Vessel Pollution EnforcementVessel Pollution EnforcementProblems and SolutionsProblems and Solutions

Richard A. UdellSenior Trial AttorneyEnvironmental Crimes SectionU.S. Department of Justice601 D Street, NW - #2008Washington, D.C. 20004202-305-0361Richard.Udell@usdoj.gov

INTERTANKOLatin America Panel

November 16, 2005Miami Beach, Florida

SummarySummaryCriminal Violations for Deliberate and Knowing ConductCriminal Violations for Deliberate and Knowing Conduct

Prosecutions against corporations resulting in multiProsecutions against corporations resulting in multi--million dollar (US) million dollar (US) criminal fines, restitution, and probation with court supervisedcriminal fines, restitution, and probation with court supervised environmental environmental compliance programs compliance programs -- $133 million since 1998. $133 million since 1998. Prosecution against individuals resulting in prison sentences Prosecution against individuals resulting in prison sentences –– total 18 years total 18 years since 1998.since 1998.All types of vessels (cruise, tanker, container, etc.).All types of vessels (cruise, tanker, container, etc.).Cases involve U.S. and foreign flag with deliberate discharges oCases involve U.S. and foreign flag with deliberate discharges of tons waste f tons waste oil in internal waters, territorial sea, contiguous zone, exclusoil in internal waters, territorial sea, contiguous zone, exclusive economic ive economic zone and high seas.zone and high seas.Many cases involve intentional bypassing of pollution preventionMany cases involve intentional bypassing of pollution prevention equipment, equipment, presentation of false statements to port authorities in Oil Recopresentation of false statements to port authorities in Oil Record Books and rd Books and other vessel records.other vessel records.Concealment: discharges at night, use of dispersants, tricking Concealment: discharges at night, use of dispersants, tricking of of ppm/odmeppm/odme, , falsification of soundings, triggering of alarms, secret logs.falsification of soundings, triggering of alarms, secret logs.Crimes committed for financial motive. Crimes committed for financial motive. Discharges of other pollutants in and beyond U.S. waters.Discharges of other pollutants in and beyond U.S. waters.Range of response by those under investigation from cooperation Range of response by those under investigation from cooperation to to obstruction, witness tampering, destruction of evidence, perjurobstruction, witness tampering, destruction of evidence, perjury and false y and false statements.statements.

DetectionDetection

Remote Remote sensing.sensing.Routine inspections.Routine inspections.Enhanced physical and record Enhanced physical and record inspections.inspections.Targeting.Targeting.Marine casualty investigations.Marine casualty investigations.““Mystery SpillMystery Spill”” investigations.investigations.Referrals from foreign countries. Referrals from foreign countries. Whistleblower allegations.Whistleblower allegations.

MotivesMotivesTo save money on purchasing and installing best To save money on purchasing and installing best available technology.available technology.To save money on the cost of offloading waste oil in To save money on the cost of offloading waste oil in port.port.To save money on the cost of providing adequate To save money on the cost of providing adequate staffing.staffing.To save money on the cost of OWS filters, membranes.To save money on the cost of OWS filters, membranes.To save money and time on labor and maintenance. To save money and time on labor and maintenance. Financial bonuses to Chief Engineers for keeping Financial bonuses to Chief Engineers for keeping within projected budget. within projected budget. For individuals, to maintain job in a militaryFor individuals, to maintain job in a military--like chain like chain of command.of command.

Prosecution GoalsProsecution Goals

Protection of the environment.Protection of the environment.Assuring accurate ship records Assuring accurate ship records and verbal statements to and verbal statements to authorities.authorities.Deter future criminal conduct.Deter future criminal conduct.Punishment of deliberate and Punishment of deliberate and intentional violations.intentional violations.Create an even playing field Create an even playing field where law abiding companies are where law abiding companies are not disadvantaged.not disadvantaged.

Each of these vessels was ISM certified and had passed Class, Flag and Port State inspections.

ISM, EMS, SMS, ECP ISM, EMS, SMS, ECP Lessons LearnedLessons Learned

Class, ISM, Flag State and Port State Class, ISM, Flag State and Port State certifications do not alone provide certifications do not alone provide assurance of compliance.assurance of compliance.Adequate equipment is essential Adequate equipment is essential -- IMO IMO approval of equipment does not alone approval of equipment does not alone provide assurance that equipment is provide assurance that equipment is appropriate for a given vessel.appropriate for a given vessel.Every conviction represents a failure of Every conviction represents a failure of ISM/SMS and a failure of company ISM/SMS and a failure of company management.management.Control procedures and devices alone Control procedures and devices alone cannot guarantee compliance.cannot guarantee compliance.Environmental crimes represent a Environmental crimes represent a management failure.management failure.Environmental nonEnvironmental non--compliance is usually compliance is usually an indication of other nonan indication of other non--compliance and compliance and management deficiencies. management deficiencies.

United States v. Evergreen Intl.United States v. Evergreen Intl.SummarySummary

$25 Million$25 Million$15 Million criminal fine.$15 Million criminal fine.$10 Million community service projects.$10 Million community service projects.

24 felony counts; 1 negligent discharge.24 felony counts; 1 negligent discharge.Guilty pleas in 5 ports:Guilty pleas in 5 ports:

CENTRAL DISTRICT OF CALIFORNIADISTRICT OF NEW JERSEYDISTRICT OF OREGONDISTRICT OF SOUTH CAROLINAWESTERN DISTRICT OF WASHINGTON

Environmental Compliance Plan a condition of Environmental Compliance Plan a condition of three year sentence of probation:three year sentence of probation:

Audits of ships by outside auditorAudits of ships by outside auditorCourt Monitor to review audits and planCourt Monitor to review audits and plan

Ever GivenEver Given

Ever GivenEver Given

Oily Water Separator Oil Water Separator Bypass

Ever Reward

Ever Gleeful Bypass Hose

Ever RefineEver Refine

Oil Found in Overboard Valve OWS Test Effluent

U.S. v. D/S ProgressU.S. v. D/S ProgressSummary of the ProsecutionSummary of the Prosecution

USCG inspection (March USCG inspection (March -- April 2000).April 2000).Search warrants (May 2000).Search warrants (May 2000).Arrest of Master (May 2000).Arrest of Master (May 2000).Surety bondSurety bondIndictment (June 2000) charging owner, operator, Indictment (June 2000) charging owner, operator, Master, Chief Engineer, V.P., Designated Person.Master, Chief Engineer, V.P., Designated Person.D/S Progress sentenced, individuals remain fugitives D/S Progress sentenced, individuals remain fugitives (October 2001).(October 2001).Half of $250,000 criminal fine awarded to crew Half of $250,000 criminal fine awarded to crew members under Act to Prevent Pollution from Ships members under Act to Prevent Pollution from Ships (APPS) reward provision.(APPS) reward provision.

U.S. v. D/S Progress, et al.

U.S. v. D/S Progress, et al.

To: D/S ProgressFm: Master, Freja JutlandicDt: 20/March/00

Re: Engine Room Crack

As we expect uscg control on arrival baltimore I believe they can found repairing place and leaks and can be problem. To avoid any mistake pls instruct proceeding re notification of this repairs to uscg.

Tks/brgdsCaptain Maric

U.S. v. D/S Progress, et al.

Source: Swedish Coast Guard

U.S. v. D/S Progress, et al.

Alleged DischargesAlleged Discharges250,000 gallons of oil contaminated cargo tank waste in 250,000 gallons of oil contaminated cargo tank waste in North Sea, February 26, 2000.North Sea, February 26, 2000.

3,162 gallons of oil contaminated cargo tank waste on 3,162 gallons of oil contaminated cargo tank waste on voyage to Baltimore, March 8, 2000.voyage to Baltimore, March 8, 2000.

2,000 gallons of oil contaminated cargo tank waste, 2,000 gallons of oil contaminated cargo tank waste, April 8, 2000. April 8, 2000.

25,000 gallons of fuel oil contaminated with water on 25,000 gallons of fuel oil contaminated with water on voyage to Baltimore on orders of V.P., April 18, 2000.voyage to Baltimore on orders of V.P., April 18, 2000.

U.S. v. D/S Progress, et al.

ComplianceComplianceProcedural ApproachesProcedural Approaches

Audit and analysis of all waste streams to determine Audit and analysis of all waste streams to determine content, volume, method of storage, capacity for storage, content, volume, method of storage, capacity for storage, treatment and disposal, and estimated cost. treatment and disposal, and estimated cost. Assignment of senior corporate officer as environmental Assignment of senior corporate officer as environmental manager who is empowered to take action.manager who is empowered to take action.Determine equipment and procedures necessary to Determine equipment and procedures necessary to maintain systems and account for aging.maintain systems and account for aging.Elimination and minimization of pollutants.Elimination and minimization of pollutants.Logs for recording waste streams and oil to sea interfaces.Logs for recording waste streams and oil to sea interfaces.Procedures to discourage routine use of bilge/ballast Procedures to discourage routine use of bilge/ballast crossovers and blind flanges.crossovers and blind flanges.Enhanced communication between shore management and Enhanced communication between shore management and line engineers and lower level crew members.line engineers and lower level crew members.Establish environmental component in routine shipEstablish environmental component in routine ship--board board and ISM safety meetings.and ISM safety meetings.

Procedural Approaches Procedural Approaches TrainingTraining

Use of inUse of in--house and outside training schools/centers.house and outside training schools/centers.Specific MARPOL training courses.Specific MARPOL training courses.Expert onExpert on--site training. site training. Documentation of training.Documentation of training.Formal written policy documents:Formal written policy documents:

Corporate compliance statementCorporate compliance statementOperational procedures regarding storage, treatment and disposalOperational procedures regarding storage, treatment and disposal of each of each waste stream and testing, use and maintenance of equipmentwaste stream and testing, use and maintenance of equipmentRecordkeeping and log entry requirementsRecordkeeping and log entry requirementsJob position descriptionsJob position descriptionsRewards and punishment for compliance/nonRewards and punishment for compliance/non--compliancecompliance

Training on obligation to be truthful with port state authoritieTraining on obligation to be truthful with port state authorities s and in ship records. and in ship records. Sign on/off checklists and certifications at turnover.Sign on/off checklists and certifications at turnover.Assignment of responsibility regarding waste streams.Assignment of responsibility regarding waste streams.Establishing reporting lines to master and senior corporate Establishing reporting lines to master and senior corporate officer regarding nonofficer regarding non--compliance.compliance.

Procedural ApproachesProcedural ApproachesOil Water SeparatorsOil Water Separators

Training of trainers by experts and vendors.Training of trainers by experts and vendors.Establishment and verification of Establishment and verification of maintenance schedules.maintenance schedules.Vendor or other outside audit including Vendor or other outside audit including operational tests.operational tests.Sounding logs with signed entries per watch Sounding logs with signed entries per watch and inclusion of sounding in Main Engine and inclusion of sounding in Main Engine Log.Log.Internal monitoring, including routine Internal monitoring, including routine operational testing, reconciling and operational testing, reconciling and certification of records.certification of records.Independent soundings and logging by deck Independent soundings and logging by deck department of waste tanks to be included in department of waste tanks to be included in daily position reports and Bridge Log.daily position reports and Bridge Log.Operational tests at sea with periodic Operational tests at sea with periodic certification.certification.

Procedural ApproachesProcedural ApproachesRecord KeepingRecord Keeping

Entries in sounding, ORB, garbage and incinerator logs by Entries in sounding, ORB, garbage and incinerator logs by person who performed task. Eliminate practice of having 3person who performed task. Eliminate practice of having 3rdrd

party sign entries.party sign entries.ORB examined and signed by Chief Engineer and Master.ORB examined and signed by Chief Engineer and Master.Signature lines for all those involved in overboard discharges Signature lines for all those involved in overboard discharges and operational tests.and operational tests.SignSign--on and signon and sign--off certifications (where persons responsible off certifications (where persons responsible for operation certify their awareness of company procedures for operation certify their awareness of company procedures and certify to the use and operability of the equipment at the and certify to the use and operability of the equipment at the turnover at the beginning and end of each contract)turnover at the beginning and end of each contract)Require status of pollution prevention equipment to be Require status of pollution prevention equipment to be recorded in turnover notes of responsible engineer and Chief recorded in turnover notes of responsible engineer and Chief Engineer.Engineer.Sampling and analysis of waste streams to make sure they are Sampling and analysis of waste streams to make sure they are consistent with pollution prevention technology.consistent with pollution prevention technology.

Procedural ApproachesProcedural ApproachesRole of Shore ManagersRole of Shore Managers

Assignment of responsibility to senior corporate officer, Port Assignment of responsibility to senior corporate officer, Port Engineers and Chief Engineers. Engineers and Chief Engineers. Assure adequacy of internal audits and implementation of correctAssure adequacy of internal audits and implementation of corrective ive actions. actions. Review of maintenance, log entries and turnover notes.Review of maintenance, log entries and turnover notes.Monitor workloads to make sure that crew prioritizes environmentMonitor workloads to make sure that crew prioritizes environmental al compliance.compliance.Assure adequate budget, including waste removal and spare parts.Assure adequate budget, including waste removal and spare parts.Establish comprehensive check list for internal/external Establish comprehensive check list for internal/external inspections/audits. inspections/audits. Test pollution prevention equipment with actual waste streams whTest pollution prevention equipment with actual waste streams while ile vessel is underway.vessel is underway.Communicate with all levels of the Engine Department and with Communicate with all levels of the Engine Department and with senior corporate officer to relay findings and concerns. senior corporate officer to relay findings and concerns. Explore new technologies. Explore new technologies. Designated person in charge.Designated person in charge.

Analysis of RecordsAnalysis of RecordsTracking Waste and MaintenanceTracking Waste and Maintenance

Analysis of waste Analysis of waste disposal records.disposal records.Comparison to volumes Comparison to volumes purchased.purchased.Scheduling of routine Scheduling of routine maintenance.maintenance.Removing stumbling Removing stumbling blocks and disincentives blocks and disincentives to offloading more waste to offloading more waste or purchasing additional or purchasing additional parts related to safety parts related to safety and the environment and the environment when necessary.when necessary.

0

50000

100000

150000

200000

250000

300000

350000

400000

1990 1992 1993 1994 1995 1996

Gallons Waste OilOffloaded in Port

0

5

10

15

20

1990 1992 1993 1994 1995

OWS MembranesPuchased: 4 Required forproper use.

Internal Monitoring

Analysis of RecordsAnalysis of Records

Alarm PrintoutOil Record Book vs. Bridge Log

Internal Monitoring

Analysis of RecordsAnalysis of Records

Internal Monitoring

Whistleblower CasesWhistleblower Cases“A person who knowingly violates the MARPOL Protocol, this chapter, or the regulations issued thereunder commits a class D

felony. In the discretion of the Court, an amount equal to not more than ½ of such fine may be paid to the person giving information leading to conviction.”Title 33, United States Code, Section 1908(a).

Princess Cruises Princess Cruises Regency CruisesRegency CruisesHolland AmericaHolland AmericaNCLNCLCrescent Ship ServicesCrescent Ship ServicesD/S ProgressD/S ProgressOMIOMIHoeghHoegh Fleet ServicesFleet ServicesFairmont ShippingFairmont ShippingFujitransFujitrans CorporationCorporationSabine TransportationSabine TransportationDST Shipping Inc.DST Shipping Inc.BoyangBoyang

Special Agents and Prosecutors Special Agents and Prosecutors are especially careful when case are especially careful when case is initiated by whistleblowers.is initiated by whistleblowers.

Allegations are usually Allegations are usually confirmed by multiple confirmed by multiple witnesses, documents and witnesses, documents and physical evidencephysical evidence

Government does not usually Government does not usually inform witnesses of possible inform witnesses of possible whistleblower award until case whistleblower award until case is complete.is complete.

Prosecutors may or may not Prosecutors may or may not bring APPS charges and may or bring APPS charges and may or may not recommend award.may not recommend award.

Final award decision is vested Final award decision is vested with Court.with Court.

Procedural ApproachesProcedural ApproachesHow to Encourage Employees to Make Internal ReportsHow to Encourage Employees to Make Internal Reports

Establish clear environmental policies.Establish clear environmental policies.Take measures to convince employees Take measures to convince employees that owner/operator really wish to that owner/operator really wish to comply fully with all applicable laws, comply fully with all applicable laws, including MARPOL.including MARPOL.Display top level commitment to Display top level commitment to environmental compliance.environmental compliance.Establish direct and anonymous lines Establish direct and anonymous lines of communication to senior of communication to senior management with regard to management with regard to environmental and safety matters.environmental and safety matters.Zero tolerance for retaliation against Zero tolerance for retaliation against those that report violations.those that report violations.Zero tolerance for violators.Zero tolerance for violators.Reward employees who report Reward employees who report violations.violations.Establish safety and environmental Establish safety and environmental compliance as positive factors in compliance as positive factors in employee evaluations.employee evaluations.

Procedural ApproachesProcedural ApproachesAuditsAudits

Internal/external audits while vessel is at sea.Internal/external audits while vessel is at sea.Audits designed to Audits designed to investigateinvestigate environmental compliance.environmental compliance.Use of a comprehensive checklist.Use of a comprehensive checklist.Getting beyond the checklist.Getting beyond the checklist.Unannounced inspections/audits.Unannounced inspections/audits.Verification and analysis:Verification and analysis:

of routine maintenanceof routine maintenanceof disposal recordsof disposal recordsof internal record keeping policiesof internal record keeping policiesof record accuracyof record accuracyof trainingof trainingof written policiesof written policies

Operational testing of key equipment while vessel is underway usOperational testing of key equipment while vessel is underway using actual waste ing actual waste streams.streams.Interviews with all crew members.Interviews with all crew members.Written audit findings.Written audit findings.Review of audits by shoreReview of audits by shore--side management including senior corporate officer.side management including senior corporate officer.PostPost--audit meetings.audit meetings.Implementation and tracking of audit findings and corrective actImplementation and tracking of audit findings and corrective actions.ions.

Internal Monitoring

Technical ApproachesTechnical ApproachesInstallation of best available technology Installation of best available technology (OWS, OCM, Incinerator, ODME, MSDS, (OWS, OCM, Incinerator, ODME, MSDS, etc.etc.Upgrade related equipment to minimize Upgrade related equipment to minimize waste production. waste production. PrePre--processing of waste (staged operations).processing of waste (staged operations).Increase tank capacity for various waste Increase tank capacity for various waste streams.streams.System modification to allow inSystem modification to allow in--port testing port testing of treatment systems and development of of treatment systems and development of ClassClass--approved test procedures. approved test procedures. Sampling and testing of waste streams and Sampling and testing of waste streams and effluent to verify technology.effluent to verify technology.Use of cleaning agents consistent with Use of cleaning agents consistent with equipment design and capability.equipment design and capability.

Technical ApproachesTechnical ApproachesControl DevicesControl Devices

Uniquely numbered Uniquely numbered environmental tags on environmental tags on flanges to prevent flanges to prevent unauthorized unauthorized bypassing.bypassing.Use of seals on Use of seals on overboard valves and overboard valves and cross connections.cross connections.Placards.Placards.Surveillance cameras.Surveillance cameras.

Note: Control devices alone cannot guarantee compliance.Control devices alone cannot guarantee compliance.

Technical ApproachesTechnical ApproachesControl DevicesControl Devices

Use of tamper resistant Use of tamper resistant recorder systems, alarms and recorder systems, alarms and printouts to verify printouts to verify equipment operation, valve equipment operation, valve position, flow, OWS position, flow, OWS ppmppm, , incineration, position, etc. incineration, position, etc. Lock boxes/cages on Lock boxes/cages on monitoring equipment.monitoring equipment.Interlocks to prevent Interlocks to prevent tricking of monitoring tricking of monitoring equipment. equipment. Use of meters to record Use of meters to record equipment runequipment run--time and time and volume for all engine room volume for all engine room pumps.pumps.

Note: Control devices alone cannot guarantee compliance.Control devices alone cannot guarantee compliance.

Addressing MotivesAddressing MotivesTo save on cost of To save on cost of offloading waste in port.offloading waste in port.

Response: Response: Emphasize environmental compliance. Have waste removal Emphasize environmental compliance. Have waste removal available in every port. Minimize waste stream. Have flexible available in every port. Minimize waste stream. Have flexible budget for budget for environmental compliance. Remove any financial incentives for cenvironmental compliance. Remove any financial incentives for crew to rew to pollute. Reward compliance. Punish violators.pollute. Reward compliance. Punish violators.

To save on cost of parts and To save on cost of parts and to save maintenance time to save maintenance time necessary if equipment used necessary if equipment used properly.properly.

Response: Response: Emphasize environmental compliance. Have waste removal Emphasize environmental compliance. Have waste removal available in every port. Minimize waste streams. Have flexibleavailable in every port. Minimize waste streams. Have flexible budget for budget for environmental compliance. Remove any financial incentives for cenvironmental compliance. Remove any financial incentives for crew to rew to pollute. Reward compliance. Punish violators. Make essential ppollute. Reward compliance. Punish violators. Make essential parts a arts a budget line item. Make Port Engineer responsible for having spabudget line item. Make Port Engineer responsible for having spares on res on board. Consider need for equipment upgrade. board. Consider need for equipment upgrade.

Corporate culture: Corporate culture: Environmental compliance Environmental compliance perceived to be low priority perceived to be low priority in relation to other in relation to other priorities. priorities.

Response: Response: Emphasize environmental compliance. Display top level Emphasize environmental compliance. Display top level environmental commitment through training, policies, audits, etcenvironmental commitment through training, policies, audits, etc. Make . Make environmental compliance a positive factor in personnel evaluatienvironmental compliance a positive factor in personnel evaluations. ons. Reward compliance. Punish violators. Emphasize importance throReward compliance. Punish violators. Emphasize importance through ugh audits, turnover, maintenance schedules, and shoreaudits, turnover, maintenance schedules, and shore--side supervision. side supervision. Consider additional staffing. Consider additional staffing.

Equipment not operable.Equipment not operable. Response: Response: Emphasize environmental compliance. Determine root cause. Emphasize environmental compliance. Determine root cause. Consider upgrade. Make operability everyoneConsider upgrade. Make operability everyone’’s responsibility. s responsibility.

Fear of losing job.Fear of losing job. Response: Response: All of the above. Establish direct lines for reporting violatioAll of the above. Establish direct lines for reporting violations. ns. Reward and protect employees who make internal reports. Zero toReward and protect employees who make internal reports. Zero tolerance lerance for retaliation against employees who report violators. Report for retaliation against employees who report violators. Report violators to violators to flag state and to port state authorities.flag state and to port state authorities.

No fear of getting caught or No fear of getting caught or being subjected to being subjected to consequences by employer. consequences by employer.

Response: Response: Create shoreCreate shore--side accountability. Reward and protect side accountability. Reward and protect employees who make internal reports. Punish violators. Zero toemployees who make internal reports. Punish violators. Zero tolerance for lerance for retaliation against employees who report violators. Report violretaliation against employees who report violators. Report violators to flag ators to flag state and to port state authorities.state and to port state authorities.

Examples of FailuresExamples of FailuresFailure to conduct waste Failure to conduct waste stream analysis.stream analysis.Failure to conduct Failure to conduct operational tests of pollution operational tests of pollution prevention equipment.prevention equipment.Failure to conduct rigorous Failure to conduct rigorous environmental audits environmental audits including reconciliation of including reconciliation of ship records.ship records.Failure to train and Failure to train and communicate directly with communicate directly with employees actually employees actually responsible for operating responsible for operating pollution prevention pollution prevention equipment and those making equipment and those making log entries. log entries.

Failure to relieve budget Failure to relieve budget pressures regarding pressures regarding environmental compliance.environmental compliance.Failure to effectively Failure to effectively communicate environmental communicate environmental compliance message.compliance message.Failure to arrange waste Failure to arrange waste removal at all ports for removal at all ports for contingencies.contingencies.Failure to conduct due Failure to conduct due diligence when taking over new diligence when taking over new ships contracts. ships contracts. Failure to take comprehensive Failure to take comprehensive and effective response after and effective response after known violations. known violations.

Response and CooperationResponse and CooperationHow A Company Responds Will Be Factored In The OutcomeHow A Company Responds Will Be Factored In The Outcome

Establish a meaningful compliance program and Establish a meaningful compliance program and report violations report violations beforebefore an investigation, pursuant to an investigation, pursuant to existing existing DOJ and EPA voluntary disclosure DOJ and EPA voluntary disclosure programs.programs.Conduct a comprehensive internal investigation and Conduct a comprehensive internal investigation and determine root causes.determine root causes.Audit entire fleet and take prompt and effective Audit entire fleet and take prompt and effective remedial measures to achieve fleetremedial measures to achieve fleet--wide compliance.wide compliance.Promptly and thoroughly produce requested records.Promptly and thoroughly produce requested records.Waive privilege and work product doctrine.Waive privilege and work product doctrine.Take disciplinary action taken against violators. Take disciplinary action taken against violators. Support crew members.Support crew members.

Vessel Pollution EnforcementVessel Pollution EnforcementProblems and SolutionsProblems and Solutions

Richard A. UdellSenior Trial AttorneyEnvironmental Crimes SectionU.S. Department of Justice601 D Street, NW - #2008Washington, D.C. 20004202-305-0361Richard.Udell@usdoj.gov

INTERTANKOLatin America Panel

November 16, 2005Miami Beach, Florida