Tag Archive for: Marine Systems

The disposal of all garbage into the sea from vessels is prohibited, except in some limited circumstances.

Under MARPOL Annex V, garbage includes all kinds of food waste, domestic waste and operational waste, all plastics, cargo residues, incinerator ashes, cooking oil, fishing gear, and animal carcasses generated during the normal operation of the vessel.

Food wastes

While the vessel is en-route, food wastes that have been ground and capable of passing through a screen with openings no greater than 25mm, can only be discharged 3nm or more from the nearest land.

Food waste not ground can only be discharged 12 nautical miles or more from the nearest land. Vessels operating alongside or within 500mtrs of a fixed and floating platform cannot discharge food waste, except under very limited circumstances.

Additional requirements are in place for vessels operating in MARPOL Special Areas and Polar Regions. Refer to MARPOL for more information, noting that there are currently no Annex V Special Areas designated around the Australian mainland. There is, however, an extended ‘nearest land’ boundary around the Great Barrier Reef area.

Cargo residues

Cargo residues may be left over after loading or unloading. Cargo residues classified as Harmful to the Marine Environment (HME), cannot be discharged into the sea, except under very limited circumstances. Such waste must be discharged to an onshore waste reception facility.

Cargo residues not classified as HME can be discharged into the sea provided that the vessel is en-route, and the discharge occurs as far as practicable from the nearest land, but not less than 12 nautical miles from the nearest land.

Cleaning agents or additives contained in holds, deck and external surfaces wash water can be discharged into the sea, provided that they are not classified as HME.

For cleaning agents and additives, HME substances are those that are identified as marine pollutants in the International Maritime Dangerous Goods (IMDG) Code, or which meet the criteria in the Appendix of MARPOL Annex III (harmful substances). These criteria can be found in the 2017 Guidelines.

Animal carcasses

Animal carcasses may only be discharged into the sea when:

  • the vessel is not in a MARPOL designated special area;
  • the vessel is en-route, and the discharge is as far as possible from the nearest land;
  • the carcass has been slit or cut so that its thoracic and abdominal cavities are opened or passed through a comminuter, grinder, hogger, mincer or similar equipment; and
  • the discharge is undertaken in accordance with section 2.12 of the 2017 Guidelines.

Mixed garbage

When different types of garbage are combined or contaminated by other substances that are prohibited from discharge, the more stringent discharge requirements will apply.

Garbage management

AMSA requires that larger vessels manage, and record waste generated on board the vessel, including discharges.

Garbage Management Plans

Under MARPOL Annex V every vessel of 100 gross tonnage and above, and every vessel certified to carry 15 or more persons, is required to carry a Garbage Management Plan. The Garbage Management Plan contains procedures for collecting, storing, processing and the discharge of garbage, including the use of equipment onboard.

Garbage Record Books

Under MARPOL Annex V every vessel of 400 gross tonnage and above, and every vessel certified to carry 15 or more persons engaged in international voyages, is required to maintain and retain onboard a Garbage Record Book.

Fishing vessel operators must record the discharge or loss of fishing gear in the Garbage Record Book or the vessel’s official logbook.

The Garbage Record Books are divided into Part I and Part II. Part I is used by all vessels, but Part II is only required for vessels that carry solid bulk cargoes.

Part I covers discharges of:

  1. Plastics
  2. Food wastes
  3. Domestic wastes
  4. Cooking oil
  5. Incinerator ashes
  6. Operational wastes
  7. Animal carcass(es)
  8. Fishing gear
  9. E-waste

Part II covers discharges of:

  1. Cargo residues (non-Harmful to the Marine Environment)
  2. Cargo residues (Harmful to the Marine Environment).

Placards

All vessels of 12 metres or more in length are required to display placards that notify the crew and passengers of the MARPOL garbage discharge requirements for that vessel under MARPOL.

The placards should be placed in prominent places onboard the vessel where the crew and passengers will see them to inform how they can manage their waste (e.g., galley spaces, wheelhouse, main deck and passenger accommodation).

Garbage Placards can be obtained from any AMSA office or by submitting a request to AMSA through the AMSA website.

Reception facilities

Australia is required under MARPOL to ensure that adequate reception facilities are available in ports and terminals to meet the needs of the vessels regularly using them, including the reception of all waste streams generated on board a vessel during normal operations.

Further information on arranging for waste reception, reporting inadequacies of facilities, and best practice regarding the provision of waste reception facilities in Australia can be found on AMSA’s Waste reception facilities in Australian ports webpage.

Exceptions

Exceptions to the prohibition of garbage discharge under MARPOL Annex V are:

General garbage

  • The discharge of garbage from a vessel is necessary to secure the safety of a vessel and those on board, or saving a life at sea;
  • The accidental loss of garbage resulting from damage to a vessel or its equipment, provided that all reasonable precautions have been taken before and after the occurrence of the damage, to prevent or minimise the accidental loss;

Fishing gear

  • The accidental loss of fishing gear from a vessel provided that all reasonable precautions have been taken to prevent such loss; or
  • The discharge of fishing gear from a vessel for the protection of the marine environment or for the safety of that vessel or its crew.

When the loss or discharge of fishing gear, such as nets, long lines, fish traps or any human-made contraptions designed to catch fish, cannot be reasonably retrieved, and poses a significant threat to the marine environment and navigation, the fishing vessel operator is required to report the approximate position and reasons for the loss to the nearest port authority or the Joint Rescue Coordination Centre in Canberra (on 1800 641 792).

This allows AMSA to broadcast Maritime Safety Information (MSI) if there is a significant risk to navigation. The loss must still be recorded in the garbage record book, as above.

It is recommended that state/NT and port authorities are consulted on any local regulations that may apply in specific circumstances.

Penalties

There are substantial penalties for MARPOL breaches in the Protection of the Sea (Prevention of Pollution from Vessels) Act 1983, including the power to detain vessels.  A detention requires the owner to post an undertaking of considerable financial security.

Guidelines for the Implementation of MARPOL Annex V

The 2017 Guidelines for the Implementation of MARPOL Annex V (Resolution MEPC.295(71)), as amended, (2017 Guidelines) were developed to assist vessel owners, vessel operators, vessels’ crews, cargo owners and equipment manufacturers in complying with certain requirements set out in Annex V of MARPOL. This includes the management of cargo residues, cleaning agents or additives, and the treatment of animal carcasses.

The 2017 Guidelines also provide information on all aspects of garbage management, such as waste minimisation, vessel board garbage handling and storage, vessel board treatment of garbage (e.g., grinding or comminution, compaction and incineration).


Shorlink’s Recommendation

Where required we recommend that you have a Garbage Record book to record the relevant information or record it in the vessels Log Book.

In today’s world ensuring you maintain the appropriate records is paramount!


Tip

Use sealable bags to store garbage onboard and dispose of all garbage in the appropriate receptacles ashore.

It’s also a good tip to separate recyclable items from general garbage and place them in the appropriate recycling bins ashore.

Australia’s COVID situation is in a constant state of change. Owing to the size of the continent, the distance between cities and the fragmented (and often contradictory) nature of Federal / State government, an outbreak of COVID can be raging in one part of the country and completely absent everywhere else.

From this prospective, it can be quite difficult to accurately report the ‘current’ restrictions and/or directives that must be adhered to for all owners, businesses and crew!

Therefore, whilst it appears we are coming out of the pandemic, the changes appear fewer, and restrictions appear lighter.

There are specific rules in place for Domestic Commercial Vessels (DCV) based on your operations. Please note that states and territories may have different requirements. We recommend checking with your state or territory for their specific requirements.

Charter operators and tourism experiences

This includes Hire & Drive/ bare boat operators.

There are now NO vaccination or check in requirements and no COVID-19 capacity or density limits apply.

Commercial Fishing

If at sea and a crew member shows any symptoms of COVID-19 immediately take a Rapid Antigen Test (RAT) and follow the guidelines below.

  1. If a NEGATIVE test result no action necessary but continue to monitor symptoms and take a second RAT test 2 or 3 days after the first test.
  2. If a POSITIVE test result then the vessel becomes a quarantine zone for 7 full days from the date of the test. This means that any person who tests positive OR displays COVID-19 symptoms (see Close Contacts below) is not permitted to leave the vessel during that period other than for situations like:
  • Going to hospital for urgent medical care
  • In an emergency such as fire, flooding, etc.

If a crew member is leaving the vessel for these very limited reasons they must wear a mask.

  1. Advise all other persons onboard that you have tested positive, and the vessel is quarantine zone for the next 7 days.
  2. Advise family and friends that you have COVID-19
  3. Continually monitor your health and if unsure call the National Coronavirus Helpline on 1800 020 080
  4. Seek medical advice if you:
  • are not improving after 2 or 3 days, or are getting sicker
  • have a chronic health condition
  • are pregnant
  1. Call 000 immediately if you are or becoming seriously ill
  2. The quarantine period ends after the 7 full days unless you have a fever, sore throat, runny nose or a cough that is getting worse on day 7
  3. If you do have a fever, sore throat, runny nose or a cough that is getting worse the vessel will need to remain a quarantine zone until the symptoms clear
  4. You do not need another RAT to end the quarantine period. This is because most people who get COVID-19 will continue to test positive for some time after they have recovered even though they no longer have COVID-19 and are no longer infectious.
  5. Another crew member tests POSITIVE for COVID-19 then you need to start a new 7 full days quarantine period and follow 1 – 10 above.
  6. The vessel remains a quarantine zone for 7 full days from the date the crew member had the test.

Most states and territories require you to report a positive RAT result, check your governments requirements for reporting positive RAT results.

NOTE: This guide is based on government information today and as states and territories continually change requirements we recommend you check your state or territory requirements regularly.

Close contacts

All persons onboard should be considered close contacts if any person onboard has tested positive to COVID-19 from the date of a positive result. Close contacts with COVID-19 symptoms should take a RAT immediately and must stay onboard until the symptoms resolve.

Anyone onboard who DOES NOT have symptoms of COVID-19 should monitor symptoms for 7 days  from the last time anyone onboard tested positive for COVID-19. If symptom free then you do not have to quarantine and can leave the vessel.

While anyone is a close contact they must:

  • Wear a mask at all times when outside
  • Not visit vulnerable settings unless in exceptional or compassionate circumstances
  • Test for COVID-19 if symptoms develop.

Managing symptoms

Most people will be able to manage their symptoms onboard. It is import to:

  • Get lots of rest
  • Drink plenty of fluids (water is best) to avoid dehydration
  • Take pain medication like paracetamol or ibuprofen if uncomfortable
  • Monitor symptoms daily to track if they are getting worse. You can use Queensland’s My COVID-19 symptoms diary  by clicking on the link below.

https://www.qld.gov.au/__data/assets/pdf_file/0019/230608/A4L_Symptoms-diary_23-12-21-INTERACTIVE.pdf


Shorlink’s Recommendation

First and foremost, ensure you have enough RAT kits onboard based on the number of crew carried and the length of your normal voyages.

Secondly ensure you have a procedure onboard for how to deal with crew members who test positive for COVID-19 and all crew know and understand their responsibilities in relation to dealing with COVID-19.


Tip

If you’re unsure about what’s required or how to incorporate a COVID-19 procedure into your SMS then give us a call and we’ll help you develop a procedure and incorporate it into your SMS.

The documents required by AMSA today and, with so many options of hard copies versus electronic it’s difficult to completely understand what is required onboard.

We have listed the primary documents that should be carried onboard  Domestic Commercial Vessels (DCV) at all times:

  1. Vessel Certificate 

    You must always carry your vessel’s Certificate of Operation (CoO) and/or Certificate of Survey (CoS) on board. This can be in hard copy or an electronic version, such as a copy on your smart phone.
    Your vessel’s certificates and surveys must be available upon request by an AMSA inspector or their compliance partners.

  1. Permissions 

    Any permissions relevant to your vessel’s operations; e.g., landing permits for specific locations, etc., must always be carried onboard. As with Certificates these may be in hard copy or an electronic version, such as a copy on your smart phone.

  1. Safety Management System 

    All DCV are required to have a Safety Management System (SMS) that complies with Marine Order 504 (MO504) Again this may be in hard copy or an electronic version.

  1. Vessel/Deck Log Book 

    All commercial vessels are required to have a vessel or deck log book in which they are required to record specific information (see our newsletter dated 15/03/2022 for details).

  1. Maintenance Log 

    All maintenance must be recorded either in a dedicated form in your SMS, a Maintenance Log Book or in an electronic maintenance program.

  1. Sewage Management Plan 

    All declared Ships must ensure they have a Sewage Management Plan onboard and available for inspection.All vessels, including recreational and commercial vessels that are fitted with sewage treatment system must ensure they have the appropriate documentation and follow specific guidelines.

    What is a Declared Ship?

    A declared ship has a fixed toilet and is:

  • a domestic commercial vessel with a certificate of operation issued, or taken to be issued, under the Marine Safety (Domestic Commercial Vessel) National Law Act 2012 stating it is a class 1B, 1C, 1D, 1E, 4C, 4D or 4E ship, or
  • any other Queensland regulated ship regulated under the Transport Operations (Marine Safety) Act 1994 and Transport Operations (Marine Safety) Regulation 2016 designed to carry more than 12 passengers.
  1. Copies and/or receipts for serviceable items service for inflatable life rafts, electrical installations, fire extinguishers, EPIRB,

Shorlink’s Recommendation

Number one recommendation is to ensure you have ALL the required documents onboard at all times. You must be able to present the relevant documents to AMSA or their delegates when asked.

Secondly it’s not good enough to just have them onboard, they must be up to date which means you need to ensure your SMS is reviewed annually and your log books are filled in daily when operational.


Tip

If for any reason you are unsure about exactly what you require on your vessel, what format is best for you (hard copy or electronic) or anything in relation to documents required don’t hesitate to contact our office!

We often get asked “how important are Annual Reviews?”

The simple answer is they are not only important, they are critical!

ALL Safety Management Systems including those developed for Domestic Commercial Vessels (DCV) under Marine Order 504 and the ones developed for workplaces under Work Health and Safety are required to undergo an Annual Review or Audit.

Failure to complete your Annual Review or Audit leaves you non-compliant and exposed to legal action in the event of an incident or accident.

With AMSA having made changes to MO504 during the last 12 months it’s critical that your manuals are updated to incorporate the changes to ensure you are compliant and protected.

The Annual Review is also more important than ever due to:

  • Increased monitoring activity by AMSA, Fisheries and Water Police;
  • Poor recording of follow-up’s to incidents. Refer to Section 9 in your SMS; and
  • AMSA bringing in Work Health and Safety in the event of a marine incident.

When reviewing your SMS, here at Shorlink we incorporate the following…

  1. Any Legislative changes or updates;
  2. Any improvements that we may have developed since delivering your SMS;
  3. Modifications to any existing procedures where changes may have been made;
  4. Inclusion of any new procedures that may be required;
  5. Incorporating any incidents into Section 9 (if required)
  6. Updating the Annual Review form.

While having a compliant Safety Management System in place is great, ‘keeping it compliant’ is something else!

If you would like us to undertake the review as a matter of priority, would you please contact our office immediately.


Shorlink’s Recommendation

My recommendation is to put the past 2 years behind you, look forward to 2022 and get going! While things are getting back to the new normal I further recommend taking a close look at your business or operations to see where and how you can better adapt to the ongoing business climate.

While there’s been a lot of heartache for many there is a lot of opportunities for those who are prepared to adapt so…go forward and prosper!


Tip

My top tip is to ensure your safety management systems comply with the relevant standards and are up to date to ensure you’re protected as both AMSA and WorkSafe are going to be very active, especially this year.  If you are unsure, send us an email today with your current SMS, and we can assess for free and advise of any changes required.

Completing a risk assessment for the number of crew required to operate your vessel in emergency situations is not as easy as you may think.

There are many factors to take into account including but not limited to:

  • The class or classes the vessel operates under
  • How many Certified crew are required
  • How many uncertified crew and/or Special Staff are required
  • The general layout including the number of decks and considerations relating to access to different decks, passenger exit points (if applicable)
  • Abandon ship locations
  • Access to and deployment of lifesaving appliances and equipment
  • Location and deployment of firefighting appliances and equipment

Once you’ve got all that together you then have to calculate emergency response capabilities for all crew members and Special Staff if included in emergency response actions.

Now you’ve identified your emergency response capabilities you can then go through the appropriate crew calculations taking into account but not limited to the following:

  • Minimum crewing or what used to be Core complement
  • Design factors
  • Operational factors
  • Emergency response

It’s no wonder most people just give up when trying to put together a risk assessment for their vessel. AMSA does have a basic and I mean very basic template on their website. You can find it by clicking on the link below.

https://www.amsa.gov.au/vessels-operators/domestic-commercial-vessels/appropriate-crewing-evaluation-template

If you operate a passenger vessel and are involved in a marine incident where crew numbers come into question, you may be asked to produce your risk assessment or appropriate crewing evaluation as AMSA call it.

This is to assist in identifying if you had an appropriate number of crew onboard to safely and efficiently deal with the emergency under investigation.

If you can’t produce it or your crew numbers are too low you can find yourself in a world of hurt!


Shorlink’s Recommendation

Number one recommendation is if you operate a vessel that carries passengers or multiple crew get to work and complete an Appropriate Crew Calculator or an appropriate crewing evaluation as AMSA call it.

If in doubt or unable to complete one, contact our office for assistance.


Tip

While it might sound like it’s not too hard to do to get it right requires quite a bit of training in risk assessment and vessel operations and that’s where Shorlink comes in.

We use a detailed Appropriate Crew Calculator to cover all the areas identified and more to ensure your crewing requirements cover the vessel and its operations.

Don’t waste time trying to do it yourself, its much easier and cheaper to get the professionals at Shorlink on the job for you!

This is another one of those things that often gets overlooked, especially on smaller vessels but…it can be a major asset in the event of an emergency onboard!

Many operators are still today asking what an emergency station list is so let’s get that out of the way first.

An emergency station list details what each crew member does in the event of an emergency situation. It is simply a duty list for all crew members.

All too often I see an emergency station list that that details what each crew members will do in each and every situation. That’s great for ships with highly trained crew who are on the same vessel for long periods.

In the size of vessels, we are dealing with and crews that come and go, achieving that can be quite difficult. In developing your emergency station list, you need to take into consideration the following:

  • Size of vessel
  • Operations
  • Number of crew
  • Do you carry passengers?
  • Are there special/service staff onboard?
  • If so are they trained in emergency response
  • Number of special/service staff onboard

Before we go any further, it’s vital that you undertake a risk assessment in relation to the number of crew required or adequate crew (more on this next week) required to operate the vessel.

It’s no good saying I have a passenger vessel that does day trips with up to 200 passengers onboard and usually have a Master plus 3 crew onboard. You need to know how many crew are required to deal with emergencies safely and efficiently.

Once you have the adequate crew number established you can then allocate duties. Where you have a Master and deckhand only it’s pretty simple. Where you have regular crew you can allocate tasks accordingly.

On vessels where the crew includes an Engineer and/or a Mate plus deck crew my preference is to have the Mate or Engineer go to the point of incident and the rest of the crew to Assembly stations and await instructions.

With so many potential emergency situations I usually find it more efficient to have the Master instruct the crew in relation to the emergency at hand.

If you have special/service staff onboard who are trained in emergency procedures you need to incorporate them into the emergency station list as well allocating them set tasks relevant to their training.


Shorlink’s Recommendation

Key recommendations are…

  1. Complete a risk assessment for the number of crew required to safely operate your vessel then;
  2. Develop an Emergency Station List based on your risk assessment.

If in doubt or unable to complete a detailed risk assessment, contact our office for assistance.


Tip

Need an Emergency Station List that is waterproof and reusable over and over again then call our office and tell us about your vessel and its operations.

We have a number of ready to go formats for different vessels, crew numbers and operations. Our Emergency Station Lists come ready to use and are laminated using a high density laminate and come with a washable ink pen and double sided tape to secure to a bulkhead.

As a commercial operator we’ve all had to deal with vessel inspections by marine agencies including AMSA, Fisheries and the Water Police.

While on most occasions you get through them without too much hassle there are times when we wonder what the hell some of these officers are talking about.

I think most of us have gotten disturbed at times and even downright angry at some of the things we get thrown at us.

I can say that in most cases the officers are not displaying any form of prejudice against you as a person. Unfortunately, I have to admit to being witness to an officer going out of his way to make life hard for an operator they believed should not be on the water!

Ordinary situations can be hard enough but when you have to deal with that sort of behaviour, its hard to keep your calm.

What’s important to remember is that the person undertaking the inspection is only doing their job and they are only human after all!

One of the biggest issues to deal with is consistency. What we’ve seen happen is an inspection being undertaken in one port and being given the “all good” then going to another port only to be told all these things are wrong.

The worst one is with SMS manuals, where officers out their twist on what they think should be in your SMS.

AMSA have an SMS Assessment check list that lays out what they need to ensure is in your SMS. That’s what they should be sticking too!

So… how do we deal with onboard inspections?   

Dealing with onboard inspections at any time can cause stress, especially when you feel things are not going so well, so below I’ve listed how I recommend ALL Owners, Masters and Crew Members to respond.

During an onboard inspection I always recommend all persons involved to remain calm and respect the officers conducting the inspection, even if you disagree with their decisions.

Actions and reactions

  • Keep calm at all times
  • Don’t blow your stack no matter what
  • If you disagree with something ask them for an explanation
  • If something is found to be non-compliant or unsafe ask to be shown what it is and have them explain to you if you’re uncertain
  • If you feel the officer has been unjust or wrong in some way don’t argue about it. Let them know your concerns and ask for clarification
  • If you’re issued with a Report of Inspection with defects listed, make sure you have anything you don’t understand explained to you
  • Being issued with an order to return to port or tying up the vessel up for any reason accept it, don’t argue with the officer and follow the direction then deal with whatever was the cause
  • If you feel any decision is wrong, first follow the instructions then you can report it to AMSA but ensure you are clear about the issue have all the facts together to support your case. Be clear and concise!
  • In relation to SMS Manuals be aware that officers are viewing them to ensure they have all the required information relevant to your vessel and its operations. They are not meant to go through procedures and issue instructions about them. They may make suggestions but remember for DCV’s there is no actual approval system in place.

If you follow the above your onboard inspections will go much easier, no matter what the outcome is!


Shorlink’s Recommendation

My number one recommendation is to follow the guideline above but if you feel there is a problem with any notices given during an inspection the I strongly recommend you contact our office for advice immediately.

We have the experience and knowledge in dealing with these matters and can make life easier for you. If you have an inspection scheduled and would like assistance in dealing with it then you can arrange for us to be onboard during the inspection (based upon availability).


Tip

Safety Management Systems (SMS) are one of the biggest issues with vessel owners and operators at present due to AMSA’s increase monitoring of them.

For those who aren’t clients, my tip is to have us undertake a FREE assessment of your SMS so we can point you in the right direction. Feel free to send us a copy to sms@shorlink.com and we would be happy to assess and advise!

If you’ve received a MO504 SMS Assessment and there are items listed as “not met” then our tip is to send them to us if you’re unsure about what’s required ASAP.

Among the many question we get another common one is “what is a DP?”

DP stands for Designated Person which used to be called Designated Person Ashore (DPA) but for DCV’s a DP can be the owner operator and may be onboard when at sea.

Section 4 of Marine Order 504 specifies:

“The owner of a vessel must designate a person to be responsible for monitoring the safety of the vessel, the environment and all persons on or near the vessel and ensuring appropriate resources and shore support are provided to the vessel.”

What’s required to be a DP?

Ideally a DP will have a solid working knowledge of the vessel, its operations and crew requirements so as to be able to provide appropriate assistance and/or advice to the crew in the event of an emergency situation.

While this is the ideal situation it’s not always possible for owner operators as they are usually the ones that have all the knowledge about their vessel and operations. In these situations its quite often the wife or partner who is listed as the DP.

Larger organisations and multi-vessel operators usually have someone who is up to speed with the organisations vessels and operations and is listed as the DP. These people usually have the knowledge and resources to deal with emergency situation efficiently.

No matter whether you’re a single vessel operator or operate multiple vessels your DP must have the owners authority and resources to act in emergency situations involving the safety of the vessel, all persons onboard, infra structure and the environment.

And the good part is to ensure your DP is available at all times when your vessel is operating which for many operators this means 24 hours a day, 7 days a week! If you’re a DP you must answer all calls from the vessels when they are operational, the safety of the vessel and/or persons onboard may depend on it!


Shorlink’s Recommendation

Ensure your DP has the appropriate authority to act in the event of an emergency situation as well as the resources that may be needed.

Have a list of emergency contact numbers ready including emergency services (Police, Ambulance and Fire) 000 and any other numbers that can assist in specific situations; e.g., mechanics, volunteer marine rescue organisations, etc.


Tip

Our best tip is to have an alternative DP listed in your SMS in the event the primary DP is unavailable for any reason whatsoever.

If you and your partner take holidays together and you’re listed as primary and alternative DP’s then you may have an issue with who deals with an emergency situation if both parties are absent.