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December 30, 2010

VIA FEDERAL RULEMAKING PORTAL: http:/www.regulations.gov

Attn: Docket ID No. EPA-HQ-OW-2010-0126

Water Docket

US Environmental Protection Agency

EPA Docket Center

EPA West, Room 3334

1301 Constitution Avenue, NW

Washington, DC 20004

Re.: Docket ID No. EPA-HQ-OW-2010-0126: Clean Water Act 

Section 312(b): Notice Seeking Stakeholder Input on Petition and 

Other Request to Revise the Performance Standards for Marine 

Sanitation Devices

SUPPLEMENTAL INFORMATION SUBMITTED ON CHAMBER OF 

SHIPPING OF AMERICA INDUSTRY SURVEY ON VESSEL SEWAGE 

MAANGEMENT PRACTICES AND MSD PERFORMANCE AND PRACTICES

Dear Sir or Madam.

The Chamber of Shipping of America (Chamber) represents 34 U.S. based 

companies that own, operate or charter oceangoing tankers, container ships, 

and other merchant vessels engaged in both the domestic and international 

trades. The Chamber also represents other entities that maintain a 

commercial interest in the operation of such oceangoing vessels. All of our 

members which own, operate or charter oceangoing vessels currently 

manage their sewage discharges through compliant MSDs as required under 

both international and domestic laws and regulations.

The Chamber appreciates the opportunity to provide supplemental 

information relevant to the above referenced notice seeking stakeholder 

input on the petition to revise the performance standards for Marine 

Sanitation Devices (MSDs) as promised in our November 9, 2010 timely 

submission to the docket. To preclude the need for retrieval of this 
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document, the relevant text in our submitted comments is as follows in 

bolded text:

CHAMBER OF SHIPPING OF AMERICA MARINE SANITATION DEVICE 

SURVEY

Shortly after this request for comments was published, the Chamber 

created a reasonably simple survey which was sent to our 34 

member companies and our international colleague trade 

associations with a request that this survey be widely distributed and 

solicit input from ship owners, operators and charterers worldwide. 

A copy of this survey is attached at annex. As indicated, the 

Chamber requested that comments be submitted by October 15, 

2010 to provide time for the qualitative and quantitative analysis of 

the submitted data which will provide answers to many of the 

specific questions posed by EPA in this notice. 

To date, the Chamber has received 621 surveys. Unfortunately, over 

250 of these surveys were received by the Chamber during the week 

of November 1, 2010 after a reminder notice was sent out in early 

October. As a result of these late submissions and considering that 

these late submissions represent nearly 50% of the surveys 

received, we have not been able to conduct the quantitative analysis

appropriate to provide detailed responses to the specific questions

posed by EPA.

Chamber staff conducted a cursory analysis of the data as it was 

being received and we provide below qualitative responses to the 

specific questions posed. We will provide to EPA a full quantitative 

analysis of the data by December 31, 2010 which we hope EPA will 

consider as support for the qualitative answers provided below.”

EXPLANATION OF SURVEY PARAMETERS AND DATA ANALYSIS 

PROTOCOLS

A copy of the survey as sent to the industry is attached as Annex I to this 

document. As shown, CSA provided introductory information as to why the 

information was being requested as well as the current requirements and 

definitions under both US and IMO requirements. The survey requested 

pertinent vessel characteristics as well as both qualitative and quantitative 

responses relative to current onboard operations regarding management of 

sewage aboard vessels, including characteristics of the sewage management 

system, operational histories, inspection and recordkeeping practices, 

maintenance procedures, sampling protocols and contingency plans should 

any component of the system fail to operate properly. Attached as Annex II 

to this document is a description of the most relevant survey data 

parameters and analysis protocols as contained in the attached Excel 

spreadsheet which includes one line item for each of the 634 surveys 

received. Finally, we are including the Excel spreadsheet as a separate file to 

to the email which includes this document.
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PRELIMINARY INDICATIONS OF SURVEY RESULTS

In our original and timely submission to the docket, CSA responded to the 

specific questions posed based on a qualitative analysis of the survey 

responses that had been received at that time. Based on our more detailed 

analysis of all of the survey responses, we provide additional information as 

indicated below. The section of our original submission to the docket is 

reproduced in full below, with our original responses noted in BLUE text. 

New responses and/or changes to the original responses are now added in 

RED text.

RESPONSES TO SPECIFIC QUESTIONS IN THE FEDERAL REGISTER 

REQUEST FOR COMMENTS

Responses to the questions below are based on qualitative assessment of 

data collected in the Chamber MSD survey and will be further supported by a 

later submission to this docket. It is important to note that our survey 

responders are owners, operators or charterers of oceangoing non-passenger 

vessels of all types and relative sizes.

Category 1 – What existing public or private data sources are 

available for use in identifying, categorizing, and describing:

A. The numbers, types, and service of foreign-flagged and domestic 

vessels currently operating in US navigable waters that have toilets 

installed onboard?

The Chamber does not have data on all vessels, regardless of flag, 

that currently operate in US navigable waters. It is recommended that 

EPA consult with the US Coast Guard, the Maritime Administration and 

the Army Corps of Engineers each of which collect data on vessels 

trading in US navigable waters, although we do not believe these 

databases would have explicit information on which vessels do or do 

not have toilets installed onboard, particularly recreational vessels. 

We would note that commercial vessels, regardless of size, have one 

or more toilets installed on these vessels. No additional 

information gained from survey responses which encompass 

vessels which may or may not be trading to US ports. Our 

survey was focused on getting a sense of the state of the art in 

the global maritime fleet.

B. Of the domestic-flagged vessels described in response to inquiry (1A) 

above, how many have one (or more) of the following sewage 

treatment devices installed onboard? CSA Note: Of the 634 survey 

responses, 18% were attributable to US flag vessels.

• Type I MSD? No (0) survey responses note Type I MSDs installed.

Survey analysis supports this statement that no US flag vessels 

responding to the survey have Type I MSDs.
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• Type II MSD? All survey responses note Type II MSDs installed. All

(100%) of US flag vessels responding to the survey reported 

Type II MSDs installed supporting this statement.

• Type III MSD? A vast majority of survey responses indicates that Type 

II MSDs are installed with some holding capacity available (Type III), 

although the holding capacity varies widely from vessel to vessel. No 

US flag vessels reported having only a Type III system (holding 

tank only with no MSD). Survey results likewise support this 

statement nothing that the majority of US vessels reporting 

have both a Type II MSD installed AND holding tanks (Type 

III). 

• Actual survey responses indicated that 29% of US flag vessels 

reporting have a Type II system, while 71% of US flag vessels 

reporting have a combination Type II/III system.

C. Of the foreign-flagged vessels described in response to inquiry (1A) 

above, how many have one (or more) of the following sewage 

treatment devices installed onboard: CSA Note: Of the 634 survey 

responses, 82% were attributable to non US flag vessels.

• Type II MSD (or) Sewage Comminuting and Disinfecting System? All

survey responses note Type II MSDs installed. 35% of non US flag 

vessels responding indicate installation of a Type II only

system.

• Type III MSD (or) Sewage Holding Tank? A vast majority of survey 

responses indicates that Type II MSDs are installed with some holding 

capacity (Type III) available, although the holding capacity varies 

widely from vessel to vessel. Only 1% of non US flag vessels 

responding indicate use of a Type III only system while a vast 

majority of non US flag vessels responding have a combination 

Type II/III system.

• Actual survey responses indicated that 35% of non US flag 

vessels responding indicate us of a Type II only system, 1% 

have a Type III only system, and 64% have a combination 

Type II/III system.

• Sewage Treatment Plant (STP)? No (0) survey responses indicate that 

STPs are installed. Final survey responses show 0 responses 

indicating installation of a sewage treatment plant per se; 

however a number of responses suggest installation of 

biologically based treatment systems which meet the old 

MARPOL standard and in some cases meet the new standard. 

Further investigation would need to be done to determine if 

some or all of these installations meet the definition of 

“sewage treatment plant”.
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D. Of those foreign-flagged vessels with STPs described in response to 

inquiry (1C) above, how many have devices that are:

• Certified to meet the MARPOL Annex IV effluent standards and 

performance tests adopted in Resolution MEPC.2(VI)?

• Certified to meet the MARPOL Annex IV effluent standards and 

performance tests adopted in Resolution MEPC.159(55)?

Although no (0) survey responses indicate installation of STPs, a vast 

majority of the Type II/III hybrid installations comply with Resolution 

MEPC.2(VI). No responses indicate compliance with MEPC.159(55) 

which is quite understandable since this standard was finalized in 

January 2010 and vessels currently in operation, even the newest, 

would not have had time to integrate a sewage management system 

compliant with this more stringent standard, into vessel design. It is 

important to note here that US flag vessels may have received a 

Certificate of Alternative Compliance by the USCG however, no US flag 

vessels included in our survey responses carry International Sewage 

Pollution Prevention Certificates since the US cannot issue these Annex 

IV based certifications due to the fact that the US is not a party to the 

Annex. 

• Again regardless of a system’s designation as an “MSD” or 

“STP” in the survey response, 20 of the 634 responses (3%) 

indicate compliance with the new Annex IV standard contained 

in MEPC.159 (55). 14 of those responses are associated with 

non US flag vessels while the remaining 6 are associated with 

US flag vessels.

Category 2 – What existing product information or performance data

is available for:

A. MSDs certified to meet the performance standards and testing 

requirements described at 33 CFR Part 159? (Please Note: EPA is 

seeking input on information that is not currently contained in the 

Coast Guard’s certification files.) A number of survey responses 

included product information and performance data on installed MSD 

systems. The Chamber will include a listing of this data in its later 

submission to the docket. CSA received a number of survey 

responses which provided system characteristics e.g. 

manufacturer, model, type, technology employed (maceration, 

disinfection, biological treatment, combination, other), and 

rated capacity. In addition, a number of survey responses also 

included information relating to onboard procedures in the 

event of a unit malfunction, routine testing and inspection 

protocols and onboard recordkeeping procedures. All of this 

type of information suggests that vessel operating procedures 

integrate the operation, maintenance, inspection and 
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recordkeeping aspects of sewage management systems into 

the vessel engineering and operating systems utilized onboard 

to monitor and maintain integral pieces of vessel equipment. 

Due to the volume of this information and the variation in its 

submission format, this was not suitable for integration into 

the Excel spreadsheet, although CSA will be pleased to work 

further with EPA to put this information in some usable format.

B. STPs that have been tested and received Certificates of Type Approval 

certifying that the device meets the MARPOL Annex IV effluent 

standards and performance tests in either Resolution MEPC.2(VI) or 

Resolution MEPC.159(55)? Not applicable as no (0) surveys indicated 

installation of STPs. 100% of the responses indicated onboard 

installations were in compliance with either MEPC.2(VI) or 

MEPC.159(55) as evidenced by issuance of either an ISPPC 

issued by a nation party to Annex IV or in the case of US flag 

vessels, a SOVC issued by the US government.

Category 3 – Are you aware of any existing information about other 

countries’ domestic laws that establish standards or discharge 

limitations for vessel sewage? The only laws/regulations in place in 

other countries of which we are aware, are those implementing the 

provisions of MARPOL Annex IV into national legislation/regulation and those 

areas which are currently designated special areas for the purposes of 

discharges of sewage from vessels. No new information provided by 

survey responses.

Category 4 – Given existing international and Federal limitations and 

controls regulating discharges of sewage from vessels, and in light of 

the numerous CWA section 312 State-established NDZs, should EPA 

consider revisions to the performance standards for MSDs, and what 

should be the basis for such a decision. EPA should NOT, at this time, 

revise the current performance standards for MSDs. As noted in our 

submission to the docket last week re: the EPA proposed rule to establish a 

no discharge zone throughout the waters of the State of California (Docket ID 

No. EPA-R09-OW-2010-0438: Marine Sanitation Devices (MSDs): Proposed 

Regulation to Establish a No Discharge Zone (NDZ) for California State 

Marine Waters), more than simple anecdotal evidence detailing water quality 

impairment is necessary to justify revisions to the current regulations which 

we believe are sufficient robust to protect the waters of the United States. 

Specifically included in our comments is the following text which we believe is 

equally important in this proceeding.

“Further, in its discussion of vessel sewage generated from large 

oceangoing vessels at 75 FR 53920, EPA notes again that “as with 

large passenger vessels, EPA does not have data for determining how 

much of this sewage is discharged in State marine waters, however it 

is likely to be a significant portion”.
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It is difficult to comprehend how causation can be established between 

water quality and a particular discharge type when not even the 

volume of the discharge in question has been determined, much less 

the spatial and temporal distribution of these discharges and their 

relative contribution to observed water quality impacts in any location. 

Absent this information, statements suggesting that sewage 

discharges are “likely to be a significant portion” or “could be causing 

or contributing to violations” are simply a guess as they are devoid of 

any scientific basis to support these questionable conclusions. 

While EPA does describe the number and location of impaired water 

bodies that have potentially been impacted by sewage discharges, it 

does so without addressing the nexus between these impairments and 

vessel discharges sought to be prohibited and in fact, lists a number of 

water bodies in which large commercial ships cannot or do not travel 

due to draft constraints and/or configuration of port/berth locations in 

California ports. This lack of nexus was noted in the CEQ comments 

found in document JP 37 in the docket where it noted that there was a 

need to address this nexus between water quality impairment and 

vessel discharges “in order to justify inclusion of this data in the 

determination”.”

Category 5 – What existing information is available on the current 

practices, protocols or regulatory approaches to testing, monitoring 

and/or reporting sewage discharges from vessels, and what, if any 

are the practical limitations or burdens associated with these 

practices? A number of survey responses included information on how the 

operation and periodic maintenance of MSDs are integrated into the vessel 

operating procedures, including periodic testing and onboard recordkeeping. 

The Chamber will include a listing of this data in its later submission to the 

docket. Again as indicated in our response to Category 2.A. above, a 

number of responses provided information on onboard procedures 

for testing, monitoring and recordkeeping/reporting which were not 

amenable for input into the Excel spreadsheet. Per above, CSA would 

be pleased to work further with EPA in providing this information in a 

useful format.

CONCLUSION

The Chamber very much appreciates the logical and rational approach which 

EPA is taking to assess the current state of affairs relative to marine 

sanitation devices. Real impacts and real capabilities are the key to 

determining the response to the petition filed by the Friends of the Earth. 

While CSA is not a “big” organization relative to staffing or analytical abilities, 

we are hopeful that the results of this survey will provide a significant insight 

into the “real world” processes and procedures which govern the 

management of sewage by vessels. Unlike what we believe to be the general 

perception that these discharges go relatively unregulated, we believe that 

the responses contained in these surveys taken in conjunction with the 

detailed legal requirements placed on these systems and discharges show 
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that today’s merchant vessels have installed not only compliant systems to 

manage sewage generated aboard these vessels but have also integrated 

comprehensive inspection, maintenance, monitoring and recordkeeping 

programs into vessel operations to ensure their continued performance to the 

legally required standards.

We are hopeful that the qualitative information provided in our prior 

submission taken in conjunction with the quantitative analysis which we 

provide here will inform the EPA decision to NOT revise the current MSD 

regulations.

We thank you again for the opportunity to comment on this proposed rule

and would be pleased to answer any questions or provide further information 

as EPA sees fit.

Sincerely,

Kathy J. Metcalf

Director, Maritime Affairs

Chamber of Shipping of America

1730 M Street, NW

Suite 407

Washington, DC 20036

202.775.4399

kmetcalf@knowships.org
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ANNEX I

CSA SURVEY FOR VESSEL MSD AND ONBOARD SEWAGE MANGEMENT 

SYSTEMS

The Chamber of Shipping of America seeks information to help prevent 

unwanted changes regarding Marine Sanitation Device regulations. Last April, 

Friends of the Earth submitted the “Petition for Rulemaking to Update the 

Regulation of Sewage Discharges from Large Vessels” to the Honorable Lisa 

P. Jackson, Administrator of the United States Environmental Protection 

Agency. EPA has now requested comments as a direct result of this petition 

which requests EPA to revise its regulations for MSD performance standards 

and to establish periodic monitoring, recordkeeping and reporting 

requirements for this equipment. This, process, as permitted under the US 

Clean Water Act, may sound vaguely familiar as it was the first step in the 

process that ultimately led to the litigation and unfavorable decision that 

placed vessel discharges under the purview of the NPDES system.

This petition contained information, from the FOE perspective, explaining 

why the sewage discharges from large vessels are harming the environment 

and why the regulations need to become stricter. There is no information on 

the record at this point to argue that the existing regulations are sufficient in 

scope and stringency.

It is critical that the maritime industry provide real time operational data 

regarding the performance and management of vessel sewage management 

systems. Failure to provide such data to EPA will most likely result in the 

proposal of more stringent regulations for sewage in the US with no 

guarantee that what is proposed will align with existing IMO requirements. 

In order to provide relevant data to EPA on the current status of onboard 

sewage treatment and hopefully mitigate the impact of new more stringent, 

costly and arguably unjustified requirements, we need to collect data on 

existing systems and how compliance with current sewage regulations is/is 

not achieved.

Please complete the enclosed survey so we can provide EPA with the 

information relative to the current performance of MSD and onboard sewage 

management systems. 

Please answer the questions on the survey for each MSD on each of your 

ships or each class of ships which have the same onboard sewage 

management systems. If you choose to answer for a group of ships which 

have the same types of systems, please include the number and 

characteristics of the ships in this group.

Please return the completed questionnaire to kmetcalf@knowships.org by 

October 15, 2010. Thank you for your help.
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For purposes of US regulations, three MSD Types are currently 

recognized:

Type I MSD: Flow through treatment device which may be installed 

only on vessels less than or equal to 65 feet in length; produce effluent with 

no visible floating solids and fecal coliform bacterial count not greater than 

1000 per 100 milliliters.

Type II MSD: Flow through treatment device which may be installed 

on vessels of any length; produce effluent with fecal coliform bacterial count 

not greater than 200 per 100 milliliters, no more than 150 mg total 

suspended solids per liter.

Type III MSD: Holding tanks which may be installed on vessels of any 

length used for storage until shore side or compliant at sea discharge is 

possible.

In addition, some vessels, most notably cruise vessels have installed 

advanced wastewater treatment systems (AWTS) and information on 

these installations is also requested.

For purposes of IMO requirements, effluent standards for sewage 

treatment plants are as follows (as compared to US Clean Water Act 

Type II MSD standards 0f <200 per 100 ml (fecal coliform) and <150 

total suspended solids):

Installation prior to 1/1/2010 Installation on/after 

1/1/2010

(MEPC.2(VI)) (MEPC.159(55))

Coliform ≤250 per 100 ml GM ≤100 per 100 ml GM

Total ≤50 GM ≤35 GM

Suspended

Solids

BOD5 ≤50 GM ≤25 GM

COD n/a ≤125 

Residual As low as practicable ≤5 

Chlorine
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MARINE SANITATION DEVICE SURVEY

Type of ship:

Flag of ship:

Size of vessel (length/gross tonnage):

Nature of service (transoceanic, coastal, inland):

Year built:

Crew size (actual and certified):

Does the vessel have a valid International Sewage Pollution 

Prevention Certificate (MARPOL Annex IV)? 

If not, does the vessel still comply with provisions of Annex IV and 

US laws and regulations e.g. certificate of alternate compliance for 

US flag ships trading internationally?

For vessels compliant with MARPOL Annex IV, do units comply with 

old standard (MEPC.2(VI)) or new more stringent standard 

(MEPC.159(55))?

Number of MSDs or other sewage treatment systems onboard ship?

Unit(s) type (please list info for each unit):

manufacturer 

type (I, II, III, AWTS)

rated capacity

design e.g. maceration, disinfection, biological treatment, 

combination, other

Total onboard holding capacity:

Estimated volume of sewage waste generated (per day, week or 

month):

If there is only a single system, what is the operational procedure for 

unit failure or overcapacity? (i.e. retain waste onboard for discharge 

ashore, retain waste onboard until unit is fixed, retain waste onboard 

until legal discharge at sea etc.)

What types of operational failures or malfunctions have occurred in 

the past 2 years and what actions have been taken to ensure 

compliance with US regulations?

Are non-operational units fixed by ships’ crew or are shore side 

technical experts required?
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Do operational procedures include periodic testing and sampling for 

proper operation of sewage treatment devices? If yes, please 

provide a copy of these procedures.

What recordkeeping requirements are in place for the documentation 

of proper operation of sewage treatment devices including testing 

and sampling provisions, upset conditions and corrective action 

programs?

Any other comments or information you can provide that might be 

valuable to this work particularly with regard to non-routine 

scenarios where holding and/or treatment capacity may be 

exceeded, need for shoreside discharge where otherwise not 

required, unavailability or inadequacy of reception facilities (please 

note port).

Legal references for MSD regulations can be found in MARPOL Annex IV and 

33 CFR Part 159
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ANNEX II

EXPLANATION OF EXCEL SPREADHEET SURVEY DATA PARAMETERS 

AND ANALYSIS PROTOCOLS

1. 1st column (Record Number). Each individual vessel reporting is 

assigned a record number in the Excel Spreadsheet. For reports which 

included entire classes of vessels with similar information, the number 

of vessels in that class was determined and individual line entries were 

created for each vessel.

2. 2nd column (Ship Type). Although its relevance was unknown at the 

time, CSA believed that collection of ship type information could be 

helpful in a more detailed analysis of the data, thus the column for 

ship type provides this detail. The vast majority of responses were 

from vessels were divided into traditional subgroups which include 

Tank vessels (wet bulk carriers of all sizes and types including crude 

oil, chemical and petroleum product tankers), Bulk carriers (dry bulk 

cargoes and combination oil/bulk carriers), Gas Carriers (GasC) which 

include both Liquefied Natural Gas (LNG) and Liquefied Petroleum Gas 

(LPG) carriers, General Cargo vessels (GenC) which includes 

conventional parcel freight vessels as well as vessels which carry 

combinations of parcel freight and containers, Container vessels 

(Cont) which only carry containerized cargoes, Roll on/Roll off 

vessels (RoRo) which carry “wheeled” cargoes including cars and 

trucks, and Specialized Refrigerated Cargo vessels (reefer) which 

exclusively carry cargoes requiring refrigeration through the transit 

from load to discharge port. A small number of responses were from 

vessels in less traditional subgroups including Special Purpose 

vessels (Sp Purp), Tugboats (Tug), Articulated Tug/Barge Units 

(ATB) and Integrated Tug/Barge Units (ITB).

3. 3rd column (Flag). This data point represents the registry of the 

reporting vessel. In a few cases, this was not reported on the survey 

itself and is thus designated “not US” after confirmation with the 

reporting entity that the vessels were flagged in nations other than the 

US. Although generally self-explanatory, some abbreviations were 

used for facilitating input into the spreadsheet including: MI (Marshall 

Islands), Ant/Barb (Antigua/Barbuda) Northern Antilles (NAnt), 

Netherlands (Neth), Singapore (Sing), and the Isle of Man (IofMan).

4. 4th column (Year Blt). This column represents the year in which the 

vessel was placed into commercial service. In a few instances, this 

data was not provided and in this case this column is left blank for that 

particular record entry.

5. 5th column (Service). This column reflects the nature of the trade in 

which the vessel was engaged at the time the survey information was 

submitted e.g. oceangoing/global (O) or coastwise (C). The vast 
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majority of the entries are for oceangoing/global trading although a 

small number of entries reflect vessels engaged in coastwise trade. All 

of the entries reflecting coastwise trade are for US flag vessels and 

thus represent vessels which are currently engaged in trade between 

US ports, although some may be capable of engaging in international 

voyages.

6. 6th column (LOA (m)). Length overall of the reporting vessel in 

meters.

7. 7th column (GRT). Gross registered tonnage normally reported in 

metric tons. This data point is relevant in determining whether the 

reporting vessel triggers the 400 gross ton application criteria 

contained in MARPOL Annex IV. In a few cases, this data point was 

not reported and after additional inquiry of the responding entity, it 

was determined that all vessels which did not specifically report their 

gross registered tonnage were, in fact, in excess of 400 gross tons.

8. 8th column (Crew). The original survey requested the responder to 

provide both actual crew onboard and the number of crew/personnel 

for which the vessel was certified. Responses varied with some 

reporting the minimum crew permitted according to the Safe Manning 

document, the actual crew serving aboard the vessel and/or the 

maximum number of crew/personnel for which the vessel is certified 

based on required safety equipment. While the actual number on 

board reflects an important data point relative to actual daily volumes 

of generated sewage, the maximum crew/personnel for which the 

vessel is certified is equally important in estimating the maximum 

sewage volume which could be generated if the vessel carried 

personnel to the maximum legally permitted. It is this latter quantity 

that serves as the basis for selection of MSDs at a rated capacity level 

sufficient to handle the potential maximum load. Due to the variation 

in responses and lack of clarity in which of these two data points were 

actually being reported, it was decided to report the higher of the two 

reported numbers where two data points were reported. While the 

two data points do not usually vary considerably e.g. usually within 

25% where an actual crew of 24 may be onboard a vessel with a 30 

person rated maximum (certified), a few entries indicated larger 

variations. For example, record number 9 indicates a special purpose 

vessel which carries a normal crew of between 25 and 30, but may 

carry a maximum of 60 persons when activated to its full operational 

capacity. However, these large variations are few in number and thus 

it is assumed that the numbers provided in this column provide a 

realistic estimate (within 25%) of the total number of individuals 

carried aboard the vessel during normal operations.

9. 9th column (ISPPC?). This column reflects whether the reporting 

vessel has a valid International Sewage Pollution Prevention Certificate 

as issued by a party to MARPOL Annex IV. The vast majority of 

reporting vessels do possess this certification. Those that do not (US 
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flag vessels) are addressed in the explanation below for the 10th

column.

10.10th column (US Cert). This column reflects whether the reporting 

vessel has a Statement of Voluntary Compliance (SOVC) as authorized 

by the USCG under USCG Navigation and Vessel Inspection Circular 

No. 1-09, “Voluntary Compliance with International Sewage 

Regulations in Annex IV to MARPOL 73/78”. Because the US is not a 

party to MARPOL Annex IV, it may not issue an ISPPC under MARPOL 

Annex IV. However, US vessels engaged in international trade are still 

subject to the provisions of MARPOL Annex IV when trading to nations 

that are parties to Annex IV. The SOVC issued by the US government 

is thus evidence of compliance with the provisions of Annex IV by the 

vessel and is generally accepted by other nations as an equivalency to 

the ISPPC. For non-US vessels calling in US ports, the US recognizes 

the validity of the ISPPC as evidence of compliance with Annex IV.

Thus the results of the survey contained in the matrix indicate that 

either the vessel carries a valid ISPPC or carries an SOVC (US flag 

vessels only). No vessels reported carrying both documents.

11.11th column (Old or New MARPOL). This data point indicates 

whether the reporting vessel complies with the provisions of IMO 

MEPC.2(VI) (the “old” MSD effluent standard) or the “new” MSD 

effluent standard contained in MEPC.159(55). Both documents outline 

in great detail the performance standards for MSDs and include testing 

and certification provisions to be applied by nations certifying that the 

equipment meets the provisions of Annex IV. The most significant 

portion of MEPC.159(55) which was adopted in October 2006, is 

increased stringent in MSD performance standards which are to be 

applied to MSDs installed on or after January 1, 2010. Please see the 

CSA survey at Annex I, for a comparison of the standards between the 

earlier MEPC.2(VI) and the new MEPC.159(55).

12.12th column (Tot Hld C). This data point indicates the total holding 

capacity in cubic meters for sewage reported by the responding vessel. 

There is a wide variation in reported capacities ranging from 0 to over 

100 cubic meters. Two entries indicate “error” in that column due to 

the incompatibility of the survey response to other reported values in 

the survey. Some entries indicate “Yes” in that column which reflects 

that the responding vessel noted holding capacity but did not provide 

the quantitative volume of that holding capacity. Finally, a few entries 

are blank in this column which reflects the failure of that vessel to 

complete that question in any manner.

13.13th column (Vol/Day). This data point reflects the daily volume in 

cubic meters of sewage generated as reported by the responding 

vessel. There is great variation in these values ranging from 0.1 to 12 

cubic meters. Some of this variation in the lower ranges can be 

attributed to vessel carrying smaller crew. Some of the variation in 

the higher ranges is likely attributable to systems which process both 
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sewage and graywater through the MSD system. Variations may also 

be attributable to the varying types of MSD technology employed on 

certain vessels which may result in reduced discharge volumes; 

however, this assumption can only be verified by more detailed 

comparison of the technology used and the volumes generated. One 

entry indicates “error” due to incompatibility of the survey response to 

other reported values while a number of entries are left blank due to 

the failure of the reporting entity to provide this quantitative 

information.

14.14th column (Days). This column represents the days of holding 

capacity which is derived by dividing column 12 by column 13 (total 

holding capacity/volume generated per day). Obviously for entities 

reporting zero holding capacity, this column also reflects zero days. 

Due to its relationship to the widely variable values contained in both 

columns 12 and 13, this column is equally variable with values ranging 

from zero (0) to 288 days. Higher values are likely associated with 

vessels that may utilize tankage not constructed for or typically 

associated with sewage and/or graywater retention. Responses which 

did not contain a response to column 13 are left blank.

15.15th column (Type). This column represents the type sewage 

management system in place on board the reporting vessel. A “2” in 

this column indicates that the vessel has no holding capacity and 

utilizes a compliant MSD. A “3” in this column indicates that the 

vessel has no MSD and utilizes only holding tanks with discharge 

ashore. A “2,3” in this column indicates that the vessel has both

holding tank capacity and a compliant MSD.