What is an operational review and why do I have to do it? 

  1. Federal regulation 33 CFR 154 Subpart P, published in 2013, set the requirement that all marine vapor control systems (MVCS) must undergo an operational review (OR) by August 15, 2016.
  2. If your MVCS was commissioned between August 15, 2011 and August 15, 2016 then your system must undergo an OR before the five-year anniversary of your initial certification date.
  3. 33 CFR 154.2021 further states that after the initial review to be completed by 2016, or within 5 years of initial certification, all facilities must undergo an operational review every five years.

My system needs an operational review. How do I go about getting one and what can I expect from the process?

  1. First, you will need to contact a United States Coast Guard (USCG) approved certifying entity (CE) to schedule your OR. Aura Engineering has been a USCG certifying entity since our inception in 1996 and would be pleased to help you through the OR process. 
  2. Once your OR is scheduled, the certifying entity will request certain, specific documentation be sent over for review. Aura can provide a list of all required documentation upon request.
  3. After the certifying entity completes the in-house documentation review, they will schedule a visit to your facility to test the appropriate systems and witness a live load to ensure the system is compliant with current regulations.
  4. Once on-site testing is complete, the CE will provide the appropriate documentation to both the USCG and the client. 

I know my facility needs an operational review, but I’m worried we may have to address a few items before we’re ready for it. What should I do?  

  1. Never fear! This is a common occurrence and we have a solution for clients who may need a review before the review to help ensure compliance.
  2. Aura Engineering offers Pre-Operational Review Gap Analysis services to address this type of situation. 
  3. During the Pre-Operational Review Gap Analysis, our technical personnel put your MVCS through the same tests that will occur during the OR. Following these on-site tests, Aura will provide a findings/recommendations report that details any maintenance services and equipment that your MVCS needs. 
  4. Once recommendations are made, our service and equipment procurement teams will quickly get to work preparing your system for its OR. 
  5. After providing gap analysis services, Aura can no longer be the certifying entity on record for your operational review. Instead, for the ease of our clients, we will remain your point of contact and schedule another trusted certifying entity to come out and complete the OR. 
  6. Our Pre-Operational Review Gap Analysis services have saved our clients valuable time and money by ensuring that their systems are compliant prior to their OR.

How is an operational review different from a recertification? 

  1. An OR is a complete review of your system. We check all documentation, test every alarm and shutdown, and witness a live vessel load. 
  2. Conversely, recertification is just a review of a specific change to your system. If you do not have an operational review letter from your certifying entity, your system is out of compliance.

How is this different from the annual testing my system undergoes? 

  1. The certifying entity must witness testing and a live load. 
  2. In addition to witnessing a live load, there are many other tests required for the operational review that are not necessary for annual testing.

Our next OR isn’t due until 2021. Why worry about it now? 

  1. 2021 is five years after the 2016 deadline for initial ORs. This means 2021 will be extremely busy as everyone will be trying to get their ORs done at the same time. As there are only a finite number of USCG approved certifying entities, it is important to be sure your system is on one of their schedules to make sure your MVCS is always in compliance. 
  2. Give Aura a call today to go ahead and get the ball rolling. We can get ahead of the game by preparing your quote and getting you on the 2021 schedule.


The applicable regulations are: 33 CFR 154.2020-2025