Former Coast Guard vice commandant cites
loss of confidence in Marine Safety Program

Retired Vice Adm. James C. Card was asked to assess the Marine Safety program.

In 2007, the Coast Guard received a boatload of criticism from maritime-industry and congressional leaders who have grown impatient with the deterioration of its marine-safety function.

This year, Coast Guard officials are hearing a similar refrain from one of their own. In a 41-page report, a former Coast Guard vice commandant, retired Vice Adm. James C. Card criticized the state of the Marine Safety program. Card said fundamental changes are necessary to restore adequate strategy, leadership, staffing and organization and to make the culture more customer-oriented.

Card’s Coast Guard Marine Safety Analysis: An Independent Assessment and Suggestions for Improvement was based on more than 170 interviews of people from the industry and within the Coast Guard.

For Card, the anonymous, candid interviews exhibited a consistent theme: a breakdown of trust between the Coast Guard and America’s professional mariners.

“The relationship between the Coast Guard and maritime industry is the most strained in my memory,” Card wrote. “The industry has lost trust and confidence in the Coast Guard. … Because the industry has historically enjoyed a positive relationship with the Coast Guard, they are grieving the loss of a good partner.”

Card spent 36 years in the Coast Guard before retiring in 2000 to become a vice president at American Bureau of Shipping. Before he was vice commandant, Card served as commander of the Coast Guard’s Pacific Area and was chief of the Merchant Vessel Inspection and Documentation Division. He is now an independent maritime consultant.

Adm. Thad Allen, the current commandant, asked Card last summer to conduct a wide-ranging analysis of the Marine Safety program. In August, Allen faced stiff questions from members of Congress at a House hearing that discussed the idea of moving marine-safety functions to the Department of Transportation.

At the hearing, industry and congressional leaders expressed worry that the Coast Guard’s homeland security role is overshadowing marine-safety duties.

Card finished his analysis in November 2007. Industry representatives have some hope that the retired vice admiral’s findings will be taken seriously, because the Coast Guard publicized the report on its own Web site in January 2008.

(Go to, then click on Marine Safety.)

Even before Card’s analysis was finished, Allen wasted no time in adopting one of Card’s recommendations. Card suggested that the Coast Guard appoint a single high-level leader to oversee Marine Safety — a newly created position called “assistant commandant for marine safety, security and stewardship.” Allen named Rear Adm. Brian Salerno to that post in August.

Patrick O’Hare, with Marine Safety Detachment Massena (N.Y.), checks ballast-water salinity aboard a vessel in the St. Lawrence Seaway.

Card’s report said most industry representatives he interviewed would prefer that marine-safety functions not be moved to another agency. The Coast Guard must improve its performance, however.

“The biggest concern expressed by all those interviewed was that the Coast Guard no longer considered Marine Safety an important mission for the Coast Guard and therefore let performance and service slide,” Card wrote. “The second biggest concern was the harsh treatment that the marine industry received from the Coast Guard during routine boardings, inspections, investigations and mariner licensing evolutions.”

Card concluded that the Coast Guard, dangerously, is headed in the wrong direction compared with advances in the industry.

“The impact of the increased complexity in the maritime world makes the Coast Guard’s Marine Safety responsibilities more critical, and more difficult, than they were 10 years ago,” the retired vice admiral wrote. “Most believe that the Coast Guard Marine Safety capabilities are less than they were, which results in an ever-increasing performance gap.”

Card stressed that Coast Guard and Department of Homeland Security leaders must be made to believe that Marine Safety is important. The Coast Guard’s overall strategy should make it clear that Marine Safety is directly related to other functions, particularly Maritime Security.

Marine Safety should be integrated into the Commandant Intent Action Orders, which are part of the current effort to re-align and transform the Coast Guard for future success, Card’s report said.

“Proper Marine Safety mission execution impacts four of the seven metrics cited in the CIAO construct: save mariners, eliminate collisions, eliminate oil spills and reduce homeland security risk,” Card noted.

Industry leaders should be invited to meetings to offer their input on the strategy development, he said.

“The Coast Guard seems reluctant to embrace the concept of industry partnerships,” Card lamented. “Some Coast Guard leaders do not see working collaboratively with the industry toward common safety and security goals as important.”

Card’s didn’t mince words in emphasizing the need to bolster Marine Safety resources. “Get more people!” he exclaimed in the very first staffing recommendation. “Viable marine safety and security programs require a robust cadre of marine inspectors!” he added. Many Coast Guard personnel don’t believe that Marine Safety is a good place to gain experience that will get them promoted. Often they rotate out of the job in less than one year.

Some experts, including Allen, have suggested hiring more experienced civilians to augment the corps of Marine Safety inspectors. Card said many of the people he interviewed want more civilians only if they are “customer focused and technically knowledgeable.” He warned that it may be more difficult to hold civilians accountable than it would be to hold a military person accountable. Still, Card recommended doubling the number of civilian marine inspectors and investigators. Currently there are 46 civilian inspection and seven civilian investigator positions.

Marine Safety inspectors need more time to gain seagoing experience within the sector system, Card said. The Coast Guard should consider re-establishing training ports. The report said the Coast Guard is already preparing a formal determination of how many Marine Safety people are needed and what skills they need.

Card proposed creating a specialized team of inspectors and investigators that can travel around to handle difficult cases and train other inspectors and investigators.

The former vice commandant also recommended improving the regulatory policy process and streamlining the appeals process.

“Those appealing have every right to do so and will be treated with proper respect and will not be punished,” he vowed. “In many cases, appeals highlight poor regulations and are helpful in improving the system.”

The Coast Guard should establish a help desk to answer mariners’ questions about inspections and investigations, Card said. More training is needed to ensure that Coast Guard personnel are customer focused, he said.

“The Coast Guard’s core values of Honor, Respect and Devotion to Duty are similar to most companies’ values,” Card wrote. “So when the Coast Guard doesn’t treat their customers with honor and respect, the public is confused and angry. They expect better treatment from their public servants.

“I sense that junior Coast Guard people don’t understand the impact of their actions on professional mariners,” he said. “I sense that many senior Coast Guard people don’t care about the impact of their actions on professional mariners.”

Card urged Marine Safety personnel to revitalize the principle of “Honoring the Mariner.” He suggested following the guidance of Alexander Hamilton, who said, “Keep in mind that your countrymen are freemen and, as such, are impatient of everything that bears the least mark of a domineering spirit.”

By Professional Mariner Staff