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

USCG ENFORCEMENT OF IMO 2020 SULFUR CAP

OCTOBER 2019

MARPOL VI REGULATION 14 COMPLIANCE & ENFORCEMENT OPTIONS

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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

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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

• perator to perform any of the

following based on the totality

• f 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

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USCG Ballast Water Management Compliance

During PSC exam review BWM plan, reports & records, visually examine system, ask questions & check logs

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• 1. No BW Discharge
• 2. Coast Guard Approved

Ballast Water Management System

• 3. Discharge to Facility

Onshore or to Another Vessel for Purpose of Treatment

• 4. Use only water from a

U.S. Public Water System

USCG Ballast Water Management Compliance Options

Two Temporary Compliance Alternatives

• 1. Alternate Management

System (AMS) – Temporary Designation for up to 5 years

• 2. Receive an Extension to

Vessel’s Compliance Date - extension period will vary depending upon TA system availability

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• 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

Inoperable BWMS