FREQUENTLY ASKED QUESTIONS

Update 20th Feb 2009

(9Please also refer document with sample log entries)

Q. Do the VGP requirements have to be complied at for calls at the offshore port of LOOP and also the offshore
lightering areas in the Gulf of Mexico?
A. Part 1.2.1 of the Permit states that: This Permit is applicable in waters subject to the permit. These waters are
"waters of the United States" which extend to the outer reach of the 3 mile territorial sea
A ship that does not enter "waters of the United States" does not need permit coverage.
As both LOOP and the lightering areas are out with territorial waters, compliance is not required. EPA has confirmed
this is correct.

Q. In the VGP Logbook, ref 4.2 Section 8 (ix) Graywater, this requires estimated volume and location of graywater
discharged while in waters subject to this permit. What is a reasonable estimate for graywater discharge?
A. EPA estimates the volume of graywater generated by a vessel is in general, 30 85 gallons (110 to 320 litres
approx) per person per day. US Navy designers use a generation standard of 50 gallons per person per day when
constructing graywater collection systems.

Q. Who carries out the inspections, completes the records and signs the forms?
A. The Master as person in charge has overall responsibility for maintenance of the Vessel General Permit and is the
key signatory as required by CFR 40 Part 122.22. Inspections Records must be signed by the person conducting the
inspection, if not the Master. Persons conducting the inspection must be either be a signatory or be his duly authorized
representative.
The Chief Engineer as head of the Engine department is a duly authorized representative.
The Chief Officer as head of the Deck department is a duly authorized representative.
The Master must issue an authorization letter to any other person carrying out inspections as required by section 4.
The routine inspections (weekly/quarterly) should be carried out by the department heads. Items such as the voyage
record can be delegated to the Second Officer.
All persons onboard must be made aware of the requirement for their individual working areas e.g. galley staff and
minimizing graywater contamination with cooking oil or left over food.
All persons must be aware of their responsibility to report violations.

Q. The VGP requires that anti-fouling hull coatings not subject to FIFRA registration (i.e. not produced for sale and
distribution in the United States must not contain any biocides or toxic materials banned for use in the United States
(including those on EPAs List of Banned or Severely Restricted Pesticides). This requirement applies to all vessels,
including those registered and painted outside the United States. What evidence is required?
A. Vessels must ensure that a certificate is obtained for anti-fouling applied. Alternativly the paint specification
showing that it is suitable for use in USA.