Vessel Circulars

CIRCULAR 018-09;  SEPTEMBER 4, 2009

 

USCG Publishes Anticipated Regulations

 


BACKGROUND


As reported in our Annual SMTTTX 2008 and in our quarterly Newsletters, there are several pending USCG regulatory initiatives that have been on-going for sometime.  These include the following:
 
*Ballast Water Discharge Systems and Standards Update
On August 28, 2009 the USCG published a Notice of Proposed Rulemaking entitled Standards for Living Organisms in Ships' Ballast Water Discharge in U.S. Waters that outlines proposed Ballast Water Discharge Standards.  The public comment period for the proposed regulations extends through November 27, 2009. 
 
*Nontank Vessel Response Plan Regulations Update
On August 31, 2009 the USCG published a Notice of Proposed Rulemaking entitled Nontank Vessel Plans and Other Vessel Response Plan Requirements that outlines specific requirements for Nontank vessels to have vessel response plans similar to existing regulations for Tank vessels.  The public comment period for the proposed regulations extends through November 30, 2009. 
 
*Removal Equipment Alternate Technology (Dispersants) (CAPS) Update
On August 31, 2009 the USCG also published a Final Rule entitled Vessel and Facility Response Plans for Oil: 2003 Removal Equipment Requirements and Alternative Technology Revisions that outlines specific requirements for new response technologies and revises methods and procedures for responding to oil spills upon the navigable waters of the US, adjoining shorelines, and exclusive economic zone (EEZ).  This is the much anticipated CAPS regulation.  Although the effective date of these regulations is September 30, 2009, the amendments to response plans are not required until February 22, 2011.  This regulation also postpones the effective date for the implementation of the Salvage and Marine Firefighting regulations that were the subject of Circular 002-09 until February 22, 2011.

 

ACTIONS TO BE TAKEN

  • NO ACTION IS REQUIRED BY PLAN HOLDERS.
  • O'Brien'sRM will continue to closely monitor the progress of these regulations and advise if and when any further actions are required of Plan Holders in the future via circular letter.
  • O'Brien'sRM intends to make all the necessary revisions to plans that will eventually be required by these regulations prior to the implementations dates for each.

 

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CONTACT US

If you should have any questions or comments, please do not hesitate to contact us at inquiry@obriensrm.com.

Chris Gregory
Executive Vice President, Vessel Services
E-mail:  chris.gregory@obriensrm.com

Sean Rock
Manager, Vessel Technical & Compliance Services
E-mail: sean.rock@obriensrm.com


24-Hour Emergency Assistance: +1 985.781.0804

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