A rule making effort is currently underway to revise the domestic regulations of 33 CFR 151 (APPS) to accurately reflect U.S. requirements under a revised MARPOL Annex V. The international MARPOL requirements go into effect on 1 January 2013, but domestic rule making will not be ready by that time. This rule making has been delayed probably to April 2013. A draft interim rule is changing the placarding requirements for domestic vessels even down to the placard size specifications (increased from 36 square inches to 40 square inches as minimum size). After 1 January 2013, and until the domestic rules are published and new placards are available, it will not be possible for vessels 26 feet and over to comply with the MARPOL Trash Placard requirement found as Item 11 on Form ANSC 7012.
Due to this inability for vessels 26 feet and over to comply with Item 11, Vessel Examiners are hereby instructed to consider Item 11 on Form ANSC 7012 as "N/A" for all vessels for the Calendar Year 2013, or until otherwise directed. Vessels otherwise satisfying all VSC decal requirements may be awarded the decal during Calendar Year 2013. This should give ample time for the domestic rules to be developed and published in the Federal Register and for new compliant placards to be developed, produced, and distributed throughout the Recreational Boating community. As funding becomes available, the Coast Guard may procure and distribute updated MARPOL decals for distribution via ANSC. This interim guidance for the VE program will be amended/superseded as new placards become available through commercial sources of supply or other means.
This interim guidance is not intended to encourage Vessel Examiners to totally ignore Item 11 on Form ANSC 7012 while conducting Vessel Safety Checks in 2013. Throughout 2013 Vessel Examiners and other members having contact with the recreational boating community will have an excellent opportunity to carry on instructional conversations about the new MARPOL placard requirements that are being developed to heighten awareness of recreational boaters about the need to understand and comply with the MARPOL requirements and to alert them to be aware that they need to procure and install new placards as soon as they become available. In the long run such conversations may enhance the effectiveness of the teaching opportunities available during the conduct of Vessel Safety Checks.
Thomas C. Mallison
National Commodore
12/19/