. While passenger vessels have an excellent safety record in the U.S., there is too much at risk to consider any changes to our passenger vessel examination policy. However, passenger vessels receiving the designation may find that it is a valuable marketing tool. Return to Page Top

Who determines which vessels will be awarded Qualship 21 designation? After receiving Qualship 21 applications from vessel owners and/or operators personnel at U.S. Coast Guard Headquarters (CG-CVC-2) will screen and process vessels for a determination of Qualship 21 eligibility. Return to Page Top

Why aren’t my vessels listed as QUALSHIP 21 vessels? Although your vessel may have an excellent examination history, there are many other criteria that must be met before a vessel will be designated as a QUALSHIP 21 vessel. One of the most common criteria vessels fail to meet requires vessels to be registered with a Flag Administration that has a detention ratio less than or equal to 1.0%, determined on a 3-year rolling average. The Flag Administration must also have submitted its International Maritime Organization Flag State Self-Assessment Form and the Executive Summary from their Voluntary Member State Audit Scheme (VMSAS) or if a Flag Administration has not undergone the audit, submittal of a letter/email attesting to this fact, with a statement that the Administration has requested the audit to the U.S. Coast Guard. Return to Page Top

How should a Qualship 21 vessel be screened by the Port State Control matrix? All vessels will continue to be screened using the PSC Safety and Environmental Protection Compliance Targeting Matrix. Qualship 21 vessels will not be assigned additional points for ship type (column V). All other overriding conditions in the targeting matrix should be considered. Return to Page Top

What criteria will cause the vessel’s Qualship 21 eligibility to be revoked? To maintain the integrity of the program, and to protect the safety of U.S. ports, a Qualship 21 vessel’s designation and incentives will be revoked when the vessel triggers the following exit criteria:

a. The vessel is detained, and determined to be substandard, in U.S. waters;

b. The vessel has a marine violation, more than 1 paid Notice of Violation case

(tickets), or a reportable marine casualty that meets the definition of a serious marine incident (46CFR4.03-2) or major marine casualty (46CFR4.40), in U.S. waters. Similar to the eligibility criteria, crewmember or passenger injuries that are not related to any other serious marine incident or major marine casualty criteria will not cause the vessel’s eligibility to be revoked. A marine violation is any violation of a law, regulation, or order that is enforced by the Coast Guard, and results in a final assessed monetary civil penalty by a hearing officer, or a judgement by the U.S. attorney in a criminal proceeding. COTPs shall notify CG-CVC-2 at [email protected] when a prima facie violation case is forwarded to the district office on a Qualship 21 vessel;

c. The vessel is found with serious deficiencies (e.g., are considered so serious

that they may warrant the detention of the vessel) that are not being monitored by the vessel’s Flag Administration or recognized organization, acting on behalf of the Flag Administration, or the vessel fails to report a hazardous condition (as defined in 33CFR160.203) prior to arrival. If the vessel is within the time limits imposed by the Flag Administration or recognized organization to correct deficiencies, the vessel will not lose eligibility for incentives;

d. The vessel transfers to a targeted recognized organization; or e. The vessel changes its registry to a Flag Administration that has a detention

ratio greater than 1.0%, determined on a 3-year rolling average, or to a Flag Administration that does not have at least 10 distinct vessel arrivals in each of the last three years;

f. The vessel's owner or operator is ordered by the U.S. Department of Justice or

Coast Guard to have an Environmental Compliance Plan. Return to Page Top

Does the vessel owner have to apply for this initiative? No. However, if vessel owners do not see their vessels on the existing Qualship 21 list found on Coast Guard Foreign & Offshore Compliance website and they believe their vessel qualifies they can apply by providing the vessel’s IMO number, last U.S. port of call with date, vessel’s name, flag and classification society. Applications are to be submitted to the following email address [email protected]. Return to Page Top

How does the vessel owner renew eligibility?

Vessel owners do not have to submit an application to renew their eligibility in the Qualship 21 initiative. However, renewal of eligibility is established under the same conditions as initial certification, including the requirement to have completed a successful, U.S. PSC Safety and Environmental Protection Compliance exam within the previous 24 months. Therefore, vessel owners are encouraged to request a PSC Safety and Environmental Protection Compliance exam from the local COTP during U.S. port visits that fall on the 35

th

or 36th

month of the term of their Qualship 21 Certificate. Return to Page Top

What are the appeals procedures? A company can submit an appeal to the U.S. Coast Guard to remain in the QUALSHIP 21 program if one of its vessels has been associated with an IMO reportable detention. An appeal request should be submitted via email to [email protected]. Return to Page Top

How do I obtain more information? The Foreign and Offshore Vessel Compliance Division (CG-CVC-2), of the Office of Commercial Vessel Compliance (CG-CVC) is managing this initiative. Please direct general questions to the Program Administrator, 202-372-1587, or CG-CVC’s public email, [email protected]. Return to Page Top

Last Updated: July 31, 2014

QUALSHIP 21

Rewarding Quality Ships QUALSHIP 21 – In our efforts to eliminate substandard shipping, the Coast Guard has primarily focused our energy on improved methods to identify poor-quality vessels (targeting schemes), and to enforce compliance with international and U.S. standards. The quality of vessels visiting U.S. ports has improved in recent years, and hundreds of vessels are typically found with few or no deficiencies. We intend to reward those high-quality ships, and provide incentives to encourage quality operations. This initiative is called QUALSHIP 21.

What is a Quality Vessel? For the purpose of Qualship 21, the initial eligibility criteria are:

• Must be a non-U.S. flagged ship. • No substandard vessel detentions in the U.S. within the previous 36 months. • No marine violations or serious marine casualties, and no more than one ticket in the U.S. within the previous 36

months. • Successful U.S. PSC Safety Exam within the previous 24 months. • Not owned or operated by any company that has been associated with any PSC detention in U.S. waters within the

previous 24 months. • Vessels cannot have their statutory convention certificates issued by, a targeted recognized organization (Targeted

recognized organizations are any that have points assigned in the U.S. Port State Control Matrix). • Not registered with a Flag Administration that has a detention ratio greater than 1.0% and the vessel’s Flag

Administration must have at least 10 distinct arrivals in each of the previous 3 years. • The vessel’s Flag Administration must have submitted their Self-Assessment of Flag Administration (State)

Performance to the IMO and provided a copy to the U.S. Coast Guard. • The vessel’s Flag Administration must submit their Executive Summary from their Voluntary Member State

Audit Scheme audit to the U.S. Coast Guard or submit a letter/email attesting to the fact that they have not yet undergone the audit but have submitted their request to be audited.

• The Coast Guard reserves the right to restrict eligibility in the QUALSHIP 21 program to any vessel because of special circumstances, including but not limited to, significant overseas casualties or detentions, and pending criminal or civil investigations.

Incentives For Quality Vessels

• All Vessels

o Qualship 21 Certificate valid for 3 years. o Vessel names posted on U.S. Coast Guard website & EQUASIS.

• Tank Vessels o Annual COC exams reduced in scope.

• Freight Vessels o Two years of limited Port State Control oversight.

• Passenger Vessels o No reduced Port State Control exams, but will receive QUALSHIP 21 certificates and recognition on the

QUALSHIP 21 web page and EQUASIS.

How Does My Vessel Qualify? Vessel owners that believe that they have ships eligible for QUALSHIP 21 designation, but do not see their vessels on the QUALSHIP 21 web page should notify the Coast Guard at the address noted on this pamphlet.

Exit Criteria A vessel will no longer be eligible for incentives during the period of the QUALSHIP 21 certificate, under the following conditions:

• The vessel is detained, and determined to be substandard, in U.S. waters. • The vessel has a marine violation, more than one unpaid ticket, or a reportable marine casualty that meets the

definition of a serious marine incident or major marine casualty. • The vessel is found with serious deficiencies (e.g., deficiencies that are considered serious enough to warrant the

detention of the vessel) that are not being monitored by the vessel’s Flag Administration or recognized organization acting on behalf of the Flag Administration, or if the vessel is found to not have reported a hazardous condition prior to arrival. If the vessel is within the time limits imposed by the Flag Administration or recognized organization to correct deficiencies, the vessel will not lose eligibility for incentives.

• The vessel transfers to a targeted recognized organization. • The vessel changes its Flag Administration to one that has a detention ratio greater than 1.0%, or to a Flag

Administration that does not have at least 10 distinct arrivals in each of the previous 3 years. • Vessel is associated with a company that is required by the U.S. Department of Justice or U.S. Coast Guard to

have and follow an Environmental Compliance Plan due to criminal prosecution or the vessel has any other pending criminal investigations.

• A company can submit an appeal to the U.S. Coast Guard (CG-5432) to remain in the QUALSHIP 21 program if it owns or operates a vessel that has been associated with an IMO reportable detention.

Renewing Eligibility

• Vessel owners do not need to submit an application to renew their eligibility. However, renewal of eligibility is

established under the same conditions as initial certification, including the requirement to have completed a successful U.S. PSC safety exam within the previous 24 months. Therefore, vessel owners are encouraged to request a PSC safety exam from the local COTP during U.S. port visits during their 35th or 36th month of the term of their QUALSHIP 21 certificate.

• When renewing eligibility, current Qualship 21 Flag States whose 3-year rolling detention ratio has gone above 1.0% will be given a one year extension, provided that their ratio is below 1.05%.

For More Information

Commandant (CG-CVC-2)

Foreign & Offshore Vessel Compliance Division 2703 Martin Luther King Jr. Ave. SE STOP 7501

Washington, DC 20593-7501

Phone: (202) 372-1587 Email: [email protected]

Website: http://www.uscg.mil/hq/cgcvc/cvc2/safety.asp

ENCLOSURE (2)