USCG: Navigational device safety guide

The United States Coast Guard issued a policy letter on guidance regarding ship devices that alter maneuvering characteristics to ensure safe operation in U.S. waters.

This policy letter was published on 10 April 2024.

The letter outlines its aim to provide essential guidance to Captains of the Port (COTPs), Officers in Charge of Marine Inspection (OCMIs), and other maritime stakeholders concerning devices that impact ship maneuverability. It emphasizes the importance of ensuring safe navigation and compliance with relevant regulations, particularly 33 CFR § 164.11 (k).

BACKGROUND:

a. Effective November 1, 2022, existing ships and those undergoing significant conversions must adhere to the Energy Efficiency Existing Ship Index (EEXI) regulations under MARPOL Annex VI. Compliance options include permanent engine de-rating or the installation of overridable Engine Power Limiters (EPL) or Shaft Power Limiters (SHaPoLi). Additionally, operators have the choice to install systems aimed at enhancing the ship's environmental profile by limiting main propulsion engine acceleration rates. This policy letter encompasses these devices and similar ones that may impact ship maneuverability.

b. EPL/SHaPoLi systems are broadly categorized into two types: (1) Electronic systems, utilizing the ship's electronic engine control system to cap maximum speed or power output, often requiring verification by a bridge officer or the master for override; (2) Mechanical systems, physical components on the engine that restrict fuel flow if power demand exceeds a predetermined threshold, usually requiring more time for override than electronic systems.

c. Compliance with SOLAS Chapter V Regulation 34 necessitates safety-focused voyage planning, especially pertinent when EPL/SHaPoLi or acceleration-limiting programs are installed. Considerations include course and speed changes, transit duration in restricted waters, commercial and recreational marine traffic density, and tug availability in ports/waterways.

d. While minimum required power specified in reference (c) pertains to ships in unrestricted navigation, this policy letter offers guidance for ship power configurations in U.S. restricted waters. It outlines procedures for overriding EPL/SHaPoLi systems when necessary for safe operation, clarifying that such overrides do not violate MARPOL Annex VI regulations.

e. Ships employing EPL/SHaPoLi or engine acceleration-limiting programs as part of their EEXI compliance structure must inform pilots of engine response characteristics before entering U.S. territorial waters. Accurate representation of ship maneuvering characteristics and limitations on pilot cards and wheelhouse posters is essential for safe navigation.

GUIDANCE:

This section offers detailed instructions and recommendations for operators, Captains of the Port (COTPs), Officers in Charge of Marine Inspection (OCMIs), and maritime stakeholders regarding the use of devices affecting ship maneuverability:

a. Update Ship Documents: Ships with permanent power modifications must update pilot cards and wheelhouse posters to accurately reflect maneuverability changes resulting from device installation. This ensures that pilots are informed of the ship's capabilities during navigation.

b. Compliance with Regulations: Compliance with 33 CFR § 164.11 (k) requires ships to update pilot cards and wheelhouse posters following the installation of EPL/SHaPoLi systems or acceleration-limiting programs. Failure to do so necessitates system or program override before entry into U.S. territorial waters to ensure regulatory adherence. The Coast Guard may mandate additional safety measures during restricted water transits for non-compliant vessels.

c. Emergency Situations: The guidance stipulates that EPL/SHaPoLi systems should only be overridden in emergencies if the pilot card and wheelhouse poster do not accurately reflect maneuverability under override conditions. Additional safety measures should be considered in consultation with relevant authorities if power beyond the setpoint is necessary for safe transit in restricted waters.

d. Procedural Requirements: If a determination is made that additional power above the EPL/SHaPoLi set point is necessary for safe transit, operators must ensure an updated pilot card and wheelhouse poster for the override condition is onboard. Override procedures should be completed well in advance of the transit to ensure safe navigation. Operators are advised to exercise discretion when deciding between overriding a mechanical EPL/SHaPoLi system and implementing other operational safety measures for underpowered ships.

e. Reporting and Documentation: Ships must adhere to reporting and documentation requirements outlined in references (a) and (b) for recording and reporting EPL/SHaPoLi override and reserve power usage to relevant authorities. U.S. flagged ships should report to Flag State Control (CVC-4) at FlagStateControl@uscg.mil, while ships in U.S. waters must report to the cognizant OCMI. Contact information for OCMI offices is available on the Coast Guard's Prevention Directory Contact List.

f. System Re-Engagement: Operators are reminded of the importance of re-engaging the EPL/SHaPoLi system once the ship is clear of situations or areas that necessitated system override. This ensures compliance with regulations and maintains safety during subsequent operations.

For more information, please see the document below (available only to subscribers):