Since 1990, various Federal and State regulations have been enacted requiring certain marine transfer facilities to control their volatile or hazardous cargo vapor emissions.
The Coast Guard, under the Clean Air Act Amendments of 1990, is charged with ensuring that systems installed to collect these cargo vapors meet minimum safety standards for design and operation. To this end, the Coast Guard has developed a program, which incorporates regulatory requirements, policy guidelines, and third-party system certification.
From the onset,
this has been a customer-focused program, responsive to the maritime
industry’s needs. It is well recognized in the federal government for its
progressive use of private third-party certifying entities, and the close
partnership demonstrated between the Coast Guard and Chemical Transportation
Advisory Committee (CTAC)
in development of vapor control system regulations.
Hazardous Materials Division of Coast Guard Headquarters manages
the technical aspects of the Coast Guard VCS regulations on a regular basis.
New safety requirements for controlling vapors of additional chemicals or
operations are developed as needed. Exemptions and inquiries from industry
are reviewed and responded to routinely. The Hazardous Materials Division also implements an oversight program for Coast Guard authorized
third-party VCS certifying entities. In addition, policy letters, technical
guidelines, and advice are provided to COTPs, OCMIs, the MSC, certifying
entities, and vessel classification societies.
Certifying Entity Oversight Program was developed by the Hazardous Materials Division whereby the authority of review, inspection, testing, and
certification of facility VCSs is delegated to private, third-party,
certifying entities accepted by the Coast Guard. This program, which is
recognized as one of most progressive of its kind in government, allows
marine facilities to hire, at their choice, the Coast Guard authorized
certifying entity who can best accommodate their needs to conduct the
certification in a cost effective and timely manner.
Guard accepted certifying entities do not work for the Coast Guard under any
procurement or service contracts. Instead, they are paid by the facilities
to conduct VCS certifications on behalf of the Coast Guard. For this reason,
it is necessary for the Coast Guard to have an oversight program to maintain
technical control and quality assurance over the VCS certification program.
A successful third-party oversight program can provide assurance that
certifying entities are capable of performing facility VCS certifications,
and that the certifications were conducted in accordance with Coast Guard
guidelines. As a result, the oversight program can significantly reduce
erroneous certifications, which may otherwise impair the safety of facility
the Hazardous Materials Division maintains such a third-party
oversight program for the facility VCS certifying entities. Division
personnel take one or two trips per year to conduct on-site audits of the
certifying entities. About one month before a scheduled audit, the Hazardous Materials Division will notify the targeted certifying entity via
a phone call, and about two weeks before the trip, the Hazardous Materials Division will confirm the visit in writing. A typical audit lasts
one day, but may extend to two. In addition to personnel interviews,
oversight personnel will also review plans, drawings, test data and reports,
and any other technical documentation pertaining to the certified facility
that all of the Coast Guard accepted CEs perform the facility VCS
certification under a standard set of criteria, the Hazardous Materials Division issued detailed guidelines to all certifying entities in
October 1991, for conducting review, certification, and initial inspection
of shore side facility VCSs. Under the administrative requirements of the
guidelines, a certifying entity, upon its satisfaction, is required to issue
a certification letter to the cognizant COTP stating that the facility VCS
complies with 33 CFR part 154, subpart E and other applicable Coast Guard
requirements. The certifying entity is also required, under a separate Coast
Guard guideline, to provide the Hazardous Materials Division with
an oversight letter forwarding the required technical information for the
To organize and file technical information provided by certifying entities on certified facility VCSs, the Hazardous Materials Division maintains a computer database using Microsoft Access 97 software. The database contains records on all certified facility VCSs, and includes specific information such as certification dates, arrangement of berths, number of facility vapor connections, system type, cargo information, and exemptions granted to the facility.
The responsibilities for implementing the VCS regulations are shared among several organizations within the Coast Guard. At the field level, the Marine Safety Center (MSC), Cargo Division, located in Washington, DC, is responsible for conducting vessel VCS design review and approval for U.S. flag vessels. Local Captains of the Port (COTPs) are responsible for reviewing the operations manual submitted by a facility, and granting a facility authority to operate its VCS. This authorization is based on certification of the VCS by a Coast Guard authorized certifying entity. Officers in Charge, Marine Inspection (OCMIs) are responsible for endorsing a vessel's Certificate of Inspection (COI) or Certificate of Compliance (COC) authorizing vapor control based on MSC approval for a U.S. flag vessel, or classification society approval for a foreign flag vessel.
At the Coast Guard Headquarters level, the Commandant’s Office of Vessel Activities (CG-543), serves as program manager for COTPs and OCMIs in administering facility VCS and vessel VCS regulations. The Hazardous Materials Division is responsible for managing and developing the technical aspects of the VCS regulations. These responsibilities include the development of VCS requirements for individual chemicals, explaining the technical aspects of the regulations to industry, administering exemption requests, and approving and providing technical advice to certifying entities, vessel classification societies, and other Coast Guard offices
US Coast Guard
2100 2nd Street SW Stop 7126
Washington DC 20593-7126
Tel: +1 (202) 372-1420