TVIB News Industry Press

USCG: CANCELLED MSIB 03-19 Certificate of Documentation Guidance

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First posted on Maritime Commons on 02/28/2019

The Coast Guard announced that effective Feb. 25, 2020, Marine Safety Information Bulletin 03-19, “Certificate of Documentation Guidance,” is cancelled. 

In 2019, the National Vessel Documentation Center (NVDC) was experiencing delays in the time necessary to issue a Certificate of Documentation (COD) that resulted, in part, due to the government shutdown. The purpose of MSIB 03-19 was to provide guidance to assist vessel owners affected by those delays. The Coast Guard is cancelling MSIB 03-19 because the NVDC is current with processing of COD renewal requests for both commercial and recreational vessels.  

USCG: Marine Safety Advisory 01-20 – Potential for Positive Drug Test Result from Use of Hemp-Plant Products

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Excerpt from MSA 01-20 Potential for Positive Drug Test Result from Use of Hemp-Plant Products, published 02/10/2020

This Marine Safety Advisory is to ensure that mariners, marine employers, and sponsoring organizations are aware that some products marketed as hemp or cannabidiol (CBD) may contain enough tetrahydrocannabinol (THC) to cause a positive drug test. In accordance with 46 CFR 16.201(c), an individual who fails a chemical test for dangerous drugs must be removed from duties directly affecting the safe operation of the vessel, and is subject to suspension and revocation proceedings against his or her credential under 46 CFR part 5. Use of hemp or CBD products is not accepted as an affirmative defense (acceptable excuse) against a THC-positive drug test
result. For these reasons, mariners wishing to avoid a positive THC drug test result should exercise extreme caution when considering the use of any hemp or CBD product because such use could result in the loss of their merchant mariner credential and immediate removal from safety sensitive duties aboard a vessel. This warning applies to hemp and CBD products in any form, including those that are taken by mouth and those that are applied to the skin.

It remains unacceptable for any U.S Coast Guard credentialed mariner or other safety-sensitive worker working aboard a vessel that is subject to U.S Coast Guard drug testing regulations to use THC. Claimed use of hemp products or CBD products is not an acceptable defense for a THC- positive drug test result.

Click here to access the full Marine Safety Advisory 01-20.

USCG: Sector Ohio Valley Issues MSIB 01-2020 Related to Non-Compliance with NTVRP Requirements

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We’ve recently encountered issues with operators that have vessels that have been measured to both the “Regulatory” tonnage (GRT) and “Convention (International)” tonnage (ITC) that were surprised during COI inspections that the USCG was holding them to the ITC with regard to compliance with the Non-Tank Vessel Response Plan requirements.

Sector Ohio Valley has issued MSIB 01-2020 clarifying their position on the matter stating:

Vessels that actively operate in commercial operations without a NTVRP are subjected to, but not limited to, the following penalties; vessel detainment by the United States Coast Guard (USCG), denial of entry into a U.S. port, and/or civil penalties of more that $47,000 per day dependent upon type and scope of violation. The USCG encourages the maritime community to review the requirements and ensure their vessels meet the regulations outlined in 33 CFR Part 155 – Subpart J.

A point of confusion has arisen in terms of tonnage application for the 400 gross tons threshold. As discussed in the preamble of the regulation (Federal Register / Vol. 78, No. 189 / Monday, September 30, 2013 / Rules and Regulations), if a vessel is measured using “Convention (International)” tonnage and “Regulatory” tonnage, the greater of the two is used for determining applicability of the NTVRP requirements.

Have you looked at your CODs lately?

Click here to download Sector Ohio Valley MSIB 01-2020 Non-Compliance Trend with Non-Tank Vessel Response Plan Requirements