U.S. Coast Guard and the Environmental Protection Agency Announce VGP Monitoring Agreement

The U.S. Coast Guard (USCG) has been working with the U.S. Environmental Protection Agency (EPA) to develop a framework from where the USCG could monitor the Vessel General Permit (VGP) requirements for the EPA. On Friday, 11 February, 2011, both organizations announced a completed Memorandum of Understanding (MOU) between the two government agencies for the USCG to begin monitoring activities.

The EPA had published the VGP on 19 December, 2008 and it became effective on 6 February, 2009. The VGP requires control and monitoring of 26 regulated wastes streams typically generated incidental to the operation of commercial vessels. However, the EPA has little marine enforcement capability and has relied on voluntary compliance to these mandatory requirements. With the new MOU between these two agencies, the USCG will be assuming the monitoring role on board vessels for the EPA.

water on leaf - smallAlthough the MOU does not provide specifics as to how or when this monitoring will begin, the USCG had previously issued some internal guidance to their field units as to what the future activities would entail. The USCG has indicated they will verify the NOI has been submitted, required monitoring is being conducted, and appropriate records are maintained. In the case of discharge violations, the USCG will ensure that appropriate notifications have been made. In cases where the USCG identifies incidents of noncompliance which have not been properly reported, the USCG will notify the EPA for further action such as warnings or fines. The USCG will not be conducting examinations specifically for VGP compliance but instead will incorporate these requirements into their existing Port State Control (PSC) boarding program.

What should shipping companies do to ensure they are prepared for these new inspections? You should contact your vessels and ensure they have on board the following:

  • A copy of their Notice of Intent (NOI);
  • Records to support conducting weekly inspections while in US waters;
  • A drydock inspection report in accordance with the VGP if a drydocking has been conducted since December 2008;
  • Annual inspection reports;
  • Records of corrective actions, if applicable; and
  • Records of discharge violation reports, if applicable.

We remind all of our clients that ECM offers assistance in submission and maintenance of NOI’s, preparation of shipspecific VGP compliance guidance including weekly checklists, and conducting annual inspections on board utilizing our experienced inspection staff. For information concerning these valuable programs contact ecm@ecmmaritime.com

ECM will also provide NPDES/VGP training in conjunction with our annual SMT TTX program.


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