Maritime Compliance Report
Welcome. Staying in compliance takes dedication, diligence and strong leadership skills to stay on top of all the requirements which seem to keep coming at a rapid pace. With this blog I hope to provide visitors with content that will help them in their daily work of staying in compliance. I hope you find it a resource worthy of your time and I look forward to your feedback, questions, comments and concerns. Thanks for stopping by.
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EPA VGP Compliance – Do You Have All the Facts?
10Each vessel owner/operator I ask about EPA VGP compliance gives me a different response: "Oh yeah, I heard about that…We've got it covered we just log how much graywater we discharge and try not to wash any oil over the side…I asked the Coast Guard and they don't know anything about it…Is that for real..?"
This year I was selected to do a session on EPA VGP compliance at the International WorkBoat Show Professional Series being held in New Orleans from December 1-3. In preparation for my presentation, I just concluded a meeting in Houston with EPA officials who are responsible for the EPA VGP in EPA Region 6.
Participating in the meeting were the person in charge of VGP enforcement for Region 6, the EPA attorney responsible for VGP issues, and the individual responsible for permitting. The purpose of the meeting was to make sure I had all the facts from the horse's mouth when it comes to my presentation, and to be able to answer the tough questions. Some clients had also provided me with their nagging questions, and these EPA officials were very forthright in their answers. I found their willingness to discuss the issues candidly quite refreshing and I am truly grateful for their taking the time to meet with me.
My approach to compliance has always been to prepare for the worst and hope for the best. This comes from my experience both in and out of the Coast Guard, seeing frustrated industry people whose compliance efforts amount to doing what everyone else was doing, or doing whatever the last government inspector said was OK. This can only result in problems or penalties. Companies must be in compliance with all aspects of written regulations and policies to ensure compliance, because a new inspector can always show up to enforce what he knows about. But sometimes when a worst case scenario approach is compared to actual enforcement levels, it can appear to be a "boy who cried wolf" scenario. That is why I wanted to make my presentation to the EPA officials first, for a reality check. I wanted to know if my compliance management ideas were "over the top" or not. Not only did they not think my approach was "over the top" they added many interesting comments. Here are a few of the highlights:
The EPA VGP is currently being enforced.
Anyone who has knowledge of the requirements of the EPA VGP and deliberately ignores them will be referred to the criminal division.
The EPA VGP was written to be general, but the response in the form of BMPs, etc. must be specific processes tailored to your specific vessel and operation.
The best management practices (BMPs) required are the industry BMPs, not what youthink are BMPs. You could be fined for not following the industry best practices regarding any particular discharge. Follow the permit closely on BMPs and you won't be far off.
Documentation is very important when it comes to enforcement.
Anyone who certifies that inspections and monitoring required by the permit have been done, and it is determined that the inspections and monitoring in fact have not been done, those certifying individuals who signed the log or report will be referred to the criminal division.
This year I was selected to do a session on EPA VGP compliance at the International WorkBoat Show Professional Series being held in New Orleans from December 1-3. In preparation for my presentation, I just concluded a meeting in Houston with EPA officials who are responsible for the EPA VGP in EPA Region 6.
Participating in the meeting were the person in charge of VGP enforcement for Region 6, the EPA attorney responsible for VGP issues, and the individual responsible for permitting. The purpose of the meeting was to make sure I had all the facts from the horse's mouth when it comes to my presentation, and to be able to answer the tough questions. Some clients had also provided me with their nagging questions, and these EPA officials were very forthright in their answers. I found their willingness to discuss the issues candidly quite refreshing and I am truly grateful for their taking the time to meet with me.
My approach to compliance has always been to prepare for the worst and hope for the best. This comes from my experience both in and out of the Coast Guard, seeing frustrated industry people whose compliance efforts amount to doing what everyone else was doing, or doing whatever the last government inspector said was OK. This can only result in problems or penalties. Companies must be in compliance with all aspects of written regulations and policies to ensure compliance, because a new inspector can always show up to enforce what he knows about. But sometimes when a worst case scenario approach is compared to actual enforcement levels, it can appear to be a "boy who cried wolf" scenario. That is why I wanted to make my presentation to the EPA officials first, for a reality check. I wanted to know if my compliance management ideas were "over the top" or not. Not only did they not think my approach was "over the top" they added many interesting comments. Here are a few of the highlights:
The EPA VGP is currently being enforced.
Anyone who has knowledge of the requirements of the EPA VGP and deliberately ignores them will be referred to the criminal division.
The EPA VGP was written to be general, but the response in the form of BMPs, etc. must be specific processes tailored to your specific vessel and operation.
The best management practices (BMPs) required are the industry BMPs, not what youthink are BMPs. You could be fined for not following the industry best practices regarding any particular discharge. Follow the permit closely on BMPs and you won't be far off.
Documentation is very important when it comes to enforcement.
Anyone who certifies that inspections and monitoring required by the permit have been done, and it is determined that the inspections and monitoring in fact have not been done, those certifying individuals who signed the log or report will be referred to the criminal division.
I hope these comments make you confident and not worried, but in either case, consider attending the WorkBoat Show Professional Series session to hear the rest of the information and get the answers to your questions. It should be noted that the comments above are paraphrased and not direct quotes and that the EPA does not endorse me, my company or any of our products. They simply listened and provided factual feedback. See you at the show.
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