The USCG issues guidance on maneuvering devices for safe navigation

Captain Akshat Arora, senior risk assessment specialist, states that members with vessels operating in the United States are advised to review USCG Policy Letter 01-24, which provides “Guidelines for Devices that Alter the Maneuvering Characteristics of Vessels to Ensure Safe Operation in waters of the United States”, including considerations for ensuring safe navigation and compliance with 33 CFR § 164.11(k).

As explained, the Strategy Letter is based on the provisions of MARPOL Annex VI, which require existing ships and ships that have undergone major conversion to comply with the provisions on the Energy Efficiency Index of Existing Ships (EEXI) by reducing the ship’s maximum speed or power, or by permanently derating the engine or by installing an extinguishable engine power limiter (EPL) or shaft power limiter (SHaPoLi).

Vessels that employ EPL/SHaPoLi or an engine acceleration limit program as part of their EEXI compliance structure must inform pilots of engine response characteristics prior to entering U.S. territorial waters and must comply with the requirements of 33 CFR § 164.11(k). Accurate representation of vessel maneuvering characteristics and limitations on pilot cards and wheelhouse posters is critical to safe navigation in confined waters.

33 CFR $164.11(k) requires pilots to be informed of the ship’s draft, maneuvering characteristics and peculiarities and of any unusual circumstances on the ship that may affect its safe navigation.

If the vessel’s maneuvering characteristics as indicated on the pilot card and wheelhouse poster are not updated after the installation of the EPL/SHaPoLi system or acceleration limiting program, the vessel is considered non-compliant. Therefore, you must bypass the system or program before entering United States territorial waters.

As explained, if it is not possible to circumvent this change, the COTP, in consultation with the pilots, may request additional measures to ensure the safety of the ship and the port during the ship’s transit in confined waters.

When transiting U.S. restricted waters, it is recommended that you follow the guidelines and procedures set forth in the On-Board Management Manual (OMM) and/or Safety Management System (SMS) to omit EPL/SHaPoLi when necessary for safe operations.

However, in accordance with IMO Resolutions MEPC.335(76) and MEPC.375(80), it is recommended that appropriate recording and reporting requirements to the flag State and/or class be followed when a bypass is activated. Furthermore, EPL/SHaPoLi bypass and use of reserve power by any vessel in U.S. waters must also be reported to the appropriate Officers in Charge of Maritime Inspection (OCMI) listed on the USCG Preventive Prevention Directory contact list.

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