FEDERAL MARITIME COMMISSION

FINAL ANNUAL PERFORMANCE PLAN

FOR FY 2001

May 2000
INTRODUCTION

This document comprises the Federal Maritime Commission’s Annual Performance

Plan for FY 2001. As set forth in the Government Performance and Results Act and

general guidelines published by OMB, the Commission has prepared a single

performance plan so as to present a comprehensive picture of performance across the

agency. This plan is closely linked to the agency’s strategic plan, although its

content is more detailed and specific as opposed to the general and long-term focus

of the strategic plan. We also have concentrated on developing objective

performance goals and narrow, measurable performance indicators, so as to facilitate

the plan’s implementation and assessment of performance.

This Performance Plan differs from our FY 1999 and FY 2000 Plans in two respects.

First, it more completely reflects the Commission’s new statutory responsibilities and

mandates under the Ocean Shipping Reform Act of 1998 (“OSRA”). While our FY

2000 Plan reflects certain impacts of OSRA, we now are in a position in our FY 2001

Plan to base our performance goals and outcomes more fully on the altered oversight

responsibilities we assumed pursuant to OSRA. 

Second, our FY 2001 Plan is presented in accordance with the Budget Program

Activities that resulted from the agency’s reorganization of February 27, 2000. This

reorganization was effectuated to enable the Commission to more effectively

accomplish its new statutory mission under OSRA. Additionally, it sought to

streamline agency operations where possible to enhance our oversight efforts, and

reallocated agency resources to improve the efficiency and effectiveness of our daily

activities. As in our prior Plans, our intent is to achieve desired results via the

approaches and processes best suited to our budgetary and resource situations. The

FMC has streamlined its organizational structure so that we now have five Budget

Program Activities as opposed to six (two prior Activities have been combined into

one so as to remove unnecessary management layers). We also have reallocated

responsibilities and resources, and established new functions in two of our Program

Activities. The five Budget Program Activities under our reorganization

are: (1) Formal Proceedings, (2) Operational and Administrative, (3) Trade

Analysis, (4) Consumer Complaints and Licensing, and (5) Enforcement. 

The Commission continues to tailor its annual performance plan to comport with the

overall objectives of GPRA, while maintaining flexibility in its presentation and

application. This modified approach has been authorized by OMB since the majority

of Commission activities are statute-driven and our goals essentially are based upon

legislative mandates which are clear and direct. Significant alteration of our existing

programs is not possible, given that many measures and goals are required by statute.

Additionally, the Commission has undergone an unusually exhaustive evaluative

process with respect to its statutory goals and performance due to legislative
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proposals which culminated in our new statute, OSRA, that significantly changed a

number of its major functions. 

Accordingly, OMB agreed that the Commission should use an appropriately scaled

mechanism for GPRA process and development with a framework which would be

productive, yet less resource-intensive. Nonetheless, our plan presents relevant

information clearly and concisely, and strives to be as detailed as necessary while

avoiding minutiae. 

Our plan sets forth the mission statement and general goals from our strategic plan,

as a point of reference for the reader. In accordance with general OMB guidance, we

have prepared performance goals for each of the program activities reflected in our

budget submission. The strategic goals aligned with these performance goals are

appropriately displayed. Each performance goal has been stated as a narrow,

measurable objective. For each performance goal, we have identified the intended

outcome, the processes and resources required to accomplish it, an appropriate

performance indicator, and the means for measuring/evaluating performance. To

ensure a clear understanding of the plan’s contents, set forth below are definitions

of basic terms used. We relied on OMB’s published guidance for these definitions,

and have included parenthetically our interpretation of their practical application. 

Budget Program Activity - The FMC’s program activities as listed in the program

and financing schedules of the agency budget (the agency’s major activities). 

Performance Goal - A target level of performance; a measurable objective (a

specific, proposed performance action). 

Outcome - Intended result or consequence of the program activity (the projected

effect or what is hoped to be achieved). 

Performance Indicator - A value or characteristic for measuring results (the

quantifier or qualifier of performance).

Processes/Activities - The processes, skills, or resources that are required to

effectively accomplish a performance goal (what is needed to achieve the goal). 

Performance Measure/Evaluation - The means used to verify and validate measured

values (methods used for assessing if programs achieved objectives, or, the specific

means to measure if outcomes were realized). 

It should be noted that, in response to the legislative reform effort that resulted in

OSRA, every segment of the maritime industry has taken the opportunity to inform

Congress of its assessment of the Commission’s current statutory goals and our

performance of them. This assessment of Commission activities continues today.
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Our oversight committee in the House of Representatives held a hearing on May 3,

2000, to assess the industry one year after OSRA’s effectiveness. The Commission’s

Chairman testified at that hearing, as did representatives from various sectors of the

industry. Additionally, the House Judiciary Committee held a hearing in March

2000 to review antitrust immunity in ocean shipping. Again, our Chairman and

leading representatives of the industry testified. Moreover, the Commission has

acted on several petitions for either reconsideration of its OSRA rules or clarification

of Commission policy under this new statute. We remain in daily contact with all

sectors of the industry, and Commission oversight operations under OSRA continue

to be the subject of news articles, conferences, seminars, and other industry events.

Accordingly, the industry has provided the Commission with a clear perspective of

what the Commission’s future goals should be. While there is no consensus, it is

clear that those involved in the various sectors of U.S. ocean shipping have a full

understanding of the Commission’s major program activities, and at the same time,

the Commission is fully cognizant of the views of all parties with whom it interacts.

Therefore, it was not necessary for the Commission to embark on an extensive

outreach effort when developing this plan. 

The Commission has provided all employees with copies of this performance plan.

We also have modified all employee performance plans to ensure that they comport

with the agency’s Strategic and Annual Performance Plans, and that they contain

specific elements and standards aimed at achieving the agency’s strategic and

performance goals. Performance of managers and staff will be evaluated in part on

how they achieve the objectives in this plan. 
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FMC MISSION

To achieve its vision, the FMC’s mission is:

Ensure the Nation’s interests are met through an efficient,

competitive, market-driven, and nondiscriminatory ocean

transportation system that is free of unfair foreign maritime trade

practices. 

The basic principles of liner shipping regulation still are being challenged. The

shipping industry continues to restructure itself, while shippers place an increasing

importance on rates and service. International trade remains dependent upon an

efficient and economic ocean transportation system. And OSRA significantly

changes the commercial environment and oversight of U.S. ocean shipping.

Therefore, it is imperative that the FMC identify the actions necessary to ensure that

its regulatory and legislative initiatives produce a competitive and nondiscriminatory

trading environment in the U.S. ocean commerce that is in harmony with and

responsive to international shipping practices. We must focus our energies and

efforts on this mission, and assure that the agency is organized and managed in a

manner best suited to accomplish it with a minimum of government intervention and

regulatory costs. Our actions also must encourage the development of a sound U.S.-

flag liner fleet, and allow the dynamics of the marketplace to prevail. Accordingly,

and in conformity with the Shipping Act of 1984, as amended by OSRA, the FMC

has established the following four strategic goals. 
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FMC STRATEGIC GOALS

1. Compliance: Promote the development of U.S. exports and the efficiency of

ocean shipping by ensuring compliance with shipping statutes administered

by the FMC. 

2. Balanced Enforcement: Foster economic efficiencies and reliance on

marketplace factors by administering U.S. shipping statutes in a balanced and

equitable manner that redresses excessive anticompetitive actions and

restrictive practices of foreign governments. 

3. Efficient Regulatory Process: Promote a timely, efficient and decisive

regulatory process, to enable all segments of the industry to plan and conduct

their operations more effectively and with minimal regulatory costs. 

4. Internal Capabilities: Ensure the FMC has the organizational ability and the

managerial leadership necessary to meet its regulatory, enforcement and

educational responsibilities. 
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LINKAGE BETWEEN MISSION STATEMENT

AND STRATEGIC GOALS

Our strategic goals address all important FMC programmatic, policy, and

management responsibilities. They were developed with a specific focus on

accomplishing the basic thrusts of our mission. 

Therefore, Strategic Goal No. 1 is designed to enable the FMC to carry out its

regulatory mandates concerning international waterborne commerce in a manner that

ensures compliance with the substantive provisions of the shipping statutes it

administers. Accomplishing this goal should minimize the unjust discrimination and

undue preference or prejudice that precludes certain shipping interests from

obtaining rates or service levels that can render their businesses more economic and

efficient. Curbing other malpractices should enable all industry participants to

concentrate on fair and legal means of increasing operational efficiency, secure in

the knowledge that competitors are not engaging in widespread illegal actions aimed

at enhancing short-term bottom-line profits without concern for the harmful longterm effects on the industry. Effective accomplishment of this goal also can help to

promote the growth of U.S. exports. 

The purpose of Strategic Goal No. 2 is to foster economic efficiencies and reliance

on typical marketplace factors, and redress excessive anticompetitive practices

harmful to international commerce. This is a direct link to our mission statement’s

call for an efficient, competitive, market-driven ocean transportation system. We

must be prepared to address malpractice activity that has market-distorting

consequences. And our continuing efforts to effectively address the actions of

foreign governments that adversely affect our foreign trade and U.S. interests

operating in that trade comport with that aspect of our mission aimed at creating an

environment “free of unfair foreign maritime trade practices.”

The primary intention of Strategic Goal No. 3 is to minimize regulatory costs by

increasing the efficiency and decisiveness of the FMC’s various regulatory

processes. Increasing our efficiency and timeliness will produce more expedient

action to address matters that are perpetuating discrimination or precluding industry

efficiency, thereby reducing the industry’s costs in pursuing matters before the

Commission. More decisive action on our part will help to remove uncertainties as

to statutory interpretations or the application of FMC rules. Such uncertainties can

delay either operational efficiencies or technological changes which would foster a

more economical ocean shipping system. 

Finally, we have developed a single comprehensive goal designed to improve

internal Commission management and operations. Enhancing our management
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oversight and improving employee morale can both foster the accomplishment of

various Administration directives and programs in this regard, while putting us in a

position to more effectively address the specific aims of our mission. 

Achieving these mission-driven goals will enable us to effectively address the

external factors we face, while assuring an equitable and efficient administration of

the shipping statutes under our jurisdiction. Our processes and procedures will be

refined or updated as necessary. We are committed to accomplishing our strategic

goals and the outcome goals related to them. Therefore, specific means have been

identified to enable the FMC to achieve these goals in the most cost-efficient and

least disruptive manner possible. 
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Budget Program Activity:Related Strategic Goals:

Formal Proceedings2. Balanced Enforcement: Foster economic efficiencies and reliance on marketplace factors by adm

a balanced and equitable manner that redresses excessive anticompetitive actions and restrictive p

3. Efficient Regulatory Process: Promote a timely, efficient and decisive regulatory process, to ena

plan and conduct their operations more effectively and with minimal regulatory costs.

Performance Goal Outcome Performance Indicator Process/Activity 

By 6/30/01 increaseinformation/data distributed throughthe Commission’s homepage toinclude, at a minimum, ALJ initialdecisions, significant Commission& ALJ interlocutory decisions, andall Commission Orders ofInvestigation, Show Cause Ordersor similar documents.

- Provide broaderdissemination ofCommission & ALJdecisions.- Enhance efficiency ofagency operations byreducing costs & timeexpended on reproducing &disseminating documents. 

- Secretary’s Office monitorsissuances placed on homepage.- Increased number of “hits” onFMC homepage in last quarterFY 2001.

- Secretary’s Office & OIRMcoordinate on timely placementof issuances on homepage. - Originating offices, i.e., ALJ,GC or BOE, coordinate withSecretary’s Office to ensureconcurrent publication inhardcopy & electronic form.
Performance Goal Outcome Performance Indicator Process/Activity 

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Continue to streamline responses toFOIA requests, with averageresponse time no greater than 15working days from date of receipt (5days less than the statutoryrequirement). 

- Provide requesters withreleasable information in atimely & efficient manner.- Enable parties to plan &conduct operations moreeffectively.

- Actual length of time torespond to FOIA requests. 

- FOIA Officer monitors date ofreceipt & response date.- Disseminate requests to staffcomponents who may haverequested documents no laterthan 2 days from the date ofreceipt, & shorten the returndate to the FOIA Officer.- FOIA Officer expedites &streamlines process forreviewing responsive documentsas to their releasibility.

Ensure that the Permanent TaskForce on International Affairsidentifies both foreign laws andpractices that disadvantage U.S.shipping and other foreign ormultilateral developments that mayimpact the Commission’s programs,and provides appropriate analysis,options, or recommendations to theCommission or program offices.

- Appropriately addressesunfair non-market barriersto U.S. ocean commerce.- Adds value to programarea decisionmaking byproviding information aboutpotential internationaleffects and implications.- Helps eliminaterestrictions or requirementsthat unjustly disadvantageU.S. interests.- Increases reliance onmarketplace factors in U.S.ocean trade.

- Regular reports, updates, andanalyses to the Commission oraffected program offices topromptly notify ofdevelopments in foreignshipping laws or practices.- Submit 2 general briefingpapers to FMC during course ofthe fiscal year.- Prompt response to requestsfor information on internationalaffairs matters from theCommission, program offices,other U.S. foreign governmentagencies or FMC stakeholders,as appropriate.

- Task Force of attorneys,economists & trans. specialists(headed by Asst. GC) who meetregularly to address involvedmatters.- Task Force performs research& analysis, exchangesinformation & prepares updates& recommendations to FMC. - Head of Task Force engages inand reports on regulardiscussions w/U.S. executiveagencies, & contactsw/representatives of foreigngovernments.
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Budget Program Activity:Related Strategic Goals:

Operational and Administrative1. Compliance: Promote the development of U.S. exports and the efficiency of ocean shipping by e

shipping statutes administered by the FMC.

3. Efficient Regulatory Process: Promote a timely, efficient and decisive regulatory process, to enab

plan and conduct their operations more effectively and with minimal regulatory costs. 

4. Internal Capabilities: Ensure the FMC has the organizational ability and the managerial leadersh

regulatory, enforcement and educational responsibilities. 

Performance Goal Outcome Performance Indicator Process/Activity 

Prepare a report on the impact ofOSRA identifying industry practicessince the passage of that Act, andevaluating effects of those practiceson U.S. ocean commerce. Finalreport with findings and anyrecommendations to be issued by7/30/01.

- Advise Congress and theAdministration of theimpact of the changesresulting from this majorlegislative reform, tofacilitate consideration ofany potential additionalchanges or refinements. - Enable FMC torecommend possiblechanges to achieveCongressional policyobjectives regarding U.S.ocean commerce andinternational trade. - Apprise industry ofgeneral overall impact ofAct to enhance its strategicand operational planningand to provide flexibility inconducting business. - Facilitate FMC oversightefforts. 

- Final report timely issued.- Assist Congress in its policymaking determinations.- Report provides useful,accurate information concerningindustry operations and effectsof OSRA.- Enhance FMC’s ability toeffectively administer oversightrole via initiation of necessaryrulemakings, redirection ofoperations, and reallocation ofresources.

- Small working group headedby agency senior executive.- Informalconsultations/discussions withall sectors of industry to confirmrelevant areas for review.- Formal process to obtainindustry comments.- Staff compiles/analyzes dataand information, and preparesdraft report for Commissionconsideration.
Performance Goal Outcome Performance Indicator Process/Activity 

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Develop by 3/31/01 a competitiveSES Candidate DevelopmentProgram to be used for selectingqualified employees to fill futureleadership positions in the agency’sSES corp.

- Efficient, orderly, andprocedurally correct processfor identifying, selecting,and eventually trainingemployees who can assumeSenior Executive positions.- Agency is better preparedto fill impending executivevacancies with qualified &trained successors. 

- Final plan comports with allprocedural, legal and personnelrequirements.- Plan for program approved byChairman in second quarter FY01.- Program ready forimplementation, budgetcircumstances permitting, by3/31/01.- Candidates are selected,budget circumstancespermitting, prior to end ofFY01.

- Agency ERB performsresearch/analysis and developsplan.- Agency Training Officer &Director of Human Resourcesassist ERB in developingprogram.- Chairman approves final plan,which is forwarded to OPM forapproval.- ERB implements plan, budgetcircumstances permitting, byreceiving/reviewingapplications, interviewingcandidates, and recommendingselections to Chairman.- Chairman selects finalcandidates.
Performance Goal Outcome Performance Indicator Process/Activity 

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By 3/31/01, assess agency’sFebruary 2000 reorganization todetermine if it is facilitatingaccomplishment of OSRA’sobjectives, resources continue to beallocated to obtain optimalefficiency, and further streamliningor organizational changes dictatedby current industry circumstances orAdministration/Congressionalpolicy directives are necessary. 

- Agency is best positionedto implement Congressionaland Administration policyobjectives for U.S. oceanshipping.- Appropriate resourceallocation to enhanceefficiency and facilitateaccomplishment of agencystrategic objectives andperformance goals.- More effective assistanceto industry in its attempts tocomply with shippingstatutes.- Enhance ocean commercebusiness operations by moretimely providing certainty asto acceptable activities/operations. 

- Agency’s appropriation for FY2001 enables effectuation of anychanges deemed necessary.- Necessarychanges/refinements identifiedby 3/31/01.- Necessary changesimplemented by 7/31/01.

- Executive Director’s Officedevelops plan to assessoperations to date, to include: consultations with SES/agencymanagers, evaluation of efficiency andsuccess of major programactivities, assessment of the timelinessand effectiveness of delegatedauthority actions,- Draft recommendationspresented to Chairman.- Chairman decides onappropriate changes via normaldeliberative process.
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Budget Program Activity:Related Strategic Goals:

Consumer Complaints & Licensing3. Efficient Regulatory Process: Promote a timely, efficient and decisive regulatory process, to ena

plan and conduct their operations more effectively and with minimal regulatory costs. 

4. Internal Capabilities: Ensure the FMC has the organizational ability and the managerial leadersh

enforcement and educational responsibilities. 

Performance Goal Outcome Performance Indicator Process/Activity 

By 6/30/01 ensure accurate/usefullisting of licensed/bonded OTIs onhomepage. 

- Public receives timely,accurate/useful informationabout licensed and bondedOTIs. - Provides vessel operatingcarriers with more certaintyas to whether OTIs arecompliant.- Facilitates cargo interests’access to legitimate OTIswith whom they can conductbusiness.

- Accurate listing on Homepageby 6/30/01.- Requesters have access toinformation on demand. 

- Maintenance of a database byBCCL(input updatedinformation provided byOTIs/sureties, i.e., changes tobond, company name,Qualifying Individual, etc.).- Audit OTI files for currentinformation (address, companyname, Qualifying Individual,telephone number, corporatestructure, branch offices, etc.)
Performance Goal Outcome Performance Indicator Process/Activity 

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By 9/30/01, enhance consumerguidance and assistance via e-mailand Homepage improvements.

- Consumers receiveassistance promptly andmore efficiently. - Matters outside FMCjurisdiction are directed tothe proper governmental andnongovernmental agencieswithout unnecessaryinvestment of agencyresources.-Communication andcooperation with otherconsumer assistance bodiesare enhanced.

- Increased number of hits onhomepage. - Reduction of complaints/assistance requests pertaining tomatters outside FMCjurisdiction. - Growth of assistance requestsby e-mail as a percentage of allsuch requests. 

- Develop a hyperlink systemfor external internet referrals. - Enhance the hyperlink systemfor internal referrals.- Instruct staff to direct inquiriesto the homepage, to the extentpossible. - Require the use of e-mailresponses to consumer inquiries,to the extent practical.

By 9/30/01 develop and implementan enhanced ADR program. 

- Lower costs to agency andthe public in pursuingformal proceedings andquicker resolution ofdisputes.- Accessible and more costeffective means of disputeresolution available to theshipping public.

- Number of complaints whereADR is employed.- Reduction in time forprocessing formal proceedings.- Increased use of informaldispute means by the shippingpublic.- Agency savings re: costs ofconducting formal proceedings.

- Task force to develop ADRplan (including training), andappropriate rule changes.- Provide 3rd party neutrals for

resolution of disputes throughmediation and other ADRmeans.
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Budget Program Activity:Related Strategic Goals:

Trade Analysis2. Balanced Enforcement: Foster economic efficiencies and reliance on marketplace factors by adm

a balanced and equitable manner that redresses excessive anticompetitive actions and restrictive p

3. Efficient Regulatory Process: Promote a timely, efficient and decisive regulatory process, to ena

plan and conduct their operations more effectively and with minimal regulatory costs.

Performance Goal Outcome Performance Indicator Process/Activity 

By 12/31/2000 institute softwareenhancements to the agencyINTERNET service contract filingsystem to assure the long termviability of the system whichreceives the service contractsrequired to be filed by OSRA.

- Improve passwordsecurity.- Facilitate filing.- Assure sufficient systemcapacity.- Enhance retrieval ofcontracts in order to moreefficiently accommodatestatutory requirementsconcerning the filing andreview of service contracts.

- Modify system foradministering passwords.- Enable carriers to efficientlyfile notices to contracts.- Enable both fuzzy and Booleansearch capability suitable/feasible for the users.- Give filers “read only”visibility to the contracts theyfile in their own directories.

- Coordination with Contractor,OMS and OIRM, to assurecompliance with the Statementof Work.- Periodic contact with carriersand Commission staff to capturefeedback from filers and users.

Develop and implement by 1/31/01a more efficient review process toanalyze confidentially filed servicecontracts for competitive problems,potential malpractices, and evidence of a liberalized contractingprocess.

- Elimination ofsignificantly anticompetitiveconcerted or individualcarrier activity that has anegative effect on shippersor U.S. commerce.- Adherence to OSRApolicy objectives.

- Quarterly service contractreview and analysis based onstatistical random sampling.- Review and analysis of servicecontracts upon specificcomplaint.

- Bureau working group ofeconomists & transportationspecialists.- Cooperation with BOE onpotential malpractices.- Ongoing contacts withindustry regarding allegedmalpractices and complaints.
Performance Goal Outcome Performance Indicator Process/Activity 

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By 3/31/01 propose amendment toCommission’s regulations foragreement minutes reporting toclarify filer’s responsibility, and todevelop and implement analternative reporting requirement forcarrier alliances.

- Require only necessaryand useful information fromfiling parties.- Improve Commission’saccess to reports anddocuments used byagreement members in theirdiscussions and decisionmaking.- Increase timeliness ofminutes filing.- Clarify and standardize thelevel of specificity forrequired submissions.- Clarify potential penaltiesfor failure to file minutes.

- Staff recommendation forproposed rule completed by3/31/01.- Commission consideration ofproposed rule.

- Bureau working group ofeconomists & transportationspecialists.- Consult with BOE on legalaspects.- Consult with industryrepresentatives to obtainadditional ideas for periodicreporting process for carrieralliances.
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Budget Program Activity:Related Strategic Goals:

Enforcement1. Compliance: Promote the development of U.S. exports and the efficiency of ocean shipping by e

shipping statutes administered by the FMC. 

2. Balanced Enforcement: Foster economic efficiencies and reliance on marketplace factors by adm

in a balanced and equitable manner that redresses excessive anticompetitive actions and restrictivgovernments.

3. Efficient Regulatory Process: Promote a timely, efficient and decisive regulatory process, to enab

plan and conduct their operations more effectively and with minimal regulatory costs.

Performance Goal Outcome Performance Indicator Process/Activity 

By 3/31/01, create program to moreeffectively identify unlicensed,untariffed or unbonded entities andpromote compliance by OTIs withOSRA’s licensing, bonding & tariffrequirements.

- Improve public protectionby insuring compliance byOTIs providingtransportation services. - Reduction in number ofunlicensed, unbonded,untariffed entities.- Increased compliance withOSRA and regulatoryrequirements.

- Program timely developed andimplemented. - Reduction in complaintsregarding unlicensed, untariffedactivity.- Increase in number of licensedOTIs. 

- Coordinate w/BCCL toidentify licensed and bondedentities.- Audit of licensees andpublished tariffs to determinelevel of compliance. 

Initiate at least 3 actions during FY2001 to address significant marketdistorting activities by VOCCs. 

- Reduce market-distortingeffect of carrier activity.- Serve as deterrent effectfor similar activity.

- Cases initiated. - Increased stability/moreequitable trading conditions ininvolved trades.

- Utilize intelligence, monitoringand information-gatheringtechniques to identify marketdistorting activities.- Respond to shipper complaintsof market-distorting carrieractivity.- Strong reliance on informationgathering by Area Reps. 
Performance Goal Outcome Performance Indicator Process/Activity 

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Throughout FY 2001, whenpossible, resolve issues ofcompliance and informal complaintsby providing regulatory assistanceand encouraging voluntarycompliance and use of ADRresources. 

- Increased understandingand compliance with OSRA requirements and FMCregulations by the shippingpublic and industry.- Improved utilization ofCommission and industryresources.- Increased opportunity toachieve the market-drivenobjectives of OSRA.

- Number of compliance andcomplaint matters resolvedinformally. - Effective use of ADRtechniques and resources. 

- ARs make referrals to BCCLwhenever possible.- ARs and enforcement staffprovide assistance to the publicin complying with regulatoryrequirements.- Encourage voluntarycompliance by shippingindustry.