Sorry Admiral Zukunft, You Are NOT “Clear and Unambiguous”

Rear Adm. John Nadeau, during a 2015 visit to USCG Sector Baltimore.

In the mistakenly-titled article “US Coast Guard seeks tighter grip over third parties in wake of El Faro sinking“, Rear Admiral John Nadeau, USCG assistant commandant for prevention policy, told Fairplay that “the (USCG Commandant’s) El Faro final action memo is clear and unambiguous: we have an obligation to do better oversight”.

This statement by RADM Nadeau is patently false.

Relegated to a position below twenty other recommendations, here are the words in question as written by Admiral Zukunft, USCG. Read them and tell me if they are “clear and unambiguous”.

“Safety Recommendation #21

…the Coast Guard must maintain adequate oversight of all delegated functions, including those SMS verification functions that have been delegated to an RO. However, rather than arbitrarily increasing oversight frequency, the frequency of Coast Guard attendance at SMS verifications will be risk based and data-driven. The Coast Guard will enhance its data systems, develop an SMS oversight policy, refine internal risk models, and establish key performance indicators. These indicators will be used to direct additional oversight of ACS performance. In addition, as described in the RO Code, the Coast Guard will establish a process to conduct Vertical Contract Audits to ensure proper execution of delegated functions.”

Today, gCaptain shared these words with experienced college and high school professors and asked them to grade Admiral Zukunft’s statement on the basis of clarity. The highest grade Admiral Zukunft received was C-.

When asked what “a process to conduct Vertical Contract Audits to ensure proper execution of delegated functions” means, neither these educators nor a small panel of master mariners we polled could formulate a clear answer.

gCaptain took the opportunity to ask educators to grade another statement published by the USCG… The recommendations from the Marine Electric casualty report which states:

“RECOMMENDATION #1
The examination of U.S. Merchant Vessels to assure their compliance with Federal Safety Statutes and regulations be conducted by knowledgable members of a U.S. Government Agency. The responsibilities for these functions shall not be delegated or entrusted to the private sector.”

The grades given by our panel of experts ranged between “A” and “A+”. Further, every one of the Master Mariners we called said they understood this statement published by USCG investigators 33 years ago. A safety recommendation written in the blood of lost mariners and one that has been ignored by the USCG since the creation of the Alternative Compliance Program.

Admiral Zukunft and Rear Admiral John Nadeau. If you would like to publish highly obfuscated statements that are anything but clear and unambiguous, then that is your prerogative, just like it is our 1st Amendment right to call bullshit. 

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