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Dear Shiptalk Readers, Welcome to this the May 2006 edition of the Shiptalk newsletter. Please take your time to read what we have to say this month about issues affecting your everyday lives at sea and do let us know if you have an opinion or comments on any of this month’s articles or other issues that you would like to air via Shiptalk.comShiptalk.com……reading you loud and clear
SHIPTALKIMAGES.COM This month's featured image from www.shiptalkimages.com is supplied courtesy of Chris Barrows and reminds us all of our everyday lives at sea. Since launching ShiptalkImages.com in January this year more than 1000 excellent images of our industry have been uploaded to the site. ShiptalkIMAGES.com provides media companies with a helpful image resource for the design and development of online and print media projects for maritime based companies and organisations We are sure we can provide you with the image you have been looking for so not why not drop us an image enquiry at enquiries@shiptalkimages.com and we will see what we can do for you.
HEADLINE ARTICLE The fist ever Seafarer's Lotto For regular visitors to Shiptalk's family of sites you will have noticed the new banner adverts we are displaying for the first ever Seafarer's lottery. The first ever draw of this new lottery took place on Saturday 29th April at 13:00 GMT and subsequent lotteries will take place at the sam e time each week. As they say..." you have to be in it to win it!" If you click on one of the on our sites banners and play the lottery you will be indirectly helping Shiptalk to continue providing the wide range of free services we offer to our visitors. Shiptalk are an affiliate of the lottery and if you register with and play the lottery by clicking on one of our banners, we will receive a small commission on your ticket price. As is that were not incentive enough, by taking part you have the chance to win the lottery safe in the knowledge that a large percentage of your ticket revenue will be returned to seafarer charities and good causes. You don't have to be a seafarer to play, friends, family and work colleagues can all join in, so why not have a flutter today. We would like to thank you for your support. Shiptalk.com..... reading you loud and clear
CAREERS China 's Maritime Safety Administration has stated that the Chinese shipping industry is short of 13,000 high-level maritime workers. With the sector continuing to grow steps are being taken to reform the barriers to recruitment in order to fill the gap as soon as possible. Speaking at the 2006 Shenzhen International Maritime Forum, Liu Gongchen, executive director general of the administration, said that China now has at least 130,000 senior sailors out of the total pool of 500,000 seafarers. To speed up the movement to senior levels and to nurture the development of qualified sailors, the administration has set up a comprehensive education, training, examination and certification system. Each year, more than 10,000 people graduate from the country's 76 maritime colleges and institutions to become seafarers. However, the demand is increasing faster than the supply. "Every two weeks, there is a new ship completed and launched," said Li Zhonghua, an official in charge of seafarers. Realising the issues relating to seafarer supply and demand, the administration invited nearly 300 experts and scholars from home and abroad to the forum to find a solution to the problem. Though the administration has already decided to take a number of urgent measures this year. These measures include steering Engineering students who show an interest in the maritime industry towards a career at sea. In the past, only those who graduated from maritime colleges and institutions are allowed to take seafaring examinations and become sailors. So these Engineering majors can now work as seafarers as long as they receive training and pass sailor examinations. The second move is to encourage youth in rural areas, especially in western China , to work at sea. In the past, most Chinese sailors came from the eastern part of the country. "A sailor's income can raise a whole family. For the poverty-stricken western areas, it is a good opportunity to change their living conditions," said Li. This legion of newly trained sailors will be used to meet domestic demand first, and then sent as a labour export, according to Liu Gongchen. Because of the domestic shortage, there are less than 40,000 seafarers working on foreign flag vessels. Compared with the Philippines , which has 250,000 sailors working on foreign flag vessels, China has a huge potential for enlarging their labour export in this field. There are of course natural concerns about such an influx of “non traditional” labour into the shipping market, and Mr Mitropoulos, Secretary-General of the International Maritime Organization, sounded a note of caution pointing out that Chinese seafarers who seek employment opportunities abroad should bear in mind the importance of English language training. "An inability to communicate properly can undermine even the best qualified of shipboard management teams," he said. Though he could have perhaps also added that what we need are skilled seafarers, not just thousands more poorly educated officers who have been rushed through an inadequate training system to fill demand. The industry deserves the best seafarers possible, and these moves by China to rush thousands upon thousands of rural youngsters and civil engineers through the process does not appear to be a recipe for safe, secure and clean seas…
It's not just China having manning concerns, as Indian flagged ships may soon sail with foreign crew on board. In response to pleas by a number of leading Indian shipping companies the Indian Directorate General of Shipping has finally taken a decision to allow ship owners to employ foreign officers on board their vessels, after maintaining the minimum manning requirement for Indian officers. However, the DG-Shipping will be giving approval for employment of foreign officers on a ship-to-ship basis. It is understood that the DG-Shipping has sent the proposal to lift the ban on employment of foreign crew on board Indian ships to the Ministry of Shipping, which is expected to issue the necessary notification soon. The shipping industry has long been seeking the lifting of this ban, as many experienced Indian marine officers have been attracted to foreign-flagged vessels because of higher pay packets. "When aviation operators are allowed to employ foreign pilots, why cannot Indian ships employ experienced foreign hands," an industry source pointed out. According to the sources, what swung the proposal to the favour of the ship owners was the pressure mounted by the oil companies. The PSU oil companies have noted that many of the vessels that bring in their crude did not have adequate experienced hands on board. As this posed a threat to the safety of their oil cargoes, the refiners wanted the Shipping Ministry to lift the ban on employment of foreign crew to "meet the experience matrix" of the crew on board the vessels nominated by them. Shipping companies such as Great Eastern Shipping and Varun Shipping have begun to scout for experienced officers from countries with an officer surplus. According to sources, the Indian shipping industry at present faces a shortage of between 500 to 700 experienced officers. Despite the shortfall the National Union of Seafarers of India (NUSI) feels that lifting the ban on foreign officers will not provide a long-term solution to the problem of shortage of experienced manpower. " India is a labour intensive country, so how can there be shortage in manpower. The issue here is proper maritime education and training," says Mr. Abdulgani Serang, NUSI General Secretary. He feels that it was time the issue of manpower in maritime industry was examined holistically. "First, I feel that the examination system should be made more practical and student-friendly. Aspiring seafarers dread to take the exam in India , opting for other countries," he pointed out. Oh well it looks like the Chinese farmhands and mechanics may be sailing on Indian vessels in the near future…
Lest we forget that despite the glamour and fun of a life on the ocean wave many are in it for the money and The International Shipping Federation (ISF) conducts an annual survey of wages and labour costs, examining the wages of Chief Officers and Able Seamen (ABs) across the world fleet. Although only providing a broad overview of wage cost trends within the industry, it is the only survey that affords a view of the general direction in which international wage rates are moving. The ISF stress that the international nature of the shipping industry means that wage rates of seafarers need to be considered country by country and it is important to take into consideration exchange rate fluctuations of national currencies against the US dollar in which most seafarers on foreign flag vessels are paid. They also remind us of the need to compare the average seafarer's wage to the national average wage in each country in order to gain some measure of the relative value of maritime wage rates, and thus the attraction of a career at sea. The 2005 ISF wages survey covered over 108 different wage rates for officers and 90 for ratings; these applied to 32-33 different nationalities of seafarers and revealed the following:
The reports concludes that manning remains the largest core operating cost for shipowners, and that as a result it was essential to have access to multinational crews. It is important to remember that the ISF are an “owners” organisation, and the study exists to let employers view international wage trends. As such the report goes on to remind readers that despite record levels of sustained high freight rates, shipowners' costs increased across 2005, with hikes in P&I Premiums, repair and maintenance costs, changes in the lube oil market, and the increased administrative burden of ISPS. Ah the poor things… For more news on this international wage study visit www.marisec.org/isf
SAFETY The International Council of Cruise Lines (ICCL) has published its findings and response to an investigation into the March 2006 "Star Princess" blaze. As a result a number of recommendations have been made to the cruise industry in an attempt to reduce the risk of further balcony fires. While the exact cause of the fire, widely suspected to be a cigarette, has not been determined, Princess Cruises announced last week that the fire had begun on a veranda, and had spread from balcony to balcony. As a result the ICCL is urging all cruise lines to:
The ICCL recommended that cruise lines complete these tasks within three months, and should ensure that a comprehensive fire risk assessment of external areas, including accessibility for fire fighting, structural materials (particularly balcony partitions), furniture, paints, deck mats, and handrails is performed. As ever it seems that it takes a major incident to hammer home even the most basic of safety messages.
At first glance the assertions of the Egyptian parliamentary report into the sinking of the ferry “Al Salam Boccaccio 98” seemed straightforward enough…the facts laid out in black and white, blocked scuppers on the car deck caused the vessel to flood as the crew merrily doused a shipboard fire. The graphic report stated that as water sprayed by crew members built up on the deck, passengers were frantically diving down into the rising waters to pull out paper and plastic bags which were blocking the drains. At face value it looks like just another tragic tale of a poorly trained response to an incident, which escalated into a dreadful accident, leading to 1000 deaths. It seems, however that there may be more to discuss than simple onboard housekeeping, as the report goes on to claim of a “wicked collaboration” between the shipowner and Egyptian maritime authorities. The parliamentary committee report has, by implying collusion between the Egyptian Authority on Maritime Safety and shipowner, Al Salam Maritime Transport Co, scuttled the government's devious efforts to pin the blame entirely on the ferry's Master, who has not been accounted for after the casualty. In an understandable expression of fury, the report's authors have vowed to “beat with an iron fist on everyone who allowed himself (sic) to tamper with the standards, laws and rules for the sake of cheap worldly gains, even if the cost was to kill people, drowning and destroying the lives of many Egyptian families and spreading calamity and catastrophe across Egypt”. The 1970-built, 11,779 gt ferries sank on February 3 while en route from Saudi Arabia to Egypt. The shipowning company, owned by Mamdouh Ismail, a member of the upper house appointed by Mr Mubarak, was castigated on several fronts, including the use of forged documents to hide safety deficiencies, and defective and insufficient life-saving gear. Mr Ismail has steadfastly maintained his company's innocence. In a newspaper advertisement in an Egyptian newspaper, he brazenly declared the ship to have been certified as having all the necessary safety equipment by its insurer. The parliamentary committee, however, concluded that the Egyptian maritime safety authority was “aware” of the ship's shortcomings, but “colluded” with the owner to allow the ferry to operate while evading “minimum” safety requirements. The damning report highlights a number of “systemic failures”, including the government allowing Mr Ismail to leave the country before stripping him of his parliamentary immunity, a slow-moving rescue operation, where the first Egyptian ships reached the sinking site some 70 km offshore only 10 hours after the incident, and a laissez-faire attitude towards relations of victims trying to ascertain their fate. The loss of so many innocent passengers and crew is a tragedy, one that has been compounded by apparent lies, cover-ups and efforts to bury the truth at the bottom of the Red Sea.
Last month we began looking at some of the information and data sources we rely on and we looked at a couple of incidents from the CHIRP database involving VTS . This month I'd like to focus on an issue which might not appear that exciting; manuals. A large number of incidents are blamed on individuals because of their errors or unfamiliarity with equipment and/or procedures. There are undoubtedly a number of contributing factors, but let's look at the quality of the instructions seafarers are given to work with. CHIRP has received a number of reports on the subject of manuals provided with various types of equipment including; life saving appliances, deck equipment, bridge equipment and engine room equipment. Criticisms have included the manual being non-specific i.e. covering every variant of the piece of equipment instead of the “as fitted” version, poorly translated or in the wrong language and poorly structured. The reports suggest that the consequences of these failings are an increased risk of operator errors either by interpreting the manual incorrectly or failing to refer to the manual at all. CHIRP is currently working on a report into these issues and it would be premature to draw conclusions at this point, but it is possible to place this issue in some sort of context by examining what is expected from seafarers. With some exceptions e.g. dangerous cargo endorsements, seafarers are generally not “type rated” and are expected to be able to transfer from ship to ship freely and rapidly familiarise themselves with a variety of equipment types. Seafarers may have been trained on equipment in simulators that they do not encounter at sea, but are nevertheless expected to operate/maintain to a high standard. This freedom of movement and variety of equipment providers are considered essential to provide maximum flexibility and a healthy competitive market. By way of comparison, aviation employees are strictly type rated and controls are established limiting the type of equipment individuals may operate and maintain and also the range of tasks they are permitted to perform. Simulation takes place on equipment which is “as fitted/flown”. Transfer between aircraft types involves conversion training and reassessment/recertification. Where do manuals fit into all this? On the maritime side there are few requirements for documents in common formats and seafarers are likely to encounter as many different types and standards of manuals as they are equipment fit. Operating company produced manuals may also vary greatly within the constraints imposed by regulation e.g. ISM Code. In aviation a considerable amount of documentation, including the operating company's manuals, are produced to common formats, making transfer between operators and aircraft/equipment types relatively straight forward. Manuals in the standard format are part of the equipment approval/certification process. Familiarity with a manual for one type of company/aircraft is readily transferable to the next company/aircraft. Two of the questions the CHIRP report will have to consider are to what, if any, extent does this issue impact safe ship operation and whether any of the aviation practices described might benefit seafarers and reduce the reported risks of operator errors. Perhaps these, admittedly general, comments in advance of the report will encourage others to consider these issues. Certainly that is what the final CHIRP report will hope to achieve. Next month we'll continue our look at the “system” and focus on procedures and training. If you have a concern you wish to discuss in confidence, please do not hesitate to get in touch. Safe sailing, Mike Powell www.chirp.co.uk/new/default.htm
SECURITY The exiled Somali Government is in talks to secure their coast line by any means possible, whether by the US Navy or private security firms. Over the past few months the Somali's have apparently cooled on a 50 million dollar agreement with Top Cat Security, a private US based company who had signed the deal to provide security off the Somali coast, as well as setting up a formal coastguard structure. Instead of this original commercial, and expensive deal there are reports emerging that the Somali Prime Minister , Ali Mohamed Gedi has signed an agreement with the US ambassador in the Kenyan capital Nairobi to grant the US Navy permission to patrol 3,300 miles of Somali coast line to combat piracy in the area. The Prime minister added that the US would also help prepare and train the Somali coastguards and provide them with technical equipment. In addition the US Navy will deploy official reconnaissance and monitoring patrols to hunt down the pirates who have made these coasts the most dangerous maritime spot in the world. Even though the United States has been carrying out strict monitoring of the Somali coasts in cooperation with some EU countries since the beginning of 2002, it has remained unable to get close to these coasts because of the Transitional Government's objection and local fishermen's complaints of the dangers resulting from the presence of US forces and navy in their areas of operations. At this stage the US State Department denied any such deal, although it does admit that “diplomatic discussions” have been held with members of Somalia 's exiled transitional government. Pentagon and intelligence sources have stated that the Navy is already taking an active anti-piracy role in the area, as has been demonstrated in recent weeks. A broader anti-piracy strategy is in hand, they say, adding that the highest-ranking officers in the service want the Navy to “get back to its roots”, which in the early days, included fighting pirates. Understandably the sources say that in line with other successful military operations, they do not plan to announce their strategy in the press before executing the attack. So the banished government are seeking to get the US Navy to do for free what mercenaries were seeking $50 million for…with shrewd moves like that they may not be in exile for much longer.
Whatever the steps taken it seems the US Navy are urgently needed, as last month saw another frenzy of piratical activity in the region. Many of the attacks, as has become the norm, were aimed at fishing vessels, but one attack showed a more disconcerting element, with pirates targeting a product tanker. A ccording to a report from the International Maritime Bureau (IMB), a dozen heavily armed pirates hijacked the UAE-registered tanker along with 19 Filipino crew members off the coast of Somalia. "Twelve pirates armed with machine guns, AK47 rifles and side arms boarded the tanker off Mogadishu during daylight," Noel Choong, head of the IMB Piracy Reporting Centre. The tanker had earlier discharged its cargo at Mogadishu port and was hit on March 29 after leaving port. Maritime officials identified the ship as "Lin 1." and confirmed that the pirates are holding the ship off the coast of Somalia and are demanding "a huge sum of money" from the owners for its release. Choong added that as the pirates are holding the ship inside Somalia 's territorial waters, which could pose a problem, should foreign war ships want to intervene. Though this stumbling block may be removed if the rumoured agreement with the US Navy comes to pass. The IMB again urged vessels to keep at least 200km away from Somalia 's coast to avoid pirate attacks. So quite why the vessel would be so bold as to have actually ventured into an “unsafe” Somali port is a question for the owners to answer…and no doubt their insurers will have a few harsh words to say once the incident is safely concluded. Since March 15, 2005 , pirates have hit 40 ships off Somalia but many more attacks have gone unreported, the IMB added.
LEGAL A drunken Master, who caused more than £3 million of damage when his Coastguard tug ran aground off Shetland, was jailed for eight months last month - the first person to be imprisoned for a pollution offence in Scotland. Peter Leask was Master of the "Anglian Sovereign" - a vessel designed to help prevent oil spills - when his drunken actions led to the biggest pollution incident in British waters since the “Braer” disaster in Shetland 13 years ago. The grounding of the vessel led to 84 tonnes of marine diesel fuel spilling into the sea. Leask, 42, of Mossbank, Shetland, had previously admitted being more than three times the legal alcohol limit when his vessel ran aground on 3 September last year, outside Scalloway harbour. He also admitted causing pollution and refloating the ship after the collision before assessing the damage. At Lerwick Sheriff Court , Sheriff Graeme Napier said his actions had been "reckless in the extreme" and he had no option but to send him to jail. The 2,258-tonne "Anglian Sovereign" was chartered to patrol the Northern Isles by the Maritime and Coastguard Agency (MCA) in 2000 following a recommendation by Lord Donaldson's inquiry into the “Braer” oil spill. The court was told that the night before the incident, Leask had been drinking at a Scalloway bar and was driven back to the ship by the landlady, taking a carry-out of a bottle of rum, a bottle of Coke and eight cans of lager. The next morning, Leask took the tug out to sea and appeared to have started drinking again. While taking it back to port, Leask missed an alter course position into Scalloway and allowed the vessel to ram rocks off the harbour at full speed. After the crew had been airlifted off and Leask was alone on the bridge, he reversed the tug off the rocks and sailed into Scalloway harbour, merrily leaking fuel into the waterway. The subsequent clean-up cost £40,000, the vessel repairs cost £1.3 million to repair and £1.7 million went on ancillary costs related to the incident. Victoria Young, acting for Leask, described him as "a shattered man". She said: "Mr Leask is from a seafaring family who has spent a long time at sea and has a deep affection for it. He is particularly distraught at the damage he has caused to it." Mr Napier jailed Leask for four months for the drinking offence and a further four months for refloating the ship without assessing the damage. He also imposed a concurrent sentence of two months for causing the pollution. The Scottish Environment Protection Agency said Leask was the first person to receive a custodial sentence for pollution in Scotland . Graeme Henderson, its investigating officer, said: "Fuel oil can have a severe polluting effect on the marine environment and this incident could have had devastating consequences. Leask a father of four was sacked by the ship's owner, Klyne Tugs of Lowestoft, for breaking the firm's strict no-alcohol policy and has since been unemployed. His actions were also condemned by Captain Allan Marsh, an enforcement officer with the MCA, who said: "We have to reinforce the message to the maritime industry that drinking and driving is not acceptable." Councillor Iris Hawkins, of Shetland Islands Council, said: "I think it's very ironic that the vessel that we campaigned for so long to get to protect our waters from pollution was actually the one that ended up polluting around our shores, very ironic indeed and very unfortunate." Rather surprisingly a Maritime and Coastguard Agency ( Scotland ) press release at the time of the September 2005 incident stated “ The master of the vessel has done an excellent job in salvaging the vessel and bringing it into Scalloway."…hmm perhaps someone else may have had a dram or two.
Way back last October Shiptalk covered the story of the Chief Engineer of the “ MSC Elena”, who was facing up to 40 years in jail for pollution offences. So much for all the hype…the case has now reached a conclusion, and the Chief was eventually sentenced to…just two months in prison. Mani Singh, 58, of India was also sentenced by U.S. District Court Judge Patti B. Saris to pay $3,500 in fines. Singh was the chief engineer on the “ MSC Elena”, a 30,971-ton vessel which made regular trips between European ports and U.S. ports, including Boston , federal prosecutors said. The ship discharged about 40 tons of oil sludge during a five-month period in 2004 by using a specially fitted steel pipe -- dubbed the "magic pipe" by crew -- to bypass required pollution prevention equipment, federal prosecutors said. Singh pleaded guilty in December to making false statements to the Coast Guard; denying knowledge about the existence and use of the bypass equipment; obstructing justice by directing subordinates to lie; concealing evidence; and concealing the discharges in a falsified log. The company that owns the vessel pleaded guilty and agreed to pay a $10.5 million fine, the largest paid in a case involving deliberate pollution from a single vessel, and the largest criminal fine paid by a defendant in an environmental case in Massachusetts , according to the U.S. attorney's office. It seems that in light of the possible punishment available that Mr Singh got off lightly…but lest we forget the stress that the accused has gone through – months in a foreign land with the prospect of dying in a prison cell…maybe not such a light reprimand after all.
GENERAL The USCG has been very busy rounding up wrongdoers up and down the coastline of the US over the past couple of years. They have been so successful at targeting polluting vessels and their crews that the New York Environmental Crimes Investigation Team has been awarded a Coast Guard Meritorious Team Commendation. This big pat on the back has been issued for, "exceptionally meritorious service during numerous investigations of alleged violations of national and international pollution laws by crews of ocean going vessel." The award recognised 54 Coast Guard employees and three Environmental Protection Agency officials for their exhaustive investigations from September 2004 to February 2006 of nine vessels alleged to have discharged oil directly into sea without meeting Oily Water Separation (OWS) System requirements. This joint Coast Guard-EPA team successfully referred six cases for criminal prosecution to three separate Justice Department districts. As a result, two companies and six individuals pleaded guilty to discharging oil, obstructing justice and making false statements. Penalties included over $2.5 million in fines, imposition of prison terms, and community service. According to the USCG, this investigative team proved so successful that team members were invited to present best practices on boarding strategies, investigative methods and information sharing at a Coast Guard Environmental Crimes Seminar and at a joint U.S. and Canada Ship Source Pollution Seminar. "The team's superior dedication, determination, and achievement reflect great credit upon each contributing team member, and are an outstanding representation of service for the public good". Shiptalk agree that good work should be rewarded, but there has been no recognition of the fear that such investigations cause amongst seafarers, and the fact that such investigations have led to the suicide of some seafarers …surely that deserves at least a mention in amongst all this self congratulatory back slapping and "high-fiving"?
An utterly bizarre incident happened this week as a Norwegian ship rescued a man floating on a raft made of four oil drums in the waters between Norway and Denmark. The gas tanker, the "Berge Odin", was on its way from England to Sweden , and spotted the makeshift raft in the international waters off the Skagerrak . The ship lowered a rescue boat and picked him up. The man found lying on the raft claimed he'd been set adrift by another ship. "We don't know why he was lying out there in the Skagerrak , but it didn't look like a coincidence," said Anders Bang-Andersen, from the rescue coordination centre for southern Norway . "He's in good shape, but was thinly clothed, cold and exhausted, but not injured". Upon rescue the victim reportedly expressed a desire to be taken to the Swedish authorities, which led local police to suspect that he may be an asylum seeker. "It's most likely, I think, that this is an asylum case," said policeman Lars Skoglund to the Swedish daily paper, Svenska Dagbladet, "but it could also be some sort of crime since the man maintains he was dumped at sea." During a police interrogation the man, claimed to be called George Williams, and said that he wanted to make his way to New York . Though we don't think he meant on his little raft! He has thus far refused to disclose any details of how he came to be in the freezing waters, saying only that he was cast overboard from a UK ship. It is understood that he has not identified the vessel from which he was allegedly cast. The idea of a UK vessel throwing anyone overboard is a bit of a puzzler to us - but to do it in busy European shipping lanes under the watchful gaze of AIS is even more nonsensical. To be made to walk the plank is one thing but to be given planks, barrels and some twine is completely bizarre...we smell a fantastical watery fantasy. Maybe George will be taken to Hollywood before he ever gets to NYC…
The USCG “National Maritime Center” has issued a Guidance Document stating how seafarers must appear in the application photos they submit for either a merchant mariner's document or an STCW certificate. According to the document the photograph must, obviously, provide an “accurate representation” of the individual. Though apparently an applicant may wear headgear or a full beard because of religious beliefs or wear a wig or sunglasses while undergoing medical procedures. They stress though that these rules do not apply to an individual who "wishes to wear a head covering solely for vanity or personal reasons" Hmm we are still trying to think of a “personal reason” for wearing a hat…but anyway. An applicant submitting a photograph showing the applicant to be wearing headgear, a wig, sunglasses, or full beard should provide evidence demonstrating the reason why. The document can be accessed at www.uscg.mil/hq/g-m/marpers/pag/DOC011.pdf The USCG stance on offensive hairstyles, such as mullets or perms is yet to be established, though we understand that these have been accepted in the past by the German Maritime Authorities. And yes, red clown noses are right out…unless of course you've broken your funny bone.
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