Seabulk Tankers, Inc.

The Federal Resource Conservation and Recovery Act (RCRA) as well as state RCRA programs apply to commercial vessels and create a tremendous disincentive to dispose certain types of waste ashore. These regulations do not go into effect until the wastes leave the vessel, at which time, the owner/vessel would be required to meet the following: Obtain a generator ID number (generally one for each state) comply with US standards for the management of hazardous waste and use hazardous waste manifests for shipments to disposal facilities. Vessels will also have to manage 'Universal waste' which includes floureescent and mercury vapor lamps, mercury containing thermostats and batteries. Universal wastes are subject to the RCRA universal waste regulations. State RCRA programs must be at least as stringent as federal regs, but states can adopt more stringent requirements. This makes it very difficult for vessels to be able to understand the regulatory requirements. Again, the fear of most vessels of the possibility of not complying with regulations they cannot understand or know is a tremendous disincentive to send garbage ashore. In addition to MARPOL requirements in 33 CFR APHIS requirements in 7 CFR and RCRA requirements in 40 CFR must be complied with.