marpol reception facilities uscg certificate of adequacy (coa) program safety branch/cargo and...
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MARPOL RECEPTIONMARPOL RECEPTIONFACILITIESFACILITIES
USCG CERTIFICATE OF ADEQUACY (COA) PROGRAMUSCG CERTIFICATE OF ADEQUACY (COA) PROGRAM
Safety Branch/Cargo and Facilities DivisionSafety Branch/Cargo and Facilities Division
Office of Port and Facility Activity CG-5442Office of Port and Facility Activity CG-5442
Capt. David A. Condino (MM)Capt. David A. Condino (MM)
April 22, 2008April 22, 2008
VMSAS 2008United States Coast Guard
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2Capt. David Condino April 22, 2008
VMSAS 2008United States Coast Guard
Overview • Office OrganizationOffice Organization
• Program Responsibilities/OversightProgram Responsibilities/Oversight
• IMO/National Regulatory MandatesIMO/National Regulatory Mandates
• Certificate of Adequacy (COA) ProgramCertificate of Adequacy (COA) Program
• MARPOL Facility InspectorsMARPOL Facility Inspectors
• MARPOL Reporting to IMOMARPOL Reporting to IMO
• Investigating Allegations of InadequacyInvestigating Allegations of Inadequacy
• Guidance to Industry and Field UnitsGuidance to Industry and Field Units
• Program Goals- 100% International ComplianceProgram Goals- 100% International Compliance
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3Capt. David Condino April 22, 2008
VMSAS 2008United States Coast Guard
Office Organization
Office of Port and Facility Activity CG-5442
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4Capt. David Condino April 22, 2008
VMSAS 2008United States Coast Guard
Program Responsibilities/Oversight
Implementation of MARPOL via US RegulationsImplementation of MARPOL via US Regulations
Develop policy and regulations based on MARPOL and US Develop policy and regulations based on MARPOL and US LawLaw
Review National Guidance for Field Units and Industry for COA Review National Guidance for Field Units and Industry for COA Certificate Issuance ProcessCertificate Issuance Process
Monitor COA Application, Inspection, and Reporting ProcessMonitor COA Application, Inspection, and Reporting Process
Review all reports of inadequacyReview all reports of inadequacy
Participation in IMO Subcommittee work with member statesParticipation in IMO Subcommittee work with member states
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5Capt. David Condino April 22, 2008
VMSAS 2008United States Coast Guard
IMO/National Regulatory Mandates
MARPOL 73/78, ANNEX I, ANNEX II, AND ANNEX VMARPOL 73/78, ANNEX I, ANNEX II, AND ANNEX V
ACT TO PREVENT POLLUTION FROM SHIPS (APPS) 33 ACT TO PREVENT POLLUTION FROM SHIPS (APPS) 33 U.S.C. §§ 1901-1912 (Giving Authority to the CG to U.S.C. §§ 1901-1912 (Giving Authority to the CG to Implement MARPOL)Implement MARPOL)
33 CFR 158 (Regulations Implementing MARPOL)33 CFR 158 (Regulations Implementing MARPOL)
COMDTINST 16450.27-Oil, 16450.29-NLS, 16450.31-COMDTINST 16450.27-Oil, 16450.29-NLS, 16450.31-Garbage. (Instructions to Field Commanders for Garbage. (Instructions to Field Commanders for administering COA Program and issuing Certificates)administering COA Program and issuing Certificates)
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6Capt. David Condino April 22, 2008
VMSAS 2008United States Coast Guard
Certificate of Adequacy (COA) ProgramUS MARPOL Compliance-33 CFR 158 APPLICABILITY TO PORTS & TERMINALS – Who must APPLICABILITY TO PORTS & TERMINALS – Who must
have a COAhave a COA Annex I – Rcvs ships 400 GT or more w/ oily mixturesAnnex I – Rcvs ships 400 GT or more w/ oily mixtures Annex II- Rcvs ships carrying NLSsAnnex II- Rcvs ships carrying NLSs Annex V- Rcvs Annex I or II vsls or fishing vsls which offload 500K Annex V- Rcvs Annex I or II vsls or fishing vsls which offload 500K
lbs/year of fisheries product. All terminals must provide MARPOL V lbs/year of fisheries product. All terminals must provide MARPOL V reception facilities including small rec. marinas not requiring a COAreception facilities including small rec. marinas not requiring a COA
REGULATORY ADEQUACY – TIME SENSITIVE CRITERIAREGULATORY ADEQUACY – TIME SENSITIVE CRITERIA Annex I – Must rcv oily mixtures w/n 24-hrs of notice & must complete Annex I – Must rcv oily mixtures w/n 24-hrs of notice & must complete
transfers w/n 10-hrs for ballast water & w/n 4-hrs for other oily mixtures. transfers w/n 10-hrs for ballast water & w/n 4-hrs for other oily mixtures. Annex II – Must rcv residues w/n 24-hrs of notice & must complete Annex II – Must rcv residues w/n 24-hrs of notice & must complete
transfers w/n 10 hrs. transfers w/n 10 hrs. Annex V – Must rcv APHIS (Animal and Plant Health Inspection Service) Annex V – Must rcv APHIS (Animal and Plant Health Inspection Service)
regulated garbage w/n 24-hrs of notice (Protecting Public Health)regulated garbage w/n 24-hrs of notice (Protecting Public Health)
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7Capt. David Condino April 22, 2008
VMSAS 2008United States Coast Guard
COA Application/Issuance STEP 1STEP 1: The facility submits a COA application (CG-5401 A, B, or C) to the COTP for : The facility submits a COA application (CG-5401 A, B, or C) to the COTP for
review.review.
STEP 2STEP 2: The COTP reviews the applications against the standards set forth in the : The COTP reviews the applications against the standards set forth in the regulations. regulations.
STEP 3STEP 3: If the application meets the requirements, the COTP conducts an inspection of the : If the application meets the requirements, the COTP conducts an inspection of the Port / Terminal and the reception facility to ensure the information provided on the Port / Terminal and the reception facility to ensure the information provided on the application is accurate. In cases where the port / terminal contracts out a mobile truck or application is accurate. In cases where the port / terminal contracts out a mobile truck or barge to provide reception facilities, these must also be inspected.barge to provide reception facilities, these must also be inspected.
STEP 4STEP 4: Particular attention should be paid for ports / terminals utilizing a common : Particular attention should be paid for ports / terminals utilizing a common reception facility (i.e. a mobile truck provided annex I capabilities for all terminals within a reception facility (i.e. a mobile truck provided annex I capabilities for all terminals within a port). In these cases, the reception facility must have the capability to service all terminals port). In these cases, the reception facility must have the capability to service all terminals within the allowable timeframes as it may be easy for a single asset to become within the allowable timeframes as it may be easy for a single asset to become overwhelmed during busy periods.overwhelmed during busy periods.
STEP 5STEP 5: If all is in order, issue a signed COA. The Port / Terminal maintains a copy of their : If all is in order, issue a signed COA. The Port / Terminal maintains a copy of their signed COA and submitted application forms in their Operations Manual. signed COA and submitted application forms in their Operations Manual.
STEP 6STEP 6: The COTP ensures MISLE is correctly updated to accurately reflect the information : The COTP ensures MISLE is correctly updated to accurately reflect the information contained on the COA for each affected Port / Terminal (facility).contained on the COA for each affected Port / Terminal (facility).
Source: 33 CFR 158.140; 158.160; 158.163Source: 33 CFR 158.140; 158.160; 158.163
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8Capt. David Condino April 22, 2008
VMSAS 2008United States Coast Guard
COA FACILITY INSPECTORS Must be qualified through Certificated ProgramMust be qualified through Certificated Program
Training CoursesTraining Courses
Minimum Experience RequirementsMinimum Experience Requirements
Designated in Writing by local commandersDesignated in Writing by local commanders
Safety Branch provides review and updates to job-aidsSafety Branch provides review and updates to job-aids
Inspectors record results of inspections, and issue COA Inspectors record results of inspections, and issue COA hard copy certificates using Coast Guard’s Marine hard copy certificates using Coast Guard’s Marine Information for Safety and Law Enforcement System Information for Safety and Law Enforcement System (MISLE)(MISLE)
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9Capt. David Condino April 22, 2008
VMSAS 2008United States Coast Guard
Inadequacy Reports/Investigations 33 CFR 158.167 – Report by any means to COTP33 CFR 158.167 – Report by any means to COTP
Field Units Copy COMDT (CG-5442) on any inadequacy Field Units Copy COMDT (CG-5442) on any inadequacy investigationinvestigation
Conduct investigation w/o needlessly revealing reporting Conduct investigation w/o needlessly revealing reporting party (recorded in MISLE by CG Investigator)party (recorded in MISLE by CG Investigator)
Examine suspected facilities’ Examine suspected facilities’ Waste stream logs for waste streams from vessels. Waste stream logs for waste streams from vessels. Uniform Hazardous Waste Manifests. Uniform Hazardous Waste Manifests. Declarations of Inspections (DOIs). Declarations of Inspections (DOIs).
Details in R 072029Z SEP 06 & R 061946Z FEB 07– Details in R 072029Z SEP 06 & R 061946Z FEB 07– (Guidance to Field Units)(Guidance to Field Units)
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10Capt. David Condino April 22, 2008
VMSAS 2008United States Coast Guard
MARPOL Reporting to IMO
Port Reception Facility Database Mandated by Congress in 33 Port Reception Facility Database Mandated by Congress in 33 USC 1905USC 1905
Coast Guard Maintains Public Database via Coast Guard’s Coast Guard Maintains Public Database via Coast Guard’s Maritime Information Exchange (GCMIX) Automatically updated Maritime Information Exchange (GCMIX) Automatically updated through MISLEthrough MISLE
Link: Link: http://cgmix.uscg.mil/MARPOL/Default.aspx available on IMO Port Reception Facility Database (PRFD) via IMO’s Global Integrated Shipping Information System (GISIS)
Reports of Inadequacy and Investigation Results provided to Reports of Inadequacy and Investigation Results provided to IMO (Legal and Regulatory Compliance Division).IMO (Legal and Regulatory Compliance Division).
Coast Guard Takes Administrative/Legal Action to insure Coast Guard Takes Administrative/Legal Action to insure adequacy/correct any inadequacyadequacy/correct any inadequacy
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11Capt. David Condino April 22, 2008
VMSAS 2008United States Coast Guard
CGMIX Database
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12Capt. David Condino April 22, 2008
VMSAS 2008United States Coast Guard
Guidance to Industry/Field UnitsOutreach Efforts Navigation and Vessel Inspection Circular (NVIC) and COMDT Navigation and Vessel Inspection Circular (NVIC) and COMDT
InstructionsInstructions
Marine Safety Manual (MSM)Marine Safety Manual (MSM)
Develop Outreach Programs for Industry, End Users, Port Develop Outreach Programs for Industry, End Users, Port OperatorsOperators
Review of MARPOL and Update Regulations via Regulatory Review of MARPOL and Update Regulations via Regulatory Project ProcessProject Process
Attend Public Meetings/CommentAttend Public Meetings/Comment
Participation with Industry PartnersParticipation with Industry Partners
National and International Correspondence and Work Groups on National and International Correspondence and Work Groups on Reception Facility and Port Related Safety, Pollution Prevention, Reception Facility and Port Related Safety, Pollution Prevention, and Environmental Issues.and Environmental Issues.
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13Capt. David Condino April 22, 2008
VMSAS 2008United States Coast Guard
Summing up Program Goals
Promote Safety and Environmental StewardshipPromote Safety and Environmental Stewardship
Promote and Encourage Pollution Prevention Policy Promote and Encourage Pollution Prevention Policy Internationally, Nationally and LocallyInternationally, Nationally and Locally
Keep Industry on the move with minimal delaysKeep Industry on the move with minimal delays
Encourage best practice methodology and use of technology by Encourage best practice methodology and use of technology by working with industry and IMO Member States.working with industry and IMO Member States.
Insure that Field Inspectors have necessary experience and Insure that Field Inspectors have necessary experience and qualifications.qualifications.
Achieve and Maintain 100% MARPOL ComplianceAchieve and Maintain 100% MARPOL Compliance
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14Capt. David Condino April 22, 2008
VMSAS 2008United States Coast Guard
In Conclusion
The United States maintains a robust MARPOL Reception The United States maintains a robust MARPOL Reception Facility Program aimed at meeting our international Facility Program aimed at meeting our international stewardship responsibilities and, as a Member State, stewardship responsibilities and, as a Member State, through our national legislation, the requirements set forth through our national legislation, the requirements set forth in MARPOL 73/78in MARPOL 73/78
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15Capt. David Condino April 22, 2008
VMSAS 2008United States Coast Guard
Safety Branch Contact Info:
LCDR Michael Roldan, Branch ManagerLCDR Michael Roldan, Branch Manager
Office: 202-372-1130Office: 202-372-1130
[email protected]@uscg.mil
Captain David Condino (MM), Asst. Branch Manager, Captain David Condino (MM), Asst. Branch Manager, MARPOL ProjectsMARPOL Projects
Office: 202-372-1145Office: 202-372-1145
[email protected]@uscg.mil
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