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ELEMENTS OF AN IMPLEMENTATION STRATEGY 114 Hazard Evolution Model Human Behavior that On-board Generation of Encourages Generating Garbage Garbage Intervention Model Modify Behavior that Reduce Garbage Encourages Generating Generation Garbage Economic (Market Provide budgets for Demonstrate any cost Forces) shipboard compliance to benefits from switch to avoid conflicts with reusable items. operating, maintenance, and repair budgets. Service employees report constant washups of items ranging from 55- gallon drums to small plastic bottles containing waste oil, acids, and a variety of other hazardous chemicals. A related problem is the significant expense associated with removing containers that have washed ashore and are suspected of containing hazardous substances. The equipment identification system helps in identifying owners, who are expected to cover removal costs ($1,700 per 55- gallon drum in 1993). Little information is available on garbage reception facilities at supply boat terminals. Because most offshore service vessels weigh less than 400 gross tons, the base terminals are not required to obtain COAs, and the Coast Guard has no other reason to visit the terminals or the vessels that call there (Green, 1993). Amendments to the MPPRCA have been proposed that would require inspection of non-COA garbage holding facilities. Control The federal government wields considerable power over this sector through an array of laws and regulations. All vessels are U.S. flag, and platforms in federal waters operate under direct permit from the MMS, which regulates equipment handling and overboard discharges under the Outer Continental Shelf Lands Act (P.L. 83-212), as amended. In addition, permits issued by the Environmental
ELEMENTS OF AN IMPLEMENTATION STRATEGY 115 Hazard Breakdown in Discharge of Exposure to Evolution Model Compliance Garbage into Sea Discharged Garbage Intervention Prevent Block Discharge Block Exposure Model Breakdown in of Garbage into to Discharged Compliance Sea Garbage Economic Return monies Organize vessel (Market Forces) from recycling to support services vessel crew for to make their discretionary compliance use. Make affordable. shoreside disposal Review waste readily available. hauling schedules and contracts. Expand use of on-board equipment to reduce need for disposal at commercial ports. Protection Agency (EPA) under the Clean Water Act (P.L. 92-500), as amended, prohibit the discharge from platforms of floating solids and rubbish, trash, and other refuse. The transfer of garbage from platforms to supply vessels is regulated under both Annex V and the Clean Water Act. Additional opportunities for government control are emerging in this sector. Supply vessels transporting and transferring platform garbage to port reception facilities are subject to the Shore Protection Act (SPA) of 198811, while the vessel's operational waste is covered by Annex V. Owners and operators of supply vessels must obtain SPA permits as commercial haulers of waste from the Coast Guard, which has been issuing conditional permits under an interim final rule (see 33 C.F.R. Â§151) since 1989 and plans to finalize this rule. In the meantime, the EPA is drafting regulations to provide guidance for waste transfer and handling; supply vessels will have to comply with these requirements when finalized. Another avenue for control may be record keeping. In addition to reporting to MMS items lost overboard, platform operators are required by the Coast Guard 11 The SPA is Title IV of the Ocean Dumping Ban Act (P.L. 100-688), which prohibits the discharge of industrial waste and sewage sludge into the sea. This law is distinct from the Ocean Dumping Act (P.L. 95-535), which prohibits the transportation of any material for the purpose of dumping it into the ocean.