FAQs: North American Emission Control Area (ECA)

Before a single piece of steel is ever cut, laid or welded, a Naval Architect(s) at a shipyard will design a ship to its customers (the cruise line) specifications. These plans are submitted to the Marine Safety Center for plan review. In this portion of the process the Coast Guard will evaluate the ship' as built design. These plans must be approved by the ship's Flag Administration before submittal to MSC. Structure and design features are evaluated during this process including, but not limited to: structural fire protection, passenger egress routes for evacuation during an emergency, space categorization, fire fighting arrangements and preliminary vessel stability calculations.

Foreign Flag vessels are not required to submit Type Approval certificates. MED certificates are all that is required.

At this point in the process the ship is a living breathing entity. Its shape is formed, its engines are running and the construction process is well underway. The Coast Guard will examine the internal arrangements on the vessel, evaluating the evacuation routes to ensure their practicality as well as the vessels internal boundaries where proper division and segregation will be examined to ensure each space is protected based on their individual fire risk. On new construction, this is less invasive due to the ships in construction state as these items are openly exposed; however, on an existing vessel the finishing touches of a vessel such as ceiling panels and walls must be removed to conduct these types of examinations.

Depending on the geographic location of the vessel, either Activities Europe or Activities Far East will be the main point of contact for any exam conducted overseas.

Activities Europe
Activities Far East

Additionally, please contact the CSNCOE to assist you in getting to the right POC for any exam conducted outside the U.S.

If lifeboats used as tenders are listed as being in full compliance with SOLAS and LSA requirements on the Record of Equipment for the Passenger Ship Safety Certificate (PSSC), this satisfies the requirements for individual lifeboats to hold a PSSC. Additionally, at initial and annual control verification exams (also known as Passenger Vessel COC exams), units are not required to issue a COC to such lifeboats when these lifeboats are listed on the Record of Equipment for the vessels PSSC. Where tenders maintained onboard the vessel are not lifeboats and are issued a PSSC or Lifeboat/Tender Safety Equipment Certificate, units shall issue a COC to each such tender after satisfactory examination.

IAW the unified interpretations in reference to SOLAS II-2 4.4.2 Waste Receptacles:
This regulation is not intended to preclude the use of containers constructed of combustible materials in galleys, pantries, bars, garbage handling or storage spaces and incinerator rooms provided they are intended purely for the carriage of wet waste, glass bottles and metal cans and are suitably marked.

The vessel needs to obtain documentation from the manufacturer attesting to the technically infeasible clause. This documentation does not need to be submitted to the EPA.  It should be kept on board for inspection purposes, and to be referenced on the vessel's Annual Report.

These areas should be identified on the vessel's VGP.

Sewage discharge is addressed in 33 CFR Part 159.7 as follows:
When operating a vessel on a body of water where the discharge of treated or untreated sewage is prohibited by the Environmental Protection Agency under 40 CFR 140.3 or 140.4, the operator must secure each Type I or Type II device in a manner which prevents discharge of treated or untreated sewage. Acceptable methods of securing the device include:

• Closing the seacock and removing the handle;
• Padlocking the seacock in the closed position;
• Using a non-releasable wire-tie to hold the seacock in the closed position; or
• Locking the door to the space enclosing the toilets with a padlock or door handle key lock.

   

When operating a vessel on a body of water where the discharge of untreated sewage is prohibited by the Environmental Protection Agency under 40 CFR 140.3, the operator must secure each Type III device in a manner which prevents discharge of sewage. Acceptable methods of securing the device include:

• Closing each valve leading to an overboard discharge and removing the handle;
• Padlocking each valve leading to an overboard discharge in the closed position; or
• Using a non-releasable wire-tie to hold each valve leading to an overboard discharge in the closed position.

Not at this time. Items 1-4 below are not being enforced at this time. The CVSSA requires a phased implementation plan to accommodate analysis, research and development that will be addressed by regulation and/or updated policy guidance. At this time, The Coast Guard is not enforcing the following CVSSA provisions until implementing regulation and policy direction is developed:

• Capturing Images of Passengers/Detecting Persons Fallen Overboard (46 U.S.C. 3507(a)(l)(O))
• Acoustical Hailing and Warning Devices (46 U.S.C. 3507(a)(l)(E)). Note most of the cruise ships that operate out of the U.S. do not visit "high risk areas"
• Video recording requirements (46 U.S.C. 3507(b)). Note a copy of video-recordings using currently installed video-recording equipment, which pertain to an alleged crime under investigation, shall be provided to law enforcement officials upon request
• Crew training and certification requirements (46 U.S.C. 3508) CG-543 Policy Letter 11-09

Crew Access to Passenger Staterooms (46 U.S.C. 3507(f)). Confirm that the vessel has established and conforms with shipboard policy to limit crew access to passenger staterooms. Crew members should only have access to the extent that their official duties require such access (for example, hotel staff/maid service, fire parties, repair personnel all have needs to access staterooms subject to appropriate restrictions).

It depends on whether the vessel is built to SOLAS or not. Please refer to CG-CVC Policy Letter 15-04 to determine which category the vessel falls under.

MSC Plan Review Guidance SOLAS-05 provides the following guidance for portable flammable lockers:

In spaces where a limited supply of flammable liquids or gases is necessary for the practical utility of the space, it may be permissible to install an approved flammable liquid cabinet to stow small quantities of items for daily use. These cabinets must:

• Provide adequate thermal insulation to protect the contents from an external fire. This thermal protection must be at least at the level required by SOLAS II-2, Table 9.1 between a category 14 space and the space in which the cabinet is located;
• Be designed to contain leakage and spills; and
• Be gas/fume-tight.

Cabinets manufactured and approved to EN14470-1, Type 60 or Type 90 are acceptable. Cabinets meeting NFPA 30 or UL 1275, only provide protection for 10 minutes and should only be used in category 11, 12 or 14 spaces. In all cases cabinets must be suitable for the intended use as determined by the flag administration. When used, these lockers must be permanently mounted to the deck and indicated on the Fire Control Plan or otherwise be included in the ship's Safety Management System (SMS) and training program. The quantity and types of materials contained in these lockers must be consistent with the manufacturer's recommendations.

Spaces other than category 14 spaces do not typically have the protections (for example: classified electrical fittings, ventilation and insulation) required for storing flammable liquids. However, the practical utility of certain spaces may necessitate the storage of a small quantity of ready-use flammable liquid or gas. This would include materials used frequently during operation where it is impractical for crew to travel to a centralized category 14 store room each time the materials are needed. As such, it may be permissible to store a small amount of these materials for daily use, not to exceed the storage capacity of a single locker of flammable liquids. Such storage should be in steel lockers designed for the purpose and provided with a means to safely contain and extinguish a fire involving these materials.