Page 9: of Maritime Reporter Magazine (August 2005)

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

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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.

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