COVID-19 Pandemic – Regulatory Guidance for the Ocean, Inland and Offshore Maritime Sectors

Baker Donelson
Contact

Baker Donelson

All aspects of the maritime industry, from global ocean-going shipping to domestic inland brown water transportation and offshore energy, have been and will continue to be profoundly affected by the COVID-19 crisis, perhaps even more than other industries given that mobility and inter/trans-national movement of people and goods are their very lifeblood.

Unsurprisingly, the regulatory response from the myriad federal agencies has been, and will continue to be, dynamic and evolving.  The following summarizes the more notable first-week regulatory/industry responses relevant to maritime concerns, although this is by no means an exhaustive list:

The United States Coast Guard (USCG) issued MSIB Number: 07-20 on March 18, 2020, providing guidance for ports and terminals with respect to COVID-19. The MSIB reminds owners and operators of “facilities” that the provisions of 33 CFR promulgated under the Marine Transportation Safety Act (MTSA) may apply to issues arising out of the COVID-10 pandemic.  “Facilities” under the MTSA and 33 CFR include “any structure or facility of any kind located in, on, under, or adjacent to any waters subject to the jurisdiction of the U.S. and used, operated, or maintained by a public or private entity, including any contiguous or adjoining property under common ownership or operation.”  33 C.F.R. §101.105.  Likewise, the MTSA regulations apply to certain “fixed or floating facility, including MODUs” operating on the Outer Continental Shelf (OCS).  33 C.F.R. §106.105.

The MSIB recognizes that “the COVID-19 pandemic has resulted in a myriad of unique operating conditions that warrant special considerations, [such as, for example] cruise ships mooring at facilities not approved for passenger operations, garbage removal, and facility and vessel crew interactions.”  As the pandemic response continues, additional instances of these kinds of non-routine “facility” operations may arise, such as potential use of industrial port/terminal “facilities” for emergency “hospital ships” (as is already happening in New York and California) or possibly mooring of unmanned vessels that have been evacuated due to corona virus/COVID-19 crew exposures, as well as dockside cleaning/disinfection of vessels from which sick crews/passengers have been disembarked.

Notwithstanding this potentially unique and unprecedented operational situations, the MSIB reminds “facility” owners/operators that the Declarations of Security (DoS) must still be completed (depending on the “Maritime Security” (MARSEC) level) for any vessels embarking/disembarking or manned cargo vessels transferring any cargo.  33 C.F.R. §105.245.  Likewise, Declarations of Inspection (DoI) will still be required before any transfer of oil or hazardous material to or from a vessel.  Nonetheless, the MSIB authorizes completion of DoS/DoI and any related documentation via non-face-to-face communication and electronic signatures in light of corona virus exposure concerns.

Further, the MSIB notes that while “facilities” are not allowed to impede embarkation/disembarkation of seafarers except as ordered by the USCG, Customs and Border Patrol, and/or the Centers for Disease Control [CDC], nothing prevents “facilities” from “from maximizing options to minimize direct interaction that may include use of camera systems, barriers, or other measures.”  This guidance is relevant to the Seafarers’ Access regulations (33 C.F.R. §105.237), which requires “facilities” to provide no-cost shore access (as specified in the regulation) for all seafarers and representatives of seafarers’ welfare and labor organizations.  These requirements are derived from the International Convention for Safety of Life at Sea (SOLAS) Chapter XI–2, the International Ship and Port Facility (ISPS) Code, the International Maritime Organization’s ‘‘Reminder in Connection with Shore Leave and Access to Ships’’ MSC/1/Circ.1342, and the 2016 Amendments to the Convention on the Facilitation of International Maritime Traffic (FAL) Annex 1, which acknowledges that “there is an internationally recognized obligation to protect the interest of seafarer’s shore leave, including shoreside access.”  84 Fed. Reg. 12102, 12104 (Apr. 1, 2019).  “As stated in Annex 1 of the FAL, ‘‘Crew members shall be allowed ashore by the public authorities while the ship on which they arrive is in port, provided that the formalities on arrival of the ship have been fulfilled and the public authorities have no reason to refuse permission to come ashore for public health, public safety or public order.”  And “[i]f private actors thwart or hinder the ability of the United States to fulfill its international obligations, such as by imposing fees on crewmembers as a condition to shoreside access in the United States, any and all legal and diplomatic responses, to include notification to the vessel’s flag-state, may be taken by the U.S. Government.”  Id.

Additionally, the MSIB reminds “facility” owners/operators that under 33 CFR 105, all U.S. ports and terminals are required to accept vessel wastes.  Under “[i]nternational regulations require these reception facilities to have a [USCG] Certificate of Adequacy (COA) … that attests to their ability to offload garbage, which may include medical waste (33 CFR 158.410)[, which] is defined in 33 CFR 158.120 as ‘isolation wastes, infectious waste, human blood and blood products, pathological wastes, sharps, body parts, contaminated bedding, surgical wastes and potentially contaminated laboratory wastes, dialysis wastes and such additional medical items as prescribed by the EPA by regulation.’”  If a port/terminal does not have a USCG COA, it must “provide vessels with adequate reception facilities for medical waste or a list of persons authorized by federal, state or local law or regulation to transport and treat such wastes.” 33 C.F.R. 158.410(a)(2). Likewise, as the MSIB points out, the USCG COTP may grant waivers to allow for disposal of “medical wastes” at non-COA “facilities.” 33 C.F.R. §158.150.  Disposal of “medical wastes” may present precarious circumstances in the event of a vessel calling at a port/terminal with a COVID-19 infected crew, given that presumably any number of items (bedding, infirmary wastes, clothing, etc.) might constitute “medical waste” that could pose health threats to the receiving “facility.”  Accordingly, the MSIB directs “facilities” to “work with the appropriate federal, state, and/or local agencies to determine the actual risks and formulate a plan of action based on information received from those agencies” in any such circumstances.

Finally, the MSIB reiterates that if a “facility” will be faced with non-compliance due to the dynamic circumstances around the pandemic, owners/operators should  “c1ontact the [USCG] Captain of the Port (COTP) to request and receive permission to temporarily deviate from the requirements.”  Any such “request should include any new measures or safeguards the facility plans to employ to mitigate any risk from the non-compliance with 33 CFR 105”; and given these unprecedented circumstances, should likewise include factors “not discussed in 33 CFR 105, [including] any safety risks that may be created from the non-compliance . . . [such as whether] the dock is physically capable of handling that vessel, and any logistical issues that may arise such as movement of personnel from the vessel off the facility, any medical issues or personnel that may be introduced to the facility, supplies for the vessel, and waste removal from the vessel.”
This guidance is critical given that ports and terminals may be included among “essential businesses” allowed to continue operations during the COVID-19 pandemic.  For example, in Louisiana, Governor Edwards’ March 22, 2020 Proclamation adopts the Cybersecurity & Infrastructure Security Agency (CISA) guidelines for “essential services,” which in turn include “[p]etroleum product storage, pipeline, marine transport [and] terminals” as well as “[o]nshore and offshore operations for maintenance and emergency response” and “[m]aritime transportation workers – port workers, mariners, equipment operators.”

Likewise, the USCG has issued MSIB Number: 06-20, echoed by a similar “Maritime Security Communication with Industry” (MSCI) promulgated by the Maritime Administration (MARAD), providing guidance for vessel operators regarding incident reporting requirements relative to the COVID-19 pandemic. Illnesses aboard vessels must be reported to both the USCG as “hazardous condition) (33 C.F.R. §160.216) and the CDC.  This applies to both international (42 C.F.R. §71.21) and interstate (42 C.F.R. § 70.4) voyages, and thus encompasses virtually the entirety of the U.S. maritime infrastructure.  Simply put, “[i]t is critical to report persons who exhibit symptoms consistent with COVID-19 or other illness to the COTP” and to the CDC, and failing to do so may result in  “civil penalties, vessel detentions, and criminal liability.”

In this regard, the International Maritime Organization (IMO), in conjunction with the World Health Organization, has issued guidance with respect to managing COVID-19 outbreaks on vessels.  Likewise, the IMO (Circular Letter No. 4203/Add. 4, Mar. 5 2020) has emphasized the humanitarian concerns implicated by the pandemic, and advises that notwithstanding any domestic port state restrictions imposed as a result of the pandemic, “it is very important for port States to accept all ships (both cargo and passenger), for docking and to disembark suspected cases on board, as it is difficult to treat suspect cases on board and it could endanger others.”

Applicable regulations (42 C.F.R. §70.1) define “illness” as including any of multiple COVID-19 symptoms, including  “[f]ever (has a measured temperature of 100.4 °F [38 °C] or greater; or feels warm to the touch; or gives a history of feeling feverish) accompanied by one or more of the following:…difficulty breathing or suspected or confirmed pneumonia, persistent cough or cough with bloody sputum…[f]ever that has persisted for more than 48 hours; …[a]cute gastroenteritis, which means either:  diarrhea, defined as three or more episodes of loose stools in a 24-hour period or what is above normal for the individual.”

The MSIB likewise reminds foreign vessel interests (or any vessels arriving from foreign ports) that “the master of a ship destined for a U.S. port shall report immediately to the quarantine station at or nearest the port at which the ship will arrive, the occurrence, on board, of any death or any ill person among passengers or crew (including those who have disembarked or have been removed) during the 15-day period preceding the date of expected arrival or during the period since departure from a U.S. port (whichever period of time is shorter).”  42 C.F.R. §71.21.

It should additionally be noted, although not addressed in the MSIB, that for interstate vessel operations (i.e. the brownwater/inland maritime industry) the CDC is authorized to “take such measures to prevent … spread of … diseases as … deem[ed] reasonably necessary.”  42 C.F.R. §70.2.  This includes the ability to apprehend and detain individuals with “quarantinable communicable diseases, as specified by Executive Order” who may be “moving or about to move from a State into another State .”  42 C.F.R. §70.6.  President Trump’s March 18, 2020 “Executive Order on Prioritizing and Allocating Health and Medical Resources to Respond to the Spread of Covid-19” would appear to trigger these provisions. And moreover, prior Executive Order No. 13295 (April 4, 2003) entitled “Revised List of Quarantinable Communicable Diseases” specifically includes “Severe Acute Respiratory Syndrome (SARS) [another corona virus-linked disease], which is a disease associated with fever and signs and symptoms of pneumonia or other respiratory illness, is transmitted from person to person predominantly by the aerosolized or droplet route, and, if spread in the population, would have severe public health consequences.”  Thus, it is possible that as the quickly-evolving COVID-19 response expands, additional restrictions/ guidance on the inland fleet and interstate vessel operations may be forthcoming.

Finally, the USCG Sector New Orleans has issued MSIB Vol XX Issue 035 – COVID19 Vessel Precautions, which provides even more detailed guidance to vessels/operators on the Mississippi River regarding operations in the midst of the COVID-19 pandemic. This MSIB gives detailed recommendations for interfacing between river pilots and vessel crews, including inter alia “wip[ing] down the entire bridge with a 5% solution of bleach water (Chart table, instruments, chairs, helm, entire console, windows, etc.)” within the hour prior to pilot boarding; washing of hands and face by all crew prior to entering the bridge, and their hands again immediately on entry; provision of sanitizing materials by the ship (although pilots are encourage to bring their own as well); and wiping down of all surfaces contacted by the pilots.  Additionally, pilots are encouraged to step out of the bridge (as safety allows) if they need to cough/sneeze, and if they cannot, to wipe down any surfaces in their immediate vicinity.  The detailed guidance in this MSIB are recommendations only, not requirements, but should be heeded both as a matter of compliance and in the interest of stemming the spread of COVID-19.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

© Baker Donelson | Attorney Advertising

Written by:

Baker Donelson
Contact
more
less

Baker Donelson on:

Readers' Choice 2017
Reporters on Deadline

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
Custom Email Digest
- hide

JD Supra Privacy Policy

Updated: May 25, 2018:

JD Supra is a legal publishing service that connects experts and their content with broader audiences of professionals, journalists and associations.

This Privacy Policy describes how JD Supra, LLC ("JD Supra" or "we," "us," or "our") collects, uses and shares personal data collected from visitors to our website (located at www.jdsupra.com) (our "Website") who view only publicly-available content as well as subscribers to our services (such as our email digests or author tools)(our "Services"). By using our Website and registering for one of our Services, you are agreeing to the terms of this Privacy Policy.

Please note that if you subscribe to one of our Services, you can make choices about how we collect, use and share your information through our Privacy Center under the "My Account" dashboard (available if you are logged into your JD Supra account).

Collection of Information

Registration Information. When you register with JD Supra for our Website and Services, either as an author or as a subscriber, you will be asked to provide identifying information to create your JD Supra account ("Registration Data"), such as your:

  • Email
  • First Name
  • Last Name
  • Company Name
  • Company Industry
  • Title
  • Country

Other Information: We also collect other information you may voluntarily provide. This may include content you provide for publication. We may also receive your communications with others through our Website and Services (such as contacting an author through our Website) or communications directly with us (such as through email, feedback or other forms or social media). If you are a subscribed user, we will also collect your user preferences, such as the types of articles you would like to read.

Information from third parties (such as, from your employer or LinkedIn): We may also receive information about you from third party sources. For example, your employer may provide your information to us, such as in connection with an article submitted by your employer for publication. If you choose to use LinkedIn to subscribe to our Website and Services, we also collect information related to your LinkedIn account and profile.

Your interactions with our Website and Services: As is true of most websites, we gather certain information automatically. This information includes IP addresses, browser type, Internet service provider (ISP), referring/exit pages, operating system, date/time stamp and clickstream data. We use this information to analyze trends, to administer the Website and our Services, to improve the content and performance of our Website and Services, and to track users' movements around the site. We may also link this automatically-collected data to personal information, for example, to inform authors about who has read their articles. Some of this data is collected through information sent by your web browser. We also use cookies and other tracking technologies to collect this information. To learn more about cookies and other tracking technologies that JD Supra may use on our Website and Services please see our "Cookies Guide" page.

How do we use this information?

We use the information and data we collect principally in order to provide our Website and Services. More specifically, we may use your personal information to:

  • Operate our Website and Services and publish content;
  • Distribute content to you in accordance with your preferences as well as to provide other notifications to you (for example, updates about our policies and terms);
  • Measure readership and usage of the Website and Services;
  • Communicate with you regarding your questions and requests;
  • Authenticate users and to provide for the safety and security of our Website and Services;
  • Conduct research and similar activities to improve our Website and Services; and
  • Comply with our legal and regulatory responsibilities and to enforce our rights.

How is your information shared?

  • Content and other public information (such as an author profile) is shared on our Website and Services, including via email digests and social media feeds, and is accessible to the general public.
  • If you choose to use our Website and Services to communicate directly with a company or individual, such communication may be shared accordingly.
  • Readership information is provided to publishing law firms and authors of content to give them insight into their readership and to help them to improve their content.
  • Our Website may offer you the opportunity to share information through our Website, such as through Facebook's "Like" or Twitter's "Tweet" button. We offer this functionality to help generate interest in our Website and content and to permit you to recommend content to your contacts. You should be aware that sharing through such functionality may result in information being collected by the applicable social media network and possibly being made publicly available (for example, through a search engine). Any such information collection would be subject to such third party social media network's privacy policy.
  • Your information may also be shared to parties who support our business, such as professional advisors as well as web-hosting providers, analytics providers and other information technology providers.
  • Any court, governmental authority, law enforcement agency or other third party where we believe disclosure is necessary to comply with a legal or regulatory obligation, or otherwise to protect our rights, the rights of any third party or individuals' personal safety, or to detect, prevent, or otherwise address fraud, security or safety issues.
  • To our affiliated entities and in connection with the sale, assignment or other transfer of our company or our business.

How We Protect Your Information

JD Supra takes reasonable and appropriate precautions to insure that user information is protected from loss, misuse and unauthorized access, disclosure, alteration and destruction. We restrict access to user information to those individuals who reasonably need access to perform their job functions, such as our third party email service, customer service personnel and technical staff. You should keep in mind that no Internet transmission is ever 100% secure or error-free. Where you use log-in credentials (usernames, passwords) on our Website, please remember that it is your responsibility to safeguard them. If you believe that your log-in credentials have been compromised, please contact us at privacy@jdsupra.com.

Children's Information

Our Website and Services are not directed at children under the age of 16 and we do not knowingly collect personal information from children under the age of 16 through our Website and/or Services. If you have reason to believe that a child under the age of 16 has provided personal information to us, please contact us, and we will endeavor to delete that information from our databases.

Links to Other Websites

Our Website and Services may contain links to other websites. The operators of such other websites may collect information about you, including through cookies or other technologies. If you are using our Website or Services and click a link to another site, you will leave our Website and this Policy will not apply to your use of and activity on those other sites. We encourage you to read the legal notices posted on those sites, including their privacy policies. We are not responsible for the data collection and use practices of such other sites. This Policy applies solely to the information collected in connection with your use of our Website and Services and does not apply to any practices conducted offline or in connection with any other websites.

Information for EU and Swiss Residents

JD Supra's principal place of business is in the United States. By subscribing to our website, you expressly consent to your information being processed in the United States.

  • Our Legal Basis for Processing: Generally, we rely on our legitimate interests in order to process your personal information. For example, we rely on this legal ground if we use your personal information to manage your Registration Data and administer our relationship with you; to deliver our Website and Services; understand and improve our Website and Services; report reader analytics to our authors; to personalize your experience on our Website and Services; and where necessary to protect or defend our or another's rights or property, or to detect, prevent, or otherwise address fraud, security, safety or privacy issues. Please see Article 6(1)(f) of the E.U. General Data Protection Regulation ("GDPR") In addition, there may be other situations where other grounds for processing may exist, such as where processing is a result of legal requirements (GDPR Article 6(1)(c)) or for reasons of public interest (GDPR Article 6(1)(e)). Please see the "Your Rights" section of this Privacy Policy immediately below for more information about how you may request that we limit or refrain from processing your personal information.
  • Your Rights
    • Right of Access/Portability: You can ask to review details about the information we hold about you and how that information has been used and disclosed. Note that we may request to verify your identification before fulfilling your request. You can also request that your personal information is provided to you in a commonly used electronic format so that you can share it with other organizations.
    • Right to Correct Information: You may ask that we make corrections to any information we hold, if you believe such correction to be necessary.
    • Right to Restrict Our Processing or Erasure of Information: You also have the right in certain circumstances to ask us to restrict processing of your personal information or to erase your personal information. Where you have consented to our use of your personal information, you can withdraw your consent at any time.

You can make a request to exercise any of these rights by emailing us at privacy@jdsupra.com or by writing to us at:

Privacy Officer
JD Supra, LLC
10 Liberty Ship Way, Suite 300
Sausalito, California 94965

You can also manage your profile and subscriptions through our Privacy Center under the "My Account" dashboard.

We will make all practical efforts to respect your wishes. There may be times, however, where we are not able to fulfill your request, for example, if applicable law prohibits our compliance. Please note that JD Supra does not use "automatic decision making" or "profiling" as those terms are defined in the GDPR.

  • Timeframe for retaining your personal information: We will retain your personal information in a form that identifies you only for as long as it serves the purpose(s) for which it was initially collected as stated in this Privacy Policy, or subsequently authorized. We may continue processing your personal information for longer periods, but only for the time and to the extent such processing reasonably serves the purposes of archiving in the public interest, journalism, literature and art, scientific or historical research and statistical analysis, and subject to the protection of this Privacy Policy. For example, if you are an author, your personal information may continue to be published in connection with your article indefinitely. When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
  • Onward Transfer to Third Parties: As noted in the "How We Share Your Data" Section above, JD Supra may share your information with third parties. When JD Supra discloses your personal information to third parties, we have ensured that such third parties have either certified under the EU-U.S. or Swiss Privacy Shield Framework and will process all personal data received from EU member states/Switzerland in reliance on the applicable Privacy Shield Framework or that they have been subjected to strict contractual provisions in their contract with us to guarantee an adequate level of data protection for your data.

California Privacy Rights

Pursuant to Section 1798.83 of the California Civil Code, our customers who are California residents have the right to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes.

You can make a request for this information by emailing us at privacy@jdsupra.com or by writing to us at:

Privacy Officer
JD Supra, LLC
10 Liberty Ship Way, Suite 300
Sausalito, California 94965

Some browsers have incorporated a Do Not Track (DNT) feature. These features, when turned on, send a signal that you prefer that the website you are visiting not collect and use data regarding your online searching and browsing activities. As there is not yet a common understanding on how to interpret the DNT signal, we currently do not respond to DNT signals on our site.

Access/Correct/Update/Delete Personal Information

For non-EU/Swiss residents, if you would like to know what personal information we have about you, you can send an e-mail to privacy@jdsupra.com. We will be in contact with you (by mail or otherwise) to verify your identity and provide you the information you request. We will respond within 30 days to your request for access to your personal information. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why. If you would like to correct or update your personal information, you can manage your profile and subscriptions through our Privacy Center under the "My Account" dashboard. If you would like to delete your account or remove your information from our Website and Services, send an e-mail to privacy@jdsupra.com.

Changes in Our Privacy Policy

We reserve the right to change this Privacy Policy at any time. Please refer to the date at the top of this page to determine when this Policy was last revised. Any changes to our Privacy Policy will become effective upon posting of the revised policy on the Website. By continuing to use our Website and Services following such changes, you will be deemed to have agreed to such changes.

Contacting JD Supra

If you have any questions about this Privacy Policy, the practices of this site, your dealings with our Website or Services, or if you would like to change any of the information you have provided to us, please contact us at: privacy@jdsupra.com.

JD Supra Cookie Guide

As with many websites, JD Supra's website (located at www.jdsupra.com) (our "Website") and our services (such as our email article digests)(our "Services") use a standard technology called a "cookie" and other similar technologies (such as, pixels and web beacons), which are small data files that are transferred to your computer when you use our Website and Services. These technologies automatically identify your browser whenever you interact with our Website and Services.

How We Use Cookies and Other Tracking Technologies

We use cookies and other tracking technologies to:

  1. Improve the user experience on our Website and Services;
  2. Store the authorization token that users receive when they login to the private areas of our Website. This token is specific to a user's login session and requires a valid username and password to obtain. It is required to access the user's profile information, subscriptions, and analytics;
  3. Track anonymous site usage; and
  4. Permit connectivity with social media networks to permit content sharing.

There are different types of cookies and other technologies used our Website, notably:

  • "Session cookies" - These cookies only last as long as your online session, and disappear from your computer or device when you close your browser (like Internet Explorer, Google Chrome or Safari).
  • "Persistent cookies" - These cookies stay on your computer or device after your browser has been closed and last for a time specified in the cookie. We use persistent cookies when we need to know who you are for more than one browsing session. For example, we use them to remember your preferences for the next time you visit.
  • "Web Beacons/Pixels" - Some of our web pages and emails may also contain small electronic images known as web beacons, clear GIFs or single-pixel GIFs. These images are placed on a web page or email and typically work in conjunction with cookies to collect data. We use these images to identify our users and user behavior, such as counting the number of users who have visited a web page or acted upon one of our email digests.

JD Supra Cookies. We place our own cookies on your computer to track certain information about you while you are using our Website and Services. For example, we place a session cookie on your computer each time you visit our Website. We use these cookies to allow you to log-in to your subscriber account. In addition, through these cookies we are able to collect information about how you use the Website, including what browser you may be using, your IP address, and the URL address you came from upon visiting our Website and the URL you next visit (even if those URLs are not on our Website). We also utilize email web beacons to monitor whether our emails are being delivered and read. We also use these tools to help deliver reader analytics to our authors to give them insight into their readership and help them to improve their content, so that it is most useful for our users.

Analytics/Performance Cookies. JD Supra also uses the following analytic tools to help us analyze the performance of our Website and Services as well as how visitors use our Website and Services:

  • HubSpot - For more information about HubSpot cookies, please visit legal.hubspot.com/privacy-policy.
  • New Relic - For more information on New Relic cookies, please visit www.newrelic.com/privacy.
  • Google Analytics - For more information on Google Analytics cookies, visit www.google.com/policies. To opt-out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout. This will allow you to download and install a Google Analytics cookie-free web browser.

Facebook, Twitter and other Social Network Cookies. Our content pages allow you to share content appearing on our Website and Services to your social media accounts through the "Like," "Tweet," or similar buttons displayed on such pages. To accomplish this Service, we embed code that such third party social networks provide and that we do not control. These buttons know that you are logged in to your social network account and therefore such social networks could also know that you are viewing the JD Supra Website.

Controlling and Deleting Cookies

If you would like to change how a browser uses cookies, including blocking or deleting cookies from the JD Supra Website and Services you can do so by changing the settings in your web browser. To control cookies, most browsers allow you to either accept or reject all cookies, only accept certain types of cookies, or prompt you every time a site wishes to save a cookie. It's also easy to delete cookies that are already saved on your device by a browser.

The processes for controlling and deleting cookies vary depending on which browser you use. To find out how to do so with a particular browser, you can use your browser's "Help" function or alternatively, you can visit http://www.aboutcookies.org which explains, step-by-step, how to control and delete cookies in most browsers.

Updates to This Policy

We may update this cookie policy and our Privacy Policy from time-to-time, particularly as technology changes. You can always check this page for the latest version. We may also notify you of changes to our privacy policy by email.

Contacting JD Supra

If you have any questions about how we use cookies and other tracking technologies, please contact us at: privacy@jdsupra.com.

- hide

This website uses cookies to improve user experience, track anonymous site usage, store authorization tokens and permit sharing on social media networks. By continuing to browse this website you accept the use of cookies. Click here to read more about how we use cookies.