Captains, if you are anything like me, you realize that it is quite easy to get lost in the sea of paperwork required to keep vessels compliant with the requirements of governing bodies such as flag state, Department of Homeland Security, U.S. Environmental Protection Agency and class societies.

Be advised that there are two additional requirements, one of which is becomes mandatory at the first of the year, the second being already in effect.

The first: Marshall Islands-flagged, commercially registered yachts of less than 500gt will be required to conform to their mini-ISM code.

The Marshall Islands’ Commercial Yacht Code, MI-103 Section 22.10.1, reads: “For all commercially registered vessels of less than 500gt, where full certification to the ISM Code is not currently required, it is strongly recommended that a safety management system be implemented at the earliest opportunity, as this will become a mandatory requirement of this administration as of 1 January 2010.”

Additionally, the Cayman Islands Shipping Registry confirmed it will enforce its requirement to have a mini-ISM much more during annual inspections and will also check that the Safety Management System is run properly.

As stated in the Large Commercial Yacht Code (LY2) section 30.2, “All vessels under 500gt should employ a safety management system (mini-ISM) as described in Annex 2.”

The second requirement pertains to all vessels over 400gt traveling in U.S. waters. A notice from June 2008 in the Federal Register, Vol. 73, No. 121, reads: “The Coast Guard is issuing this notice to inform U.S.- and foreign-flag non-tank vessel owners and operators effective Aug. 22, 2008, we will begin enforcing the requirement to prepare and submit a non-tank vessel response plan (NTVRP) for certain non-tank vessels.”

It goes further to define a non-tank vessel as a self-propelled vessel of 400gt or greater, which carries oil as fuel for main propulsion and operates on the navigable waters of the United States.

Captains, please take note of the NTVRP requirements as at least two yachts have now been denied entrance to St. Thomas, USVI, and another was delayed when entering New York for not having a NTVRP in place.

Capt. Taylor Lawson is a manager with Megayacht Technical Services International, a company that provides safety and security management, compliance documentation, custom training manuals, SOPEPs, mini-ISMs, fire and safety plans and NTVRPs to private and commercial yachts. Contact him at +1 954-761-7934 or taylor@mts-ism.com.