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Updated 24 January 2017

The US Coast Guard has now issued a number of type approval certificates for ballast water management systems and has further clarified the implications for vessel owners and operators.

The first “US Type-Approval Certificate” for a ballast water management system (BWMS) was issued on 2 December 2016 to the manufacturer Optimarin AS. In conjunction with this approval, the US Coast Guard (USCG) published a Marine Safety Information Bulletin (OES-MSIB 14-16) which provided advice on the impact of the type approval with respect to the existing extension program, vessel compliance dates and use of alternate management systems (AMS). It was announced on 23 December 2016 that a further two manufacturers, Alfa Laval Tumba AB and OceanSaver AS, had received US type approval certificates for their BWMSs. The USCG has therefore published additional advice concerning extension applications in order to reflect that a number of type approved systems are now available.

A vessel’s current compliance date, also if this is an extended compliance date, will not be affected by the availability of type approved systems. The USCG also emphasises that, although a number of type-approved BWMSs are now available, it will continue to accept requests for extensions if compliance with one of the approved ballast water management methods under 33 CFR 151 (Subparts C and D), including installation of a US type-approved BWMS, is not possible.

Members and clients with vessels operating in US waters are advised to review the clarifications provided in OES-MSIB 14-16 of 2 December 2016 and the Highlights and Tips for Applications document revised as of 23 December 2016 and note that:

  • Requests for an extension must now be accompanied by an explicit statement, supported by documentary evidence, that installation of a type approved BWMS is not possible (e.g. vessel design limitations preclude installation of type approved systems, commercial unavailability etc.). Only the current version of the application spreadsheet should be used.
  • Applications already submitted to the USCG must also be supplemented with documentary evidence as to why installation of a type approved BWMS is not possible.
  • Applications should be submitted 12-16 months before a vessel's compliance date. This applies to applications for both initial and supplemental extensions.
  • Batch applications are no longer permitted as vessel-specific justifications are required. Each application must be submitted in separate emails.
  • Existing extension letters granted by the USGC will remain valid until the extended compliance date in the extension letter.
  • Any vessel with an AMS will still be allowed to use that AMS for up to five years after its compliance date, see also USCG’s Policy Letter 13-01 and our Gard Alert of 14 July 2016. If an extension has been granted, the start of the five-year period can be based on the vessel’s extended compliance date.

To prevent delays to vessel schedules, Masters should keep BWM records onboard the vessel and immediately available for review by USCG officials. Such records may include, but are not limited to, BWM plan, current extension letter granted to the vessel, vessel certificates, contracts and/or records verifying the date the vessel entered its last dry dock, BWMS installation documents, and vessel log books.

Where to find up to date information:

Information and documents relating to the US Coast Guard ballast water management program can be found at: http://homeport.uscg.mil/ballastwater. For a copy of Policy Letter 13-01, the latest version of the application spreadsheet and the document with highlights and tips for extension applications, please go to the item “Extended Compliance Dates - Application, Guidance, and Approved Vessels” in the “Regulations and Policy Documents” sub-folder on the above website. A new “Frequently Asked Questions – Extensions after USCG Type Approval” is also available in the “FAQs” sub-folder on the website.

Information on regulatory updates are also provided via the blog Coast Guard Maritime Commons and we particularly recommend the article “Ballast water management – Beyond type-approval” published on 24 January 2017. For those still in the process of planning the installation of a ballast water treatment systems, key elements of the preparatory work is highlighted in our Gard Alert “Prepare to manage ballast water“.