USCG Ballast Water Extension Programme – current status

As the USCG has issued US type approvals to three ballast water treatment systems in December 2017, vessels can no longer request an extension based on the absence of US type approvals. 

However, the extension programme is still active. Individual vessels can still seek an extension if: 

1. The vessel can provide documentation that these approved systems are not fit for purpose on the vessel seeking the extension or 
2. if approved system is fit for purpose, the requested extension is justified based on the non- availability of the system; or inability of the vessel to secure drydock space before its current implementation date. 

Rear Admiral Paul Thomas provided an excellent summary of the USCG’s perspective on the extension programme as it now stands given the existence of the three US type approvals. 

Commercial Vessel Incidental Discharge Act (VIDA) – current status

In January 2017, several senators introduced S. 168, the Commercial Vessel Incidental Discharge Act (CVIDA) with text closely mirroring that of the VIDA legislation, which was worked through the last Congress. This Act is for replacing multiple federal and state regulations by introducing a single national standard for the regulation of ballast water and other discharges incidental to normal vessel operations. Another opportunity has now been presented to push this legislation in the new Congress. In conjunction with this, under the initiative of the American Waterways Operators, an industry letter representing a broad stakeholders’ support has been sent to the Senate to express support for the VIDA initiative. Please refer to the full CSA report for the said letter.

Clarification of issues related to the USCG Initiated Remote Access and Consultation (RAC) Drills

In relation to the issues related to the USCG RAC drills, the USCG has issued Marine Safety Information Bulletin (MSIB) 02-17 to clarify them. A more thorough discussion and analysis can be found in the full CSA report. 

US Coast Guard initiate cyber reporting mechanism

The USCG have launched a new policy to include cyber attacks when reporting any suspicious activity or breach of security to ships. Only significant targeted cyber incidents are to be reported. 

The full policy including guidelines can be found at: USCG Policy Letter- Reporting Suspicious Activity and Breaches of Security

This will help the shipping industry expand their knowledge of the threat of cyber incidents to ships and should in turn improve training and awareness to mitigate any possible incidents. 

Reporting to the national centre (NCCIC) is also encouraged. 

STCW 2010 Amendments – US follow IMO’s recommendation to delay enforcement

The USCG has issued a notice that the US will follow IMO's recommendation (MSC Circ. linked below) to delay enforcement of the 2010 STCW amendments until 1 July 2017. 

USCG Port State Control (PSC) Officers will still review the requirements of the STCW 2010 amendments during examinations in the US and include those in the PSC report. Enforcement action will only be taken on any deficiencies found that are not part of the new transitional provisions within the STCW requirements. 

Aboard US flag ships, any mariner with a limitation on their MMC must provide evidence to the inspector that they have completed the training and submitted the application to the NMC. If not, a deficiency will be issued to the ship but no control actions will be taken against the mariner or ship until 1 July 2017. 

USCG contact information for this: 

• US flag ships: CG-CVC-1@uscg.mil  (Domestic Vessel Compliance) 
• Foreign flag ships: PortStateControl@uscg.mil  (Port State Control Program) 

Supporting documents: 

• MSC Circular on STCW 2010 Amendments Enforcement
• Maritime Commons-US will follow IMO recommendation for enforcement of STCW 2010 amendments

Launch of the US Maritime Advisory System

The US Maritime Advisory System was launched this week to streamline the process for government entities issuing maritime security alerts and advisories.

Advisories and alerts will be emailed out and posted on the web at www.marad.dot.gov/MSCI

For the full advisory: US Maritime Advisory 2017-001- please go to the full CSA report.