United States - VRP Compliance Issues

The Club is grateful to Gallagher Marine Systems for advice on two compliance issues which may affect ships trading to the United States.

Firstly, the Alternative Compliance Procedure (APC) schemes operated in Alaska by both Alaska Maritime Prevention & Response Network and 1-Call Alaska have been given approval by the United States Coast Guard (USCG) to continue their operations until 2021, although the Network’s tanker APC has only been extended until the end of this year.

The other current provider Alaska Response Company (ARC) has not been approved for further operation however and Members who currently cite ARC in their vessel response plans need to make alternative arrangements with one of the two other providers to ensure that they are in compliance with the regulations when transiting Alaskan waters.

Secondly, the USCG is said to taking more time than previously to approve new vessel response plans and additions to an existing plan. This may cause vessels trading to the United States at short notice to be denied entry. The only alternative in these circumstances is to seek a “one-time waiver” from each of the USCG Sectors that the ship plans to call in, but Gallagher advise that this a time-consuming task and waivers are only granted at the discretion of a particular Sector.

Members should therefore ensure that they make timely arrangements when planning to call in U.S. waters and should recognise that a failure (or insufficient time) to do so may result in the ship being denied entry or at least delayed pending application for a waiver.