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c. The VGP applies to discharges incidental to the normal operation of all non-recreational 

vessels of 79 feet or greater in length. In addition, the ballast water discharge provisions 

also apply to any non-recreational vessel of less than 79 feet or commercial fishing vessel 

of any size discharging ballast water. 

d. The VGP covers 26 different types of discharges, many of which have not previously 

been covered by U.S. regulations. For ballast water discharges, the VGP incorporates the 

Coast Guard’s mandatory ballast water management standards and has several additional 

mandatory management requirements. The VGP also has additional requirements for 

eight vessel types such as large and medium-sized cruise vessels and oil tankers. Under 

the CWA, discharges of pollutants from vessels that are not covered by the VGP are 

unlawful unless they are separately covered under another CWA permit or are exempt 

from permitting requirements (for example, sewage from vessels, incidental discharges 

from a vessel of the armed forces, or discharges in compliance with the instructions of a 

federal on-scene coordinator). 

e. The VGP requires vessel owners/operators to perform training, inspections, monitoring, 

and reporting, and take assessments and corrective actions as necessary. It also requires 

vessel owners or operators to submit a Notice of Intent (NOI) to receive permit coverage 

and submit a one-time permit report between 30 and 36 months after obtaining permit 

coverage. 

f. The EPA has posted electronic copies of the VGP and other related information, 

including VGP Fact Sheets, on the EPA’s NPDES – Vessel Discharges webpage at 

www.epa.gov/npdes/vessels. 

5. Discussion. 

a. The VGP is an EPA permitting program under the CWA. The EPA developed and 

manages the VGP, and has the primary federal responsibility for enforcing its provisions. 

The Coast Guard’s role up to this point of time has been focused on education and 

outreach. 

b. Noting that since the provisions provided in the VGP require vessel operators to utilize 

best practices in the management of shipboard discharges incidental to the normal 

operation of the vessel in order to protect the marine environment, the Coast Guard 

shares a mutual interest in ensuring vessels comply with VGP provisions. Therefore, in 

fulfilling its role as the nation’s lead maritime law enforcement agency and to carry out 

its mission of environmental stewardship, it is in the interest of the Coast Guard to assist 

the EPA in the detection and reporting of VGP deficiencies onboard vessels. 

c. To facilitate this mutual interest, the Coast Guard and the EPA have signed a 

Memorandum of Understanding (MOU) regarding matters related to the VGP 

(USCG/EPA VGP MOU). 

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d. The USCG/EPA VGP MOU established cooperative relationships, roles and 

responsibilities between the Coast Guard and the EPA in the implementation of the VGP 

compliance and enforcement. It established that Coast Guard and EPA cooperation in 

sharing information, expertise, and technical assistance for VGP implementation reduces 

redundancy in government oversight of vessel activities and increases the effectiveness of 

each Agency’s ability to accomplish its mission to enhance environmental protection. 

e. Under the USCG/EPA VGP MOU, the Coast Guard’s main role will be to assist the EPA 

with examining compliance with basic provisions of the VGP1

 during routine inspections 

onboard U.S. vessels and during Port State Control exams on foreign vessels. The Coast 

Guard will report detected VGP deficiencies to the EPA. The EPA retains full 

responsibility and enforcement authority under the CWA to address VGP violations and 

unauthorized discharges, which includes issuance of administrative orders, administrative 

penalties, and judicial action. Additional assistance and cooperation between the Coast 

Guard and EPA may be established through support agreements under the MOU. 

f. This policy has been developed by the Coast Guard, in consultation with the EPA, to 

assist Coast Guard staff in the preparation for and the execution of VGP compliance 

monitoring inspections and exams. Vessel owners and/or operators are responsible for 

compliance with all aspects of the VGP and any other CWA requirements. Vessels may 

be subject to inspection to verify compliance with any and all legal requirements. The 

inspection guidelines (VGP Job Aid) provided in enclosure (1) represent the minimum 

items that the Marine Inspectors (MI) and PSC Officers should examine during VGP 

compliance exams. The MI/PSC Officers are not limited in the depth and scope of the 

examination. The Coast Guard and EPA may assess program execution and shipboard 

performance and adjust the VGP Job Aid as appropriate. 

g. Implementation of VGP compliance exams and follow-up activities during routine vessel 

inspections and Port State Control exams will require additional time to complete vessel 

inspections and exams. However, as the VGP compliance component of an inspection 

and exam is incorporated and consistent with normal Coast Guard vessel exam 

procedures and routines, we expect this additional effort to be manageable. 

6. Procedure. 

a. Implementation. Effective 30 days after the promulgation of this policy, Sector 

Commanders / OCMI’s staff should use the VGP Job Aid provided in enclosure (1) in the 

implementation and execution of Coast Guard VGP compliance activities during routine 

vessel inspections and Port State Control exams. In the period prior to this 

implementation date, Coast Guard MIs and PSC Officers must continue education and 

outreach efforts to the marine industry and communicate the upcoming VGP verification 

 

1

 The Coast Guard will not check vessel compliance with the State and Indian Country Lands specific requirements 

contained in Section 6 of the VGP. 

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exams under this policy and the VGP Job Aid. 

b. VGP Deficiencies. MI/PSC Officers must take the following action upon discovering 

any VGP deficiencies as guided by the VGP Job Aid provided in enclosure (1) as well as 

any other observed VGP deficiencies: 

i. Encourage vessel operators to correct VGP deficiencies by the conclusion of the 

vessel inspection / PSC exam, if feasible, i.e. “corrected on the spot.” 

ii. Inform the vessel’s master/person-in-charge of all detected deficiencies, including 

those “corrected on the spot”, and record the findings using routine deficiency 

reporting documents, such as the CG-835 or PSC Form B, as appropriate. 

iii. Inform the vessel’s master/person-in-charge that the Coast Guard will report the VGP 

related deficiencies to the EPA, as well as any actions by the vessel taken or planned 

to address them, and that EPA’s enforcement authority under the CWA to address 

VGP violations and unauthorized discharges includes administrative orders, 

administrative penalties, and judicial action. 

c. MISLE - Documenting and Reporting. As soon as practicable, but in all cases not later 

than close of business the following day of the exam, the MI/PSC Officers should enter 

the VGP related deficiency in the Coast Guard’s MISLE database under the associated 

inspection activities’ “Inspection Results”: 

i. VGP deficiencies are found under the System “Operations/Management”, Subsystem 

“EPA Vessel General Permit” and associated Components by VGP reference/cite. 

ii. When entering VGP deficiencies, the MI/PSC Officer should ensure that the 

following information is provided within the “Details” block: 

(1) MI/PSC Boarding Officer’s name, phone number and e-mail. 

(2) MI/PSC Boarding Officer’s unit’s name and state. 

(3) A brief description regarding the VGP deficiency, including a description of the 

MI/PSC Officer’s observations and findings, if the vessel corrected the deficiency 

by the conclusion of the exam, and description of any documentary evidence or 

pictures obtained or viewed. 

(4) In cases where VGP deficiencies are also deficiencies under Coast Guard 

regulations, as discussed in section 6.d below, provide a brief statement that 

indicates any concurrent Coast Guard enforcement action and what steps, if any, 

the Coast Guard has taken to address the deficiency. For example, if a ship fails 

to maintain ballast water records under Coast Guard regulations in 33 CFR part 

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151, this is also a VGP deficiency under VGP section 2.2.3. If the Coast Guard 

takes enforcement action, then that action should be described – i.e. the Coast 

Guard issued a requirement for the vessel to maintain ballast water records in 

accordance with the operative section of 33 CFR part 151. 

iii. Under the “Requirement/Resolution” section, enter the following: 

(1) Due Date: select the date of the VGP verification exam and select “To the 

satisfaction of the certificate issuing authority” option. 

(2) If the VGP deficiency was resolved or corrected by the conclusion of the vessel 

exam: 

(a) Place a check-mark in the “Resolved/Corrected” block. 

(b) Select the date of the VGP verification exam. 

(c) Enter the details of the resolution in the “Resolution” block. 

iv. No further reporting action is necessary, but MI/PSC Officers must make themselves 

available to assist the EPA with additional information and supporting documentation 

upon request by the EPA. 

d. Coast Guard Pollution Prevention Regulations. The USCG/EPA VGP MOU does not 

affect the Coast Guard’s existing authorities under any laws. Therefore, in cases where 

VGP deficiencies are also deficiencies under Coast Guard regulations, such as ballast 

water and oil pollution prevention regulations, MI/PSC Officers must report the VGP 

deficiency to the EPA as discussed above, as well as concurrently process the deficiency 

under applicable Coast Guard regulations and enforcement policy. As discussed in 

section 6.b.iii above, EPA’s enforcement authority under the CWA to address VGP 

violations and unauthorized discharges includes administrative orders, administrative 

penalties, and judicial action. 

 

7. Disclaimer. While the guidance contained in this document may assist the industry, public, 

Coast Guard, and other Federal and State regulators in applying statutory and regulatory 

requirements, the guidance is not a substitute for applicable legal requirements nor is it a 

regulation itself. It is not intended to nor does it impose legally binding requirements on any 

party. This guidance does not create any right or benefit, substantive or procedural, 

enforceable by law or equity, by any person against the Coast Guard, EPA, their officers or 

employees, or any other person. This guidance may be superseded, modified, or terminated 

at any time without prior notice. 

8. Additional Information and Changes. 

a. This policy, the USCG/EPA VGP MOU, and additional information pertaining to the 

VGP including links to the EPA’s VGP web page is available on the Coast Guard’s VGP 

information page on Homeport at http://homeport.uscg.mil by selecting the following 

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6

tabs: Missions > Domestic Vessels > Domestic Vessels General > EPA Vessel General 

Permit (VGP). 

b. Interested parties may suggest improvements to this policy by writing to the Coast 

Guard’s VGP Program Manager listed under Contact Information on the VGP 

information page on Homeport or via e-mail at CG543@uscg.mil. 

# 

Enclosures: (1) Coast Guard VGP Job Aid 

 

Distribution: All Area/District (p) offices 

 All Sectors/MSUs/MSDs 
Enclosure (1) to CG-543 Policy Letter 11-01 

EPA Vessel General Permit (VGP) - USCG Job Aid 

This enclosure is intended to be used as a Job Aid by Coast Guard Marine Inspectors (MI) and Port State Contro

during inspections of U.S. flag vessels and during PSC examinations to assist in verifying that a vessel is in comp

specified EPA VGP. This Job Aid contains a list of minimum items that MI and PSC Officers should examine. of the examination must be determined by the MI and PSC Officers based on the condition of the vessel, operatiothe competency of the vessel’s crew. The EPA VGP addresses many of the same water pollution prevention items that the Coast Guard currently examcompliance examinations. This Job Aid addresses the key or “first tier” inspection items currently not covered binspection regulations or policy. Coast Guard personnel will perform these checks in addition to the current poll

inspections/examinations covered in the applicable CG-840 books. All deficiencies, even if corrected while onboard, shall be documented within MISLE as discussed in Section 6 othis policy. MISLE documentation will then be sent to the EPA via generated CGBI Cube reports. Note: Citations to the VGP sections are given as references for the specific requirements and legal authorities. 
Enclosure (1) to CG-543 Policy Letter 11-01 

Record Keeping VGP Requirement Cite Finding Action CoAre the vessel master and senior crew aware of the VGP? 

Vessel General Permit Yes No action required. 

No Inform the master/crew that they 

must obtain and read the VGP. Provide the master/crew with a copy of the EPA VGP Fact Sheet.

If the vessel is greater than or equal to 300 gross tons or has the capacity to hold or discharge 8 cubic meters (2113 gallons) of ballast water, has the vessel submitted a Notice of Intent (NOI)? 

VGP Part 1.5.1.1; Part 10 - Appendix E –Notice of Intent (NOI) 

Yes No action required. 

No Advise the master/crew they 

must submit an NOI to EPA. Provide the master/crew with a copy of the EPA VGP Fact Sheet.

The vesvesYoweb viehttp

ess

EPvessubEle(eNww

eN

Record of routine visual inspections 

VGP Parts 4.1.1, 4.1.1.1, and 4.2, #4 

Yes No action required. 
Enclosure (1) to CG-543 Policy Letter 11-01 

VGP Requirement Cite Finding Action CoRecord of annual inspections (effective after December 19, 2010). Record of VGP drydock inspection if last drydocking was conducted after Feb. 6, 2009. 

VGP Parts 4.1.3 and 4.2, #6 VGP Part 4.1.4 

No Advise the master/crew they 

must complete visual inspections at least once per week or per voyage, whichever is more frequent; unless they engage in multiple voyages per day, in which case a daily inspection is required. They must also have a comprehensive inspection annually and record all results in the vessel’s recordkeeping documentation. Additionally, a drydock report is required per section 4.1.4 of the VGP. 

The recpaginsvesIf rvesbe acc(unrecexc

Documentation of Corrective Action Assessments: does the vessel maintain records of completed actions 

VGP Parts 3, 4.2 para. 3, Yes No action required. 

No Advise the master/crew they 

must conduct a corrective action assessment including a description of identified deficiencies, an explanation of the cause and the corrective action to be taken and a schedule to complete such action. 

If rvesbe 

Ballast Water Management Plans: For vessels with ballast water 

VGP Parts 2.2.3.2, 4.3 Yes No action required. 

No Advise the master/crew that they 

must have a Ballast Water 

The com
Enclosure (1) to CG-543 Policy Letter 11-01 

VGP Requirement Cite Finding Action Cotanks, plan adequately lays out a ballast water management strategy specifically for the vessel. Plan must be in accordance with 33 C.F.R. 151 and section 4.3 of the VGP. 

Management Plan which lays out the ballast water management strategy and and which complies with section 4.3 of the VGP. Personnel who actively take part in the management of ballast discharge must understand and follow the plan. 

Wareq151ViovioBalfouSub

Ballast Water Records: If applicable, has the vessel maintained records of conducting ballast water exchange, near shore ballast water exchange, and saltwater flushing? For those vessels which periodically enter as NOBOBs, and which do not report salt water flushing to the NBIC, they must have records of salt water flushing onboard. 

VGP Parts 2.2.3.5, 2.2.3.6, 2.2.3.7, 2.2.3.8, and 2.2.3.9 

Yes No action required. 

No Advise the master/crew that they 

must maintain records of conducting ballast water exchanges and saltwater flushing. 

Nothe balcarfluscomfroPac(saCOfroGreUS 

Bilgewater Discharges: VGP Part 2.2.2; 4.2, #8 Yes No action required 
Enclosure (1) to CG-543 Policy Letter 11-01 

VGP Requirement Cite Finding Action CoIf the vessel measures 150 GT or more (tank vessels) or measures 400 GT or more (other vessels), is it maintaining records of its bilge water discharges? If the vessel measures 150 GT or more (tank vessels) or measures 400 GT or more (other vessels), and regularly sails outside the territorial sea, is it not discharging within 1 nm of shore or within National Parks, Marine Sanctuaries, etc., listed in Part 12 of the VGP? 

and #9; 12 No records Advise the master/crew to begin 

maintaining records. Vio

vioPolreqCF

No, discharging within 1 nm of shore or within waters listed in VGP Part 12. 

Advise the master/crew that if technologically feasible or if not necessary to maintain the safety and stability of the ship, to hold bilgewater onboard or discharge to a shore side facility. 
Enclosure (1) to CG-543 Policy Letter 11-01 

Deck/Topside Walk VGP Requirement Cite Finding Action CoIs the state of deck and work areas housekeeping adequate? Deck is free of clutter, garbage, fuel/oil spills? Are spill rails and drip pans in place and utilized? 

VGP Parts 2.1 and 2.2.1 Yes No action required. 

No Advise the master/crew that they 

must maintain proper housekeeping onboard the vessel - contain garbage, secure containers in proper storage, prevent oil and fuel spills, and use containers or rails to contain oil. 

Evihouneeof l

Large and Medium Cruise Vessels “Large Cruise Ships” are that provide overnight accommodations (has onboard sleeping facilities) to passengers 

500 people or more for hire. VGP 5.1. “Medium Cruise Ships” are vessels that provide overnight accommodatiosleeping facilities) to passengers authorized to carry between 100-499 people for hire. VGP 5.2 

VGP Requirement Cite Finding Action CoFor untreated graywater: VGP Parts 5.1.2.1 and Yes No action required. 
Enclosure (1) to CG-543 Policy Letter 11-01 

VGP Requirement Cite Finding Action CoDoes the vessel have records estimating discharges of untreated graywater including date location and volume, speed of vessel? 

5.2.2.1 No Advise the master/crew 

that they must maintain records of estimating discharges of untreated graywater including date, location, volume, and vessel speed. 

For untreated graywater: For large and medium cruise vessels which sail outside 1 nm, was graywater only discharged outside 1 nm while sailing at least 6 knots or outside 3 nm (regardless of speed) and not in nutrient impaired waters such as 

VGP Parts 5.1.1.1.1 and 5.2.1.1.1 

Yes No action required. 
Enclosure (1) to CG-543 Policy Letter 11-01 

VGP Requirement Cite Finding Action Cothe Chesapeake Bay? No Advise the master/crew 

that graywater must be treated or discharged consistent with Parts 5.1 and 5.2 of the VGP. 

For treated graywater: Yes No action needed. 
Enclosure (1) to CG-543 Policy Letter 11-01 

VGP Requirement Cite Finding Action CoFor large and medium cruise vessels, did the vessel maintain records of date, location and volume of treated graywater discharged? Did the vessel conduct monitoring and assure that graywater discharged is below limits in Part 5.1.1.1.2 or 5.2.1.1.2 of the VGP, as applicable? 

VGP Parts Large cruise vessels: 5.1.1.1, 5.1.2.2, and 5.1.2.2.5. Medium cruise vessels: 5.2.1.1.1, 5.1.2.2., and 5.2.2.2.5. 

No Advise the master/crew 

that they must maintain records of date, location and volume of treated graywater. If they are discharging treated graywater in waters of the US; remind them they must conduct monitoring. Monitoring records must also include who did the analysis, date and results. The vessel must maintain one sample per quarter (four per year) and records of the sampling and testing results must be retained onboard for a period of 3 years in the vessel’s recordkeeping documentation 

For treated graywater: Yes No action needed. 
Enclosure (1) to CG-543 Policy Letter 11-01 

VGP Requirement Cite Finding Action CoIf swimming pools or spas are on board large or medium cruise vessels and the pool or spa water is discharged into the territorial sea: Is there a record onboard of the testing of swimming pool water before discharge to assure it meets limits of 50 micrograms per liter for brominated discharge and 10 ug/L for Chlorine? Is there a record of the location of the discharge, the estimated volume of the discharge, and the concentration of chlorine or bromine (as applicable)? 

Large cruise vessels: VGP 5.1.2.3 Medium cruise vessels: 5.2.2.3 

No Advise the master/crew 

that there must be a record of testing of swimming pool water before discharge to assure it meets limits of 50 micrograms per liter for brominated discharge and 10 ug/L for Chlorine. 

Sware insprecsucexiVG