The deadline for the submission of the Vessel General Permit (VGP) annual report to the Environmental Protection Agency (EPA) is fast approaching. Vessels calling, or soon to call at US ports must be ready.
Tanker at anchor (Source: Skuld)
The deadline
By 28 February 2015 vessels must file their annual report documenting VGP activities to the EPA.
This will apply to ships as follows:
- vessels that have a VGP Notice of Intent (NOI) for the period of 19 December 2013 to 31 December 2014
- this applies whether or not the vessel actually called in the US during 2014
- it also applies if the vessel was sold or left the management
Warning: failure to submit an annual report is a non-compliance and can result in the USCG noting a PSC deficiency on the vessel.
Further information, including on how to submit the report, can be found in the ECM Maritime Services LLC Client Alert 06-2015, republished alongside this bulletin.
The Vessel General Permit
The VGP system applies to all commercial vessels of 79 feet / 24.08 metres in length, or greater, and which operate in the capacity of "a means of transportation". Further it specifically focuses on vessel "discharges" which may occur within 3 nautical miles of the US coastline or inland water.
First introduced in December 2008, the system was revised as of December 2014, and it affects a full range of member's vessels including fishing boats, barges and even emergency response vessels. Recreational craft and those of armed forces are not subject to these requirements.
The documents accompanying the system are quite extensive (re-published alongside this bulletin), but owners and technical managers will have to ensure they are read and understood, as a failure to comply will come with consequences, that includes fines and prosecutions.
It must also be kept in mind that there are a number of liquids and items that are not eligible for coverage under the VGP, including:
- used or spent oil
- garbage and trash
- photo-processing effluent
- effluent from dry-cleaning operations
- discharges of medical waste and related materials
- discharges of noxious liquid substance residues
To ensure a vessel is covered under the VGP, a NOI must be submitted, and submission deadlines and discharge authorisations are explained further in the VGP documentation.
The NOI must be kept on board the vessel, ready for inspection.
Furthermore annual reports must be submitted, and the upcoming deadline is a good opportunity for companies to verify that they are presently in compliance and that they will be able to continue in this manner.
Further reading
The Association has previously published updates and circulars on the VGP system.
Members can also access further information via the EPA's own website.
Assistance to members
Should a vessel have an issue while in the United States, members are urged to urgently make contact with Skuld's New York office.
The New York 24/7 number is as follows: +1 212 758 9200
For other vessel specific enquiries, members are asked to contact their usual Skuld business unit.
The Association is grateful to Messrs. ECM Maritime Services LLC for permission to republish their Client Alert 06-2015.