1. MARPOL RECEPTION FACILITIES USCG CERTIFICATE OF ADEQUACY (COA) PROGRAM
Safety Branch/Cargo and Facilities Division
Office of Port and Facility Activity CG-5442
Capt. David A. Condino (MM)
April 22, 2008
Brief qualifications/background for LCDR Roldan and Me.
VMSAS 2008
United States Coast Guard

2. Overview Certificate of Adequacy (COA) Program
Office Organization
Program Responsibilities/Oversight
IMO/National Regulatory Mandates
Certificate of Adequacy (COA) Program
MARPOL Facility Inspectors
MARPOL Reporting to IMO
Investigating Allegations of Inadequacy
Guidance to Industry and Field Units
Program Goals- 100% International Compliance
I will cover the following topics in more-or-less order.

3. Office of Port and Facility Activity CG-5442
Office Organization
The Port and Facilities Safety Branch sits within the Office of Port and Facility Activities in the Directorate for Prevention Policy along with the Directorate for Commercial Regulations and Standards and the Directorate for Response Policy, all reporting to the Assistant COMDT For Marine Safety, Security, and Stewardship.
Office of Port and Facility Activity CG-5442

4. Program Responsibilities/Oversight
Implementation of MARPOL via US Regulations
Develop policy and regulations based on MARPOL and US Law
Review National Guidance for Field Units and Industry for COA Certificate Issuance Process
Monitor COA Application, Inspection, and Reporting Process
Review all reports of inadequacy
Participation in IMO Subcommittee work with member states
The major tasking for the program involves the following area:

5. IMO/National Regulatory Mandates
MARPOL 73/78, ANNEX I, ANNEX II, AND ANNEX V
ACT TO PREVENT POLLUTION FROM SHIPS (APPS) 33 U.S.C. §§ (Giving Authority to the CG to Implement MARPOL)
33 CFR 158 (Regulations Implementing MARPOL)
COMDTINST Oil, NLS, Garbage. (Instructions to Field Commanders for administering COA Program and issuing Certificates)
COMDTINST’s are not mandates but they serve as guidance and are based on guidance provided in MARPOL Implementation Guidelines.

6. Certificate of Adequacy (COA) Program US MARPOL Compliance-33 CFR 158
APPLICABILITY TO PORTS & TERMINALS – Who must have a COA
Annex I – Rcvs ships 400 GT or more w/ oily mixtures
Annex II- Rcvs ships carrying NLSs
Annex V- Rcvs Annex I or II vsls or fishing vsls which offload 500K lbs/year of fisheries product. All terminals must provide MARPOL V reception facilities including small rec. marinas not requiring a COA
REGULATORY ADEQUACY – TIME SENSITIVE CRITERIA
Annex I – Must rcv oily mixtures w/n 24-hrs of notice & must complete transfers w/n 10-hrs for ballast water & w/n 4-hrs for other oily mixtures.
Annex II – Must rcv residues w/n 24-hrs of notice & must complete transfers w/n 10 hrs.
Annex V – Must rcv APHIS (Animal and Plant Health Inspection Service) regulated garbage w/n 24-hrs of notice (Protecting Public Health)
Note that proscriptive criteria guidance is provided in the Annexes and/or Guidelines for Implementation.

7. COA Application/Issuance
STEP 1: The facility submits a COA application (CG-5401 A, B, or C) to the COTP for review.
STEP 2: The COTP reviews the applications against the standards set forth in the regulations.
STEP 3: If the application meets the requirements, the COTP conducts an inspection of the Port / Terminal and the reception facility to ensure the information provided on the application is accurate. In cases where the port / terminal contracts out a mobile truck or barge to provide reception facilities, these must also be inspected.
STEP 4: Particular attention should be paid for ports / terminals utilizing a common reception facility (i.e. a mobile truck provided annex I capabilities for all terminals within a port). In these cases, the reception facility must have the capability to service all terminals within the allowable timeframes as it may be easy for a single asset to become overwhelmed during busy periods.
STEP 5: If all is in order, issue a signed COA. The Port / Terminal maintains a copy of their signed COA and submitted application forms in their Operations Manual.
STEP 6: The COTP ensures MISLE is correctly updated to accurately reflect the information contained on the COA for each affected Port / Terminal (facility).
Source: 33 CFR ; ;
For Form A (Oily Mixtures) 33 CFR Part 158 Subpart B
For Form B (NLS Residues) 33 CFR Part 158 Subpart C
For Form C (Garbage) 33 CFR Part 158 Subpart D

8. COA FACILITY INSPECTORS
Must be qualified through Certificated Program
Training Courses
Minimum Experience Requirements
Designated in Writing by local commanders
Safety Branch provides review and updates to job-aids
Inspectors record results of inspections, and issue COA hard copy certificates using Coast Guard’s Marine Information for Safety and Law Enforcement System (MISLE)
HQ Safety Branch Monitoring of Facility Inspectors and MISLE to insure field units have proper resources, training, and tools for recording results of inspections, issuance of COA, and results of investigations of inadequacy reports.

9. Inadequacy Reports/Investigations
33 CFR – Report by any means to COTP
Field Units Copy COMDT (CG-5442) on any inadequacy investigation
Conduct investigation w/o needlessly revealing reporting party (recorded in MISLE by CG Investigator)
Examine suspected facilities’
Waste stream logs for waste streams from vessels.
Uniform Hazardous Waste Manifests.
Declarations of Inspections (DOIs).
Details in R Z SEP 06 & R Z FEB 07– (Guidance to Field Units)
Inadequacy Reports are submitted to the relevant COTP and can be submitted by the MASTER, OWNER, Vessel Agent, or Industry Organization representing the Owner/Operator of the Vessel. The COMDT Messages cited provide details regarding updates to HQ Oversight of MARPOL Field programs and the conduct of investigations of inadequacies.

10. MARPOL Reporting to IMO
Port Reception Facility Database Mandated by Congress in 33 USC 1905
Coast Guard Maintains Public Database via Coast Guard’s Maritime Information Exchange (GCMIX) Automatically updated through MISLE
Link: available on IMO Port Reception Facility Database (PRFD) via IMO’s Global Integrated Shipping Information System (GISIS)
Reports of Inadequacy and Investigation Results provided to IMO (Legal and Regulatory Compliance Division).
Coast Guard Takes Administrative/Legal Action to insure adequacy/correct any inadequacy
E.J. Terminella provided 2006 Annual Report (2007 Report is due in Sept)
USCG maintains a robust program but is always looking to improve program’s non-proscriptive performance measures.
Use live link to CGMIX if time permits or move to next slide (screen shot).

11. CGMIX Database
Use Live Link on Previous Slide if time permits.

12. Guidance to Industry/Field Units Outreach Efforts
Navigation and Vessel Inspection Circular (NVIC) and COMDT Instructions
Marine Safety Manual (MSM)
Develop Outreach Programs for Industry, End Users, Port Operators
Review of MARPOL and Update Regulations via Regulatory Project Process
Attend Public Meetings/Comment
Participation with Industry Partners
National and International Correspondence and Work Groups on Reception Facility and Port Related Safety, Pollution Prevention, and Environmental Issues.
Safety Branch outreach efforts include:
Use of both on-line and print editions are available to industry/field units.

13. Summing up Program Goals
Promote Safety and Environmental Stewardship
Promote and Encourage Pollution Prevention Policy Internationally, Nationally and Locally
Keep Industry on the move with minimal delays
Encourage best practice methodology and use of technology by working with industry and IMO Member States.
Insure that Field Inspectors have necessary experience and qualifications.
Achieve and Maintain 100% MARPOL Compliance

14. In Conclusion
The United States maintains a robust MARPOL Reception Facility Program aimed at meeting our international stewardship responsibilities and, as a Member State, through our national legislation, the requirements set forth in MARPOL 73/78

15. Safety Branch Contact Info:
LCDR Michael Roldan, Branch Manager
Office:
Captain David Condino (MM), Asst. Branch Manager, MARPOL Projects
Office:

16. Questions?
2006 Data:
# of Vessel Arrivals at US Ports: 146,756
# of US Facilities of all types (includes waterfront, marinas, bridges, fixed platforms, deepwater ports, etc.): 35,000+
# of Annex I Facilities Holding a COA: 651
# of Annex II Facilities Holding a COA: 127
# of Annex V Facilities Holding a COA: 2319 (Total Includes Annex I and II Facilities)
# of Facility Inspections Conducted (Total for all types): 17,243
# of Facility Deficiencies issued from inspections (Total for all types): 8,453
# of Pollution incidents investigated (total): 4,038
# of Facility Pollution Incidents investigated: 1,214