Commandant 

United States Coast Guard 

2100 2nd

 Street, S.W. 

Washington, DC 20593-7355 

Staff Symbol: CG-5 

Phone: 1 (202) 372-1367 

Fax: 1 (202) 372-1925 

 COMDTPUB P16700.4 

 NVIC 1-09 

 JUNE 23, 2009 

NAVIGATION AND VESSEL INSPECTION CIRCULAR NO. 1-09 

Subj: VOLUNTARY COMPLIANCE WITH INTERNATIONAL SEWAGE REGULATIONS IN 

ANNEX IV TO MARPOL 73/78 

Ref: (a) Regulations for Prevention of Pollution by Sewage from Ships, Annex IV to MARPOL 

73/78, adopted by MEPC.115(51) on April 1, 2004. 

(b) Effluent Standards and Performance Tests for Sewage Treatment Plants, adopted by 

MEPC.159(55) on October 13, 2006. 

(c) Specifications for Environmental Testing for Type Approval of Pollution Prevention 

Equipment, Annex: Part 3, adopted by MEPC.107(49) on July 18, 2003. 

(d) Standards for the Rate of Discharge of Untreated Sewage from Ships, adopted by 

MEPC.157(55) on October 13, 2006. 

(e) Marine Sanitation Devices, 33 Code of Federal Regulations Part 159 

1. PURPOSE. This circular establishes guidance for the owner or operator of any vessel as well as the 

manufacturer of any shipboard sewage processing equipment, including facilities that test shipboard 

sewage and related processing equipment, to voluntarily request U.S. Coast Guard certification of 

compliance with international sewage regulations in Annex IV to MARPOL 73/78. It also provides 

for reciprocity under Annex IV for non-U.S. flagged ships operating in waters subject to the 

jurisdiction of the United States. 

2. ACTION. Area, district, and sector commanders, commanders of maintenance and logistics 

commands, Commander Deployable Operations Group, commanding officers of headquarters units, 

assistant commandants for directorates, Judge Advocate General, and special staff offices at 

Headquarters shall ensure that the provisions of this circular are followed. Internet release is 

authorized. 

DISTRIBUTION – SDL No. 152 

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NON-STANDARD DISTRIBUTION: D:l ABS Americas, MARAD, MSC; Special Mailing List: CG-1, CG-10; 
NAVIGATION AND VESSEL INSPECTION CIRCULAR NO. 1-09 

3. DIRECTIVES AFFECTED. The Navigation and Vessel Inspection Circular (NVIC) No. 9-82 

(Change 1) on MSD Certification as well as Guidelines for Equivalent Compliance with MARPOL 

73/78 Annex IV (sewage), MOC Policy Letter No. 03-03, are cancelled on January 1, 2010. 

4. BACKGROUND. 

a. The Marine Environment Protection Committee (MEPC) of the International Maritime 

Organization (IMO) recently revised MARPOL Annex IV resulting in several changes to the 

international regulations governing discharge of sewage from ships on international voyages. 

First, inspection criteria were enhanced to include initial surveys of installed sewage systems 

prior to being placed into service and periodic surveys throughout the life of the ship. Next, 

standards for discharging treated sewage into the water were made more stringent and equipment 

testing procedures were standardized. Finally, discharge rates for untreated sewage were 

established. 

b. MARPOL Annex IV was implemented through a series of MEPC resolutions adopted over a 

two-year period. 

(1) On April 1, 2004, resolution MEPC.115(51) in reference (a) adopted MARPOL Annex IV. 

It is applicable to new ships on international voyages with a keel laid date on or after 

September 27, 2003, or delivered on or after September 27, 2006, and existing ships after 

September 27, 2008, that are 400 gross tons and above or which are certified to carry more 

than 15 persons. The term person is defined by reference (a) to include both passengers and 

crew. 

(2) On October 13, 2006, resolution MEPC.159(55) in reference (b) adopted the effluent 

standards and performance tests for MARPOL Annex IV. It is applicable to sewage 

treatment plants for ships with a keel laid date on or after January 1, 2010 and for ships 

having plants installed or delivered on or after January 1, 2010.1

 Ships with a keel laid date 

prior to January 1, 2010, or ships having sewage treatment plants installed or delivered prior 

to that date, may continue to use equipment certified to either the 1976 international effluent 

standards contained in resolution MEPC.2(VI) or an applicable national specification. 

Reference (b) also adopted environmental testing procedures from existing pollution 

prevention equipment regulations, which are contained in reference (c). 

(3) On October 13, 2006, resolution MEPC.157(55) in reference (d) adopted the standard for 

maximum rate of discharge of untreated sewage in holding tanks at a distance equal to or 

greater than 12 nautical miles from the nearest land. It is applicable using the same dates as 

in subparagraph (1) above. 

c. These revisions to MARPOL Annex IV effectively eliminate the prior equivalency that had 

existed between Type I and Type II marine sanitation device (MSD) requirements approved by 

the United States and sewage treatment plant requirements of MARPOL Annex IV. This creates 

a potential for adverse port State control action (e.g., detention) to be taken against U.S. 

 

1

 From Unified Interpretation MEPC 56/23. 

2
NAVIGATION AND VESSEL INSPECTION CIRCULAR NO. 1-09 

registered vessels engaged in international voyages with a keel laid date on or after January 1, 

2010, or having a sewage treatment plant installed or delivered on or after January 1, 2010. 

5. DISCUSSION. 

a. MARPOL Annex IV requires certain ships that engage in international voyages to have a valid 

International Sewage Pollution Prevention Certificate (ISPPC) issued by its flag Administration 

or by a recognized organization acting on behalf of the flag Administration. Under the 

provisions of Annex IV, an ISPPC cannot be issued to a ship unless its flag State is party to the 

annex. 

b. The United States is not party to MARPOL Annex IV. U.S. vessels that engage in international 

voyages with sewage systems in compliance with Annex IV may be eligible instead to receive a 

Statement of Voluntary Compliance (SOVC). This certificate takes the place of the ISPPC and 

is issued to a U.S. vessel by the U.S. Coast Guard or by an Authorized Classification Society 

(ACS), as appropriate, to demonstrate voluntary compliance with MARPOL Annex IV. The 

owner or operator of a U.S. vessel subject to requirements of MARPOL Annex IV, while not 

compelled to obtain a SOVC, may obtain one. Vessels without a valid ISPPC or SOVC on or 

after January 1, 2010, risk being detained overseas by a port State while operating in waters 

subject to its jurisdiction. 

c. MARPOL Annex IV prohibits discharge of sewage into the sea except when the ship has in 

operation an approved sewage treatment plant, or is discharging comminuted and disinfected 

sewage using an approved system at a distance of more than three nautical miles from the nearest 

land, or is discharging sewage which is not comminuted or disinfected at a distance of more than 

12 nautical miles from the nearest land. The term sewage is defined by reference (a) to include 

drainage and other wastes from toilets and urinals, drainage from medical spaces including wash 

basins, wash tubs, and scuppers located in such spaces, drainage from spaces containing live 

animals, and other waste water when mixed with any of these drainages. 

d. Regulation 9 of MARPOL Annex IV recognizes three different classes of sewage systems. 

(1) The first is a sewage treatment plant. This is a system approved by the flag Administration 

to comply with the standards and test methods established by the IMO. Sewage treatment 

plants continuously discharge their treated effluent so long as it is not within a special 

regulated area. In the United States, existing U.S. Coast Guard Type I and Type II MSDs 

most closely align as sewage treatment plants as they may discharge their treated sewage 

effluent directly into the waterway unless on a body of water where such discharges are 

otherwise prohibited (e.g., no discharge zones). The more stringent effluent requirements 

established for new installations of sewage treatment plants on or after January 1, 2010, or 

keel laid dates on or after that date, will invalidate the U.S. Coast Guard’s existing 

equivalency arguments for Type I and Type II MSDs. For ships with approved Type I or 

Type II MSDs not undergoing installation of a new sewage system, such vessels may 

continue to use such devices as an Administration approved sewage treatment plant. 

3
NAVIGATION AND VESSEL INSPECTION CIRCULAR NO. 1-09 

(2) The second system recognized by Annex IV is a sewage comminuting and disinfecting 

system with holding tank approved by the flag Administration. This type of system must 

include a holding tank for the temporary storage of treated sewage when the ship is less than 

three nautical miles from land. Ships utilizing a comminuter system are prohibited from 

discharging treated sewage effluent within three nautical miles from land. Type II MSDs 

equipped with a storage tank align closely with this type of system. Beginning in 2010, U.S. 

Coast Guard certified Type II MSDs that are unable to meet the new effluent standards for a 

sewage treatment plant may still qualify as a sewage comminuting and disinfecting system

provided it is equipped with a satisfactorily sized storage tank. 

(3) The third type of system recognized by Annex IV is a sewage holding tank and this most 

closely aligns with the U.S. Coast Guard holding tank requirements for Type III MSDs. 

e. In the United States, a sewage treatment plant is referred to as a marine sanitation device and 

while both systems may perform similar functions the two terms are distinct in application. Use 

sewage treatment plant when referring to equipment under the international regulations 

contained in MARPOL Annex IV and use MSD when referring to equipment under the U.S. 

regulations contained in 33 CFR Part 159. 

6. PROCEDURE. This circular establishes guidance for requesting U.S. Coast Guard certification of 

voluntary compliance with MARPOL Annex IV. These guidelines are divided into four distinct 

sections covering general applicability, testing facilities, equipment manufacturers, and the issuance 

of vessel certificates. Additionally, there is a section covering special circumstances. 

a. Applicability. 

(1) MARPOL Annex IV is applicable to ships on international voyages that are: 

(a) ≥400GT; or 

(b) <400GT certified to carry >15 persons, which includes both passengers and crew. 

(2) The more stringent effluent standards and performance tests contained in resolution 

MEPC.159(55) are applicable to sewage treatment plants for ships with a keel laid date on or 

after January 1, 2010 and for ships having sewage treatment plants installed or delivered on 

or after January 1, 2010.2

 

(3) Ships with keel laid dates prior to January 1, 2010, or ships having sewage treatment plants

installed or delivered prior to that date may continue to use equipment certified to either the 

1976 international effluent standards contained in resolution MEPC.2(VI) or an applicable 

national specification. In the United States, this applicable national specification is 33 CFR 

Part 159. 

 

2

 From Unified Interpretation MEPC 56/23. 

4
NAVIGATION AND VESSEL INSPECTION CIRCULAR NO. 1-09 

b. Testing Facility. Enclosure (1) contains guidance for testing facilities to be accepted by the U.S. 

Coast Guard as a qualified facility and includes the performance testing protocols for each type 

of sewage system. 

c. Equipment Manufacturer. Enclosure (2) contains guidance for equipment manufacturers to 

request a Certificate of Approval from the U.S. Coast Guard. 

d. Vessel Certificates. Enclosure (3) contains guidance for owners or operators of vessels that 

engage in international voyages to request a Statement of Voluntary Compliance with MARPOL 

Annex IV from the U.S. Coast Guard. 

e. Special Circumstances. MARPOL Annex IV may be applicable to other vessels including small 

tugs, recreational boats, yachts, etc., that engage in international voyages. Regulation 4 in 

Annex IV requires a flag Administration to establish appropriate measures for vessels not 

specifically subject to international sewage regulations. In this case, for U.S. vessels and other 

vessels subject to the jurisdiction of the United States, appropriate measures are provided for 

under 33 CFR Part 159 in reference (e). U.S. vessels intending to engage on international 

voyages may apply for a SOVC using the procedures in enclosure (3). 

f. Reconsideration. If a vessel owner, laboratory official, or manufacturer’s representative does not 

agree with a U.S. Coast Guard decision directly related to any provision of this NVIC, a 

reconsideration of that decision may be submitted to the office responsible for implementing this 

guidance listed under Contact Information at the end of enclosures (1) through (3). The 

procedures in 46 CFR 1.03 may be followed when submitting a request for reconsideration. 

7. DISCLAIMER. This guidance is not a substitute for applicable legal requirements, nor is it itself a 

rule. It is not intended to nor does it impose legally-binding requirements on any party. It 

represents the Coast Guard’s current thinking on this topic and may assist industry, mariners, the 

general public, and the Coast Guard, as well as other federal and state regulators, in applying 

statutory and regulatory requirements. You can use an alternative approach for complying with 

these requirements if the approach satisfies the requirements of the applicable statutes and 

regulations. If you want to discuss an alternative approach (you are not required to do so), you may 

contact the office responsible for implementing this guidance listed under Contact Information at the 

end of enclosures (1) through (3). 

8. CHANGES. This circular is available on the Web at http://www.uscg.mil/hq/cg5/nvic/. The Coast 

Guard will issue and post time sensitive amendments as an urgent change message on its Website for 

the benefit of the industry. Interested parties may suggest improvements to this circular by writing 

to the office responsible for implementing this guidance listed under Contact Information at the end 

of enclosures (1) through (3). 

9. ENVIRONMENTAL ASPECT AND IMPACT CONSIDERATIONS. Environmental 

considerations were examined in the development of this circular. While in many cases the 

equipping of vessels has no impact on the environment, in this case guidance on obtaining the 

certification of voluntary compliance with the provisions of MARPOL Annex IV is hoped to have a 

positive impact on the marine environment. 

5
NAVIGATION AND VESSEL INSPECTION CIRCULAR NO. 1-09 

6

10. FORMS/REPORTS. The forms called for in this NVIC are available in USCG Electronic Forms on 

the Standard Workstation or on CG Central at http://cgcentral.uscg.mil/ (Resources Tab) and 

Intranet at http://cgweb.comdt.uscg.mil/CGForms. 

BRIAN M. SALERNO 

Rear Admiral, U. S. Coast Guard 

Assistant Commandant for Marine 

Safety, Security and Stewardship 

Enclosure: (1) Testing Facility Guidance 

 (2) Equipment Manufacturer Guidance 

 (3) Vessel Certificate Guidance 

 (4) Sample Statements of Voluntary Compliance 
Enclosure (1) to NVIC No. 1-09 

Testing Facility Guidance 

1. U.S. TESTING FACILITY. 

a. Letter of Acceptance. Facilities in the United States that are in the business of independently 

evaluating, inspecting, and testing shipboard sewage systems and the effluent discharged from 

such systems for compliance with published standards may be eligible to receive a U.S. Coast 

Guard letter of acceptance as a qualified facility to evaluate, inspect, and test sewage treatment 

plants for compliance with MARPOL Annex IV. 

b. Application. A U.S. laboratory may, at its discretion, apply to the U.S. Coast Guard to be 

accepted as a qualified facility. Any laboratory previously accepted as a recognized facility

under 33 CFR Part 159 may also apply to the U.S. Coast Guard for acceptance as a qualified 

facility under MARPOL Annex IV by using these application procedures. The application for 

acceptance should be made in writing, signed by the chief laboratory official, and include the 

location of each facility that will evaluate, inspect, and test shipboard sewage systems and the 

effluent discharged from such systems. Send the application to Commandant (CG-5213) using 

the address under Contact Information in paragraph 4 below and include the following: 

(1) A detailed technical report that describes the rig, material, and equipment to be used at each 

facility, including, where applicable, the minimum and maximum operating limits for each 

piece of equipment to be used; 

(2) A brief summary of the instrument calibration program at each facility, including, where 

applicable, the calibration status of each piece of equipment to be used; 

(3) A brief summary of the relevant training, qualification, and experience for each person who 

performs, supervises, or witnesses a performance test; 

(4) A statement affirming that neither the laboratory nor any sub-laboratory, including a 

subsidiary, is subject to any of the following: 

(a) Owned or controlled by a supplier, vendor, or manufacturer of equipment or material to 

be evaluated, inspected, or tested; 

(b) Dependent on the U.S. Coast Guard for acceptance to remain in business; 

(c) Advertises or promotes the equipment or material to be evaluated, inspected, or tested; 

(5) The name, title, address, and principal business activity of each laboratory officer and 

director as well as each person, company, or corporation that owns at least three percent 

interest in the laboratory or sub-laboratory, including a subsidiary, or in the company or 

corporation that controls the laboratory or sub-laboratory; and 

(6) A statement that an official representative of the U.S. Coast Guard is allowed access to each 

facility to verify the information submitted in an application or to witness inspections, 

evaluations, and tests. 

1
Enclosure (1) to NVIC No. 1-09 

c. Multiple Laboratories. A letter of acceptance may include one or more sub-laboratories also 

accepted by the U.S. Coast Guard to perform certain tests on behalf of the qualified facility. 

Under this special arrangement, multiple laboratories having discrete capabilities each perform a 

defined series of tests on the same device simulating installation onboard ship. The qualified 

facility provides for interfacility coordination and attends each procedure at the sub-laboratory to 

observe and validate results. Multiple day procedures may be attended selectively during critical 

periods, e.g., startup, maximum loading, final inspection, etc. For acceptance, the qualified 

facility submits a signed application together with a separate signed application from each sublaboratory so that when viewed together the consolidated application not only covers all aspects 

of evaluation, inspection, and testing contained herein but also includes a brief description of 

how the various facilities will coordinate functions. 

d. Performance Testing Program. The performance testing program composes three discrete 

protocols, one for each type of sewage system having its own operational requirements and 

related discharge criteria. In addition, each of these three protocols comprises four phases that 

start with an evaluation of the manufacturer’s documentation and is followed by an inspection of 

the equipment design and construction, environmental (i.e., mechanical) testing, and finally 

analytical testing of the effluent. 

(1) Sewage Treatment Plant Protocol. A qualified facility evaluates, inspects, and tests the 

manufacturer’s sewage treatment plant and effluent discharged from that system for 

compliance with MARPOL Annex IV using the protocol in paragraphs a through d below. 

(a) Documentation evaluation. The laboratory performs an independent evaluation of the 

manufacturer’s documentation as it relates to manufacturing of the sewage treatment 

plant using each of the following standards: 

Standard Title 

33 CFR 159.14(b)(1) Quality control program 

33 CFR 159.14(b)(2) Design drawings 

33 CFR 159.14(b)(3) Instructions 

(b) Design & construction inspection. The laboratory performs an independent inspection on 

the production model for which type approval is requested as well as on the material from 

which the system is constructed using each of the following standards: 

Standard Title 

33 CFR 159.55 Identification label 

33 CFR 159.57 Installation, operation, & maintenance instructions

33 CFR 159.59 Placard 

33 CFR 159.61 Vents 

33 CFR 159.63 Access to parts 

33 CFR 159.65 Chemical level indicator 

33 CFR 159.67 Electrical component rating 

33 CFR 159.69 Motor ratings 

33 CFR 159.71 Electrical controls & conductors 

2
Enclosure (1) to NVIC No. 1-09 

33 CFR 159.73 Conductors 

33 CFR 159.75 Overcurrent protection 

33 CFR 159.79 Terminals 

33 CFR 159.81 Baffles 

33 CFR 159.83 Level indicator 

33 CFR 159.85 Sewage removal 

Regulation 10, 

MEPC 115(51) 

Standard discharge connections 

33 CFR 159.89 Power interruption 

33 CFR 159.93 Independent supporting 

33 CFR 159.95 Safety 

33 CFR 159.97 Safety, inspected vessel 

(c) Environmental tests. The laboratory performs independent environmental (i.e., 

mechanical) testing on the production model for which type approval is requested as well 

as on the material from which the system is constructed. All testing is performed on the 

same device installed either onboard ship or ashore, following the manufacturer’s 

instructions. This testing is made using each of the following standards: 

Standard Title 

Specification 3.2.2.1, 

MEPC.107(49) Annex 

Vibration. Note: Liquid retention components, if 

any, filled with water to 1⁄2 volume. 

33 CFR 159.105 Shock 

33 CFR 159.107 Rolling 

Specification 3.2.2.4, 

MEPC.107(49) Annex 

Inclination 

Specification 3.2.2.2, 

MEPC.107(49) Annex 

Temperature range 

Specification 3.2.2.3, 

MEPC.107(49) Annex 

Humidity 

33 CFR 159.117 Chemical resistance 

33 CFR 159.119 Operability, temp. range 

33 CFR 159.129 Ignition prevention 

33 CFR 159.109 Pressure 

33 CFR 159.111 Pressure & vacuum pulse 

(d) Analytical tests. The laboratory performs independent analytical testing on effluent 

discharged from the same device that underwent environmental testing. The laboratory 

specifies the testing method used along with all variable test conditions, such as quality 

of influent sewage, loading factors, sampling method, etc., and whether or not the 

effluent produced visible floating solids or caused discoloration of the surrounding water. 

This testing is made using each of the following standards: 

Standard Title 

MEPC.159(55) Thermotolerant coliform 

3
Enclosure (1) to NVIC No. 1-09 

4

MEPC.159(55) Total suspended solids 

MEPC.159(55) Biochemical oxygen demand & chemical oxygen 

demand 

MEPC.159(55) pH 

MEPC.159(55) Residual chlorine 

MEPC.159(55) Zero or non-detected values 

(2) Sewage Comminuting and Disinfection System Protocol. A recognized facility, as defined in 

reference (e), evaluates, inspects, and tests the manufacturer’s sewage comminuting and 

disinfection system with holding tank and the effluent discharged from that system for 

compliance with MARPOL Annex IV using the procedures for a USCG Type II certified 

device in 33 CFR Part 159. 

(3) Sewage Holding Tank Protocol. A recognized facility, as defined in reference (e), evaluates, 

inspects, and tests the manufacturer’s sewage holding tank for compliance with MARPOL 

Annex IV using the procedures for a USCG Type III certified device in 33 CFR Part 159. 

e. Certification of Results. The facility that performed the above evaluation, inspection, and testing 

on a given manufacturer’s system and the effluent discharged from that system certifies its test 

results are accurate and complete in a statement signed by the person in charge of testing. These 

results are part of a detailed technical report that is created by the qualified facility and includes a 

description of each evaluation, inspection, and test performed. The completed report is then 

forwarded, with all information submitted by the manufacturer, to the Marine Safety Center 

using the address under Contact Information in paragraph 6 of enclosure (2). 

2. NON-U.S. TESTING FACILITY. Facilities located outside the United States that are in the 

business of independently evaluating, inspecting, and testing shipboard sewage systems and the 

effluent discharged from such systems for compliance with published standards may be eligible to 

receive a U.S. Coast Guard letter of acceptance as a qualified facility by using the same application 

procedures as described above for U.S. testing facilities. 

3. LIST OF LABORATORIES. Any laboratory accepted by the U.S. Coast Guard is issued a letter of 

acceptance and entered into the Coast Guard Maritime Information Exchange (CGMIX), available 

on the Web at http://cgmix.uscg.mil/. This online searchable database is the official listing of all 

equipment and laboratories that have been accepted by the U.S. Coast Guard. 

4. CONTACT INFORMATION. For more information on this section including acceptance of testing 

facilities, or to apply for acceptance, please contact: 

COMMANDANT (CG-5213) 

US COAST GUARD 

ATTN SYSTEMS ENGINEERING DIVISION 

2100 2ND ST SW STOP 7126 

WASHINGTON DC 20593-7126 

Phone: 1 (202) 372-1367 

Fax: 1 (202) 372-1925 
Enclosure (2) to NVIC No. 1-09 

Equipment Manufacturer Guidance 

1. U.S. MANUFACTURER. 

a. Certificate of Approval. Shipboard sewage systems manufacturered in the United States in 

compliance with MARPOL Annex IV may be certified by the U.S. Coast Guard Marine Safety 

Center (MSC). Type approval is annotated on the U.S. Coast Guard Certificate of Approval 

issued under 33 CFR Part 159. A copy of this certificate is provided by the U.S. manufacturer 

prior to shipboard installation and should be maintained onboard ship for as long as the system is 

installed. 

b. Application. A U.S. manufacturer may, at its discretion, apply to any facility accepted by the 

U.S. Coast Guard as a qualified facility to perform independent evaluation, inspection, and 

testing of a sewage treatment plant for compliance with MARPOL Annex IV. For sewage 

comminuting and disinfection system with holding tank, the manufacturer may apply to any 

facility accepted by the U.S. Coast Guard as a recognized facility, as defined in reference (e), for 

compliance with MARPOL Annex IV using the procedures for a USCG Type II certified device 

in 33 CFR Part 159. For sewage holding tanks, the manufacturer may apply to any facility 

accepted by the U.S. Coast Guard as either a qualified facility or a recognized facility, as defined 

in reference (e), for compliance with MARPOL Annex IV using the procedures for a USCG 

Type III certified device in 33 CFR Part 159. In all cases, the application for performance 

testing should be made in writing, signed by a representative of the manufacturer, and include 

the name and address of the applicant and the manufacturing plant. Send the application and one 

production model to the qualified facility or recognized facility, as appropriate, and include the 

following: 

(1) The type and size of sewage system to be tested; 

(2) The specific performance testing standard in enclosure (1) to be used; 

(3) The sewage system design, including drawings, specifications, and other information that 

describes the materials, construction, and operation of the plant; 

(4) The installation, operation, and maintenance instructions for the system; 

(5) A complete description of the manufacturer’s production quality control and inspection 

methods, record keeping systems that pertain to the manufacturer of the sewage system; and 

(6) The name and location of the ship to which the sewage system will be installed, and whether 

testing should be performed either onboard the ship or ashore in the laboratory, or some 

combination of both. 

1
Enclosure (2) to NVIC No. 1-09 

c. Certification. The U.S. Coast Guard MSC may issue a Certificate of Approval to a U.S. 

manufacturer for any of the following: 

(1) A sewage treatment plant may be certified by the U.S. Coast Guard MSC to meet the 

operational requirements in regulation 9.1.1 to MARPOL Annex IV if it is evaluated, 

inspected, and tested by a qualified facility using the sewage treatment plant protocol 

contained in enclosure (1) and produces effluent having no visible floating solids or 

discoloration on the surrounding water. 

(2) A sewage comminuting and disinfecting system with holding tank may be certified by the 

U.S. Coast Guard MSC to meet the operational requirements in regulation 9.1.2 to MARPOL 

Annex IV if it is a USCG Type II certified device under 33 CFR Part 159 and is equipped 

with a holding tank suitable for temporary storage of treated sewage when the ship is less 

than three nautical miles from the nearest land. Under reference (a), this type of system 

produces treated sewage that is acceptable for discharge beyond three nautical miles from 

nearest land, except where otherwise prohibited, and can retain treated sewage in a holding 

tank when necessary. Stored treated sewage, as well as sewage from spaces containing 

living animals, may be discharged beyond three nautical miles from nearest land. Although 

reference (a) prohibits discharge of treated sewage from this type of system while the ship is 

operating internationally inside three nautical miles from nearest land, a certified USCG 

Type II device may, under the provisions of reference (e), discharge sewage inside three 

nautical miles while operating on waters subject to the jurisdiction of the United States, 

except where otherwise prohibited. 

(3) A sewage holding tank may be considered certified by the U.S. Coast Guard MSC as meeting 

the operational requirements in regulation 9.1.3 to MARPOL Annex IV if it is a USCG Type 

III certified device under reference (e). Following a favorable review by a recognized 

facility or a qualified facility, the MSC may issue a letter indicating that the sewage holding 

tank has met the requirements of Regulation 9.1.3 in MARPOL Annex IV and 33 CFR Part 

159. This type of system contains untreated sewage that is acceptable for discharge beyond 

12 nautical miles from land, except where otherwise prohibited. Stored untreated sewage, as 

well as sewage from spaces containing living animals, may be discharged beyond 12 nautical 

miles from nearest land at a discharge rate using the calculations in reference (d). Although 

reference (a) prohibits discharge of sewage from this type of system while the ship is 

operating internationally inside 12 nautical miles from nearest land, a certified USCG Type 

III device may, under the provisions of reference (e), discharge sewage beyond three nautical 

miles while operating on waters subject to the jurisdiction of the United States, except where 

otherwise prohibited. 

d. Existing Equipment. A U.S. manufacturer may apply to any facility accepted by the U.S. Coast 

Guard as a qualified facility or as a recognized facility, as appropriate, to perform independent 

evaluation, inspection, and testing of any existing sewage system for compliance with MARPOL 

Annex IV by using the same application procedures as described above for U.S. manufacturers. 

The qualified facility or recognized facility follows the testing and reporting procedures 

applicable to that device. Installed systems may only be removed from a U.S. flagged vessel for 

purposes of certification by following the manufacturer’s removal instructions. For inspected 

2
Enclosure (2) to NVIC No. 1-09 

vessels, prior written approval is needed from the local Officer in Charge, Marine Inspection 

(OCMI) before any installed systems may be removed. For vessels enrolled in the Alternate 

Compliance Program (ACP) prior written approval is obtained instead from the ship’s 

Authorized Classification Society (ACS). In any case, all vessels remain subject to the 

requirements of treating or retaining sewage as provided for in reference (e) while operating in 

waters subject to the jurisdiction of the United States. 

2. NON-U.S. MANUFACTURER. Shipboard sewage systems manufacturered outside the United 

States in compliance with MARPOL Annex IV may be eligible for type approval by the U.S. Coast 

Guard MSC. A non-U.S. manufacturer may, at its discretion, apply to any facility accepted by the 

U.S. Coast Guard as a qualified facility or a recognized facility, as appropriate, to perform 

independent evaluation, inspection, and testing of a sewage system for compliance with Annex IV 

by using the same application procedures as described above for U.S. manufacturers. The qualified 

facility or recognized facility follows the testing and reporting procedures that are applicable for the 

given type of system. Type approval is annotated on the U.S. Coast Guard Certificate of Approval. 

A copy of the certificate is provided by the manufacturer prior to installation and should be 

maintained onboard the ship for as long as the system is installed. 

3. RECIPROCITY. A shipboard sewage system having non-U.S. Coast Guard type approval may be 

eligible for type approval by the U.S. Coast Guard MSC. A manufacturer may apply to any facility 

accepted by the U.S. Coast Guard as a qualified facility or a recognized facility, as appropriate, to 

perform independent evaluation, inspection, and testing of sewage systems for compliance with 

MARPOL Annex IV by using the same application procedures as described above for U.S. 

manufacturers, being certain to include a copy of all prior test reports. The qualified facility or 

recognized facility follows the same testing and reporting procedures that are applicable for the 

given type of system and may, where appropriate, accept prior results having testing protocols that 

are substantially equivalent to those listed in the applicable protocol in enclosure (1). Type approval 

is annotated on the U.S. Coast Guard Certificate of Approval. A copy of the certificate is provided 

by the manufacturer prior to installation and should be maintained onboard the ship for as long as 

the system is installed. 

4. SCALING. Only full-scale production quality sewage treatment plants may be accepted for 

evaluation, inspection, and testing under MARPOL Annex IV. Such plants are of the actual size and 

capacity to be installed onboard ships. However, a manufacturer may apply in writing to the U.S. 

Coast Guard MSC in Washington DC using the address under Contact Information in paragraph 6 

below for a defined range of equipment sizes that employ the same design principles and technology 

using prior test results from a U.S. Coast Guard certified system. 

5. LIST OF EQUIPMENT. Equipment certified by the U.S. Coast Guard MSC are issued a Certificate 

of Approval and entered into the Coast Guard Maritime Information Exchange (CGMIX), available 

on the Web at http://cgmix.uscg.mil/. This online searchable database is the official listing of all 

equipment and laboratories that have been accepted by the U.S. Coast Guard. 

3
Enclosure (2) to NVIC No. 1-09 

4

6. CONTACT INFORMATION. For more information on this section including equipment 

certification or design review, please contact: 

COMMANDING OFFICER (MSC-2) 

US COAST GUARD 

ATTN MARINE SAFETY CENTER 

2100 2ND ST SW STOP 7102 

WASHINGTON DC 20593-7102 

Phone: 1 (202) 475-3402 

Fax: 1 (202) 475-3920 
Enclosure (3) to NVIC No. 1-09 

Vessel Certificate Guidance 

1. U.S. REGISTRY. 

a. Statement of Voluntary Compliance. Vessels registered in the United States that engage in 

international voyages with sewage systems in compliance with MARPOL Annex IV may be 

eligible to receive a Statement of Voluntary Compliance (SOVC). This certificate takes the 

place of the International Sewage Pollution Prevention Certificate (ISPPC) and is only issued to 

U.S. vessels to demonstrate compliance with MARPOL Annex IV. See enclosure (4) for sample 

SOVCs. 

b. Application. The owner or operator of a vessel registered in the United States with an installed 

and operational sewage system type approved by the U.S. Coast Guard may, at their discretion, 

apply for a SOVC for MARPOL Annex IV. The application for SOVC should be in writing, 

signed by the vessel owner or operator, and contain the name and address of the applicant. Send 

the application to the local Officer in Charge, Marine Inspection (OCMI), or to the Authorized 

Classification Society (ACS), as appropriate, and include the following: 

(1) Vessel name and official number; 

(2) Port of registry; 

(3) Gross tonnage; 

(4) Number of persons, including both passengers and crew, that the vessel is certified to carry; 

(5) IMO Number, if any; and 

(6) Copy of the U.S. Coast Guard Certificate of Approval indicating that the installed sewage 

system is one of the following approved types: 

(a) A sewage treatment plant certified by the U.S. Coast Guard under the provisions of 

MEPC.159(55) to meet the operational requirements in regulation 9.1.1 to MARPOL 

Annex IV. Include a copy of the laboratory test results, which are attached to the U.S. 

Coast Guard Certificate of Approval. 

(b) A sewage comminuting and disinfecting system with holding tank certified by the U.S. 

Coast Guard as a Type II MSD under the provisions of 33 CFR Part 159 to meet the 

operational requirements in regulation 9.1.2 to MARPOL Annex IV. 

(c) A sewage holding tank certified by the U.S. Coast Guard as a Type III MSD under the 

provisions of 33 CFR Part 159 to meet the operational requirements in regulation 9.1.3 to 

MARPOL Annex IV. For holding tanks having no USCG Certificate of Approval, the 

vessel owner or operator may request a letter of certification from the MSC indicating 

that the holding tank meets the requirements of Regulation 9.1.3 in MARPOL Annex IV 

and 33 CFR 159. 

1
Enclosure (3) to NVIC No. 1-09 

c. Survey. The cognizant OCMI or ACS, as appropriate, performs an examination of the vessel at 

any of the following: 

(1) Initial Survey. The vessel is subject to an initial examination before the ship is put into 

service or before the SOVC is issued for this first time. The purpose of this examination is to 

verify that the vessel’s structure, equipment, systems, fittings, arrangement, and material of 

the installed sewage system are fully compliant with MARPOL Annex IV. 

(2) Renewal Survey. The vessel is subject to a renewal examination before five years after the 

initial or last renewal survey. The purpose of this examination is to verify that the vessel’s 

structure, equipment, systems, fittings, arrangement, and material of the installed sewage 

system are compliant with MARPOL Annex IV. If the renewal survey is completed within 

three months either before or after expiration of the certificate then the new expiration will 

be set ahead five years from the old expiration date, otherwise the new expiration will be 

reset to five years after the examination date. 

(3) Additional Survey. The vessel is subject to additional examinations, either general or partial, 

according to the circumstances, whenever any important repairs or renewals have been made 

to the installed sewage system. The purpose of this examination is to verify that the 

necessary repairs or renewals have been effectively made, that the materials and 

workmanship of such repairs or renewals are satisfactory, and that the ship is compliant with 

MARPOL Annex IV. 

d. Issuance of Statement of Voluntary Compliance. The cognizant OCMI or ACS may issue or 

renew, as appropriate, a SOVC for MARPOL Annex IV to a U.S. vessel that is equipped with an 

installed and operational sewage system certified by the U.S. Coast Guard after successful 

onboard survey. Enclosure (4) contains sample SOVCs. Coast Guard Marine Inspectors may 

download an electronic version of the SOVC certificate, form CG-6047A, from the Coast 

Guard's electronic forms page. To complete the SOVC, refer to the enclosed samples and 

perform the following steps to the electronic document: 

(1) Fill in the vessel’s particulars e.g., name, official number, etc., including the number of 

persons (i.e., passengers and crew) that the vessel is certified to carry. It is not necessary to 

include M/V before the name or D before the official number. Indicate the port of registry 

as Falling Waters, WV. 

(2) Place an X in the appropriate box corresponding to either new or existing ship. 

(a) New is a ship having a keel laid date on or after September 27, 2003, or a delivery date 

on or after September 27, 2006. 

(b) Existing is a ship having a keel laid date before September 27, 2003, or a delivery date 

before September 27, 2006. 

(3) Insert the vessel’s keel laid date or delivery date, as appropriate. 

2
Enclosure (3) to NVIC No. 1-09 

(4) Select the type of sewage system installed onboard the vessel by placing an X in the 

appropriate box for ⌧ .1 Sewage Treatment Plant, ⌧ .2 Comminuter, and/or ⌧ .3 Holding 

Tank. For each type of installed system, enter the equipment particulars in the area below 

the checked box. Vessels equipped with more than one type of system may have an X

placed in all that apply. 

(a) For sewage treatment plant, enter the equipment model number in type of sewage 

treatment plant, the name of the manufacturer, and indicate the applicable effluent 

standard under MARPOL Annex IV by placing an X in either MEPC.2(VI) or 

MEPC.159(55). See the U.S. Coast Guard Certificate of Approval for equipment 

particulars. 

(b) For comminuter, enter the equipment model number in type, the name of the 

manufacturer, and enter 33 CFR Part 159 – Type II in standard of sewage after 

disinfection. Do not enter any particulars of a holding tank that is part of a comminuter 

system. See the U.S. Coast Guard Certificate of Approval for equipment particulars. 

(c) For holding tank, enter the tank capacity, location of the tank, and other equipment 

particulars being careful to enter all values in SI units as indicated on the form. Do not 

enter any particulars of a holding tank that is part of a comminuter system. The values 

entered for maximum service speed, maximum summer draft, and breadth on page 1 of 

the form will automatically generate a table on page 2 indicating the maximum 

permissible discharge rates for untreated sewage. See the U.S. Coast Guard Certificate of 

Approval or Letter of Approval for equipment particulars. 

1. Tank capacity. Enter the total capacity (i.e., volume) of the holding tank in cubic 

meters. To convert from English to SI units, multiply cubic feet by 0.02832 to obtain 

cubic meters or multiply gallons by 0.003785 to obtain cubic meters. 

2. Location. Enter the physical location of the holding tank using space, frame, side, 

etc. 

3. Maximum service speed. Enter the maximum service speed in knots from data on the 

vessel’s speed curve. 

4. Maximum summer draft. Enter the maximum summer draft (i.e., deepest draft) in 

meters by subtracting the summer freeboard listed on load line certificate from the 

total molded depth. Multiply feet by 0.3048 to obtain meters. 

5. Breadth. Enter the breadth of the vessel in meters directly from the tonnage 

certificate. Multiply feet by 0.3048 to obtain meters. 

(5) In the blank after This Certificate is valid until, insert the SOVC validity (i.e., expiration) 

date by selecting a date that is not more than five years from the date of issue. See also 

paragraph 1.c.(2) above for setting an expiration date following a renewal survey. 

3
Enclosure (3) to NVIC No. 1-09 

(6) In the blank after Completion date of survey, insert the date that the installed sewage system 

was recently examined or surveyed by OCMI or ACS. 

(7) In the two blank spaces after Issued at, insert the city and state where the SOVC is being 

issued. 

(8) Attach the following documents to the SOVC: 

(a) For sewage treatment plants, attach a copy of the U.S. Coast Guard Certificate of 

Approval and a copy of the laboratory test results. 

(b) For sewage comminuting and disinfecting system with holding tank, attach a copy of the 

U.S. Coast Guard Certificate of Approval. Laboratory test results are not required. 

(c) For sewage holding tank, attach a copy of the U.S. Coast Guard Certificate of Approval, 

or if one is not required, attach the letter from MSC indicating that the holding tank 

meets the requirements of Regulation 9.1.3 in MARPOL Annex IV and 33 CFR 159. 

The vessel owner/operator may contact the MSC to obtain a letter before the SOVC is 

issued. 

(9) Insert the date of issue and the name and title of the person signing on behalf of the OCMI 

or ACS. Sign the document in blue ink and affix a crimped seal. 

(10) Scan the signed original SOVC including appropriate attachments into MISLE. See 

paragraph 3 below for MISLE entry requirements. 

(11) Send the signed original SOVC including appropriate attachments to the vessel. 

e. Endorsements to Extend Certificate. The reverse side of the SOVC contains three endorsements 

to extend the validity period of an existing certificate. When the SOVC is first issued these 

endorsements are usually blank. The cognizant OCMI or ACS, as appropriate, may later endorse 

an original SOVC using the guidance contained in the relevant MARPOL Annex IV regulations 

that are cited after each endorsement (e.g., regulation 8.3) on the form. After endorsing an 

SOVC, scan a copy into documents in MISLE and provide the signed original endorsed SOVC 

to the vessel. See paragraph 3 below for MISLE entry instructions. 

f. Safety Management. Ship staff training should also include familiarization in the operation and 

maintenance of the sewage system as required by the Ship’s Safety Management Systems under 

the ISM Code. 

g. Casualty and Repair. The owner or operator of a U.S. registered vessel that holds a SOVC for 

MARPOL Annex IV should notify, as soon as practicable, the nearest OCMI or ACS, as 

appropriate, of any system degradation (e.g., defect, accident, malfunction, etc.) that affects the 

performance of the installed sewage system. The cognizant OCMI or ACS may, at its discretion, 

allow a reasonable period of time for repairs to be made or allow the vessel to proceed to an 

alternate port or repair yard, as appropriate, for repairs especially when the vessel does not 

4
Enclosure (3) to NVIC No. 1-09 

present an unreasonable threat of harm to the marine environment. In this case, form CG-835 

may be used. 

h. Non-Compliance. The cognizant OCMI or ACS may, at its discretion, withdraw a SOVC held 

by a U.S. vessel found not substantially compliant with the provisions of MARPOL Annex IV 

especially when that vessel presents an unreasonable threat of harm to the marine environment. 

Any non-compliance will be documented in MISLE. 

i. Expiration. The SOVC for MARPOL Annex IV becomes invalid at expiration unless endorsed 

with an extension and immediately after a change in the vessel’s flag. 

j. U.S. Regulations. Any U.S. registered vessel that holds a valid SOVC for MARPOL Annex IV 

will be accepted by the U.S. Coast Guard as being in compliance with U.S. regulations contained 

in reference (e) as it relates to the design, construction, testing, and certification of sewage 

systems, while operating in waters subject to the jurisdiction of the United States. 

k. Existing Certificates of Equivalency. The cognizant OCMI or ACS, as appropriate, may 

continue to issue and renew existing Certificates of Equivalency to U.S. vessels under the 

provisions of MOC Policy Letter No. 03-03 until January 1, 2010, at which time all such 

certificates will expire. SOVC certificates are required on or after January 1, 2010. 

2. NON-U.S. REGISTRY. 

a. Reciprocity. Any vessel flagged or registered outside the United States that holds a valid ISPPC 

issued by its flag Administration indicating the installed sewage system complies with MARPOL 

Annex IV as amended by either resolution MEPC.159(55) or MEPC.2(VI) will be accepted by 

the U.S. Coast Guard as being in compliance with U.S. regulations contained in reference (e) as 

it relates to the design, construction, testing, and certification, while operating in waters subject 

to the jurisdiction of the United States. 

b. Compliance. Acceptance of a valid ISPPC is conditional on the installed sewage system being 

substantially in an operable condition as required by MARPOL Annex IV and may be subject to 

verification by the U.S. Coast Guard under port State control. 

c. Non-compliance. Any vessel flagged or registered outside the United States that is not in 

compliance with MARPOL Annex IV is required instead to comply with 33 CFR Part 159 while 

operating in waters subject to the jurisdiction of the Unites States. Other applicable U.S. laws or 

regulations may provide for enforcement actions in the case of non-compliance e.g., discharge of 

sewage, negligence, etc. Additionally, any vessel operating on waters subject to the jurisdiction 

of the United States that is non-compliant with MARPOL Annex IV and non-compliant with 33 

CFR Part 159 may be subject to control actions restricting the movement of the vessel as deemed 

appropriate by the Captain of the Port (COTP). 

d. Statement of Voluntary Compliance. SOVC certificates issued by the U.S. Coast Guard are not 

available to vessels flagged outside the United States. 

5
Enclosure (3) to NVIC No. 1-09 

6

3. MISLE Entries. The inspector that performs a MARPOL Annex IV examination (e.g., initial survey, 

renewal survey, etc.) shall enter the results in MISLE. First create a new vessel activity and then 

select activity type Vessel Inspection/PSC. For activity title/description, enter MARPOL Annex IV 

Examination. Under the inspections tab add a new inspection and select inspection type of 

MARPOL Annex IV Examination from the drop down list, being certain to select the correct entry 

having Roman numeral four (IV). Provide a brief narrative summary that includes the type of 

survey performed (e.g., initial survey, renewal survey, etc.) and results of the examination. See 

survey paragraph 1.c above for sample language. Once signed, scan the original SOVC, front and 

back, and all related attachments from paragraph 1.d.(8) above as one document into MISLE. If the 

examination activity is still open, then simply add the scanned documents to Documents/Certificates 

and select document type MARPOL Annex IV SOVC from the drop down list, being certain to select 

the correct entry having Roman numeral four (IV). Otherwise add the scanned documents to the 

vessel’s Documents file in MISLE. For certificate entry in MISLE, enter the certificate issue date 

and expire date, leaving blank the certificate number and audit survey date. Once the activity is 

complete, it may be reviewed and closed at the field unit level or as otherwise required by local 

instruction. When the SOVC is issued by an ACS, the OCMI shall ensure a copy is obtained and 

entered in to MISLE as above. 

4. CONTACT INFORMATION. For more information on this section including vessel certificates and 

reciprocity, please contact: 

COMMANDANT (CG-543) 

US COAST GUARD 

ATTN OFFICE OF VESSEL ACTIVITIES 

2100 2ND ST SW STOP 7581 

WASHINGTON DC 20593-7581 

Phone: 1 (202) 372-1250 

Fax: 1 (202) 372-1917 
Enclosure (4) to NVIC No. 1-09 

1

Figure 1 Sample SOVC for Sewage Treatment Plant.

Sample 
Enclosure (4) to NVIC No. 1-09 

2

Sample 
Enclosure (4) to NVIC No. 1-09 

3

Figure 2 Sample SOVC for Sewage Comminuting and Disinfecting System.

Sample 
Enclosure (4) to NVIC No. 1-09 

4

Sample 
Enclosure (4) to NVIC No. 1-09 

Figure 3 Sample SOVC for Sewage Holding Tank.

Sample 

5
Enclosure (4) to NVIC No. 1-09 

6

Sample 
Enclosure (4) to NVIC No. 1-09 

7

Figure 4 Sample SOVC for Sewage Treatment Plant and Sewage Holding Tank.

Sample 
Enclosure (4) to NVIC No. 1-09 

8

Sample