VAPOR CONTROL SYSTEM (VCS) SECTION

For the most current information, please visit the VCS page on Homeport.

INTRODUCTION

Since 1990, various Federal and State regulations have been enacted requiring certain marine transfer facilities to control their volatile or hazardous cargo vapor emissions.

The Coast Guard, under the Clean Air Act Amendments of 1990, is charged with ensuring that systems installed to collect these cargo vapors meet minimum safety standards for design and operation. To this end, the Coast Guard has developed a program, which incorporates regulatory requirements, policy guidelines, and third-party system certification.

From the onset, this has been a customer-focused program, responsive to the maritime industry’s needs. It is well recognized in the federal government for its progressive use of private third-party certifying entities, and the close partnership demonstrated between the Coast Guard and Chemical Transportation Advisory Committee (CTAC) in development of vapor control system regulations.
 

THE HAZARDOUS MATERIALS DIVISION VAPOR CONTROL PROGRAM

The Hazardous Materials Division of Coast Guard Headquarters manages the technical aspects of the Coast Guard VCS regulations on a regular basis. New safety requirements for controlling vapors of additional chemicals or operations are developed as needed. Exemptions and inquiries from industry are reviewed and responded to routinely. The Hazardous Materials Division also implements an oversight program for Coast Guard authorized third-party VCS certifying entities. In addition, policy letters, technical guidelines, and advice are provided to COTPs, OCMIs, the MSC, certifying entities, and vessel classification societies.  
 

A Certifying Entity Oversight Program was developed by the Hazardous Materials Division whereby the authority of review, inspection, testing, and certification of facility VCSs is delegated to private, third-party, certifying entities accepted by the Coast Guard. This program, which is recognized as one of most progressive of its kind in government, allows marine facilities to hire, at their choice, the Coast Guard authorized certifying entity who can best accommodate their needs to conduct the certification in a cost effective and timely manner.

Certifying entities accepted by the Coast Guard do not work for the Coast Guard under any procurement or service contracts. Instead, they are paid by the facilities to conduct VCS certifications on behalf of the Coast Guard. For this reason, it is necessary for the Coast Guard to have an oversight program to maintain technical control and quality assurance over the VCS certification program. A successful third-party oversight program can provide assurance that certifying entities are capable of performing facility VCS certifications, and that the certifications were conducted in accordance with Coast Guard guidelines. As a result, the oversight program can significantly reduce erroneous certifications, which may otherwise impair the safety of facility VCSs.

Currently, the Hazardous Materials Division maintains such a third-party oversight program for the facility VCS certifying entities. Division personnel take one or two trips per year to conduct on-site audits of the certifying entities. About one month before a scheduled audit, the Hazardous Materials Division will notify the targeted certifying entity, and about two weeks before the trip, the Hazardous Materials Division will confirm the visit. A typical audit lasts one day, but may extend to two. In addition to personnel interviews, oversight personnel will also review plans, drawings, test data and reports, and any other technical documentation pertaining to the certified facility VCS.

To ensure that all of the Coast Guard accepted CEs perform the facility VCS certification under a standard set of criteria, the Hazardous Materials Division issued detailed guidelines to all certifying entities in October 1991, for conducting review, certification, and initial inspection of shore side facility VCSs. New regulations, 33 CFR 154 Subpart P, took effect on August 15, 2013 for new facilities and on August 15, 2016 for existing facilities. These new regulations replaced 33 CFR 154 Subpart E. Under the administrative requirements of the guidelines, a certifying entity, upon its satisfaction, is required to issue a certification letter to the cognizant COTP stating that the facility VCS complies with 33 CFR part 154, subpart P and other applicable Coast Guard requirements. The certifying entity is also required, under a separate Coast Guard guideline, to provide the Hazardous Materials Division with an oversight letter forwarding the required technical information for the VCS certified.

The Hazardous Materials Division maintains a page on Homeport which contains information and documents relating to the VCS regulations. These documents include a list of accepted certifying entities, a list of facilities certified for dual barge loading operations, policy letters related to VCS, and guidance for certifying entities and facilities.

The responsibilities for implementing the VCS regulations are shared among several organizations within the Coast Guard. At the field level, the Marine Safety Center (MSC), Cargo Division, located in Washington, DC, is responsible for conducting vessel VCS design review and approval for U.S. flag vessels. Local Captains of the Port (COTPs) are responsible for reviewing the operations manual submitted by a facility, and granting a facility authority to operate its VCS. This authorization is based on certification of the VCS by a Coast Guard authorized certifying entity. Officers in Charge, Marine Inspection (OCMIs) are responsible for endorsing a vessel's Certificate of Inspection (COI) or Certificate of Compliance (COC) authorizing vapor control based on MSC approval for a U.S. flag vessel, or classification society approval for a foreign flag vessel.

At the Coast Guard Headquarters level, the Commandant’s Office of Vessel Activities (CG-543), serves as program manager for COTPs and OCMIs in administering facility VCS and vessel VCS regulations. The Hazardous Materials Division is responsible for managing and developing the technical aspects of the VCS regulations. These responsibilities include the development of VCS requirements for individual chemicals, explaining the technical aspects of the regulations to industry, administering exemption requests, and approving and providing technical advice to certifying entities, vessel classification societies, and other Coast Guard offices.

CONTACT THE HAZARDOUS MATERIALS DIVISION (CG-ENG-5)

Commandant (CG-ENG-5)
U.S. Coast Guard Headquarters
2703 Martin Luther King Jr. Ave SE, Stop 7509
Washington DC 20593-7509

Email: hazmatstandards@uscg.mil