Assisting the maritime industry in regulatory compliance

Bryant's Maritime Consulting

Air emissions

The International Maritime Organization (IMO), in 2008, adopted a major amendment to MARPOL Annex VI – Regulations for the Prevention of Air Pollution from Ships and to the NOx Technical Code.

After some initial delay, the United States became party to the Annex VI with passage of Public Law 110-280 – the Maritime Pollution Prevention Act of 2008.

The United States and Canada recently submitted to the IMO a joint proposal seeking to have almost all coastal waters of the two nations designated as an Emission Control Area (ECA). The petition is explained by the EPA in its accompanying Regulatory Announcement.

On June 27, 2011, the US Coast Guard and Environmental Protection Agency (EPA) issued a Joint Letter reminding vessel owners and other stakeholders of the requirements established by MARPOL Annex VI.

The European Union (EU) directive on use of low sulphur fuel while berthed in an EU port came into effect on 1 January 2010. Directive 2005/33/EC

The US Coast Guard’s Eleventh District issued a Marine Safety Alert to increase awareness and reiterate general guidance on fuel systems and fuel switching safety in an effort to prevent propulsion loss. Proper procedures, training, and maintenance are essential for vessels to safely switch between heavy/intermediate fuel oils and marine distillates.

The US Coast Guard posted Frequently Asked Questions (FAQ) regarding commercial vessel compliance with the North American ECA requirements. (8/30/12).



    logo11 Rebuilding the presumption of preemption

    In the May 2013 edition of Maritime Reporter and Engineering News, you can find my article entitled "Rebuilding the presumption of preemption". In the article, I discuss how federal control of maritime commerce prevailed over state control in the early days of the Republic. Over the years, that federal preemption has been eroded. It is time to rebuild the presumption in favor of federal preemption with respect to all matters related to maritime commerce. The industry should not be unregulated or even under-regulated, but it deserves to be uniformly regulated.