AMO Currents - U.S. Coast Guard: A closer look at ballast water management system compliance date extensions

AMO Currents - Posted: March 15, 2018

U.S. Coast Guard: A closer look at ballast water management system compliance date extensions

The following is excerpted from an article posted on the U.S. Coast Guard's Maritime Commons Blog on compliance date extensions for ballast water management systems and NVIC 01-18, which includes the following statement: "This circular is to inform the maritime industry and Coast Guard personnel and provide guidance to ensure a more complete understanding of, and maximum compliance with, ballast water management requirements." The complete article is available online.

The Coast Guard recently published Navigation and Vessel Inspection Circular (NVIC) 01-18, "Ballast Water Management For Control Of Non-Indigenous Species In Waters Of The United States." The purpose of this blog is to highlight guidance provided in NVIC 01-18 regarding requests for compliance extensions in accordance with 33 CFR-151.1513 or 33 CFR-151.2036.

Vessel owners and operators are reminded that there are several acceptable methods for managing ballast water listed in 33 CFR-151.1510 or 151.2025. For vessel owners and operators choosing to install a Ballast Water Management System (BWMS), there are six Coast Guard type approved BWMS at this time. The type approved BWMS cover nearly all classes of vessels and are compatible with a broad range of operational requirements.

Per 33 CFR-151.1513 or 33 CFR-151.2036, vessel owners/operators may request an extension of the vessel's compliance date. The Coast Guard will typically grant an extension to a vessel's compliance date only in those cases where the master, owner, operator, agent, or person in charge of a vessel can document that, despite all efforts, compliance with the requirements under 33 CFR-151.1510 or 151.2025 is not possible. Documentation that establishes this need may include information why existing type approved BWMS are not compatible, are unavailable or cannot be installed before the compliance date. In the last instance, the supporting information may include proof of acquisition of a type approved BWMS, and installation on a specific date. In general, extensions will not be granted for more than 12 months from the vessel's current compliance date.

No extensions will be granted to a vessel with an installed alternate management system (AMS) and no extensions will be granted to install an AMS. However, the Coast Guard will consider granting extensions to vessels that intend to install a BWMS that is expected to receive type approval in the near future. These requests should include specific documentation clearly indicating the system is expected to receive Coast Guard type approval within 12 months of the vessel's current compliance date. Documentation should include proof from the manufacturer or independent lab that shows they have applied for Coast Guard type approval, proof of acquisition of the BWMS, and proof of arrangements for installation on a specific date not to exceed 12 months from the vessel's current compliance date.