EPA Vessel General Permit (VGP) Best Management Practices (BMPs)

The VGP identifies 28 types of incidental discharges which may occur from vessels, including: sacrificial anodes, gray water, elevator pit effluent, controllable pitch propellers hydraulic fluid, deck run-off, etc. Recognizing that totally eliminating discharges may be an unachievable goal, the EPA requires vessels to establish and follow best management practices (BMP) to minimize these discharges, such as wiping galley dishes free of oil and grease prior to placing them in the sink. The EPA has indicated during conversations that this kind of BMP may be verified by USCG or EPA inspectors who may ask an unsuspecting crewmember, "What do you do with that plate after you're done eating?" The VGP is another form of performance-based regulation such as ISM and ISPS. The same pitfalls are associated with this VGP as are found with other performance-based programs. The key to compliance with performance-based programs is in the implementation and training. Unfortunately, implementation and training levels are usually commensurate with the level of enforcement, which can be inconsistent. Since we do not yet know how the VGP will be enforced, the VGP best management practices may run the risk of becoming another "book on the shelf." Of course, there are requirements for record keeping and inspections which must be provided to enforcement personnel upon request in order to verify compliance.   In order to avoid that situation and the costly penalties associated with it, vessel operators should consider the following: Draft best management practices in accordance with the VGP which cover all applicable discharges. The best management practices should meet the requirements of the VGP, but be realistic and able to be implemented. Go through the VGP and produce a comprehensive system of logs and records which will cover every aspect of the VGP, including the corrective action. Don't wait until you have something to correct to look at the requirements. Train all vessel personnel on the requirements of the VGP on a regular basis. Finally, always keep in mind the intent of the regulation, because that is how the enforcement person will approach it. For example: If your vessel discharges gray water over the side, and an inspector asks a crewmember what he does with the dishes prior to putting them in the sink; if the crewmember starts explaining about separating garbage, but fails to mention that he wipes each plate free of oil and grease, you could be subject to a violation.