As the Polar Code entry into force date approaches, USCG will feature a series of posts aiming to provide additional guidance on the issue. Specifically, after having received several questions regarding domestic applicability and interpretations of certain regulations, the Coast Guard’s Office of Commercial Vessel Compliance has issued CG-CVC Policy Letter in order to inform on certain aspects of the Code and its implementation.
The Polar Code will apply to ships subject to the SOLAS Convention as well as Annexes I, II, IV, and V of MARPOL. With entry into force approaching the Coast Guard and maritime industry are preparing to ensure compliance with these new international standards.
The Polar Code is a goal-based standard that establishes functional requirements and regulations that are adaptable to a wide range of ship types and operations. The Code aims to holistically mitigate risks that are identified through mandatory ship specific operational risk assessments. In this way, the Code is very similar in approach to the International Safety Management (ISM) Code and the International Ship & Port Facility Security (ISPS) Code, which rely heavily on the owner/operator to develop processes that adequately address a ship specific operation.
One of the challenges of any goal-based standard, including the Polar Code, is that non-prescriptive provisions are subject to interpretation. Specifically, the CG-CVC Policy Letter 06-16 addresses:
- Applicability to U.S. Ships
- Survey and certification options for U.S. Ships
- Additional guidance on Polar Class notations and ship categories
- Guidance on performing operational risk assessments
- Guidance on Port State Control for foreign-flagged vessels operating in U.S. Polar Waters
Finally the Coast Guard recognizes that there is no single solution for what will be considered “acceptable” in terms of meeting the functional requirements of the Code. As such, the Coast Guard says that they look forward to working closely with the industry to develop solutions to the risks derived through the course of operational assessments to ensure safe and environmentally responsible polar operations.
Furhter details may be found by reading the policy letter below
Source: UCCG News
