
USCG – enforcement of MARPOL Annex I
Holland & Knight LLP has provided us with the following information.
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The U.S. Coast Guard issued a Policy Letter advising its port state control officers regarding how they should conduct port state control examinations to enforce MARPOL Annex I. The emphasis is on the oily water separator (OWS), the oil content monitor (OCM), and the oil record book (ORB). The letter provides details on what to look for and how to conduct various tests. This document should be required reading for chief engineers, masters, and shoreside management. These personnel should go through the same procedures on a regular basis to ensure that the ship is in full compliance with applicable requirements and will pass muster when a port state control examination is conducted – whether by the U.S. Coast Guard or by another port state administration. Note: If you have trouble printing this document (as I did), I recommend that you copy it to file and print it from there. G-PCV Policy Letter 06-01 (https://www.uscg.mil/hq/g-m/moc/pol0601.pdf) (1/20/06).
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