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23/03/2018

Small Vessel General Permit: What is new?

Bart van Lee

The (Small) Vessel General Permit is something you cannot avoid if you are active in the maritime sector. Do you own a commercial fishing vessel or a vessel of less than 79 feet and are you operating in US waters? Then keep on reading – this blog is interesting to you! Did you know that in January 2018 there was a change in the permit? What does this change mean for you as a ship owner? And how can Lagersmit make your vessel sVGP proof? Find out more about it in this blog!

The changes summarised

  • The sVGP consists of requirements that include topics such as vessel hull maintenance and engine and oil control.
  • The sVGP controls incidental discharges of wastewater for vessels of less than 79 feet (24 meters), and commercial fishing vessels.
  • Due to legislation all the incidental discharges of wastewater were excluded, with the exception of ballast water, until 19 January 2018.
  • Until that time the permit was only required for discharges of ballast water.
  • From 19 January 2018, the smaller and fishing vessels have to meet the requirements for all incidental discharges.

VGP and smaller vessels

The Vessel General Permit is applicable on vessels that are 79 feet or longer that operate in US waters. But where do the smaller vessels fit in this picture? For these ships the Environmental Protection Agency (EPA) issued the Small Vessel General Permit (sVGP). The sVGP controls incidental discharges for vessels that are less than 79 feet (24 meters) and is effective from 19 December 2014 and 18 December 2019. The term ‘incidental discharges’ includes a range of wastewater discharges from vessels during normal operations. Examples are ballast water, bilge water and grey water (e.g. water from sinks and showers.


Due to Congressional legislation the smaller vessels were not required to obtain coverage und the permit, with the exception of ballast water, until 19 January 2018. This means that, until that time, the obligations of the sVGP were only mandatory for discharges of ballast water from non-military and non-recreational vessels of less than 79 feet. The legislation is also valid for commercial fishing vessels of all sizes. These vessels have to deal with the same regulations as the smaller vessels: they are only obliged to have a permit for discharges of ballast water. Now, by passing the 19th of January, all small vessels and commercial fishing vessels have to meet the sVGP’s requirements for incidental discharges.

The consequences for ship owners

Besides controlling incidental discharges, the sVGP also consists of requirements that include topics such as vessel hull maintenance and engine and oil control.

To meet the sVGP, vessel operators must also:

  • Carry a Permit Authorization and Record of Inspection (PARI) form onboard the ship to certify that they have read and understood the terms of the permit and to document performance of the required annual inspection;
  • Perform the required annual self-inspection.


In contrast to the VGP, vessel operators are not required to submit a Notice of Intent (NOI) to obtain coverage under this permit.

VGP, refresh your mind

The VGP was issued by the US Environmental Protection Agency (EPA) and intends to reduce the environmental impact of oily lubricant discharges to the ecosystem. In December 2013 the revised Vessel General Permit came into force. The VGP approves discharges incidental to the normal operation of merchant vessels of 79 feet or longer that are sailing in coastal and inland waters from the USA.

Looking for more detailed information about the Vessel General Permit? Read one of our blogs about this topic!

 

How to make your (small) vessel VGP compliant?

As said before, the sVGP also consists of requirements about engine and oil control. This means that the sVGP mandates the use of Environmentally Acceptable Lubricants (EALs) in all oil-to-water interfaces (e.g. stern tube seals, thruster seals) – unless technically infeasible. Instead of using EALs, the sVGP also accepts the use of alternative seal designs, such as air type seals.

 

Our Supreme Ventus® stern tube seal is one of those air type seals that is in compliance with the sVGP. This seal guarantees zero-emissions of oil and is based on Condition Monitoring. Besides offering VGP compliant sealing solutions, Lagersmit also tests EAL’s to evaluate the compatibility of our Supreme ® lip seals with various EAL’s. Read the blog about Lagersmit’s testing of EAL’s to find out more.

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