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Maritime Environmental Regulations & the Challenges of

Compliance

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Regulation HierarchyInternational

United Nations- IMOUNCLOS, MARPOL, SOLAS

Area/Regional SpecificHELCOM

EU Directives

National /Port StateClean Water Act

US NPDES Vessel General Permit

State/ProvincialVGP – 401 Certifications

Other State RequirementsProvincial Requirements

Port Specific

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MARPOL and SOLAS1. Overseen by the International Maritime Organization (IMO)

-Specialized agency of the United Nations with 169 Member States and three Associate Members. - Primary purpose is to develop and maintain a comprehensive regulatory framework for shipping and today that includes: safety, environmental concerns, legal matters, technical co-operation, maritime security and the efficiency of shipping.

2. MARPOL - is the International Convention for the Prevention of Pollution From Ships established in Feb. 1973.• Contains 6 annexes, concerned with preventing different forms of

marine pollution from ships: Annex I - Oil Annex II - Noxious Liquid Substances carried in Bulk Annex III - Harmful Substances carried in Packaged Form Annex IV - Sewage Annex V - Garbage Annex VI - Air Pollution

Generally does not pertain to cruise vessels

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MARPOL / Regional Agreements -1. Emission Control Areas – The North America (NA) ECA which

generally covers within 200nm of the NA coast (Canada and USA) requires the use of 0.1% sulfur fuel. As of January 1, 2016 all new vessels will also be required to meet Tier 3 NOx levels.

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World Emission Control Areas

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US Requirements - Vessel General Permit & Clean Water Act

1. Vessel General Permit – covers 27 operational discharges examples are• Deck washing – must use specific NPDES soaps and cleaners• Gray Water - Prohibited to discharge GW within 3nm• Sewage and GW mix – to discharge <3nm must meet the requirements of

section 5.1 of the VGP: • Using end of pipe monitoring must be treated using an AWP prior to

discharge. • Sewage – to discharge <3nm and within US waters (12nm) must meet 40 CFR

140 or 33 CFR 159 requirements.• Ballast water – must install and operate a USCG Approved BWMS, differs

from the IMO Type Approved systems.

2. Ballast Water – National Invasive Species Act 1996• Requires the installation and operation of a USCG Approved BWMS, differs

from the IMO Type Approved systems. Allows for extension of the installation requirement until an approved

system is identified.

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Provincial / State Specific1. Oil Spill Response – Must identify and contract with an Oil

Spill Response Organization (OSRO) for all ships sailing in Canadian or US waters:• Canada – Eastern Canada Response Corporation• US – NRC or MSRC

2. State specific discharge requirements – Example of some requirements are:• Connecticut - prohibits the discharge of GW, Bilge water or Exhaust

Gas Cleaning water regardless of treatment.• Maine & New York - requires exchange and treatment of ballast

water.• New York – prohibits the discharge of Bilge water regardless of

treatment.

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MARPOL Regulations vs RCL Policy

ABOVE AND BEYOND COMPLIANCE

Waste MARPOL RCL Policy

Treated Sewage 3nm 12 nm, & >6ktsGray water No min. 12 nm, & >6ktsBilge Water 15 PPM 5 PPM, & >12nmFood Waste 3 nm 12 nm, & >6kts

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Regulatory Impacts

Overview of a single ships regulatory requirements:• Sailing from Boston calling on Portland, ME; Bar Harbor, ME; St.

John, New Brunswick and Halifax Nova Scotia a ship must abide with the following regulations: Emissions

• NA ECA – 0.1% fuel within approximately 200nm • Shorepower – available in Halifax beginning in 2015

Discharges – • VGP – Deck cleaning, Sewage, Gray water, Ballast water, Bilge water,

Scrubber wash water, etc.• Canadian - Sewage, Ballast water, Bilge water, scrubber wash water, etc.• Port Specific – prohibitions (ie. Bilge, scrubber wash water, GW)

Oil Spill Response – • Canadian and US requirements for OSRO’s

Garbage – • Waste classification requirements (Hazardous vs Nonhazardous)

» Example of this is incinerator ash is defined in Canada as regulated waste, in the US is deemed non-regulated waste.

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How RCL manages this monumental task By using an integrated living database call ESIMS (Environmental Stewardship Information Management System). It allows our vessels to input their itinerary and receive all the relevant Env. Regulations for that itinerary.

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How RCL manages this monumental task

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Environmental Binders

1. Australia & New Zealand 2. Baltic & Northern Europe3. Eastern - North America4. Mediterranean5. Western - North America6. South America & Caribbean7. Hawaii & Polynesia (Micronesia & Melanesia)8. Antarctica9. China and Southeastern Asia