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Frequently Asked Questions - FAQs
FAQs are current at the time of posting and are not monitored.  They are posted for the convenience of the reader and does not substitute any regulatory requirement or any updated change in policy.  Always verify with the local Captain of the Port / Officer in Charge or Marine Inspections. 


Fuel FAQ#   2022-08-18
  For companies that are chartering Foreign Flag LNG Bunker Vessels which may operate in US waters, what are the USCG requirements/notifications ship operators must comply with prior to any offshore bunkering?

The requirements of 33 CFR 156.210 apply to all STS transfers of LNG. Currently, all STS transfers of LNG must be approved by COMDT (CG-ENG-5). The approval is contingent upon local COTP approval. CG-ENG-5 is available seven days a week to receive these requests, which are normally be processed within 48 hours.  To ensure uninterrupted operations, we strongly recommend that requests are submitted to CG-ENG-5 (hazmatstandards@uscg.mil) and your local COTP as early as possible.

Please find STS transfer requirements here:  https://homeport.uscg.mil/Lists/Content/DispForm.aspx?ID=359&Source=/Lists/Content/DispForm.aspx?ID=359

Carrier FAQ#     2019-02-28
Question   Can a gas carrier connect vapor lines, conduct vapor balancing, with the facility prior receiving / completing the Certificate of Compliance (COC)?
Answer   No and Yes
    No:  U.S. law does not allow for the transfer of cargo on board foreign vessels without a current Certificate of Compliance (COC).

Yes:  As per 26 Feb 2016 correspondence with Coast Guard Commercial Vessel Compliance (GC-CVC-2), individual units have the authority, on a case by case basis, to allow vessels to connect vapor lines without a current Certificate of Compliance (COC)..

 “Liquefied Gas Carriers are designed to be able to manage vapor pressure created due to boil-off gas IAW IGC Code 7.1 without venting to the atmosphere. IAW 46 CFR 154.1836, when the vessel is on the navigable waters of the United States, the master shall ensure that the cargo pressure and temperature control system under 46 CFR 154-701 through 154.709 is operating and that venting of cargo is unnecessary to maintain cargo temperature and pressure control, except under emergency conditions. In the event of an emergency or abnormal situation, venting to the facility is a preferred and safer option rather than venting to the atmosphere. Units may allow a foreign gas carrier to hook up their vapor hose prior to the completion of the Certificate of Compliance exam once all risk factors have been considered such as any conditions/concerns noted from the Marine Safety Center's plan review, initial impressions of the ship and prior inspection and compliance history.”

* The above text can be found in the Foreign Gas Carrier TTP on the menu under Liquefied Gas Carriers.

Fuel FAQ#   2018-03-21
Question   How does the USCG define Regular Intervals for LNG as Fuel related Drills and Emergency Exercise?
Answer   Quarterly;  the OES 01-15 Policy Letter indicates Quarterly


5.1 A training manual should be developed and a training program and exercises should be

specially designed for each individual vessel and its gas installations.

5.2 Emergency exercises on board vessels using gases or other low flashpoint fuels should be

conducted at regular intervals (e.g. quarterly). Such gas-related exercises could include for


                5.1.1 tabletop exercise;

                5.1.2 review of fueling procedures based in the fuel handling manual;

                5.1.3 responses to potential contingences;

                5.1.4 tests of equipment intended for contingency response; and

                6.1.5 reviews that assigned seafarers are trained to perform assigned duties during fueling and contingency response.

5.3 Gas related exercises may be incorporated into periodical drills required by regulation

and/or SOLAS. The response and safety system for hazard and accident control should be

reviewed and tested.

Fuel FAQ#    2018-03-15
Question   Are U.S. Flag ship's required to follow all the requirements in ENG 01-12 (Change-1) Policy Letter?
Answer   Short & Long
    Short Answer:

ENG 01-12 (Change-1) Policy Letter is primarily for U.S. Flag vessels.

No, you do not "have" to follow "all" the requirements found in the 01-12 (Change-1) policy letter.  But, if you don't, those areas that you do not follow will likely be subject for review and approval by the Marine Safety Center (MSC); see 2.3.3 in Enclosure 1 of the Policy Letter 01-12 (Change-1).

Long Answer:

01-12 (Change-1) policy letter was written to help the maritime community.

01-12 (Change-1) policy letter was provided following the effective 01 Jan 2017 date of the IGF Code. The new IGF Code brings greater defined safety.  It also has provisions for acceptance, by the ADIMISTRATION, of certain line items, read as "variables", found in the Code.

By publishing the policy letter, the ADMINISTRATION - the U.S. Coast Guard, has done three things:

1) It identifies the 2017 IGF Code as the base line for acceptance for new construction design criteria. (First paragraph of Enclosure 1)

2) Enclosure 1 defines, in advance, all the "variables" in the new IGF Code (2017) where the Code states, something to the effect of: "Other solutions providing an equivalent safety level may also be accepted by the Administration".

3) It has strengthened / simplified / defined areas where the Code required additional guidance.  For example, if you look at 5.6 in the IGF Code, it reads:

5.6.1 - ESD protection shall be limited to machinery spaces that are certified for periodically unattended operation.

The policy letter explains how the ADMINISTRATION defines "certified for periodically unattended operation" by stating: Certified for periodically unattended operation shall mean compliance with the requirements for periodically unattended machinery plants as specified in 46 CFR 62.50-30.

In closing, Enclosure 1 is there to help the reader of the IGF Code when s/he thinks to themselves, "What's that supposed to mean, how is the Coast Guard going to define that"?

Suggestion:  So now that you know this, pull your IGF Code book and annotate all the cites where the Coast Guard has addressed each site in Enclosure 1.  Then, if an issue referencing the site were to come up, your annotated IGF Code would indicate right away that the Coast Guard has already addressed the cite with the policy letter.

If you have more questions about Liquefied Gas as Fuel, please reach out to one of our SMEs listed on our contacts page.

Bunkering FAQ   ISO Standards
Question   Will the Coast Guard Enforce the new ISO Standard for the Safe Bunkering of LNG Fueled Ships?
Answer   The ISO is not a USCG enforcement item as of Feb 2017. However, the Coast Guard was involved in its development and encourages operators to make use of the guidance.

Also, the ISO standards may one day become incorporated by reference.


Carrier FAQ   When filling out the COC form.
Question   What blocks on the Certificate of Compliance (COC) form must be filled out for an LPG carrier that holds an International Oil Pollution Prevention (IOPP) Noxious Liquid Substance (NLS) Certificate in addition to the Certificate of Fitness (CoF)?
Answer   When issuing a COC to a LPG/C, the only block that should be checked under the heading "Vessel is authorized to carry into or from US ports" is the 2nd block out of the four (The products listed on the Certificate of Fitness for the Carriage...).  In all situations, the cargos listed on the IOPP NLS Certificate will be listed on the CoF with conditions noted on the Subchapter "O" Endorsement.

The governing document for consideration in our issuance of the COC for an LPG/C is the CoF, not the NLS certificate (because all NLS cargoes are listed in the International Gas Carrier (IGC)/Gas Carrier (GC) Codes and have to be referenced on the CoF).

ECA FAQs   Frequently Asked Questions: North American Emission Control Area (ECA)