Patrick Stephen Unger

I appreciate the opportunity to submit comments, thank you. I understand that USCG is interested in identifying all issues that impact shipping vessels operating in the WCR and obtaining recommendations to address the issues. One issue that leads to confusion is that in US there are different definitions for garbage which effect shipping: one following MARPOL in 33 CFR and another in 7 CFR chapter lll enforced by CBP formerly USDA. Normally, in US, only CBP inspects vessels for sanitary and 'Garbage' violations. When the term 'Garbage' is used by the crew it means operational waste. However, what CBP hears is 'food waste' which is regulated in 7 CFR and must be incinerated or treated adding significantly to the cost of disposal. Many times I have heard CBP inspectors state: "All garbage is regulated!" per the definition in 7 CFR this is correct. Unfortunately, vessel crews do not understand the distinction CBP is making and CBP does not understand or have training in the MARPOl definition for garbage. I have typed the 7 CFR definition below: 7 CFR definition of Garbage: All waste material that is derived in whole or in part from fruits, vegetables, meats, or other plant or animal (including poultry) material, and other refuse of any character whatsoever that has been in contact with any such material. Regulated garbage is: Garbage regulated because of movements outside the United States or Canada. Garbage on or removed from a ship is ‘regulated garbage’, if the ship has been in any port outside the United States and Canada within the previous 2-year period; except, movements to Hawaii, territories or US possessions within 1-year. Waste Material that is commingled with regulated garbage becomes regulated garbage. Recommendation: Change the definition of garbage in 7 CFR and provide training in MARPOL to CBP personnel who inspect ships for USDA compliance. I am out of space so will submit other comments later. Pat Unger