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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New EPA Vessel General Permits
Sorry, it's not going away… The Environmental Protection Agency (EPA) released the new Vessel General Permit (VGP) on November 30, 2011. This is a draft of the permit which will go into effect on December 19, 2013. This draft has been released for public comment, so don't miss the opportunity to provide your input.
I must commend the EPA for providing some constructive clarifications and procedures in this updated version of the permit.
Here are some highlights:
"This permit does not apply to any vessel when it is operating in a capacity other than as a means of transportation."
Vessels less than 300 gross tons that do not have capacity for 8 cubic meters of ballast water, that do not have to submit a notice of intent, but fall under the permit because they are over 79 feet, will now have to complete a Permit Authorization and Record of Inspection "PARI" form and carry it on the vessel at all times.
For each vessel, owner/operators are required to submit an Annual Report by February 28.
All reporting, such as annual reports, must be done electronically, with limited exceptions.
"For cargoes or onboard materials which might wash overboard or dissolve as a result of contact with precipitation or surface water spray, or which may be blown overboard by air currents, you must minimize the amount of time these items are exposed to such conditions."
General training is now required for those who actively take part in the management of incidental discharges.
"Vessel owner/operators must minimize deck washdowns while in port."
"Before deck washdowns occur, you must broom clean exposed decks or use comparable management measures and remove all existing debris."
"Vessels using water from a public water supply (PWS) as ballast must maintain a record of which PWS they received and a receipt, invoice, or other documentation from the PWS indicating that water came form that system."
"Unmanned, unpowered barges such as hopper barges are not required to meet the ballast water management measures of Part 2.2.3.5."
"Examples of ways to minimize the production of graywater include…restricting the length of showers while in port."
4.1.1.2 Extended Unmanned Period (EUP) Inspections
The EPA has also release the Small Vessel General Permit (sVGP). This sVGP applies to all commercial vessels less than 79 feet. This permit was also released for comment and will also go into effect on December 19, 2013. It will affect commercial fishing vessels, crew boats, utility boats and towboats excluded from the current VGP. The document is much shorter than the large vessel VGP, but contains many of the same requirements and is much more prescriptive.
I must commend the EPA for providing some constructive clarifications and procedures in this updated version of the permit.
Here are some highlights:
"This permit does not apply to any vessel when it is operating in a capacity other than as a means of transportation."
Vessels less than 300 gross tons that do not have capacity for 8 cubic meters of ballast water, that do not have to submit a notice of intent, but fall under the permit because they are over 79 feet, will now have to complete a Permit Authorization and Record of Inspection "PARI" form and carry it on the vessel at all times.
For each vessel, owner/operators are required to submit an Annual Report by February 28.
All reporting, such as annual reports, must be done electronically, with limited exceptions.
"For cargoes or onboard materials which might wash overboard or dissolve as a result of contact with precipitation or surface water spray, or which may be blown overboard by air currents, you must minimize the amount of time these items are exposed to such conditions."
General training is now required for those who actively take part in the management of incidental discharges.
"Vessel owner/operators must minimize deck washdowns while in port."
"Before deck washdowns occur, you must broom clean exposed decks or use comparable management measures and remove all existing debris."
"Vessels using water from a public water supply (PWS) as ballast must maintain a record of which PWS they received and a receipt, invoice, or other documentation from the PWS indicating that water came form that system."
"Unmanned, unpowered barges such as hopper barges are not required to meet the ballast water management measures of Part 2.2.3.5."
"Examples of ways to minimize the production of graywater include…restricting the length of showers while in port."
4.1.1.2 Extended Unmanned Period (EUP) Inspections
The EPA has also release the Small Vessel General Permit (sVGP). This sVGP applies to all commercial vessels less than 79 feet. This permit was also released for comment and will also go into effect on December 19, 2013. It will affect commercial fishing vessels, crew boats, utility boats and towboats excluded from the current VGP. The document is much shorter than the large vessel VGP, but contains many of the same requirements and is much more prescriptive.
For those owner/operators subject to the current VGP, don't forget to submit the required one-time reports, which are currently due during the 30-36 month of coverage.
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