U.S. Coast Guard (USCG) Chemical Transportation Advisory Committee meeting on 8 November

The U.S. Coast Guard (USCG) Chemical Transportation Advisory Committee (CTAC) held its autumn meeting on 8 November 2005 in Galveston, TX. A number of new and returning members were sworn in for the 2005-2007 term, among them INTERTANKO Chemicals Manager, Margaret Doyle. Agenda items from the full committee meeting included a report from the CTAC National Fire Protection Association (NFPA) 472, Hazardous Cargo Transportation Security (HCTS) and Outreach Subcommittees.  

National Fire Protection Association (NFPA) 472 Subcommittee 

The National Fire Protection Association 472 Subcommittee presented an update on its final report to the full Committee. The work of this Subcommittee culminated in the development of a draft marine emergency responder chapter to NFPA 472 (Professional Competence of Responders to Hazardous Materials Incidents). It is the hope of the Subcommittee that this guideline will be used by the USCG (by reference) in the development of its pending OPA 90 Hazardous Substances Response Plan (HSRP) regulations. Although, promulgation of the HSRP Rulemaking is not expected until 2008 and the addition to NFPA 472 will not take place until mid-2007, the Subcommittee will remain active 

The Hazardous Cargo Transportation (HCTS) Subcommittee 

The Hazardous Cargo Transportation (HCTS) Subcommittee discussed the issues dealt with at the subcommittee meeting held the previous day. The report to the CTAC included: 

·         Review of the Viewed Security Sensitive Information (SSI) Training Video. This video is available in streaming mode from the MTSA website.  NVIC 10-04 is also expected to be updated relative to the proper handling of SSI.

·         The review and prioritisation of a list of issues originally developed by the Subcommittee earlier this year. Top priority issues identified by the Subcommittee include the use of the Homeport (www.homeport.uscg.mil ) Homeport is the official Coast Guard information technology system for maritime security created to provide information and services to the maritime community and the public over the internet. Everyone is encouraged to register with Homeport but users are reminded that the portal is still in its infancy.

·         CDC residues on ships and barges –Problems with the requirement of reporting CDC residues still exists, especially for chemical tankers. USCG and industry have been asked to address this issue (and the real versus unrealistic risk that residues pose).

·         Security policy inconsistencies in the USCG Captain of the Port Zones and newly formed Sectors throughout the U.S. There exists a need to address the centralised vs. non-centralised decision-making process in the implementation of vessel and facility security policies. The possibility of setting up a COTP Conference in 2006 under the Port Security Directive will be discussed at the next Subcommittee/Work Group meeting to be held the second week of December. 

The CTAC Outreach Subcommittee 

The CTAC Outreach Subcommittee report highlighted the issues discussed at the subcommittee meeting held the previous day. One of the primary issues discussed was need for CTAC to be more involved in both national and international activities. INTERTANKO Chemicals Manger, Margaret Doyle, has been asked to track all international regulation forwarding them to the USCG. As a follow-up to a presentation given by INTERTANKO at the last CTAC meeting on the MARPOL Annex II (Regulations for the control of pollution by noxious liquid substances in bulk) Revisions the Committee voted to approve the formation of a work group under the auspices of the CTAC Outreach Committee. The objectives of the MARPOL Annex II Work Group will be twofold: 

·         Develop a framework for the Navigation and Vessel Inspection Circular (NVIC) that will be used to implement MARPOL Annex II. 

·          Raise awareness regarding the data that is missing from Chapters 17 or 18 of the revised International Code for the Construction & Equipment of Ships Carrying Dangerous Chemicals in Bulk (IBC Code). These products have been excluded because of missing safety data, pollution data or both. The revised IBC Code was adopted by the IMO Maritime Safety Committee (MSC) last year. An updated list has been forwarded to CTAC for inclusion in the final report of the full committee meeting and is to be placed on the CTAC website. As reported in earlier issues of the INTERTANKO Weekly News, If no action is taken, these products will not be able to be carried in bulk after 1/1/2007. It is therefore imperative that the manufacturers of these products supply the missing safety/pollution data to the IMO secretariat as soon as possible. We understand that the deadline for submission of data for these products remains the31 December 2005. 

The first meeting of the MARPOL Annex II Work Group is tentatively scheduled for 14 December 2005 in Houston, TX 

A number of presentations were made to the Committee including a presentation by the Louisiana Department of Environmental Quality (LDEQ) focusing on VOC releases from barges and proper identification of products in these vessels. A workgroup under the auspices of the Outreach Subcommittee has been formed to work with the LDEQ to address these issues, led by Amy Husted of Kirby Corporation. 

Two excellent informational presentations were given regarding recent developments in the area of nitrile antidotes for the carriage of onboard vessels and the importance the adherence to the U.S. Food & Drug Administration’s (USFDA's) Good Manufacturing Practice/Quality System in the transport of chemicals that are integral to a number of consumer products in use today.  

CTAC Executive Director CDR Bob Hennessy, in his regulatory update, indicated that because of resource constraints, other regulatory projects, including the NPRM for Vapour Control, and Hazardous Substance Response Plan regulations, do not have a definitive regulatory timeline. He also announced that the USCG will not be implementing the MARPOL Annex II Revisions on 1 January 2007 because of the constraints mentioned above. CTAC has been asked to develop guidelines for a MARPOL Annex II Navigation and Vessel Inspection Circular (NVIC). This will be carried through the MARPOL Annex II Work Group mentioned above.  

The next meeting will probably take place in early May 2006 in either the Baltimore or Philadelphia area. 

Contact: Margaret Doyle