Is a diving inspection required to determine whether there are living organisms on a vessels hull? How does EPA suggest making such a determination without a diving inspection?
A diving inspection is not required by the VGP. As explained in section 6.1 of the VGP Fact Sheet, the permit requires self-inspections for the visible portion of the hull (e.g., those portions that are visible from above the waterline or those portions which are visible when the vessel is in reasonably clear water) for the presence of attached living organisms. However, in accordance with VGP Part 4.1.3 vessel owner/operators must document which portions of the vessel are not inspectable for the annual inspection in their recordkeeping documentation. Discussion In addition, as stated in Part 4.1.3 of the VGP, if any of portions of the vessel hull are not inspectable without the vessel entering drydock, the vessel owner/operator must inspect those areas during their drydock inspection and their results must be documented in their drydock inspection reports.
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