The US Coast Guard Office of Commercial Vessel Compliance (CVC) announced the publication of CG CVC-WI-018(2), Laid up Inspected/Examined Vessels.
This Work Instruction (WI) was updated to clarify industry notification requirements for vessels going into inactive vessel status and explain when a Third Party Organization (TPO) can issue specific non-conformities (or deficiencies) to Subchapter M TSMS option vessels, while in an inactive vessel status.
Oil as Cargo
In accordance with this WI, vessels must discharge all oil or other hazardous cargo prior to entering laid up status.6 While in a laid up status, the vessel is not subject to vessel inspection regulations; however, the requirements of 33 CFR part 155, Oil or Hazardous Material Pollution Prevention Regulations for Vessels, may still be applicable.
Generally, a vessel no longer requires a Tank Vessel Response Plan (TVRP)7 or Non-tank Vessel response Plan (NTVRP) 8 after discharging all oil and hazardous cargo, which has been verified by the MI or attested to by the TPO, if applicable, that the vessel is no longer storing or carrying oil in bulk as cargo or oil cargo residue.
However, the vessel may elect to keep a TVRP, if the vessel plans to carry oil in bulk as cargo or oil cargo residue in the future.
Hazardous Cargo
Owners or managing operators should provide assurance to the OCMI that all hazardous cargo tanks, pump rooms, cargo piping systems, and cargo venting arrangements are thoroughly clean and gas-free.
The OCMI or COTP may require submission of a gas-free certificate provided by a qualified marine chemist as verification of this condition. Such situations include:
- Prior to entering a laid up status, a vessel inspected under 46 CFR subchapter D shall provide objective evidence that the vessel is cleaned of all cargo residue and maintained in a gas free condition, per 46 CFR § 31.01-1(b);
- If the COTP can articulate a hazardous condition, as defined in 33 CFR § 160.202, on board the vessel, a gas free certificate may be required under the Ports and Waterways Safety Authority (PWSA), per 33 CFR § 160.111;
- In accordance with 33 CFR § 126.30 and § 154.735, when requests are made for hot work to be performed on the vessel at a waterfront facility or facility transferring oil or hazardous materials in bulk, respectively.
Fuel bunkering
The vessel should not load any new fuel while laid up, other than the fuel or consumables required to operate the vessel’s main and auxiliary machinery. Bunkering operations must still be conducted in accordance with the transfer regulations in 33 CFR part 156 – Oil and Hazardous Material Transfer Operations.
Laid up Vessels Returning to Service
If the owner or managing operator of a vessel with a previously surrendered COI seeks to return the vessel to service, they shall submit an Application for Inspection of U.S. Vessel (Form CG-3752) to the local OCMI and schedule a Coast Guard Marine Inspector to attend the vessel.
If a laid up vessel was sold, the new owner should notify the local OCMI of any change in registry or ownership. The new owner should contact the local OCMI where the vessel entered laid up status if they want to change the status of the vessel.
Vessel modifications and Major Conversion determination
Owners and operators should communicate their intentions for modifications to the local OCMI. If modifications to the vessel are planned, then the owner or operator should request a Major Conversion determination from the Marine Safety Center (MSC) if applicable.
12 This determination will be used by the OCMI in the evaluation of existing or current standards that should be applied to the vessel.
Vessel Inspection Fees
In accordance with 46 CFR § 2.10, the vessel inspection fee anniversary date will remain as originally assigned and fees for the current year must be paid prior to receiving any Coast Guard inspection services.
If a vessel is past its annual inspection date and placed back in service, the owner or operator will be required to pay the full annual vessel inspection fee before the Coast Guard inspects the vessel.