Maintaining safety in tankers
The proposal before CAP in November 2016 seeks to bring this scheme in as a licence condition. We are not supportive of this approach or process. Our views are that the benefits of this approach have yet to be demonstrated and that proper process should be followed in order to do so.
There have been considerable discussions in recent times around the concerns expressed by NSW EPA as to safety issues with some tankers. EPA NSW has developed a draft inspection procedure and an inspection protocol, to be conducted by people designated as “suitably competent persons” (SCP’s). The NBTA has participated in this process but has not reached a final position as to supporting the initiative.
Whilst NBTA is supportive of the need to maintain the safety of all tankers at all times it has sought an assurance that this process be nationally consistent and in line with the current ADG Code and AS2809 standard.
At a meeting held on 14 September 2016 at Eastern Creek between EPA NSW and a range of potential SCP’s and NBTA tanker operator members, NSW EPA were asked for an assurance that should they diverge from the Code or Standard that they would follow established regulatory process. The NBTA believes that EPA NSW gave that undertaking at that meeting. We also believe that Senior Management at the NSW EPA has also given this undertaking to the NSW Government’s Better Regulation Office.
To not follow this path is in our view an abuse of process and not within CAP powers.
At present the inspection procedures and the SCP scheme lack definition and also are inconsistent with the Code and Standard. For those reasons we wish to register our opposition to CAP adopting a licence condition approach to this issue at this time.
For more information contact:
Rob Perkins, Executive Director, National Bulk Tanker Association Inc.
Tel 0411 402 832, firstname.lastname@example.org