Issue link: https://geospatial.trimble.com/en/resources/i/1415432
Spring 2019 67 I n order to begin or continue operations in the US, hundreds of facilities – and potentially thousands of assets – nationwide must achieve or maintain certifi cation with US Coast Guard (USCG) marine facility and vessel vapour control system safety regulations. This is a labour-intensive process, as it involves a complete operational review of the vessel vapour control system at each marine facility. Facilities that must be certifi ed are defi ned in 33 CFR (US Code of Federal Regulations) 154 Subpart P as any that control vapours emitted to or from vessel cargo tanks. Certifi cation of marine vapour control systems (MVCS) is applicable to all tank farms or terminals that have vapour recovery systems as a component of marine loading to or from ships or barges. With fewer than two dozen USCG-approved certifi cation entities, any error or omission within the required documentation, or inconsistencies between documentation and operations, could result in signifi cant and costly delays. New facilities are required to be certifi ed before operations can commence, while existing facilities must be recertifi ed every fi ve years or after system modifi cations. The certifi cation process requires collecting and auditing volumes of mandatory documentation. Moreover, the audit often reveals documentation that must be updated. Needless to say, this labour-intensive process requires dedicated resources focused on scheduling and facilitating onsite operational reviews and leading preparation efforts. Though not required, many facility owners have found it necessary to engage third-party consultants who have expertise in verifying system compliance, managing documentation and coordinating directly with certifi cation entities. With facility owners focused on safely executing the day-to-day operations of a marine facility, this step can take much of the risk out of the certifi cation process. Facilitating operational reviews Subpart P requires that every facility with an MVCS completes an operational review every fi ve years at minimum; additional reviews are required following any system modifi cation. It is imperative that all certifi cation documents remain current with facility procedures, as they detail how the applicant meets the rules and requirements of the CFR. The operations Allyson Golden and Caitlin Geisinger, Burns & McDonnell, explain how a few simple steps can streamline the certification process for marine vapour control systems.