The United States Coast Guard (USCG) has issued new guidelines for bunkering of liquefied natural gas (LNG) and other alternative marine fuels, stressing that no transfer can proceed without a prior risk assessment. The USCG explains that these guidelines aim to close gaps in existing regulations, which largely address traditional petroleum-based fuel.
On July 24, 2025, the U.S. Coast Guard issued Policy Letter No. 01-25, establishing a uniform, risk-based safety framework for all bunkering operations in US waters involving LNG and alternative marine fuels, such as: methanol, ammonia, hydrogen, and LPG. This policy replaces earlier LNG-specific guidance from Policy Letters 01-15 and 02-15.
The policy requires vessel owners and operators to work with the fuel supplier who will submit a bunkering proposal and a risk assessment plan for review by the Captain of the Port (COTP) prior to any bunkering activity. This must be submitted in adequate time for review before the operation. The plan must include:
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Information of the fuel to be delivered
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Anticipated date ranges
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Location and facilities
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Details of the companies involved
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Technical details of the vessels
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Proposed participants in the risk assessment process
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Risk assessment methodologies to be used (recommending ISO/IEC 31010)
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Qualifications and training of personnel directly involved in the operation
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Operational assumptions and any pre-identified hazards
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Hazards associated with:
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Mooring, docking, or anchoring
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Connection and testing (including compatibility assessment)
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Fuel transfer operations (including pressure management and vapor return)
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Completion and disconnection
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Protection of critical infrastructure, waterways, personnel, and the environment
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Port emergency response capability
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Simultaneous operations (SIMOPS)
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The COTP has enforcement authority to issue orders halting operations if the assessment is not submitted in time or if operations deviate from the approved plan.
Whilst the guidelines specifically mention it is the fuel suppliers responsibility to submit the documents, the specifics required in the plans require collaboration from the operators and owners.
The USCG advises there is no specific template required for submission. We suggest providing the information in the attached checklist to the fuel supplier during bunkering procurement to help prevent any delays in the bunkering process. Please note that this is a general guide only and should be adapted according to the vessel, fuel type, and port requirements.
Download the checklist here.