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

Patrick.A.Keffler@uscg.mil

(202) 372-1424

LCDR Andrew Murphy

Andrew.J.Murphy@uscg.mil

(202) 372-1398

Thank you

Questions?