DECEMBER 29, 1999

CIRCULAR NO. 19/99

TO MEMBERS OF THE ASSOCIATION

Dear Member:

POLLUTION IN THE UNITED STATES

Recent California Legislation regarding Dry Cargo Ships

Reference is made to Circulars Nos. 4/99, 10/99 and 13/99 of January 29, September 1 and September 23, 1999 respectively.

The Club has been advised that the new regulations in regard to non-tank vessels were recently returned by the California Office of Administration and Law and were filed with the California Secretary of State on December 28, 1999.

As will be recalled by reference to Appendix II of Circular 10/99 dated September 1, 1999, the Administrator of the California Department of Fish and Game, Office of Oil Spill Prevention and Response, originally indicated that the new regulations would become effective at least 30 days after filing with the Secretary of State.

However, because of the holiday schedule and concerns about potential "millennium bug" problems, the Administrator has now set February 3, 2000 as the new effective date.

Accordingly, all non-tank vessels of 300 gross tons or more must have on file a contingency plan and have been issued a California Certificate of Financial Responsibility by February 3, 2000.

The means of achieving compliance have already been described in detail in the earlier Circulars mentioned above, but if any further elaboration is required, the Managers will be pleased to respond.

Yours faithfully,

Joseph E.M. Hughes, Chairman & CEO

Shipowners Claims Bureau, Inc., Managers for

THE AMERICAN CLUB

VAPS X:\IGA\CIRCULR19.99