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USCG Regulatory Update INTERTANKO CTC
Pat Keffler
CG-ENG-5
April 18, 2018
Deputy Commandant for Operations Assistant Commandant for Prevention Policy
Commercial Regulations & Standards Directorate
CG-5PS Commercial Regulations & Standards Directorate – Mr. Jeff Lantz
CG-ENG Design & Engineering Standards – CAPT Ben Hawkins
CG-OES Operating & Environmental Standards - CAPT Sean Brady
CG-REG Standards Evaluation & Development - Mr. Tim Brown
CG-MMC Merchant Mariner Credentialing - Ms. Mayte Medina
Marine Safety Center (MSC) - CAPT Scott Kelly
National Maritime Center (NMC) - CAPT Kirsten Martin
Hazardous Materials Division
CDR Marc Montemerlo - Division Chief
Mr. Pat Keffler – Bulk Liquids Team Leader
LCDR Andrew Murphy - Cargo Authority
GS-13 position - vacant
Dr. Cindy Znati – VCS & Gases Team Leader
LCDR Julie Blanchfield– Vapor Control Systems
LT Jake Lobb – Liquefied Gases and CTAC
Ms. Amy Parker – Bulk Solids and Packaged HazMat Team Leader
Ms. Hillary Sadoff– IMDG Code
Port State Control Detentions by Ship Type
2016
2017
IMO Update
• 5th Session of the Pollution, Prevention and Response Subcommittee at IMO HQ Feb 5-9, 2018
• Agenda Items
– Safety and pollution hazards of chemicals
– MARPOL Annex II
– Guidance on ballast water management
– Standards associated with MARPOL Annex VI
– OPRC – Dispersant Guidelines
– Use of Electronic Record Books
ESPH Working Group
• Drafts amendments to the IBC Code
• Current Agenda Items
– No new products at this meeting
– Evaluate cleaning additives • 10 new cleaning additives added to Annex 10 of the MEPC.2/Circ.
• 38 cleaning additives have a name or manufacturer’s name change
– There are 50 products in the MEPC.2/Circ.23 scheduled to expire at the end of 2018
ESPH Working Group
• Review of Chapters 17, 18 and 21 of the IBC Code
– Chapter 21 revision is complete
– Resultant changes to requirements in Chapters 17 and 18 were finalized at this meeting; come into force on January 1, 2021
– Trade name mixtures currently in List 2, 3 and 4 of the MEPC.2/Circ. will be deleted and need to be re-submitted using the revised Chapter 21 criteria.
– Many products that are currently “Pollution only” will now pick up safety hazards. There will be impacts to the carriage requirements accordingly.
– IMO Secretariat is preparing a spreadsheet to cross-walk the changes to the carriage requirements
ESPH Working Group
• Guidance for the assessment of products under MARPOL Annex I and Annex II
– Energy-rich fuels (also called second generation biofuels)
– Prepared draft circular on energy-rich fuels for submission to MEPC 73
– Energy-rich fuels will be classified and carried under MARPOL Annex I and listed in the MEPC.2/Circ. in a new Annex 12
– Some biofuels (Annex 11) that meet the energy-rich fuels criteria will move to Annex 12
ESPH Working Group
• MARPOL Annex II requirements on cargo residues and tank washings of High Viscosity and Persistent Floating Products
– First considered at ESPH 19 impacted beaches in northern Europe
– Draft amendments to MARPOL Annex II and the IBC Code finalized at this session using a geographic and cargo phased approach.
– These products (including most vegetable oils and fats, paraffins and waxes) will require a prewash after discharging in the NW Europe area starting January 1, 2021.
– In general, this will apply to the North Atlantic (north of Gibraltar and east of the west coast of Ireland), North Sea, Norwegian Sea, Baltic Sea
– New paragraph 16.2.7 will be added to column “o” in Chapter 17 of the IBC Code to indicate which cargoes will fall under this new requirement
Regulations under development
• Liquid Chemical Categorization
– 46 CFR Parts 30, 150 and 153 Table 2
– Public comment period closed in Jan 2016, expect Final Rule to be published this summer
• 46 CFR Part 153
– Harmonize with IBC Code/MARPOL Annex II
– Currently working on this project with CTAC
Ballast Water Management
Six Years of Implementation
• 5 CG-approved Independent Labs
• Extensions to compliance dates: 13,000+
• 6 CG Type Approved Systems
• More systems under review or in testing phase
• IMO Convention entered into force Sept 8, 2017
• New NVIC in March 2018 consolidates a number of policy and guidance documents
• Extensions now more difficult to obtain
BWM-Options for Compliance
2. Coast Guard Approved Ballast Water Management System
1. Alternate Management System (AMS) – Temporary Designation for up to 5 years
1. No BW Discharge
3. Discharge to Facility Onshore or to Another Vessel for Purpose of Treatment
4. Use only water from a U.S. Public Water System
2. Receive an Extension to Vessel’s Compliance Date - extension period will vary depending upon TA system availability
Two Temporary Compliance Alternatives
Ballast Water Management
Alternate Management Systems
• A BWMS is accepted for use as an AMS based on its type approval by a foreign administration.
• AMS may be used for 5 years after expiration of the vessel’s compliance date.
• Vessels with AMS can comply and must operate the AMS once their original/extended compliance date has passed.
• Extension will not be grated to facilitate installation of an AMS.
Ballast Water Management
Extensions
• No longer align with scheduled dry docking dates.
• Extensions will grant:
– Minimum time necessary
– To come into compliance
• Three major elements of an extension request are:
– Acquisition of a BWMS,
– that is type approved or is expected to receive type approval,
– and is scheduled for installation at the first opportunity.
Ballast Water Management
Extension (con’t)
• Extension letters will be honored and may be transferred to new owners.
• Extensions reissued due to drydock date slips will be issued to a date and may result in less time than previously anticipated
• Failure to plan ahead may result in ship delays or lapse in eligibility to trade in U.S. waters.
• Navigation and Vessel Inspection Circular 01-18 has more details
Contact Info
CG-ENG-5 Bulk Liquids
Pat Keffler
(202) 372-1424
LCDR Andrew Murphy
(202) 372-1398
Thank you
Questions?