Placard Placement

As I read the federal requirements, it appears that I'm required to have a pollution placard and a trash placard mounted on my vessel (over 26 feet). What I don't see is if there is a requirement on where these placards should be mounted. For example can I place the pollution placard in my engine compartment or does it need to be mounted somewhere more visible to anyone coming aboard? Thanks in advance for your wisdom.

I put the trash placard right on my trash can.

I've seen them inside lockers.

Jamup said:

As I read the federal requirements, it appears that I'm required to have a pollution placard and a trash placard mounted on my vessel (over 26 feet). What I don't see is if there is a requirement on where these placards should be mounted. For example can I place the pollution placard in my engine compartment or does it need to be mounted somewhere more visible to anyone coming aboard? Thanks in advance for your wisdom.

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They are supposed to be visible to all crew as I understand it. As such, they can't be hidden in lockers but must be visible. Now, I don't have them visible but will do so as soon as I am told to do so by a USCG boarding party.

Trash placard usually in galley or where trash is stored.

Oil placard is curious...no guidance...have seen and heard everything from above engine to above engineroom door to bilge pump switch/helm area. If pretty obvious placement, I bet you are OK. If paranoid, 2 or 3 spread around will work.

If your vessel is 12m or more, in the US you have to have a garbage plan too. Simple ones on the internet to copy.

The oil placard talks about discharge, so I mounted it above the oil change pump. Following that logic, trash placard at trash can, etc.

Ted

I am a CGAUX boat examiner and come across this often. I advise that the oil discharge placard be where someone going into or in engine room will readily see it. it can be elsewhere but hidden is defeating the purpose. The Marpol pollution placard can be in the open or readily visible in the garbage collection bin area,and If over 40 ft. a written garbage disposal plan document is also needed in similar locations.

Thank you. I appreciate everyone's response.

Greetings,
Mr. J. Our oil discharge placard is in the ER just inside the door but I couldn't say for sure in spite of the fact I KNOW there's one there but I forget where exactly it is. The garbage placard is on the inside of the locker door where the garbage can is. Our trash disposal plan reads..."Trash will be taken ashore by the Captain and placed in appropriate containers".

eyschulman said:

I am a CGAUX boat examiner and come across this often. I advise that the oil discharge placard be where someone going into or in engine room will readily see it. it can be elsewhere but hidden is defeating the purpose. The Marpol pollution placard can be in the open or readily visible in the garbage collection bin area,and If over 40 ft. a written garbage disposal plan document is also needed in similar locations.

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Thanks. Good information.

eyschulman said:

I advise that the oil discharge placard be where someone going into or in engine room will readily see it. it can be elsewhere but hidden is defeating the purpose. The Marpol pollution placard can be in the open or readily visible in the garbage collection bin area

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That all makes sense, but is there any regulatory basis for it?

No regulated position I have ever come across

On my boat, it is Garbage sign on cabinet above the stove and Discharge sign in engine compartment. Both builder-installed.

MP

Same on my boat. Sounds legal to me.

danderer said:

That all makes sense, but is there any regulatory basis for it?

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From The USCG / USPS Vessel Examination Manual...

10. ITEM #10 - POLLUTION PLACARD (Oil Pollution Prevention/Oily Waste Discharge) (33 CFR 151/155)
a. The Federal Water Pollution Control Act prohibits the discharge of oil or hazardous substances that may be harmful into U.S. navigable waters. Vessels 26 feet and greater in length, with machinery spaces, must display a placard, at least 5 by 8 inches, made of durable material, fixed in a conspicuous place in the machinery space or at the bilge pump control station, stating the following:

11. ITEM #11 - MARPOL PLACARD (Discharge of Garbage MARPOL Trash Placards) (33 CFR 151/155)
a. The Act to Prevent Pollution from Ships (MARPOL, Annex V) places limitations on the discharge of garbage from vessels. It is illegal to dump plastic trash anywhere in the ocean or navigable waters of the United States. It is also illegal to discharge garbage in the navigable waters of the United States, including the Great Lakes. The discharge of other types of garbage is permitted outside of specific distances offshore, based on the nature of that garbage.
b. United States vessels 26 feet or longer must display in a prominent location a durable placard notifying the crew and passengers of the discharge restrictions.

I consider any noticeable location in, near, on the way to the ER meeting the oil discharge.
I also consider inside a galley locker containing a trash can as complying w/ the "prominent location" requirement - I do not require owners place them on outside of cabinets.
I think those interpretations are consistent with the intent of the requirements - never heard of anyone being cited for having the placards but not displaying them adequately.

Conspicuous and Prominent. I have no idea how one determines what either of those two words means in this case. However, I think I know what isn't. If you're unlikely to ever see them, they definitely don't qualify. I suspect the most you'd ever get would be a suggestion of moving them.

We look at the intended purpose and that means to us the Pollution placard in the engine room where one changing oil or handling other fluids would see it. New boats seem very consistent in very noticeable engine room locations.

For garbage, seems like every boat is different. I see them by the helm, in the galley, and on the aft deck. The apparent arguments are helm because captain and crew will always see, galley because that's where you collect most of the trash, and aft deck because that's where you'd most tend to throw something overboard and need the reminder.

I've seen boaters who want to hide them because they don't like the looks of such placards. To me, it's a normal part of a boat and I just don't mind visibility of most placards.

Fortunately for me, my boat's head is close to the ER door and it has a waste basket, so my placards are in the head for regular reference when contemplating such issues. It's a benefit to me, my crew and my guests. We all need something to read sometimes.

I was given an oil placard sticker which goes well on my aluminium fuel tanks near the laz hatch. I also store my spare ER diapers there.

It's passed 2 VSC checks with flying colors.

Good one, Al.

Bacchus said:

From The USCG / USPS Vessel Examination Manual...

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This is the most detailed answer I've seen -- but it also includes the following statement:

5. DISCLAIMER. This Manual is guidance and is not a substitute for applicable legal requirements, nor is it itself a rule. It is intended to provide operational guidance for Coast Guard personnel and is not intended to nor does it impose legally binding requirements on any party outside the Coast Guard.

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Must have been authored by a politician!

danderer said:

This is the most detailed answer I've seen -- but it also includes the following statement:

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Quote:
5. DISCLAIMER. This Manual is guidance and is not a substitute for applicable legal requirements, nor is it itself a rule. It is intended to provide operational guidance for Coast Guard personnel and is not intended to nor does it impose legally binding requirements on any party outside the Coast Guard.

You are absolutely correct - what I extracted was from the Vessel Safety Check manual published by USCG - not the law but it is an interpretation of the law to help guide examiners.

If you go back to the law it states...

§ 155.450 Placard.
(a) A ship, except a ship of less than 26 feet in length, must have a placard of at least 5 by 8 inches, made of durable material fixed in a conspicuous place in each machinery space, or at the bilge and ballast pump control station, stating the following:

Doesn't look very different does it.
Many laws require interpretation based on situation... we'd all be complaining if every law was specific enough to cover every possible situation because they would be unmanageable -

What am I missing - OP asked for guidance on where to place a placard - several have given good advice based on the legal requirement and educated advice / interpretation provided by USCG

Should we need to hire a lawyer to argue the definition of "conspicuous" and place it someplace other than was is suggested in the law?

I don't think you're missing anything. I was just curious about what the actual law said -- and you've led me to that (thanks).

For trash it is 33 CFR 151.59. Note that there are additional requirements for operating on the Great Lakes, so loopers beware.

For oil it is 33 CFR 155.450.

If the operator has a card mounted I don't believe he will be fined with enough of a penalty to hire an attorney. Perhaps just a warning and the next guy to examine might not have the sane interpretation of the regulation.

Greetings,
Mr. B. "...the sane interpretation..." Freudian slip?

RT

Yes, of course, I intended that. LOL. In college I once made a six bank shot that I called but my friends had hearing loss. ��

Thanks for your observation.

Mine is old. Are you supposed to keep these up to date ?

Greetings,
Mr. PM. Have the regulations changed?

RT is on a roll!

Greetings,
Mr. B. Nope. I was serious. Given the propensity for regulations to change, an out of date requirement/installation may not be passed by an overzealous enforcement person. So a fine may be levied instead of just a warning...

Wifey B: A new yacht owner was complaining about the placards on his yacht. He said, "I want my yacht to be like a five star hotel, not with some %^#&# sign on the wall." The builder looked at him a moment and then asked, "When was the last time you stayed in a five star hotel?" He said, "I'd have you know I stayed in one last night." The builder said, "I thought you probably did. Did you not notice the placards on the back of the door with the room rate and the fire instructions and check in and check out times, all on paper stuck in plastic, and not nearly as nice as your placards?" That was the end of the discussion. :lol: