US regulations affecting your ships - get the June 2018 update!


This is the latest in a series of reports supplied by the Chamber of Shipping of America (CSA) with the intention of keeping BIMCO members appraised of legislative developments in the US affecting international shipping. BIMCO highlights only the relevant developments that would impact members. The full CSA June report is also provided. 

VGP – when is the 3rd VGP? 

The current Vessel General Permit (VGP 2.0) expires in mid-December 2018 (the Clean Water Act requires these discharges to be covered by a discharge permit) and hence, there is a critical need to have something in place e.g. VGP 3.0 when it expires.  CSA continues discussions with EPA on possible alternatives including extension of the current VGP 2.0 for some period of time or reissuance of VGP 2.0 as VGP 3.0 for the full 5 year permit term.  CSA does not expect any major changes to the current requirements regardless of whether the current VGP is extended or reissued for its full term.

Update on Commercial Vessel Incidental Discharge Act (CVIDA)

Discussions regarding the CVIDA text amongst the maritime industry/industry coalition and Congress are still on-going, trying to find a suitable compromise for all stakeholders. CSA continues to participate in these discussions maintaining its position that the agreed text should contain the critical provisions of eliminating the VGP and creating one national programme to regulate discharges incidental to the operation of commercial vessels with a suitable preemption clause to take care of certain requirements imposed by individual states under the current VGP 401 certification programme. 

Release of BMP5, GOG Guidance V3 and New Maritime Security Guidance and Resources

With regard to maritime security, the following are the latest guidance issued free of charge for companies and seafarers : 

• BMP5: Best Management Practices (BMP) to Deter Piracy and Enhance Maritime Safety in the Red Sea, Gulf of Aden, Indian Ocean and the Arabian Sea containing guidance on region-specific threats.

• Global Counter Piracy Guidance for Companies, Masters and Seafarers is a new publication containing guidance on piracy and armed robbery worldwide.

• The third edition of the Guidelines for Owners, Operators and Masters for protection against piracy and armed robbery in the Gulf of Guinea region is also provided. Link to Full Document: GOG Guidelines Version 3

• A new website dedicated to providing comprehensive maritime security guidance to companies and mariners. The new website is intended to serve as a one-stop shop for companies and mariners seeking guidance on a wide range of maritime security issues. 

US Legislation on Export of Crude Oil and LNG

As reported in last month’s report, a set of parallel bills focusing on the need to stimulate the American shipbuilding industry by mandating the carriage of crude oil and LNG exports by US built and US flag vessels has been introduced. No  action has been taken on any of these bills including scheduling of a hearing session. 

White House's New Executive Order on Ocean Policy

CSA met with White House officials hours before the Executive Order Regarding the Ocean Policy to Advance the Economic, Security, and Environmental Interests of the United States was signed by the President. This rescinded the National Ocean Policy implemented by the previous Administration.

To read CSA’s work in this regard as well view the complete text of the new Executive order, please refer to the full CSA report. 

Maritime Regulatory Reform Request for Comments- existing agency requirements

CSA drafted comments in relation to this request. For more information, please refer to the full CSA report. 

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