USCG E NFORCEMENT OF IMO 2020 S ULFUR C AP O CTOBER 2019 MARPOL VI R - PowerPoint PPT Presentation

USCG E NFORCEMENT OF IMO 2020 S ULFUR C AP O CTOBER 2019 MARPOL VI R EGULATION 14 C OMPLIANCE & E NFORCEMENT O PTIONS

Verifying Compliance & Enforcement • USCG will continue to review bunker delivery notes (BDNs), change over procedures and relevant documentation to verify Annex VI compliance • USCG will conduct a more detailed inspection when clear grounds is established • Lack of or inconsistent BDNs • Crew not following change over procedures • Faults/errors on EGCS • Range of USCG action include issuing a deficiency, detaining vessel, taking fuel samples and/or referring to EPA/DOJ as appropriate 2

Verifying Compliance & Enforcement • After March 1, 2020 , if non- compliant fuel is found onboard (unless appropriately approved EGCS is operational), then the USCG will require the vessel operator to perform any of the following based on the totality of the situation : • Offload non-compliant fuel at current port • Onload compliant fuel appropriate for the length of subsequent voyage • Allow vessel to sail utilizing compliant fuel, then offload non-compliant fuel at a subsequent destination or repair inoperable EGCS • Requires coordination with port state of destination port to ensure this approach is acceptable • Remain consistent with IMO Guidelines MEPC.320(74) and MEPC.1/Circ.881 3

USCG Ballast Water Management Compliance During PSC exam review BWM plan, reports & records, visually examine system, ask questions & check logs 4

USCG Ballast Water Management Compliance Options Two Temporary Compliance 1. No BW Discharge Alternatives 1. Alternate Management 2. Coast Guard Approved System (AMS) – Ballast Water Temporary Designation for Management System up to 5 years 3. Discharge to Facility Onshore or to 2. Receive an Extension to Another Vessel for Vessel’s Compliance Date - Purpose of Treatment extension period will vary depending upon TA system availability 4. Use only water from a U.S. Public Water System 5

Inoperable BWMS • Have a contingency plan for inoperable BWMS in SMS! • CG-CVC Policy Letter 18-02 on Inoperable BWMS • USCG NVIC 01-18 on BWM for Control of Non-Indigenous Species • Immediately report inoperable BWMS to OMCI/ COTP or District Commander at the arrival port • OCMI/COTP will assess BWMS contingency and/or repair proposal the same as other vital shipboard systems • Due to multitude of variables and scenarios, decisions will be made vessel-by- vessel 6