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US Coast Guard Implementation of MARPOL Annex IIbbbbb

US Coast Guard Implementation of MARPOL Annex IIbbbbb. By Tom Felleisen. Disclaimer. The views expressed are those of the author and do not necessarily represent the official view of the US Coast Guard. Changes to MARPOL Annex II. Simplification. Changes to MARPOL Annex II. Simplification

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US Coast Guard Implementation of MARPOL Annex IIbbbbb

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  1. US Coast Guard Implementation of MARPOL Annex IIbbbbb By Tom Felleisen

  2. Disclaimer The views expressed are those of the author and do not necessarily represent the official view of the US Coast Guard

  3. Changes to MARPOL Annex II • Simplification

  4. Changes to MARPOL Annex II • Simplification • Align with the Globally Harmonized System for Classification and Labeling of ChemicalsAn activity which resulted from UN Rio Conference (1992) – Agenda 21

  5. Changes to MARPOL Annex II • Simplification • Align with the Globally Harmonized System for Classification and Labeling of Chemicals • Lipophilic substances (Vegetable oils and Animal Fats)

  6. Vegetable oils and Animal Fats • Existing Annex II Not “en route”No underwater discharge

  7. Vegetable oils and Animal Fats • Existing Annex II Not “en route”No underwater discharge • Implemented differently by US

  8. Changes to MARPOL Annex II • Simplification • Align with the Globally Harmonized System for Classification and Labeling of Chemicals Parallel Processes – Unclear outcome

  9. Changes to MARPOL Annex II • Change from 4 pollution categories +unregulated to 3 pollution categories + unregulated • Ship typing changes for chemical cargoesBased on hazards of residue dischargesBased on hazards of tank breach

  10. Ship Typing Based on entirely new pollution criteria developed from the Globally Harmonized System

  11. Rulemaking • Requirements of the Administrative Procedures Act

  12. Rulemaking • Requirements of the Administrative Procedures Act (APA) • APA precludes private disclosure concerning rulemaking (Ex Parte Communication)

  13. Rulemaking • Requirements of the Administrative Procedures Act (APA) • APA precludes private disclosure concerning rulemaking (Ex Parte Communication) • Start of rulemaking in Spring ‘06

  14. Rulemaking • Requirements of the Administrative Procedures Act (APA) • APA precludes private disclosure concerning rulemaking (Ex Parte Communication) • Start of rulemaking in Spring ’06 • After BLG 10 finalizes the list of chemicals

  15. Rulemaking Process • Advance Notice of Proposed Rulemaking (ANPRM)Requests comments from public Indicates the Agency’s intentions

  16. Rulemaking Process • Advance Notice of Proposed Rulemaking (ANPRM) • Notice of Proposed Rulemaking (NPRM)Gives proposed regulatory language for rulemaking Requests comments on rulemaking

  17. Rulemaking Process • Notice of Proposed Rulemaking (NPRM) • Advance Notice of Proposed Rulemaking (ANPRM) • Final RuleWhat we – USCG and Public - need to live with

  18. Rulemaking Process • Notice of Proposed Rulemaking (NPRM) • Advance Notice of Proposed Rulemaking (ANPRM) • Office of Management and Budget (White House) review • Final Rule

  19. Rulemaking Process Total rulemaking time: many monthstowell over a couple of years

  20. MAPOL Annex II Effective Date 01/01/2007

  21. Interim Measure Navigation and Vessel Inspection Circular (NVIC)

  22. Navigation and Vessel Inspection Circular • Elective alternative to current MARPOL Annex II

  23. Navigation and Vessel Inspection Circular • Elective alternative to current MARPOL Annex II • Permits compliance with 01/01/2007 requirements Allows trading to ports that will vigorously enforce the new requirements

  24. Navigation and Vessel Inspection Circular • Elective alternative to current MARPOL Annex II • Permits compliance with 01/01/2007 requirements • Introduces Third-Party SurveyorsReduces burden on USCG assets

  25. Some Current Problems • LatexLargest employer in Liberia,which supported MARPOL Annex IIrevision

  26. Some Current Problems • LatexLargest employer in Liberia,which supported MARPOL Annex IIrevisionTwo “Latex tankers” thrown out of trade Will not likely be tested for Health and Safety in time to be in the International Bulk Chemical Code

  27. Some Current Problems • Latex • Some vegetable oils

  28. Some Current Problems • Latex • Some vegetable oilsNo testing yet: Perilla Rice Bran Safflower etc.

  29. Some Current Problems • Latex • Some vegetable oils • Available tonnage of type 2 tanks on type 2 shipsInterruption of trades in the absence of shipsAppreciably higher freight ratesfor all chemicals

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