MARPOL enforcement cases in the US historically have involved violations of Annex I, such as oily water separator bypasses and falsified oil record books (ORBs), coupled with post-incident misconduct by crev members, such as destroying/altering records or lying to the US Coast Guard (USCG). While these cases are likely to continue (as they have for three decades), we also expect enforcement authorities to target Annex VI violations. The US brought the first Annex VI criminal case in 2019. That case is likely to be a bellwether, particularly now that the worldwide sulphur cap of 0.50% and carriage ban are in effect. Ship owners/operators must ensure compliance with Annex VI, which includes comprehensive training for crew on policies, procedures, and recordkeeping requirements, to avoid becoming a target during the next US port call.
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