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Volume 116, Issue 1
Page 8
Marine Safety
The Coast Guard and MARPOL Annex VI
We normally think of water pollution prevention/abatement as the primary
concern of the Coast Guard and Auxiliary when it comes to the Environmental
Protection component of Marine Safety and rightly so, yet a significant piece of
international legislation, the International Convention for the Prevention of
Pollution from Ships or MARPOL, contains one whole "annex" or series of
provisions called Annex VI dealing with air pollution from ocean-going ships. In
U.S. law, this is the Act to Prevent Pollution from Ships, 33 U.S.C. 1901-1905,
a.k.a. "APPS."
Without going into great detail, Annex VI is the international air pollution
requirements that limit emission of nitrogen oxides (NOx) and regulations
requiring usage of low sulfur content fuel in ocean-going vessels. Ocean-transiting
vessels also emit fine particulate matter, sulfur oxides (SOx), hydrocarbons (HC),
and carbon monoxide (CO). The aforementioned provisions are applicable to all
U.S. waters and the North American Emission Control Area or ECA which is an
area 200 nautical miles off the coast of North America.
Gregg Bollinger
DSO
Marine Safety
U.S.flagged vessels with a regulated diesel engine(s) are required to have an Engine International Air Pollution
Prevention or EIAPP certificate issued by the Environmental Protection Agency (EPA). Some vessels must have
an International Air Pollution Certificate or IAPP which is USCG-issued. Either the Coast Guard or EPA may
bring legal action for violations noted during inspections of U.S. flagged vessels and non-U.S. flagged vessels
subject to Port State Control inspections while in U.S. waters.
The EPA and USCG entered into a Memorandum of Understanding (MOU) on 27 JUN 2011 which ensures joint
effort to oversee marine fueling facilities, on-board inspections, and review of records which includes EIAPP
certificates, a file for each diesel engine containing engine specs to be used for compliance with NOx limits and a
record book of engine parameters for recording all changes made relative to an engine's components and
settings. Additionally, fuel suppliers must provide bunker delivery notes and fuel samples which are kept on board
for three years and 12 months respectively, https://www.epa.gov/sites/production/files/documents/
jointletter062711.pdf.
USCG diligence in carrying out this mission of monitoring air pollution by ships helps to ensure that ships do not
harm the environment by contributing unnecessary air pollution.
Gregg Bollinger, Th.D
ADSO-MS (W), SO-MS Div. 19, FSO-MS Flotilla 19-04