The US Coast Guard has issued a policy letter providing guidance to US vessels and to foreign vessels calling in US waters on compliance with the International Convention on the Control of Harmful Anti-Fouling Systems on Ships (AFS Convention).
The policy letter addresses domestic vessel inspections and certifications, as well as port state control (PSC) procedures for foreign vessels.
The AFS Convection was adopted by the IMO to prohibit the use of harmful organotins in anti- fouling paints used on ships and to establish a mechanish to prevent the potential future use of other harmful substances in anti- fouling systems. Starting on November 21, 2012, US flagged vessels, wherever located, and foreign flagged vessels in the United States, in any port, shipyard, offshore terminal, or other place in the US, lightering in the territorial sea of the US, or anchoring in the territorial sea of the US, must comply with the applicable portions of the AFS Convention as outlined below. The type of anti- fouling systems controlled (prohibited) are specified in Annex 1 of the Convention. The Coast Guard implements the AFS Convention through reference (a), (33 U.S.C. 3801-3857). Compliance verification for US and foreign vessels shall follow the process and scope as described in the applicable portions of this policy letter.
Port State Control (PSC) Procedures
The Coast Guard shall examine vessels for compliance with the AFS Convection during regularly scheduled PSC examinations and shall be guided by the provisions of references (b) and (c) as implemented or modified by this policy letter.
Port State Control Officers (PSCO) should examine the IAFS Certificate of Declaration on Anti- fouling System and the attached ROAFS, if appropriate. PSCOs should not take AFS samples during PSC examinations.
The IAFS Certificate should be in conformity with Appendix 1 to Annex 4 of the AFS Convention has or has not been applied, removed or been covered with a sealer coat, and whether an anti- fouling system controlled under Annex I of the AFS Convention was applied on the vessel prior to or after the date specified in AFS Convention.
The IAFS Certificate should be properly completed and endorsed by the Admninistration or RCS.
The ROAFS should be up to date and include attached records from dry- dockings related to AFS or sealer coat applications. Further information on the ROAFS should agree with that shown on the IAFS Certificate.
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