August 2005 9
In this age when it seems like every-
thing related to ships has been regulated
to an extreme, it comes as a surprise to
learn that there are no general regula-
tions relating to potable water on U.S.
vessels. That is about to end, as the
Coast Guard initiates a rulemaking proj-
ect to establish such standards.
Rulemaking project
The project seems to have begun with
a 2002 letter from the Gulf Coast
Mariners Association petitioning the
Coast Guard for a rulemaking. The let-
ter complained of the poor quality of
drinking water on some of the vessels
manned by members of the Association.
It pointed out that the Coast Guard has
general superintendence over the mer-
chant marine and one of the agency's
missions is to look after seamen's wel-
fare.
In 2004, Congress amended the vessel
inspection law to provide that, for U.S.
vessels subject to inspection, the inspec-
tion process shall ensure an adequate
supply of potable water for drinking and
washing by passengers and crew. In
determining the adequacy of the supply
of potable water, the Coast Guard is to
consider: (1) the size and type of vessel;
(2) the number of passengers and crew
on board; (3) the duration and routing of
voyages; and (4) guidelines recom-
mended by other federal agencies.
On July 11, 2005, the Coast Guard
issued a notice soliciting public input on
this issue. Comments should be submit-
ted by September 9. In addition to the
statutory requirements, the agency
would like comments on: (a) other fac-
tors that should be considered in deter-
mining the amount of potable water that
should be available on a vessel; (b)
design practices and policies used for
potable water systems on vessels; (c)
periodic water tests conducted on ves-
sels to determine continued potability;
(d) protocols or test methods used for
testing; and (e) industry standards that
could be applied to the design and test-
ing of potable water systems on vessels.
Vague Definition
The word "potable" is defined as "fit
to drink" and is as accurate as it is con-
cise. The word is derived from the Latin
word "potare", meaning "to drink".
Thus, potable water is water that is fit to
drink. The problem is that, like pornog-
raphy, you may know it when you drink
it, but it is difficult to write a regulation
setting enforceable standards regarding
potability.
Standards and Guidelines
While there currently are no general
U.S. regulations regarding potable water
on U.S. vessels, that does not mean there
is no available guidance. There is actu-
ally a wide variety of guidance docu-
ments available for adaptation into
appropriate regulatory format.
The U.S. Centers for Disease Control
and Prevention (CDC) issues guidelines
on sanitary issues related to construction
and operation of large passenger ships.
These guidelines are applicable to the
cruise ships (mostly foreign flag) that
embark passengers at U.S. ports and
may have limited applicability to non-
passenger ships. The Food and Drug
Administration (FDA) has promulgated
regulations regarding the source and use
of potable water on conveyances
engaged in interstate traffic. Portions of
those regulations apply to vessels, but
they provide few specifics. Under the
Safe Drinking Water Act, the
Environmental Protection Agency
(EPA) has issued regulations and guid-
ance regarding standards for safe drink-
ing water and maximum contaminant
levels for drinking water. The EPA stan-
dards are focused on municipal water
sources and similar land-based water
3330, Av. Francis-Hughes Fax: 450-663-7774
Laval, Canada, H7L 5A7 e-mail : info@genirosys.com
Geniro Systems Inc. is ready to be your Systems Integrator for:
• Integrated Power Generation and Distribution
Integrated Automation Systems
Refits and Upgrades of existing Electric and Automation Systems
Power Management Systems
Alarm and Monitoring Systems adapted to any new or existing ship
Data Management Systems
Ballast and Bilge Automation Systems
Switchboards, MCC's and Distribution Panels
Consoles, Control Panels, Control Cabinets.
Etc…
For all these systems we provide Design, Engineering Drawings, Engineering
Studies, Manufacturing, Installation, Commissioning and Service.
www.genirosystems.comGENIRO SYSTEMS Inc. Tel: 450-663-4447
Circle 256 on Reader Service Card
Circle 220 on Reader Service Card
ENGINEERING +EXPERIENCE =AWINNING TRADITION
™
The LEADER Since 1939
Sliding Watertight Doors and Custom Closures
Walz & Krenzer, Inc.
91 Willenbrock Rd., Unit B4, Oxford, CT 06478 • www.wkdoors.com
Tel: 203-267-5712 • Fax: 203-267-5716 • E-mail: sales@wkdoors.com
Government Update
Potable Water
Dennis L. Bryant, Senior Maritime
Counsel at the law firm of Holland
& Knight, Washington, D.C., is a
contributing editor of MR/EN.
MR AUGUST 2005 #2 (9-16).qxd 8/4/2005 4:47 PM Page 9
Digital Wave Publishing