Topic of the Week (1/12/24):
Welcome back and we're already entering season three! Join us as we catch up on some of the stories we're watching...
The Maritime Professorᵀᴹ presents By Land and By Sea - an attorney breaking down the week in supply chain
with Lauren Beagen (Founder of The Maritime Professorᵀᴹ and Squall Strategies)
Let's dive in...
1 - The Federal Maritime Commission is still working through three rulemakings. No new movements.
2 - The FMC released an industry advisory announcing that common carriers and conferences must provide public access to tariff publication systems free of charge effective Feb 1, 2024.
https://lnkd.in/eaTMf8VR
3 - Revisiting the White House's Fact Sheet on Supply Chain Resiliency including watching the progress of FLOW: Freight Logistics Optimization Works and the U.S. Department of Transportation's Office of Multimodal Freight Infrastructure and Policy and the U.S. Department of Commerce's Supply Chain Center.
4 - A.P. Moller - Maersk has decided to use a land bridge (via rail) instead of using the Canal de Panamá and just about all containerized cargo is forgoing the Red Sea and therefore the Suez Canal. It's time to start sitting up straight and paying closer attention.
-------------------------------
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Transcript
Episode Transcript
Available transcripts are automatically generated. Complete accuracy is not guaranteed.
Lauren Beagen (00:56):
We're back.
Welcome to season three.
Can you believe it?
Season three already Of by landand by sea.
I feel like I just started this, but here we are, the third
year of doing this.
Every week, we break down inreal people terms what's
happening in the world of supplychain.
And man, oh man, the globalocean shipping world can't catch
(01:17):
a break.
Talk about volatile.
Let's break down some of thestuff happening out there.
Let's shake off the cobwebs ofthe holidays and look.
We're going to talk aboutwhether it's time to sell the
farm or not.
It's not, but it might be timeto start paying more attention,
and that's why you tune in here,right?
Hi, welcome by land and by sea.
(01:37):
An attorney breaking down theweekend supply chain presented
by the maritime professor me.
Lauren Beagen, founder of TheMaritime Professor and Squall
Strategies, and I'm yourfavorite maritime attorney, join
me every week as we walkthrough both ocean transport and
surface transport topics in thewild world of supply chain.
As always, the guidance here isgeneral and for educational
(01:58):
purposes only.
It should not be construed tobe legal advice and there's no
attorney client privilegecreated by this video.
If you need an attorney,contact an attorney.
So we usually get into thediscussion of the day, but we go
through the top three storiesof the week.
We're catching up from theholidays, so we're just going to
hit it with captain's logedition.
We're going to be going throughshowcasing the top stories from
(02:21):
the last few weeks andcertainly this week, and that's
where we'll hit it.
I'll sprinkle in somebackground information, but
without further ado, let's getgoing.
Story number one as always,we're watching the federal
maritime commission closely forthe release of any movement on
any of the three open rulemakings.
We didn't see much over theholidays, right, we didn't.
(02:42):
We haven't seen much in a while.
Perhaps today's the day I saythat every Friday we have a by
land and by sea, but but ithasn't happened yet today,
remember.
Let's just kind of take a countof all that we're watching here
.
I'm not going to go through allthe details that we covered
over November and December.
There were a few little thingshere and there that was
happening, but we haven't seenthe final language and that's
(03:03):
what we're waiting on.
So we have three open rulemakings.
We have defining unreasonable orphysical dealer negotiate with
respect to vessel spaceaccommodations provided by an
ocean common carrier.
I bet everybody can say thatentire title with their eyes
closed, not reading off anything.
We don't have anything thereyet.
That was the supplementalnotice of proposed rulemaking.
It was reopened over the summer.
(03:25):
It closed July 2023.
This one is.
This one is is interesting.
If you haven't looked at it yet, I encourage you to look at the
docket here because they theFMC is defining some terms.
I think that it's worth theindustry paying attention on,
because some of thesedefinitions, if not applied in a
(03:45):
precise way, I think could havesome accidental overlap into
other areas.
And so defining unreasonable orfeasible to deal and negotiate
with respect to vessel spaceaccommodations inherently in
there is a reasonablenessdefinition, and I just always
get a little nervous whengeneral terms like
reasonableness are created bydefinition.
(04:08):
So go take a look at it.
That's all I'm saying.
Go take a look at it, check outwhat the FMC has put out in
their last supplemental noticeof proposed rulemaking.
The next round is probablygoing to be a final rule.
I don't know, maybe we're gonnahave another supplemental
notice of proposed rulemaking,but I think we're moving toward
a final rule track on that.
So if there's anything else youhave to say, it looks like
(04:29):
there's certainly stillaccepting late filed comments.
So if there's something burning, send it over, see what happens
, but pay attention to this one.
Even if you don't think thatyou have anything to do with
unreasonable or feasible to dealor negotiate with respect to
vessel space accommodations,take a look at it.
Take a look at the definitions.
The other rule.
The second rule that we'rewatching is billing practices of
(04:50):
detention to merge.
This one has the attention ofthe industry.
I get more comments andquestions on detention to merge,
billing practices rulemaking.
This one last closed upDecember 2022.
So that was a year ago and amonth, so 13 months ago.
This one closed up.
This one had 180 some commentsfiled on it.
They're still probably goingthrough, but this one, as we
(05:12):
highlighted this fall, had alate filed comment from TNI
Transportation andInfrastructure Member
Congressman Jake Ockincloss fromMassachusetts and Brian Babin
from Texas that this one wascalling into question some of
the application of the incentiveprinciple as it relates to
reasonableness of demerge anddetention charges.
That's what the congressmenwere saying.
(05:33):
They think that thisessentially shouldn't be applied
to the MTOs as they think thatthe FMC is kind of applying it.
So I think that we're going toget into a larger discussion of
incentive principle because ofthis.
So what does this mean for thefinal rule of detention to merge
billing practices rule?
I'm not sure.
It's been, like I said, 13months since the comments closed
(05:55):
up on this.
Would there be a supplementalnotice of proposed rulemaking?
Another bite at the apple tosubmit comments?
Perhaps I'm gonna be interestedto see what they say at the
next commission meeting.
If they're gonna talk aboutthis, if they're gonna talk
about some of their plans.
Perhaps we'll get some finallanguage at the next commission
meeting.
We'll see Gonna keep watchingit.
(06:16):
But this is it's gettinginteresting.
I think the longer it takes,the more complicated it could
get.
So at some point they just needto create a final rule, move
forward and say we're gonnafigure it out in case law or
we're gonna figure it out withsupplemental modifications to
the rulemaking or digging in onsome of these smaller issues,
but we gotta get something inthe books here.
So we'll see if we go finallanguage on the next one.
(06:38):
That's where they intended togo.
I think they had intended tohave a final rulemaking out by
now, but they certainly have totake into consideration their
committee, the TransportationInfrastructure Committee of the
House.
They have to take thosecomments into consideration.
The third rulemaking that we'rewatching is defining unfair on
just the discriminatory methods.
The FMC has said that theyincluded some of that in their
(07:01):
unreasonable physical to dealand negotiate Texts that they're
putting out there in thesupplemental notice of proposed
rulemaking, that firstrulemaking.
They're saying that they kindof covered this third one by the
first one.
But we're still waiting ondirect language for defining
unfair on just thediscriminatory methods as a
standalone rulemaking.
We haven't seen anything as astandalone rulemaking, doesn't
(07:23):
even have a docket yet, so stillwaiting on that.
The other thing that we'rewatching is the request for
information.
This was the maritimetransportation data initiative
had an rfi request forinformation.
There's been a talk of aAnother rfi round coming.
We haven't seen anything yetthere.
But I'll keep watching.
I'm just gonna keep watchingall this stuff.
I'll let you know when I seeany movement.
I'll let you know if anythingkind of peaks my interest or if
(07:45):
there's anything interestinghappening.
But that that's where we're at.
I'm gonna keep watching it into2024.
Remember, this was all Createdby the ocean shipping format of
2022, right, so that was signedJune 16th of 2022.
The FMC had actually alreadystarted work on the tension to
merge rulemaking in the springof 2022, where they had released
(08:06):
an advance notice of proposedrulemaking, so an a, n prm.
They had kind of sent somequestions out to the industry
saying we want to dive into dnd.
What do you think?
Congress came around with Osraand said, hey, you should do a
rulemaking on detention to merge.
And the FMC was like Thanks,we're doing so, we're already
doing it.
But then they obviously tookinto consideration what Congress
(08:28):
passed, folded that into theirnext round of the tension to
merge rulemaking, and now herewe are waiting on the final
language.
So that's where kind of all ofthis started the rulemaking's,
the additional rulemaking's, sowhere I'm gonna keep watching it
to see.
Everything was supposed to beclosed up.
The first one making wassupposed to be closed up within
six months.
That became a little bit morecomplicated, be a new one.
(08:48):
So Chairman buffet at the timesaid it's better to get it right
then get it fast.
All of the rulemaking's weresupposed to be closed up within
one year.
We are now a year and a halfpast.
That are a year and a half pastthe signing.
So We'll see, we'll see what'shappening.
I they are still working on it.
They certainly haven't let itgone stagnant, but we are past
(09:11):
that line.
But I'll keep watching.
All right.
Story number two speaking of theFMC, they quietly announced an
industry advisory last weekregarding tariffs and access to
tariffs and I just wanted tobring it to your attention and
kind of, I guess, explain it alittle bit.
So the FMC announced that,pursuant to the rulemaking
finalized on January 2nd 2024 sothey were back at work January
(09:32):
2nd that common carriers andconferences so conferences are
kind of a mostly outdatedconstruct, but.
But common carriers andconferences must provide public
access to their tariffpublication systems.
And here's the change free ofcharge, effective February 1
2024.
So tariffs already have arequirement to be and and this
(09:52):
is from the language unlessotherwise exempted, all common
carriers and conferences shallthis is the language keep open
for public inspection inautomated tariff systems tariff
showing all rates, charges,classifications, rules and
practices between all points orports on their own routes and on
any through transportationroute that has been established.
So there it is in in section 520, 520.3 a, a, presumption of
(10:18):
public inspection, meaningopenly available right, and it
kind of it kind of presumes willonly available should probably
mean free, but it didn'tnecessarily, because if you look
a little bit further intosection 520.
You're going to see section520.9, access to tariffs, and
this is where the modificationwas happening.
But if you look at a 520.9 a,methods to access, the language
(10:43):
that's in the regulation rightnow says carriers and
conferences shall provide accessto their published tariff via a
personal computer.
Okay, a1, dial up connectionvia public switch telephone
networks.
A2, the internet, parentheses,web by, and then the
subcategories is web browser ortelnet session.
(11:05):
This is oddly specific and alsois it starting to feel a little
outdated?
So keeping going down section520.9.
B is dial up connection via PSTand saying the subsection here
the connection option requiresthe tariffs provide A minimum of
(11:27):
14.4 kilobits per second.
Modem capable of receivingincoming calls, smart terminal
capability for VT-100 terminalor terminal emulation access and
telephone line quality for datatransmission.
The last part of this the modemmay be included in a collection
bank of modems as long as allmodems in the bank meet the
(11:49):
minimum speed.
This feels very outdated.
They're talking about dial-upinternet, okay.
So now you're kind ofunderstanding the regulation and
where this regulation was andwhy the FMC might have been
looking at this and why the FMCmight have allowed for a cost
(12:10):
recovery by anybody who neededto be publishing these tariffs,
the conferences or the oceancommon carriers.
So I mean, talk about outdated,right.
So that's what I wanted to kindof highlight here is that this
is kind of an outdated sectionand this gives those people who
needed to, the companies whoneeded to have this public
(12:31):
access to this tariff, a littlebit of a nod in that, look, it
used to cost money to publishthese things on the internet.
I mean, for the most part nowit doesn't, right?
You can just put it on awebsite.
Minimal, right.
It might be minimal, butcompared to what it used to cost
, and this is more than 20 yearsold, right.
(12:51):
So exactly what's changing here?
The commission amended itsregulations to remove the option
to charge a fee for tariffaccess currently found in that
same section 520.9.
It was subsection E3.
So it used to say carriers andconferences may assess a
reasonable fee for access totheir tariff publication systems
and such fees shall not bediscriminatory.
(13:12):
And so basically that's what itwas was saying look, it might
cost money.
We don't want this to bedelimiting on your ability to
provide public access to yourtariff and your tariff
publication systems.
And so that's what it used tosay is, you can charge kind of
small fee and it can't bediscriminatory.
Now it doesn't right.
That's what got eliminated.
They eliminated that sectionsaying carriers and conferences
(13:34):
may assess a reasonable fee andthey eliminated that.
There was some discussion in thedocket about the justification
for charging a minimal fee andwallet partially hinged on the
outdated nature.
There was also some talk aboutreasonable charge for access
tariffs, but the FMC kind ofdispelled that in the final rule
language, basically saying itdidn't find any of the arguments
(13:55):
large enough to say that it wasdebilitating, the amount that
was being charged by some ofthese tariff publishing
companies wasn't debilitating tothe member or the person who
was filing the commenter, andthat they said they didn't find
the argument compelling enough.
I think is the language thatthey used or making that
(14:17):
argument that this wasdebilitating, that now they
weren't able to publicly publishthat tariff because of how much
they have to pay this thirdparty tariff publishing system.
So I don't know, this is this.
I think it really relates moreto the outdatedness of the
section.
Right, they're talking aboutdial up internet and how it used
(14:40):
to cost potentially prohibitiveamounts of money, and so the
FMC at the time said okay, youcan pass a reasonable fee on to
the users, but it still needs tobe considered publicly
available.
Now they're saying look, itdoesn't cost that much, it's,
it's, unless we got commentssaying that it was prohibitive,
and that's what they're sayingin this final rule.
We didn't get comments thatsaid it was prohibitive to
(15:01):
publish it in a free and fairlyavailable and freely available
way.
They're eliminating thatsection.
The rule also amended a fewother things that I wanted to
bring to your attention.
I'm not going to go too farinto it, but I did want to bring
it to your attention just sothat you know that it was in
this rule, because I think theattention on this rule was about
the free nature of tariffpublishing, but I wanted you to
(15:23):
notice that there was also.
There were also a few otherthings that were referenced in
this rule, and so they relate.
The rule also talked aboutcross referencing tariffs.
I talked about charges passedthrough by NVOCC's to NVOCC's,
by VOCC's, and it also talkedabout co loaded cargo.
So while it's important toreview the rule, if you have
anything to do with thepublishing of tariffs and
(15:45):
they're now requirements forfree access, it's also important
to take a look at this rule ifyou have anything to do with
these other categories withinthe rule.
It gets a little nuanced, sothat's why I chose not to kind
of go into it too far today.
But I wanted you to know.
Cross referencing tariffs,charges passed through by to
NVOCC's by VOCC's and co loadedcargo are the other topics that
are covered in this rulemaking.
(16:06):
Take a look at it.
But that I wanted to give youthat kind of background.
Look, it wasn't so much as theywere trying to take away the
ability to charge.
It was that you're required tohave these tariffs publicly
available, and now you'rerequired to have them freely and
publicly available, all right.
So story number three at the endof November, the White House
(16:28):
made a bunch of announcementsabout the supply chain and
initiatives that the Bidenadministration had undertaken or
plans to undertake still duringhis tenure.
Again, as we're shaking off theholiday cobwebs, I wanted to
kind of bring some of these backto top of mind as things that
we're watching in 2024.
So the creation on the Councilof Supply Chain Resilience so
this is a Council co-chaired bythe National Security Advisor
(16:50):
and National Economic Advisorand is basically including, I
mean, all cabinet members.
It looks like you haveSecretaries of Agriculture,
commerce, defense, energy,health and Human Services.
I mean the list is quitelengthy here, so go back and
check the overall fact sheet.
I think is what they calledthis announcement.
They also are in thisannouncement talking about using
(17:14):
the Defense Production Act tomake more essential medicines in
America and mitigate drugshortages.
As it relates to supply chain,they're also talking about in
this announcement a newcross-governmental supply chain
data sharing capabilities.
So this is the Department ofCommerce's new first of its kind
is what the announcement saidSupply Chain Center, which is
integrating industry expertiseand data analytics to develop
(17:37):
innovative supply chain riskassessment tools and is
coordinating deep dive analyseson select critical supply chains
to drive targeted actions toincrease resilience.
And I think that's going to bethe name of the game throughout.
What the administration islooking for is this supply chain
resilience and the health ofthe supply chain, so that we
don't get into a situation in2021 where we had this just
(18:01):
massive COVID congestion backup.
We want to create a little bitmore.
It sounds like future proofingof these supply chains through
some of these initiatives.
Another one that they mentionedis the Department of
Transportation's freightlogistics optimization works
Flow.
We've talked about Flow a fewdifferent times before.
They were making a bigannouncement and push for that
(18:21):
in kind of that Thanksgivingholiday, christmas time Watch
Flow.
I think Flow is reallyinteresting.
I think it's a pretty cooleffort.
It's continuing to mature.
As they said in theannouncement, it's a
public-private partnership thatbrings together US supply chain
stakeholders to create, asthey're saying, a shared common
picture of supply chain networksand facilitate a more reliable
flow of goods.
And it announced a milestonesaying that participants are
(18:44):
beginning to utilize Flow datato inform their logistics
decision making, helping toavoid bottlenecks, shorten lead
times for customers and enable amore resilient and globally
competitive freight network.
The earlier warnings of supplychain disruptions.
I think that this is going tobe something interesting to
watch.
I think that Flow it's just aninteresting overall initiative
(19:05):
Going down the rest of the factsheet and I'm kind of hopping
around here, but there was a newresilience center and tabletop
exercise for supply chaindisruptions.
That's going to be with theDepartment of Homeland Security
and the launch of a new supplychain resilience center which
the announcement said will bededicated to ensuring the
resilience of supply chains forcritical infrastructure needed
to deliver essential services tothe American people.
(19:27):
Again, it looks like they'retying some of the security side
of things.
They're tying it to drugshortages and that sort of thing
, but they're kind of going inon content-based supply chain
resiliency as well as generaloverall supply chain resiliency.
We talked about this and a fewdifferent times we've talked
(19:49):
about the launch of the DOTmultimodal freight office as
part of the bipartisaninfrastructure law.
We talked about implementationDOT launched and we've been
watching and waiting for it fora while.
This office of multimodalfreight infrastructure and
policy that is where Flow iskind of being run through.
It said the continuedadvancement of the Flow
initiative in partnership withthe Bureau of Transportation
(20:11):
Statistics.
We also will see.
The office will be responsiblefor maintaining and improving
the condition and performance ofthe nation's multimodal freight
network, including through thedevelopment of the National
Multimodal Freight Networkreview of state freight plans.
It looks like it's notnecessarily a standalone office.
(20:34):
It looks like it's actuallyhoused under the office of the
Undersecretary for Policy, andthey named the Deputy Assistant
Secretary for Multimodal Policyas Alison Dane Camden.
I think that we're going to seea lot of great things coming out
of this office.
I'm certainly going to bewatching to see what happens.
Flow is one of the initiatives,like I said within it, but some
of these other things thatthey've been tasked with I think
(20:55):
are going to be hopefullyhelpful for the overall US
supply chain resilience and kindof future proofing.
Another thing that we'rewatching is the supply chain
data and analytics summit.
There isn't a lot ofinformation out there yet, but
what this overall fact sheetfrom the White House said is
that there is an aim to have asupply chain data and analytics
(21:16):
summit sometime in 2024.
They said that the key aim ofthe summit will be to invite
expert input into supply chainrisk assessment models and tools
.
As I learn more, I'll keepfollowing this, but this one, I
think this will be interesting.
There were two previous summitsheld and I think that this one
is going to be like it says it'sgoing to be talking more about
the data and analytics side ofthings.
(21:38):
So let's keep watching.
But I wanted to bring this factsheet back up top of mind so
that you know what the WhiteHouse and the administration is
looking to continue movement onin the supply chain realm in
2024.
So story number four we'realready hitting a lot of stuff,
right.
So story number four is thePanama Canal.
(21:58):
It's still here, it's still inthe news.
Certainly, the Red Sea has cometop of mind with the Suez Canal
, but the Panama Canal is stillaround.
We've been reporting on itsince last spring and although
in the fall I kind of kepteveryone in the loop on the
different decisions that thecanal authority was deciding due
to the drought, one of thosewas that they were going to be
(22:19):
dropping their vessel transitsfrom 36 to 18.
Now I've been hearing thatthey're going to be upping that
to 20 vessel transits startingFebruary 1st.
But actually just yesterdayMerisk has decided to take
matters into their own hands andannounce that they would be
embarking on a land bridge, kindof foregoing the Panama Canal
entirely and using rail to takethe cargo across that same route
(22:40):
.
I kept saying through the fallespecially, and through kind of
early winter, that this isn't ared alert moment yet.
I still don't think it is, butI do think that this, paired
with the Red Sea troubles, it'stime to start paying attention
and perhaps start planning yourcontingency plans for congestion
.
It's been forecasted that theoperational routing problems of
(23:01):
the blocking or the inability totransit freely both the Panama
Canal and the Suez Canal mightlead to equipment imbalances is
what I've been reading.
I'm not sure if it will or ifit won't.
That's ultimately for you andyour company to decide if that's
something that you are going tobe making any changes because
of.
But these stressors on the oceanshipping system, I mean, I
(23:24):
don't see quick fixes right,they certainly haven't been
quick fixed yet and they don'tseem to be going away in short
order either.
And the longer the system isstressed, the worse it really is
for everybody, right?
So time is often, as they say,equals money, right, time equals
money.
And these are going to take alittle bit longer to get to
places if the two main canalsthat help these vessels avoid
(23:44):
the extra long trips aroundSouth America and the Horn of
Africa are unavailable for thesufficient transit.
So I'm sure you've beenwatching the Red Sea.
It continues to be a problemfor commercial containerized
vessels, with the attacks fromthe Houtti militants on vessels
traversing the Red Sea.
Since the new year, we've had alot of experts in the field
giving daily reports on the RedSea.
There's some nuances there, soI'm not going to go too far into
(24:07):
details here.
I'd be remiss if I didn'tmention the Red Sea and the
impacts that it is having on theSuez Canal.
If you haven't been payingattention, it's time to start
paying attention to that.
This is going to be, as I'veread, directly affecting Asia to
Europe and vice versa, but itis going to have a knock on
effect for the rest of the oceanshipping, as we've always seen.
(24:27):
It is one large global oceanshipping ecosystem and, like I
said, there's been someforecasting that this might
impact operational shortages andcreate imbalances of equipment
within the overall ecosystem.
Look, we've had a few dayswhere commercial container ocean
carriers tried the Red Seaagain, but at least for now, it
(24:48):
appears that all majorcommercial cargo movements have
really ceased in that area,Except for a few, and even so,
I'm reading that even some ofthe few commercial vessel
movements that have beenhappening are actually signaling
through, I believe, is AIS data.
They say all Chinese crew orthey're signaling no connection
to Israel.
It's interesting, right?
(25:10):
This is very interesting.
This is very nuanced.
I don't want to do an injusticeby not covering it
appropriately, but I do want tocall your attention to it.
The Panama Canal continues to bea problem because of the
drought that's happening in theregion.
Unless they get a lot of rain,that's not going to change
anytime soon and the Houtimilitants that are affecting and
(25:33):
impacting the Red Sea so thatthe vessels can't transit.
The area going through the Suezcontinues to be a problem and
will continue to delay thevessels.
I mean, that's a no-go rightnow.
It feels like for most,although it seems that there's
maybe some strange exceptions,some exceptions happening in the
area.
The Panama Canal at least stillhas some vessel transit, but
(25:57):
with the vessel number reduction.
Previously it was a draftreduction, now it is a vessel
number reduction.
So that makes it more impactfulto, I'd say, containerized
cargo than previously, becausecontainerized cargo doesn't pull
the same draft as some of thesebulk carriers do, and so, while
the draft seemed to have moreimpact on the bulk carriers, the
(26:19):
vessel numbers transitingthrough, I think, creates that
potential for the containercargo movement to be a little
bit more impacted.
A lot going on right.
This was just to help you kindof shake off the cobwebs, like I
said, from the holiday.
We're gonna continue to watchall of this.
I'm gonna try to make sense ofit all.
(26:40):
Like I said, there's a lot ofexperts out there that are
diving into even daily updateson the Red Sea, so continue to
watch them.
I'm gonna pull anything that Ithink is particularly notable or
something that you should bewatching or something that needs
a little bit of translating.
Please let me know if there'sanything during season three
that you want me to hit a littlebit more.
Do you enjoy these captain'slog additions better than diving
(27:02):
deeper into some of theseissues?
Should I keep the deeper divesfor really interesting things or
, I guess, suggested questionsthat you have?
I'll keep going pretty much howwe've gone before.
I'm gonna try to introduce afew more interviews throughout
this new year and this newseason, but look, that's it for
(27:22):
today.
Keep it tuned here for all ofyour industry highlights from
the week and the littlesprinkler of their background
information that I like to bringin.
As always, though, the guidancehere is general.
For educational purposes.
It should not be construed tobe legal advice directly related
to your matter.
If you need an attorney,contact an attorney, but if you
do have specific legal questions, feel free to reach out to meet
my legal company, SquallStrategies.
(27:44):
Otherwise, for the non-legalquestions, the e-learning, the
general industry information andinsights, come find me at the
Maritime Professor.
If you like these videos, letme know, comment, like and share
.
If you wanna listen to theseepisodes on demand, or if you
missed any previous episodes,check out the podcast By Land
and By Sea and if you prefer tosee the video, they live on my
YouTube page By Land and By Sea,presented by the Maritime
Professor.
(28:04):
While you're at it, check outthe website TheMaritimeProfessor
.
com.
There's gonna be some new stuffhappening in 2024 over there,
so definitely get on our emaillist.
So until next week.
This is Lauren Beagen, theMaritime Professor, and you've
just listened to By Land and BySea.
See you next time.
We're back.
Welcome to season three.
Can you believe it?
Season three already Of by landand by sea.
I feel like I just started this, but here we are, the third
year of doing this.
Every week, we break down inreal people terms what's
happening in the world of supplychain.
And man, oh man, the globalocean shipping world can't catch
(01:17):
a break.
Talk about volatile.
Let's break down some of thestuff happening out there.
Let's shake off the cobwebs ofthe holidays and look.
We're going to talk aboutwhether it's time to sell the
farm or not.
It's not, but it might be timeto start paying more attention,
and that's why you tune in here,right?
Hi, welcome by land and by sea.
(01:37):
An attorney breaking down theweekend supply chain presented
by the maritime professor me.
Lauren Beagen, founder of TheMaritime Professor and Squall
Strategies, and I'm yourfavorite maritime attorney, join
me every week as we walkthrough both ocean transport and
surface transport topics in thewild world of supply chain.
As always, the guidance here isgeneral and for educational
(01:58):
purposes only.
It should not be construed tobe legal advice and there's no
attorney client privilegecreated by this video.
If you need an attorney,contact an attorney.
So we usually get into thediscussion of the day, but we go
through the top three storiesof the week.
We're catching up from theholidays, so we're just going to
hit it with captain's logedition.
We're going to be going throughshowcasing the top stories from
(02:21):
the last few weeks andcertainly this week, and that's
where we'll hit it.
I'll sprinkle in somebackground information, but
without further ado, let's getgoing.
Story number one as always,we're watching the federal
maritime commission closely forthe release of any movement on
any of the three open rulemakings.
We didn't see much over theholidays, right, we didn't.
(02:42):
We haven't seen much in a while.
Perhaps today's the day I saythat every Friday we have a by
land and by sea, but but ithasn't happened yet today,
remember.
Let's just kind of take a countof all that we're watching here
.
I'm not going to go through allthe details that we covered
over November and December.
There were a few little thingshere and there that was
happening, but we haven't seenthe final language and that's
(03:03):
what we're waiting on.
So we have three open rulemakings.
We have defining unreasonable orphysical dealer negotiate with
respect to vessel spaceaccommodations provided by an
ocean common carrier.
I bet everybody can say thatentire title with their eyes
closed, not reading off anything.
We don't have anything thereyet.
That was the supplementalnotice of proposed rulemaking.
It was reopened over the summer.
(03:25):
It closed July 2023.
This one is.
This one is is interesting.
If you haven't looked at it yet, I encourage you to look at the
docket here because they theFMC is defining some terms.
I think that it's worth theindustry paying attention on,
because some of thesedefinitions, if not applied in a
(03:45):
precise way, I think could havesome accidental overlap into
other areas.
And so defining unreasonable orfeasible to deal and negotiate
with respect to vessel spaceaccommodations inherently in
there is a reasonablenessdefinition, and I just always
get a little nervous whengeneral terms like
reasonableness are created bydefinition.
(04:08):
So go take a look at it.
That's all I'm saying.
Go take a look at it, check outwhat the FMC has put out in
their last supplemental noticeof proposed rulemaking.
The next round is probablygoing to be a final rule.
I don't know, maybe we're gonnahave another supplemental
notice of proposed rulemaking,but I think we're moving toward
a final rule track on that.
So if there's anything else youhave to say, it looks like
(04:29):
there's certainly stillaccepting late filed comments.
So if there's something burning, send it over, see what happens
, but pay attention to this one.
Even if you don't think thatyou have anything to do with
unreasonable or feasible to dealor negotiate with respect to
vessel space accommodations,take a look at it.
Take a look at the definitions.
The other rule.
The second rule that we'rewatching is billing practices of
(04:50):
detention to merge.
This one has the attention ofthe industry.
I get more comments andquestions on detention to merge,
billing practices rulemaking.
This one last closed upDecember 2022.
So that was a year ago and amonth, so 13 months ago.
This one closed up.
This one had 180 some commentsfiled on it.
They're still probably goingthrough, but this one, as we
(05:12):
highlighted this fall, had alate filed comment from TNI
Transportation andInfrastructure Member
Congressman Jake Ockincloss fromMassachusetts and Brian Babin
from Texas that this one wascalling into question some of
the application of the incentiveprinciple as it relates to
reasonableness of demerge anddetention charges.
That's what the congressmenwere saying.
(05:33):
They think that thisessentially shouldn't be applied
to the MTOs as they think thatthe FMC is kind of applying it.
So I think that we're going toget into a larger discussion of
incentive principle because ofthis.
So what does this mean for thefinal rule of detention to merge
billing practices rule?
I'm not sure.
It's been, like I said, 13months since the comments closed
(05:55):
up on this.
Would there be a supplementalnotice of proposed rulemaking?
Another bite at the apple tosubmit comments?
Perhaps I'm gonna be interestedto see what they say at the
next commission meeting.
If they're gonna talk aboutthis, if they're gonna talk
about some of their plans.
Perhaps we'll get some finallanguage at the next commission
meeting.
We'll see Gonna keep watchingit.
(06:16):
But this is it's gettinginteresting.
I think the longer it takes,the more complicated it could
get.
So at some point they just needto create a final rule, move
forward and say we're gonnafigure it out in case law or
we're gonna figure it out withsupplemental modifications to
the rulemaking or digging in onsome of these smaller issues,
but we gotta get something inthe books here.
So we'll see if we go finallanguage on the next one.
(06:38):
That's where they intended togo.
I think they had intended tohave a final rulemaking out by
now, but they certainly have totake into consideration their
committee, the TransportationInfrastructure Committee of the
House.
They have to take thosecomments into consideration.
The third rulemaking that we'rewatching is defining unfair on
just the discriminatory methods.
The FMC has said that theyincluded some of that in their
(07:01):
unreasonable physical to dealand negotiate Texts that they're
putting out there in thesupplemental notice of proposed
rulemaking, that firstrulemaking.
They're saying that they kindof covered this third one by the
first one.
But we're still waiting ondirect language for defining
unfair on just thediscriminatory methods as a
standalone rulemaking.
We haven't seen anything as astandalone rulemaking, doesn't
(07:23):
even have a docket yet, so stillwaiting on that.
The other thing that we'rewatching is the request for
information.
This was the maritimetransportation data initiative
had an rfi request forinformation.
There's been a talk of aAnother rfi round coming.
We haven't seen anything yetthere.
But I'll keep watching.
I'm just gonna keep watchingall this stuff.
I'll let you know when I seeany movement.
I'll let you know if anythingkind of peaks my interest or if
(07:45):
there's anything interestinghappening.
But that that's where we're at.
I'm gonna keep watching it into2024.
Remember, this was all Createdby the ocean shipping format of
2022, right, so that was signedJune 16th of 2022.
The FMC had actually alreadystarted work on the tension to
merge rulemaking in the springof 2022, where they had released
(08:06):
an advance notice of proposedrulemaking, so an a, n prm.
They had kind of sent somequestions out to the industry
saying we want to dive into dnd.
What do you think?
Congress came around with Osraand said, hey, you should do a
rulemaking on detention to merge.
And the FMC was like Thanks,we're doing so, we're already
doing it.
But then they obviously tookinto consideration what Congress
(08:28):
passed, folded that into theirnext round of the tension to
merge rulemaking, and now herewe are waiting on the final
language.
So that's where kind of all ofthis started the rulemaking's,
the additional rulemaking's, sowhere I'm gonna keep watching it
to see.
Everything was supposed to beclosed up.
The first one making wassupposed to be closed up within
six months.
That became a little bit morecomplicated, be a new one.
(08:48):
So Chairman buffet at the timesaid it's better to get it right
then get it fast.
All of the rulemaking's weresupposed to be closed up within
one year.
We are now a year and a halfpast.
That are a year and a half pastthe signing.
So We'll see, we'll see what'shappening.
I they are still working on it.
They certainly haven't let itgone stagnant, but we are past
(09:11):
that line.
But I'll keep watching.
All right.
Story number two speaking of theFMC, they quietly announced an
industry advisory last weekregarding tariffs and access to
tariffs and I just wanted tobring it to your attention and
kind of, I guess, explain it alittle bit.
So the FMC announced that,pursuant to the rulemaking
finalized on January 2nd 2024 sothey were back at work January
(09:32):
2nd that common carriers andconferences so conferences are
kind of a mostly outdatedconstruct, but.
But common carriers andconferences must provide public
access to their tariffpublication systems.
And here's the change free ofcharge, effective February 1
2024.
So tariffs already have arequirement to be and and this
(09:52):
is from the language unlessotherwise exempted, all common
carriers and conferences shallthis is the language keep open
for public inspection inautomated tariff systems tariff
showing all rates, charges,classifications, rules and
practices between all points orports on their own routes and on
any through transportationroute that has been established.
So there it is in in section 520, 520.3 a, a, presumption of
(10:18):
public inspection, meaningopenly available right, and it
kind of it kind of presumes willonly available should probably
mean free, but it didn'tnecessarily, because if you look
a little bit further intosection 520.
You're going to see section520.9, access to tariffs, and
this is where the modificationwas happening.
But if you look at a 520.9 a,methods to access, the language
(10:43):
that's in the regulation rightnow says carriers and
conferences shall provide accessto their published tariff via a
personal computer.
Okay, a1, dial up connectionvia public switch telephone
networks.
A2, the internet, parentheses,web by, and then the
subcategories is web browser ortelnet session.
(11:05):
This is oddly specific and alsois it starting to feel a little
outdated?
So keeping going down section520.9.
B is dial up connection via PSTand saying the subsection here
the connection option requiresthe tariffs provide A minimum of
(11:27):
14.4 kilobits per second.
Modem capable of receivingincoming calls, smart terminal
capability for VT-100 terminalor terminal emulation access and
telephone line quality for datatransmission.
The last part of this the modemmay be included in a collection
bank of modems as long as allmodems in the bank meet the
(11:49):
minimum speed.
This feels very outdated.
They're talking about dial-upinternet, okay.
So now you're kind ofunderstanding the regulation and
where this regulation was andwhy the FMC might have been
looking at this and why the FMCmight have allowed for a cost
(12:10):
recovery by anybody who neededto be publishing these tariffs,
the conferences or the oceancommon carriers.
So I mean, talk about outdated,right.
So that's what I wanted to kindof highlight here is that this
is kind of an outdated sectionand this gives those people who
needed to, the companies whoneeded to have this public
(12:31):
access to this tariff, a littlebit of a nod in that, look, it
used to cost money to publishthese things on the internet.
I mean, for the most part nowit doesn't, right?
You can just put it on awebsite.
Minimal, right.
It might be minimal, butcompared to what it used to cost
, and this is more than 20 yearsold, right.
(12:51):
So exactly what's changing here?
The commission amended itsregulations to remove the option
to charge a fee for tariffaccess currently found in that
same section 520.9.
It was subsection E3.
So it used to say carriers andconferences may assess a
reasonable fee for access totheir tariff publication systems
and such fees shall not bediscriminatory.
(13:12):
And so basically that's what itwas was saying look, it might
cost money.
We don't want this to bedelimiting on your ability to
provide public access to yourtariff and your tariff
publication systems.
And so that's what it used tosay is, you can charge kind of
small fee and it can't bediscriminatory.
Now it doesn't right.
That's what got eliminated.
They eliminated that sectionsaying carriers and conferences
(13:34):
may assess a reasonable fee andthey eliminated that.
There was some discussion in thedocket about the justification
for charging a minimal fee andwallet partially hinged on the
outdated nature.
There was also some talk aboutreasonable charge for access
tariffs, but the FMC kind ofdispelled that in the final rule
language, basically saying itdidn't find any of the arguments
(13:55):
large enough to say that it wasdebilitating, the amount that
was being charged by some ofthese tariff publishing
companies wasn't debilitating tothe member or the person who
was filing the commenter, andthat they said they didn't find
the argument compelling enough.
I think is the language thatthey used or making that
(14:17):
argument that this wasdebilitating, that now they
weren't able to publicly publishthat tariff because of how much
they have to pay this thirdparty tariff publishing system.
So I don't know, this is this.
I think it really relates moreto the outdatedness of the
section.
Right, they're talking aboutdial up internet and how it used
(14:40):
to cost potentially prohibitiveamounts of money, and so the
FMC at the time said okay, youcan pass a reasonable fee on to
the users, but it still needs tobe considered publicly
available.
Now they're saying look, itdoesn't cost that much, it's,
it's, unless we got commentssaying that it was prohibitive,
and that's what they're sayingin this final rule.
We didn't get comments thatsaid it was prohibitive to
(15:01):
publish it in a free and fairlyavailable and freely available
way.
They're eliminating thatsection.
The rule also amended a fewother things that I wanted to
bring to your attention.
I'm not going to go too farinto it, but I did want to bring
it to your attention just sothat you know that it was in
this rule, because I think theattention on this rule was about
the free nature of tariffpublishing, but I wanted you to
(15:23):
notice that there was also.
There were also a few otherthings that were referenced in
this rule, and so they relate.
The rule also talked aboutcross referencing tariffs.
I talked about charges passedthrough by NVOCC's to NVOCC's,
by VOCC's, and it also talkedabout co loaded cargo.
So while it's important toreview the rule, if you have
anything to do with thepublishing of tariffs and
(15:45):
they're now requirements forfree access, it's also important
to take a look at this rule ifyou have anything to do with
these other categories withinthe rule.
It gets a little nuanced, sothat's why I chose not to kind
of go into it too far today.
But I wanted you to know.
Cross referencing tariffs,charges passed through by to
NVOCC's by VOCC's and co loadedcargo are the other topics that
are covered in this rulemaking.
(16:06):
Take a look at it.
But that I wanted to give youthat kind of background.
Look, it wasn't so much as theywere trying to take away the
ability to charge.
It was that you're required tohave these tariffs publicly
available, and now you'rerequired to have them freely and
publicly available, all right.
So story number three at the endof November, the White House
(16:28):
made a bunch of announcementsabout the supply chain and
initiatives that the Bidenadministration had undertaken or
plans to undertake still duringhis tenure.
Again, as we're shaking off theholiday cobwebs, I wanted to
kind of bring some of these backto top of mind as things that
we're watching in 2024.
So the creation on the Councilof Supply Chain Resilience so
this is a Council co-chaired bythe National Security Advisor
(16:50):
and National Economic Advisorand is basically including, I
mean, all cabinet members.
It looks like you haveSecretaries of Agriculture,
commerce, defense, energy,health and Human Services.
I mean the list is quitelengthy here, so go back and
check the overall fact sheet.
I think is what they calledthis announcement.
They also are in thisannouncement talking about using
(17:14):
the Defense Production Act tomake more essential medicines in
America and mitigate drugshortages.
As it relates to supply chain,they're also talking about in
this announcement a newcross-governmental supply chain
data sharing capabilities.
So this is the Department ofCommerce's new first of its kind
is what the announcement saidSupply Chain Center, which is
integrating industry expertiseand data analytics to develop
(17:37):
innovative supply chain riskassessment tools and is
coordinating deep dive analyseson select critical supply chains
to drive targeted actions toincrease resilience.
And I think that's going to bethe name of the game throughout.
What the administration islooking for is this supply chain
resilience and the health ofthe supply chain, so that we
don't get into a situation in2021 where we had this just
(18:01):
massive COVID congestion backup.
We want to create a little bitmore.
It sounds like future proofingof these supply chains through
some of these initiatives.
Another one that they mentionedis the Department of
Transportation's freightlogistics optimization works
Flow.
We've talked about Flow a fewdifferent times before.
They were making a bigannouncement and push for that
(18:21):
in kind of that Thanksgivingholiday, christmas time Watch
Flow.
I think Flow is reallyinteresting.
I think it's a pretty cooleffort.
It's continuing to mature.
As they said in theannouncement, it's a
public-private partnership thatbrings together US supply chain
stakeholders to create, asthey're saying, a shared common
picture of supply chain networksand facilitate a more reliable
flow of goods.
And it announced a milestonesaying that participants are
(18:44):
beginning to utilize Flow datato inform their logistics
decision making, helping toavoid bottlenecks, shorten lead
times for customers and enable amore resilient and globally
competitive freight network.
The earlier warnings of supplychain disruptions.
I think that this is going tobe something interesting to
watch.
I think that Flow it's just aninteresting overall initiative
(19:05):
Going down the rest of the factsheet and I'm kind of hopping
around here, but there was a newresilience center and tabletop
exercise for supply chaindisruptions.
That's going to be with theDepartment of Homeland Security
and the launch of a new supplychain resilience center which
the announcement said will bededicated to ensuring the
resilience of supply chains forcritical infrastructure needed
to deliver essential services tothe American people.
(19:27):
Again, it looks like they'retying some of the security side
of things.
They're tying it to drugshortages and that sort of thing
, but they're kind of going inon content-based supply chain
resiliency as well as generaloverall supply chain resiliency.
We talked about this and a fewdifferent times we've talked
(19:49):
about the launch of the DOTmultimodal freight office as
part of the bipartisaninfrastructure law.
We talked about implementationDOT launched and we've been
watching and waiting for it fora while.
This office of multimodalfreight infrastructure and
policy that is where Flow iskind of being run through.
It said the continuedadvancement of the Flow
initiative in partnership withthe Bureau of Transportation
(20:11):
Statistics.
We also will see.
The office will be responsiblefor maintaining and improving
the condition and performance ofthe nation's multimodal freight
network, including through thedevelopment of the National
Multimodal Freight Networkreview of state freight plans.
It looks like it's notnecessarily a standalone office.
(20:34):
It looks like it's actuallyhoused under the office of the
Undersecretary for Policy, andthey named the Deputy Assistant
Secretary for Multimodal Policyas Alison Dane Camden.
I think that we're going to seea lot of great things coming out
of this office.
I'm certainly going to bewatching to see what happens.
Flow is one of the initiatives,like I said within it, but some
of these other things thatthey've been tasked with I think
(20:55):
are going to be hopefullyhelpful for the overall US
supply chain resilience and kindof future proofing.
Another thing that we'rewatching is the supply chain
data and analytics summit.
There isn't a lot ofinformation out there yet, but
what this overall fact sheetfrom the White House said is
that there is an aim to have asupply chain data and analytics
(21:16):
summit sometime in 2024.
They said that the key aim ofthe summit will be to invite
expert input into supply chainrisk assessment models and tools
.
As I learn more, I'll keepfollowing this, but this one, I
think this will be interesting.
There were two previous summitsheld and I think that this one
is going to be like it says it'sgoing to be talking more about
the data and analytics side ofthings.
(21:38):
So let's keep watching.
But I wanted to bring this factsheet back up top of mind so
that you know what the WhiteHouse and the administration is
looking to continue movement onin the supply chain realm in
2024.
So story number four we'realready hitting a lot of stuff,
right.
So story number four is thePanama Canal.
(21:58):
It's still here, it's still inthe news.
Certainly, the Red Sea has cometop of mind with the Suez Canal
, but the Panama Canal is stillaround.
We've been reporting on itsince last spring and although
in the fall I kind of kepteveryone in the loop on the
different decisions that thecanal authority was deciding due
to the drought, one of thosewas that they were going to be
(22:19):
dropping their vessel transitsfrom 36 to 18.
Now I've been hearing thatthey're going to be upping that
to 20 vessel transits startingFebruary 1st.
But actually just yesterdayMerisk has decided to take
matters into their own hands andannounce that they would be
embarking on a land bridge, kindof foregoing the Panama Canal
entirely and using rail to takethe cargo across that same route
(22:40):
.
I kept saying through the fallespecially, and through kind of
early winter, that this isn't ared alert moment yet.
I still don't think it is, butI do think that this, paired
with the Red Sea troubles, it'stime to start paying attention
and perhaps start planning yourcontingency plans for congestion
.
It's been forecasted that theoperational routing problems of
(23:01):
the blocking or the inability totransit freely both the Panama
Canal and the Suez Canal mightlead to equipment imbalances is
what I've been reading.
I'm not sure if it will or ifit won't.
That's ultimately for you andyour company to decide if that's
something that you are going tobe making any changes because
of.
But these stressors on the oceanshipping system, I mean, I
(23:24):
don't see quick fixes right,they certainly haven't been
quick fixed yet and they don'tseem to be going away in short
order either.
And the longer the system isstressed, the worse it really is
for everybody, right?
So time is often, as they say,equals money, right, time equals
money.
And these are going to take alittle bit longer to get to
places if the two main canalsthat help these vessels avoid
(23:44):
the extra long trips aroundSouth America and the Horn of
Africa are unavailable for thesufficient transit.
So I'm sure you've beenwatching the Red Sea.
It continues to be a problemfor commercial containerized
vessels, with the attacks fromthe Houtti militants on vessels
traversing the Red Sea.
Since the new year, we've had alot of experts in the field
giving daily reports on the RedSea.
There's some nuances there, soI'm not going to go too far into
(24:07):
details here.
I'd be remiss if I didn'tmention the Red Sea and the
impacts that it is having on theSuez Canal.
If you haven't been payingattention, it's time to start
paying attention to that.
This is going to be, as I'veread, directly affecting Asia to
Europe and vice versa, but itis going to have a knock on
effect for the rest of the oceanshipping, as we've always seen.
(24:27):
It is one large global oceanshipping ecosystem and, like I
said, there's been someforecasting that this might
impact operational shortages andcreate imbalances of equipment
within the overall ecosystem.
Look, we've had a few dayswhere commercial container ocean
carriers tried the Red Seaagain, but at least for now, it
(24:48):
appears that all majorcommercial cargo movements have
really ceased in that area,Except for a few, and even so,
I'm reading that even some ofthe few commercial vessel
movements that have beenhappening are actually signaling
through, I believe, is AIS data.
They say all Chinese crew orthey're signaling no connection
to Israel.
It's interesting, right?
(25:10):
This is very interesting.
This is very nuanced.
I don't want to do an injusticeby not covering it
appropriately, but I do want tocall your attention to it.
The Panama Canal continues to bea problem because of the
drought that's happening in theregion.
Unless they get a lot of rain,that's not going to change
anytime soon and the Houtimilitants that are affecting and
(25:33):
impacting the Red Sea so thatthe vessels can't transit.
The area going through the Suezcontinues to be a problem and
will continue to delay thevessels.
I mean, that's a no-go rightnow.
It feels like for most,although it seems that there's
maybe some strange exceptions,some exceptions happening in the
area.
The Panama Canal at least stillhas some vessel transit, but
(25:57):
with the vessel number reduction.
Previously it was a draftreduction, now it is a vessel
number reduction.
So that makes it more impactfulto, I'd say, containerized
cargo than previously, becausecontainerized cargo doesn't pull
the same draft as some of thesebulk carriers do, and so, while
the draft seemed to have moreimpact on the bulk carriers, the
(26:19):
vessel numbers transitingthrough, I think, creates that
potential for the containercargo movement to be a little
bit more impacted.
A lot going on right.
This was just to help you kindof shake off the cobwebs, like I
said, from the holiday.
We're gonna continue to watchall of this.
I'm gonna try to make sense ofit all.
(26:40):
Like I said, there's a lot ofexperts out there that are
diving into even daily updateson the Red Sea, so continue to
watch them.
I'm gonna pull anything that Ithink is particularly notable or
something that you should bewatching or something that needs
a little bit of translating.
Please let me know if there'sanything during season three
that you want me to hit a littlebit more.
Do you enjoy these captain'slog additions better than diving
(27:02):
deeper into some of theseissues?
Should I keep the deeper divesfor really interesting things or
, I guess, suggested questionsthat you have?
I'll keep going pretty much howwe've gone before.
I'm gonna try to introduce afew more interviews throughout
this new year and this newseason, but look, that's it for
(27:22):
today.
Keep it tuned here for all ofyour industry highlights from
the week and the littlesprinkler of their background
information that I like to bringin.
As always, though, the guidancehere is general.
For educational purposes.
It should not be construed tobe legal advice directly related
to your matter.
If you need an attorney,contact an attorney, but if you
do have specific legal questions, feel free to reach out to meet
my legal company, SquallStrategies.
(27:44):
Otherwise, for the non-legalquestions, the e-learning, the
general industry information andinsights, come find me at the
Maritime Professor.
If you like these videos, letme know, comment, like and share
.
If you wanna listen to theseepisodes on demand, or if you
missed any previous episodes,check out the podcast By Land
and By Sea and if you prefer tosee the video, they live on my
YouTube page By Land and By Sea,presented by the Maritime
Professor.
(28:04):
While you're at it, check outthe website TheMaritimeProfessor
.
com.
There's gonna be some new stuffhappening in 2024 over there,
so definitely get on our emaillist.
So until next week.
This is Lauren Beagen, theMaritime Professor, and you've
just listened to By Land and BySea.
See you next time.
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