U.S. Department of Commandant 2100 Second Steet SW. Homeland Security United States Coast Guard Wasnnaon, OC 20580 af0 United States Phone (202) 267-2735 Coasf Guard Fax: (202) 267-4394 le7it COMDT recuen OUL No. 04-13 To: Distribution - ° FEB 17 2005 ‘Subj: GUIDELINES FOR THE INSPECTION OF OILY WATER MONITOR AND SEPARATOR SYSTEMS Ref: (a) International Maritime Organization (IMO) Resolution Marine Environment Protection Committee (MEPC).107(49) 1. Purpose. To alert Coast Guard personnel to reference (a) that provides new requirements for oily ‘water monitoring and separating systems installed after | January 2005. This policy also recommends inspection and testing procedures inspectors can use to examine Oily Water Monitor and Separating Systems. 2._Action. OCMI/COTPs shall apply the following guidance during inspections, verifications, or tests of Oily Water Monitoring and Separating systems. The following guidance applies equally to port state control activities as well as U.S. flag compliance inspections. Locally, units should promote this policy with appropriate stakeholders. This policy will also be posted on the World Wide Web at www useg.mil/ha/g-m/moc/does.htm. 3. Directives affected. None. 4. Background and Information. Reference (a) applies only to f vessels with a keel laid date on or after | January 2005 or a replacement installation fitted on an existing vessel after | January 2005. Otherwise, existing vessels using systems approved by the U.S. or applicable Administration, which were installed before | January 2005 should be held to the existing standards of the International Convention for the Prevention of Pollution from Ships (MARPOL) 1973/1978, Annex , Regulation 9. (a) The Coast Guard will enforce reference (a) on U.S. vessels subject to MARPOL as of | January 2005. (b) USS. flag vessels with a keel laying date before | January 2005 that install Oily Water Monitoring and Separating equipment after | January 2005 as part of the initial construction project, do not need to meet the new standards of reference (a). 5. Implementation. During regularly scheduled inspections of U.S. vessels and Port State Control examinations (including annual examinations and Priority 1 and II examinations), marine safety personnel should follow the recommended guidelines of enclosure (1) for pollution prevention equipment (PPE) installed on or after | January 2005 # Enclosure (1) Recommended Guidelines for Oily Water Separator/Monitoring Systems Distribution: CG LANTAREA (Am) CG PACAREA (Pm) CG Marine Safety Center All Districts, Sectors, Activities, MSOs, and MSUsa) Enclosure (1) Recommended Guidelines ‘for Oily Water Separator/Monitoring Systems (Installed after 01 January 2005) Verify that the Oily Water Separator has been approved by the Coast Guard or appropriate ‘Administration meeting Resolution MEPC.107(49). (2) Verify that the Oily Water Monitor/Bilge Alarm has been approved by the Coast Guard or G) appropriate Administration meeting Resolution MEPC.107(49).. Conduct a cursory review of 15 parts per million (ppm) bilge monitoring/alarm records during MARPOL Annex I examinations. m 6) © Oily water monitoring/bilge alarm equipment should be designed to store data for up to 18 ‘months and should be able to print a protocol for inspectors if needed. '* Items required to be recorded include: date, time, alarm status, and operating status of the 15, ppm separator. ‘© Inspectors should compare those entries against existing Oil Record Book entries to determine any non-conformities. of + AIL15 ppm monitor/bilge alarms are required to be sealed to prevent willful manipul overboard discharge data ‘Verify that the required seal(s) are in place. Vessel owners are required to verify the accuracy of the 15 ppm oily water monitors/ bilge alarms which must be conducted by the equipment manufacturer at each International Oil Pollution Prevention (OPP) Certificate renewal. ‘© The calibration certificate should be verified during all IOPP examinations on U.S. flag vessels. '* Port State Control officers may accept a valid IOPP certificate accompanied by the manufacturer's calibration certificate as proof of compliance from a foreign vessel. ‘© Manufacturers’ calibration certificates cannot be accepted as proof of compliance if they are older than five years. Therefore, for U.S. flag vessels, manufacturers’ calibration testing should align with IOPP Certificate cycles to eliminate confusion and compliance lapses. ‘* No further testing is required unless tampering or malfunctioning is suspected. ‘© Alternatively, the entire alarm unit may be replaced by a calibrated 15 ppm alarm. A bilge alarm should not be accepted as compliant if it is over five years old unless it has been calibrated as discussed in paragraph (4). Compliance officers should verify appropriate stallation documentation for both U.S. and foreign flag vessels when unit replacement is selected. No further testing is required unless tampering or malfunctioning is suspected. Existing vessels must meet the provisions of MEPC.107(49) when changing out OWS systems or major components of an existing system (for example, the 15 ppm oily water monitor/bilge alarm).