In International Shipping News 23/04/2015
For ships sailing in US waters, regulations are tightening. DNV GL has devised a verification system to ease compliance and give shipowners and operators peace of mind while saving time and energy.
“It’s not enough simply to achieve compliance,” says Sarah Lasselle, project manager for the verification work. “You have to be confident that the ship will continue to operate under compliance during the entire journey.” For that reason the new US Vessel General Permit (VGP) verification system also focuses on reducing the risk of potentially costly new violations.
The VGP verification service consists of a review of company-wide VGP procedures, if they exist, which are usually based on VGP or environmental best practice documentation. On-board visits confirm that the vessel’s documentation is consistent with the on-board documentation required and that the vessel is operating in compliance with its environmental procedures and VGP requirements.
Systematic approach simplifies, clarifies
According to Per Holmvang, Program Director for Environmental Protection Technologies at DNV GL – Maritime, the VGP verification service provides users with a second set of unbiased expert eyes on their documentation procedures. “DNV GL’s VGP verification service can be tailored exactly to the customer’s needs, from a desktop review or workshop outlining VGP changes, to a full on-board and shore review and plan for corrective action, even help and advice on developing a VGP plan from scratch,” he says.
The most recent updates to the VGP include requirements for the preparation of a detailed annual report. The VGP verification service provides a comprehensive review of both VGP procedures and documentation. DNV GL’s new solution includes performing a gap analysis of vessel operations, reporting, and discharge technology to provide answers to the following questions:
- Does the vessel documentation and reporting on board satisfy VGP requirements?
- Are vessel operations in accordance with the VGP?
- Does the vessel have the necessary VGP-sanctioned pollution prevention technology?
- If there are risks of non-compliance, how will they be corrected?
Once the review and any necessary corrective actions have been undertaken, DNV GL provides a verification statement indicating that the vessel’s operations and record-keeping are consistent with VGP requirements. This verification statement also contains a list of the VGP requirements and outlines how the vessel fulfils the requirements.
Wilh. Wilhelmsen leads on with a good example
Known for their high technical, safety and environmental standards, Wilh. Wilhelmsen was a natural partner for a pilot test of the new DNV GL compliance system. After a full examination of Wilh. Wilhelmsen’s company-wide VGP recommended practices, DNV GL experts went on board the RoRo vessel Tarago to conduct a careful review of the record-keeping. The ballast water management plan, deck log book, engine room and oil record log books, and the VGP log book were all checked to ensure that all necessary records were present for VGP-related procedures.
The verification confirmed Wilh. Wilhelmsen’s high standards and thorough preparation. Key project takeaways from the investigation, part of the VGP check-list, highlighted the importance of:
- Consistency of scheduled and weekly inspections
- Up-to-date manufacturer documentation, especially for Environmentally Acceptable Lubricants (EALs)
- Record-keeping in vessel log books according to the company’s own recommended best practice
Filip Svensson, Vice President Marine Operations at Wilh. Wilhelmsen ASA, had this to say about the VGP experience: “Our ambition is to be an environmental forerunner. With several port calls in the US, it was valuable for us to team up with DNV GL to do a pilot on new technical and reporting requirements set forth in the updated VGP. As vessel owners, we want to ensure our operations and standards are in line with regulatory requirements. Through the cooperation with DNV GL, we confirmed that our efforts towards high standards pay off, but we also acknowledge that there is always room for improvement. By being in the forefront, we take steps towards our long-term ambition of shaping the maritime industry.”
Sarah Lasselle concludes: ”It was a valuable learning experience to see how Wilhelmsen tackles the environmental problems of operating a ship like the Tarago, and to exchange ideas on how best to stay in compliance with the VGP.”
Customers who need to take action now have the chance to develop a plan in a fast and efficient manner or correct any deficiencies in an existing plan. DNV GL’s verification statement also provides an easy way for vessel operators to demonstrate they have taken all aspects of the VGP into consideration, in the event of controls by US authorities.
Training on Vessel General Permit
DNV GL’s Maritime Academy offers a training course on Vessel General Permit. It covers the VGP training requirements for vessel operators and shipboard personnel involved in the management and control of the eligible discharges. The participants will become familiar with the sound management of the potential discharges from their vessels and the proper implementation of the applicable federal and state requirements.
