Management of Ship’s Waste On-board and Ashore : MARPOL Annex V Roundtable Discussion

Presented by : Presented by : North American Marine Environmental Protection AssociationNorth American Marine Environmental Protection Association

West Gulf Maritime Association, Houston, TXWest Gulf Maritime Association, Houston, TX

Capt. David Condino, USMM, CIVCapt. David Condino, USMM, CIVHQ USCGHQ USCG

Office of Port and Facility Compliance (CG-FAC-2)Office of Port and Facility Compliance (CG-FAC-2)

United StatesCoast Guard

http://www.southcom.mil/PA/Images/logoCoastGuard.jpg


Promote Safety and environmental stewardshipPromote Safety and environmental stewardship

Encourage pollution prevention policy internationally, Encourage pollution prevention policy internationally, nationally and locallynationally and locally

Keep industry on the move with minimal delaysKeep industry on the move with minimal delays

Encourage best practice methodology and use of technology Encourage best practice methodology and use of technology by working with industry and IMO Member Statesby working with industry and IMO Member States

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IMO Guidance to IMO Guidance to Member StatesMember States

““MARPOL provisions require the MARPOL provisions require the government of each party to ensure government of each party to ensure the provision of adequate port the provision of adequate port reception facilities without causing reception facilities without causing undue delay.undue delay.””

““……failure to establish adequate failure to establish adequate facilities is a breach of international facilities is a breach of international obligations and will increase the risk obligations and will increase the risk of illegal discharges from ships.of illegal discharges from ships.””

““……ship operators will favor ports ship operators will favor ports with good services at reasonable with good services at reasonable cost.cost.””



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National LegislationNational Legislation

•US incorporates MARPOL regulations US incorporates MARPOL regulations in in the Act to Prevent Pollution from the Act to Prevent Pollution from Ships (APPS) Ships (APPS) as Codified in 33 CFR as Codified in 33 CFR 151 and 33 CFR 158 (Reception 151 and 33 CFR 158 (Reception Facility Regulations)Facility Regulations)

•Other countries may have variations Other countries may have variations based on Their ownbased on Their own National National environmental prioritiesenvironmental priorities



US Coast GuardUS Coast Guard’’s s Certificate of Adequacy Certificate of Adequacy (COA)(COA)

Program: (33 CFR 158)Program: (33 CFR 158)

MARPOL MARPOL Applies to Ships Applies to Ships and to and to ports and terminalsports and terminals

Ports and Terminals must provide Port Ports and Terminals must provide Port Reception Facilities (PRF) for ShipsReception Facilities (PRF) for Ships

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33 CFR 158.135:“To continue to receive ships, a port or terminal must hold one or more Certificates of Adequacy”(See Criteria)

33 CFR 158.140:“To continue to receive ships at a port or terminal required by 158.135 . . . the person in charge must apply to the Coast Guard . . .”

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◦ Annex I – Receives ships Annex I – Receives ships 400 GT 400 GT or more w/ oily or more w/ oily mixturesmixtures

◦ Annex II- Receives ships carrying Annex II- Receives ships carrying NLSsNLSs◦ Annex V- Receives Annex V- Receives Annex I or II ships or fishing Annex I or II ships or fishing

vesselsvessels which offload 500K lbs/year of fisheries which offload 500K lbs/year of fisheries product.product. In the US All terminals must provide In the US All terminals must provide MARPOL V reception facilities including small MARPOL V reception facilities including small recreational marinas not requiring certificationrecreational marinas not requiring certification

◦ Annex VI – Stack Scrubber Residues and Ozone Annex VI – Stack Scrubber Residues and Ozone Depletion SubstancesDepletion Substances

Reception Facility Applicability Reception Facility Applicability Who Must Provide Them: Who Must Provide Them: 33 CFR 15833 CFR 158



Penalties for violation:

“a person who violates MARPOL . . .”

“$25,000. . .EACH DAY”

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•Private Companies such as waterfront facility/land Private Companies such as waterfront facility/land owners (piers, basins, docks, quays, terminals) owners (piers, basins, docks, quays, terminals)

•Public enterprise or a combination (Municipally, i.e. Public enterprise or a combination (Municipally, i.e. federal, state, city owned/operated ports or terminals)federal, state, city owned/operated ports or terminals)

• A port may determine their own cost considerations A port may determine their own cost considerations (Fixed Port Fees, Tonnage Tax, Commercial (Fixed Port Fees, Tonnage Tax, Commercial transaction?) But they should be reasonable. transaction?) But they should be reasonable.

Port Reception Facilities can be:Port Reception Facilities can be:



◦ A General Guidance document in A General Guidance document in the form of an the form of an IMO Circular: IMO Circular: MEPC.1/Circ.671MEPC.1/Circ.671

◦ Downloadable from GISIS Downloadable from GISIS website: website: http://gisis.imo.org/Public/http://gisis.imo.org/Public/

◦ Definitions and suggestions for Definitions and suggestions for ship owners/operators and ship owners/operators and reception facility operatorsreception facility operators

◦ Inadequacy Reporting and Inadequacy Reporting and Advance Notice and Waste Advance Notice and Waste Receipt Receipt FormsForms

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Reception Facility Adequacy: Reception Facility Adequacy: What determines Adequacy?What determines Adequacy?

Timeliness: US Coast Guard Certificate Timeliness: US Coast Guard Certificate of Adequacy (COA) program in keeping of Adequacy (COA) program in keeping with IMO Guidancewith IMO Guidance◦ Annex I – Must receive oily mixtures w/n Annex I – Must receive oily mixtures w/n 24-hrs of notice24-hrs of notice

& must complete transfers w/n & must complete transfers w/n 10-hrs for ballast water & 10-hrs for ballast water & within 4-hrs for other oily mixtureswithin 4-hrs for other oily mixtures. .

◦ Annex II – Must receive residues w/n Annex II – Must receive residues w/n 24-hrs of notice 24-hrs of notice & & must complete must complete transfers w/n 10 hrs. transfers w/n 10 hrs.

◦ Annex V – within Annex V – within 24-hrs of notice including for 24-hrs of notice including for Quarantine WasteQuarantine Waste (Protecting Public Health) (Protecting Public Health)

◦ Annex VI – Must receive Annex VI – Must receive ODS and Stack Scrubber ODS and Stack Scrubber ResiduesResidues

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PORT RECEPTION PORT RECEPTION FACILITIES FACILITIES (Operational (Operational Adequacy and Best Adequacy and Best Practices)Practices)◦ Conform with national and local Conform with national and local

permitting schemes or licensing permitting schemes or licensing required by environmental and required by environmental and public health laws concerning waste public health laws concerning waste handlinghandling

◦ Must be arranged so as not to Must be arranged so as not to interfere with port or terminal interfere with port or terminal operationsoperations

◦ Must be conveniently located so it Must be conveniently located so it can be easily found and use is not can be easily found and use is not discourageddiscouraged

◦ Must be situated so that wastes and Must be situated so that wastes and residues removed from ships cannot residues removed from ships cannot readily enter the waterreadily enter the water

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The Coast Guard investigates all allegations of The Coast Guard investigates all allegations of inadequacy at PRFs and may examine: inadequacy at PRFs and may examine: Waste stream logs for waste streams from vessels Waste stream logs for waste streams from vessels Hazardous Waste Manifests Hazardous Waste Manifests Cargo and Bunker Transfer DocumentsCargo and Bunker Transfer Documents Advance Notice and Advance Notice and Waste Receipt Forms Waste Receipt Forms on-board and at on-board and at

PRFsPRFs

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Report Inadequacies to the Captain of the Port (COTP) by any Report Inadequacies to the Captain of the Port (COTP) by any means (33 CFR 158.167)means (33 CFR 158.167)

Use of the standard format for reporting alleged inadequacy of Use of the standard format for reporting alleged inadequacy of PRFs to the IMO PRFs to the IMO ((MEPC.1/Circ.469/Rev.1MEPC.1/Circ.469/Rev.1))



IMOIMO’’s Global Integrated Shipping Information System s Global Integrated Shipping Information System (GISIS) (GISIS) http://gisis.imo.org/Public/

Use of the IMO PRFD Use of the IMO PRFD as the primary source for as the primary source for information about port reception facilities worldwideinformation about port reception facilities worldwide

Reports of Inadequacy Reports of Inadequacy and Investigation Results and Investigation Results provided to IMO (Legal and Regulatory Compliance provided to IMO (Legal and Regulatory Compliance Division)Division)

Standardized Advance Notice and Waste Receipts Standardized Advance Notice and Waste Receipts approved and available for download as approved and available for download as MEPC.1/Circ.644 MEPC.1/Circ.644 and Circ.645and Circ.645

““Guide to Good PracticesGuide to Good Practices”” for PRF users available on for PRF users available on GISIS websiteGISIS website

Some Port States may be able to provide their own web Some Port States may be able to provide their own web based information based information (example: USA has its Coast Guard (example: USA has its Coast Guard Maritime Information Exchange Maritime Information Exchange (http://cgmix.uscg.mil/MARPOL/Default.aspx)(http://cgmix.uscg.mil/MARPOL/Default.aspx)

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http://gisis.imo.org/Public/



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Other Issues Affecting Other Issues Affecting Ship Owners/Operators Ship Owners/Operators and Port Operatorsand Port Operators

•Special Area DesignationSpecial Area Designation

•ISO Standards for Shipboard and PRF ISO Standards for Shipboard and PRF waste managementwaste management

•Quarantine WastesQuarantine Wastes Cruise ship at a US port preparing to leave for a week-long voyage to the Caribbean!



Wider Caribbean Region Special Area (WCR SA)



◦ ISO 21070 (Published ISO 21070 (Published 2011)2011) Waste SegregationWaste Segregation StorageStorage Waste MinimizingWaste Minimizing Waste Handling EquipmentWaste Handling Equipment

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ISO 16304 (Published 2012)ISO 16304 (Published 2012) Waste Segregation Waste Segregation StorageStorage Waste MinimizingWaste Minimizing Waste Handling EquipmentWaste Handling Equipment RecyclingRecycling Local and National Local and National

RegulationsRegulations Treatment technologies at Treatment technologies at

the portthe port

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US Ports must be able to receive APHIS regulated US Ports must be able to receive APHIS regulated garbage within garbage within 24-hrs of notice24-hrs of notice (Protecting Public (Protecting Public Health) 33 CFR 158 Part D – It is the law!!Health) 33 CFR 158 Part D – It is the law!!

Regulated Wastes (quarantine): Regulated Wastes (quarantine): Animal and Plant Health Animal and Plant Health Inspection Service (APHIS)Inspection Service (APHIS)



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Summary - ConclusionsSummary - Conclusions

The Way Forward for Cleaner Oceans:The Way Forward for Cleaner Oceans:Adhering to Adhering to Best Management Practices Best Management Practices for Management of for Management of ships waste ships waste Aboard and AshoreAboard and Ashore

Enhanced Enhanced Record Keeping Record Keeping and Reporting for ship and Reporting for ship owners/crews and Port/Terminal operators.owners/crews and Port/Terminal operators.

Embracing Concepts of Embracing Concepts of ““Cradle-to-GraveCradle-to-Grave”” management of management of shipsships’’ waste and principles of waste and principles of Reduce, Re-use and RecycleReduce, Re-use and Recycle

Widest distribution of Widest distribution of guidance and standards guidance and standards for waste for waste handling/management/technology and responsible and handling/management/technology and responsible and environmentally safe ultimate disposalenvironmentally safe ultimate disposal

Working toward Working toward keeping shipskeeping ships’’ waste out of the oceans waste out of the oceans..



David Condino, CG-FAC-2, Facility Safety BranchDavid Condino, CG-FAC-2, Facility Safety BranchOffice: +1-202-372-1145Office: +1-202-372-1145

[email protected]@USCG.MIL

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Management of Ship’s Waste On-board and Ashore : MARPOL Annex V Roundtable Discussion

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