1. Introduction to
ECM Maritime Services, LLC
and
ECM Europe Srl
Organization & Services
09 Novembre 2011

2. ECM Three pillars
1. Maritime regulatory compliance
2. Emergency preparedness
3. Environmental and response
management

3. ECM Europe’s Main Services
1. Integration of Management Systems *
2. Ship Management Consultancy *
3. Security Management
* From January 2012 these services
Will be rendered with main partner

4. Office Locations
ECM Norwalk, Connecticut ECM Houston, Texas ECM Japan
(Headquarters) 11550 Fuqua Street POLARIS / Agent in Japan
Suite 315
1 Selleck Street Houston, TX 77034 607 B's Tower, 6-2-2 Hashimoto
Suite 511 Midori-Ku, Sagamihara-City
Norwalk, CT 06855 252-0143 Japan
ECM Seattle, Washington ECM Roanoke, Virginia
900 Winslow Way East 3959 Electric Road SW ECM Europe
Suite 250
Suite 200 Agent in Europe
Bainbridge Island, WA 98110
Roanoke, VA 24018 Porto Turistico di Roma
Lungomare Duca Degli Abruzzi, 872
ECM Panama Rome 00121 Italy
ECM Irvine, California
ECM (Panama) S.A. Tel: +39 06 9760 6135
320 Goddard
P.O. Box 2007 Fax: +39 06 9725 6010
Suite 100 Email: bruno.dilascio@ecmeurope.net
Balboa, Ancon
Irvine, CA 92618
Panama

5. ECM Europe
Porto Turistico di Roma (Lido di Ostia)

6. Full Service Maritime Regulatory
Compliance Provider
ECM provide Response Services in USA:
 Qualified Individual (QI) services as required under OPA 90
and California Law
 Spill Management Team (SMT) services
 USCG, California and Alaska Certificate of Financial
Responsibility arrangements
 Plan Writing
 USCG Tank and Nontank Plans
 SOPEPs
 SMPEPs
 PCSOPEPs (Panama Canal SOPEP)
 OSRO and SMFF Vetting and Contracting
 AMPD Coverage Arrangements

7. Full Service Maritime Regulatory
Compliance Provider
 Additional Plan Writing
 California Tank and Nontank
 Alaska Nontank
 Washington VBAP and ECOPRO
 Ballast Water Management Plan (BWMP)
 Garbage Plans
 Security Plans (vessels and Facilities)
 Ship to Ship (STS) Transfer Plan
 All plans may be Class approved

8. Full Service Maritime Regulatory
Compliance Provider
 Inspections/Audits Assistance with USCG COC exams in US
and/or Europe
 World Wide assistance with Port State Control (PSC)
 On Board Attendance (Port Captain)
 Inspections / Audits (i.e. Navigational, etc)
 Leading provider to US Dept of Justice Environmental Crimes
Section of Auditing Services
• External Audit Group/Independent Environmental Compliance
Program Consultant
• Court Appointed Monitor
• Third Party Auditor
• Environmental Management System Manuals
• Over 40 ECP cases

9. Emergency Preparedness
 Drills & Exercises
 Quarterly QI Notification
 Annual SMT TTX
 AP Notification in Panama
 SMFF Annual TTX Facilitation
 Training
 HAZWOPER
 Incident Command System (ICS)
 National Pollution Discharge
Elimination System/ Vessel General
Permit (NPDES/VGP)
 Security Officer

10. Preventing Environmental Violation
 The prevalence of a highly focused and punitive regime in
the U.S. against MARPOL violators is not news.
 Nor is the quantum of fines and penalties (financial and
regulatory) levied upon operators
 This has been the case since 1999/2000, when the first
companies were investigated and prosecuted

11. Preventing Environmental Violation
Dept. of Justice enforcement : Plea
Agreement/ Environmental Compliance
Program (ECP) cases:
 2005 --- 15 ECP cases
 2006 --- 6 ECP cases
 2007 --- 15 ECP cases
 2008 --- 14 ECP cases
 2009 --- 9 ECP cases
 2010 --- 7 ECP cases
 2011 --- 5 ECP cases (that we are aware of)

12. Preventing Environmental Violation
 Even the U.S. Department of Justice (DoJ)
recently expressed surprise over the
frequency and recurrence of APPS/MARPOL
violation.
 They had (logically) assumed that such
cases would die a natural death over a
period of a few years, once the message of
enforcement spread.
 Yet, news of more violations keeps on
coming…

13. General Plea Agreement Requirements
 Escrow Fund established to pay for this
program
 Vessel owner on probation with this
program for three (3) to five (5) years
 Independent EMS Consultant retained to
audit office / all vessels
 Court Appointed Monitor to be retained to
supervise Consultant
 A strict Environmental Management
System (EMS) to be implemented. EMS
Manual to be approved by USCG

14. General Plea Agreement Requirements
 In the majority of cases, a Plea
Agreement is negotiated by the lawyers
 For our part, the single most important
constituent of the Plea Agreement is the
Environmental Compliance
Program/Plan (ECP), in MARPOL/APPS
cases

15. Environmental Compliance Program (ECP)
The EMS will include and address the
following:
 environmental policy
 environmental requirements and voluntary
undertakings
 objectives and targets
 structure, responsibility and resources
 operational controls
 corrective, preventative action and emergency
procedures
 training, awareness and competence
 organizational decision making and planning
 document control
 continuous evaluation and improvement

16. Preventing Environmental Violation
 The “E” in ECP no longer stands for just “Environmental”
 Following an allision between a container vessel and the San
Francisco Bay Bridge during 2007, a large ship management
company has been placed on probation under an “Enhanced”
Compliance Program, after being fined $10 Million.
 This “ECP” requires fleetwide and training center audits of the
Company to promote navigation safety

17. The upcoming scenario
 31th December 2010 - Penalties for ship-source pollution are
now effective in Europe, EU Directive 2009/123/EC.
 07th July 2011 - Penalties for ship-source pollution are now
effective in Italy, when the Italian Government implemented the
duties imposed by above Directive. The Italian Decree 231/01 has
been amended accordingly.
 Oct 2011 – ECM Europe launch the Voluntary Environmental
Compliance Program (VECP)
 2012 - ?

18. Conclusion
 Shipowners should protect to the maximum possible extent
their assets against possible violations of environmental
requirements by ships, office and shipboard personnel
particularly in the US waters;
 One single violation could lead to :
 criminal prosecution of crewmembers and of the Company;
 to serious financial losses due to fines, legal expenses,
preparation and implementation of the ECP and initial and
third part audits as established in the Plea Agreement with
the US DoJ.
 Protection may be achieved by implementing the USCG
“Voluntary disclosure of Marpol violations” policy and VECP.

19. ECM Europe’s Services
Our services acting as ECM’s European
Representative
1. Environmental Compliance Program (ECP)
2. In-office exercise based on VRP or SOPEP
3. USCG Assistance
 Training
 OPA’90 and other US Regulations
 NPDES Training
 ECP Training
 Incident Command System (ICS)

20. Our Team
Managing Director
Bruno Di Lascio
ECP Team Safety Team
Quality Team
Executive Senior Coach
John Balai Carlo Trombetta
Andrea Monni
George Papoutsoglou John Bussells Alessandro Palumbo
Alina Zawadzka
Davor Bakota Brian Vanderberghe
Mauro Castagnola

21. Lungomare Duca Degli Abruzzi, 872
00121 Porto di Roma (Ostia)
Roma
Tel. 06.97.60.61.35
Fax. 06.97.25.60.10
www.ecmeurope.net