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Commander
13th Coast Guard District
915 Second Ave
Seattle, WA 98176

The Alternate Compliance and Safety Agreement (ACSA)

13th Coast Guard District

What is the ACSA?

Unlike commercial fishing vessels, Fish processing vessels are required to meet classification and loadline requirements.The District Commander has the authoirty to allow exemptions of regulations provide that good cause exists and the safety of the vessel and crew are not compromised.

The ACSA was established for a fleet of vessels that were actually processing fish as opposed to just head, gutting and freezing (below is a list of processes a fishing vessel is allowed to preform). Initially it was difficult for the Coast Guard to determine whether a vessel was truly a fishing vessel or doing more to the fish that caused the vessel to be considered as a fish processing vessel.

A tool for determining exactly what each vessel was doing to the fish became apparent when the 17th Coast Guard District discovered that the National Marine Fisheries Service (NMFS) requires these vessel to report the products they produce using a list called the NMFS product codes. By examining the products these vessels were reporting to NMFS the Coast Guard was able to clearly determine whether a vessel was truly operating as a fishing vessel or as a fish processing vessel. Many vessels that were operating as fishing vessels were driven to more fully utilize the fish to satisfy the requirements in the Magnuson-Stevens Fishery Conservation and Management Act (excerpt section 104-297(i)).

A fishing vessel is allowed to:

Catch fish and perform the following minimal processing in order to preserve the fish…

Remove the head (decapitate)
Remove the organs (gut)
Remove the gills
Remove the skin
Shuck (such as oysters)
Ice
Freeze
Brine Chill

Labeled as "H&G" in NMFS Processing codes.

Fish processing vessels –

A vessel that does any processing beyond those listed above.
Example

Removing the tail
Producing fillets
Removing and keeping the eggs.

A fish processing vessel may or may not also catch fish.

Several vessel owners elected to stop producing those products that constituted processing and only perform those allowed of a fishing vessel (listed as H_&_G). Most vessels opted to comply with the newly established standards in the ACSA program and were allowed to continue minimul processing as listed. These vessels were not allowed to producing products listed as extensive processing. Only fish processing vessels that are classed and loadlined are allowed to perform "extensive processing".
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VIew the on-line version of the Guidance for the ACSA Program

You can view the online version of the guide by left cllicking on the link below.

Click here to view the ACSA Guide.

How to Download a copy of the Guidance for the ACSA Program.

Right click on the below link.
Select "Target Save As"
Browse to a location on your computer to download the file.

RIght click on this link.

To reduce download time this file was compressed using Winzip. Once you have downloaded the file, you will need Winzip to uncompress the file.

Note: an evaluation copy of WINZIP is available at http://www.winzip.com/downwz.htm.

To uncompress the file using winzip select the "Extract" button, then browse to a location on your computer where you want to place the files. Once uncompressed you will see the ACSA Guide and a folder labeled "ACSA_References".

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To view the guide, open the document "2011_ACSA_Guide_revision_3.pdf". The "ACSA_References" folder contains .pdf files of all of the regulations referenced in the guide. Do not move the relative location of these files and folders or you may break the hyperlinks in the ACSA Guide to these regulations.

Viewing your downloaded version of the guide

You must have the Adobe Acrobat Reader in order to view the Guide and the references. You can download a free copy of the reader at http://get.adobe.com/reader/enterprise/.

Four inspection types performed on ACSA vessels

Each vessel enrolled in the ACSA program must receive a Certificate of Compliance (COC) and keep a copy on board the vessel and available for inspection by Coast Guard Law Enforcement personnel. A COC is valid for two years.

"Renewal Exemption" accomplished by a Coast Guard Marine Inspector at the beginning of the exemption period and the issuance of the ACSA Exemption Letter.
- Must be completed prior to the expiration of the previous ACSA Exemption Letter. During this inspection the vessel is examined for the requirements listed in Sections A, B and F, G, H, I J, K, L of the Guidance for the ACSA Program.
- The request for renewal must be made by the owner or operator to the Thirteenth District Commander 60 days prior to the expiration of the vessels previous exemption letter.
"Mid-Period" inspection conducted by a Coast Guard Marine Inspector and required one year after anniversary of the "Renewal Exemption". The ACSA Exemption letter must be signed by the attending Marine Inspector in the space provided in the endorsement section of the current ACSA Exemption Letter.
- The owner is allowed 60 days either side of the one year anniversary. This examination includes a check of Sections A, B and F, G, H, I, J, K, L listed in the Guidance for the ACSA Program.
"Certificate of Compliance (COC)" can be conducted by a 3rd Party organization or a Coast Guard Commercial Fishing Vessel Safety Dockside Examiner to ensure the vessel is in compliance with the fishing vessel safety regulations in 46 CFR part 28 and other safety regulations.
- If conducted by a 3rd Party organization the organization will issue the vessel a separate COC. The vessel must retain a copy of the COC issued by the 3rd Party aboard the vessel.
- If conducted by the Coast Guard the ACSA Exemption letter will include wording that the Coast Guard conducted the exam and the exemption letter is also the COC. SInce the Exemption Letter is good for two yearsa a space will be provided for the attending coskside examiner to endorse the exemption letter

This inspection must be accomplished annually and not be allowed to expire. A Commercial Fishing Vessel Decal is issued at the time of this inspection. The examination includes applicable items listed in the CFIVS Exam Book (CG-5587) and it's supplement (CG-5587B).

"Hull Examination" is conducted by a Coast Guard Marine Inspector and is required twice in a five year period, with no interval allowed to exceed 3 years. The ACSA Exemption letter must be signed by the attending Marine Inspector in the space provided in the endorsement section of the current ACSA Exemption Letter.
- This examination includes a check of requirements listed in Sections C - G of the Guidance for the ACSA Program.

Additional ACSA program Documents

In additon to the above program guidance, below is a copy of the current inspection checklist. In addition are historical documents which originally create the ACSA.

Current Inspection Checklist

CG-840 Inspection Booklet for ACSA - Current version dated Nov 2009.

Historical Documents

Historical Timeline - This document provides a timeline of significant events during the implementation of the ACSA.

Original ACSA Implementing Document - This is a copy of the agreement signed by both the Thirteenth and Seventeenth District Commanders implementing the ACSA program dated June 15, 2006. Below are the list of enclosures for this document...
- Enclosure (2) - NMFS product codes - This is the list of product codes used by fishing processing vessels to report the products being produced aboard each vessel. The Coast Guard and industry meet to categorize each product code as being normal head and gutting as allowed aboard fishing vessels, and those items that went beyond what was allowed by fishing vessels divided into two categories. Those products that were considered processing but would be allowed on ACSA vessels, and those products that were only allowed by fish processing vessels that were required to be classed and loadlined (unless grandfathered).
- Enclosure (3) - ACSA Guidance - This was the document listing the additional vessel requirements for vessels enrolled into the ACSA program.
- Enclosure (4) - Application for enrollment - This was the application required to be submitted by July 15, 2006 in order to be enrolled in the ACSA program.
- Enclosure (5) - Compliance matrix - This matrix identified what inspections were required and who could do the various inspections.
Original ACSA Inspection Checklist - This was the first version of the CG-840 book released June 2, 2006.

1st Update to the ACSA Inspection Checklist - released January 29, 2008.

CG-543 Policy Ltr 12-01 - This is the headquarters guidance for the implementation of the ACSA program established by the Thirteenth and Seventeenth Districts dated February 15, 2012.

Federal Register ACSA Implementation Guidance release - Dated March 24, 2009, this announced the release of the ACSA Implementation Guidance document.

Annual Coast Guard meetings with industry

An annual industry meeting is scheduled around the 1st of July each year. Industry and Coast Guard personnel involved in the oversight of the ACSA program meet to discuss potential changes to the ACSA Implementation Guide.

Click here to view the notes from the June 16, 2011 industry meeting.

Click here to view the notes from the June 23, 2010 industry meeting.

Click here to view the notes from the June 30, 2009 industry meeting.

Click here to view the notes from the July 1, 2008 industry meeting.

If you have any questions contact Troy Rentz at 206 220-7216 or Troy.Rentz@uscg.mil.

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Last Modified 4/3/2012