The US Coast Guard has issued its fourth US type approval certificate to Sunrui Marine Environment Engineering Co., Ltd. This system uses a three-step process (filtration, electrolysis and neutralization) to meet the performance standards found in the US regulations and the IMO Convention. More details on this type approval may be found on the Marine Safety Center website.
Ship owners are urged to contact the manufacturer to obtain a copy of the type approval certificate which contains all limitations applicable to this system. Of interest is the fact that the USCG issued an updated certificate clarifying certain provisions relating to installations in hazardous areas. Non US flag ships must meet the requirements of their flag administration. The US flag ships must meet the requirements of 46 CFR 111.105, which from CSA perspective, makes it difficult, if not impossible the installation of such a system on a US flag ship. This is due to materials/design/construction provisions found in the above referenced regulation.
In the last BIMCO roundup, the EPA had asked for comments with regard to regulatory reform. Now it is the US Coast Guard's turn to do the same. This is all in response to the relatively recent regulatory reform Executive Order signed by President Trump. The US Coast Guard has issued a request for comments on its current regulations and requests information as to which, if any, regulations should be reviewed with an aim to repeal, replace or modify them.
CSA intends to submit comments by the July 10, 2017 and is currently polling its members for comments on specific regulations. At a minimum, CSA will focus on the need for alignment of the US regulations with international requirements with the ballast water regulations to be used as the case in point as well as addressing the current debate concerning sufficiency of salvage and marine firefighting services under the vessel response plan regulations.
A copy of the Federal register notice may be viewed at FR Vol 80-109 Evaluation of Existing Coast Guard Regulations.
The CSA notes that while this is an opportunity for the regulated community to comment on a wide variety of issues covered by US regulations, it is unclear at this point, what, if any, pressure will be applied to executive branch agencies by the White House to actually respond to these comments with proposed changes to existing regulations. What is clear however, is that the executive order provisions, which requires elimination of 2 regulations where a new regulation is proposed, has placed new regulatory initiatives into a “full stop” mode.
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