A circular and a series of online posts reveal a new US approach to implementing USCG ballast rules
In March, the US Coast Guard (USCG) issued a revised Navigation and Vessel Inspection Circular, NVIC 01-18 that fundamentally changed how it views requests for extensions to compliance dates under its ballast water management requirements. The circular replaced an earlier version issued in 2004.
One of the circular’s main implications is that compliance extensions for ballast water management systems (BWMSs) now require additional documentation. A follow-up posting on the USCG’s online blog Maritime Commons, dated 7 March, said that 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 USCG will consider granting extensions to vessels “that intend to install a BWMS that is expected to receive [USCG] type-approval in the near future,” it said.
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 an 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.”
Another significant topic addressed in the 35-page NVIC relates to ships with inoperable BWMSs. It includes a section covering the situation when a BWMS “stops operating properly or the BWM method is unexpectedly unavailable” and advises, among other things, that a BWM method “that was unavailable on a previous voyage and remains unavailable is not considered ‘unexpectedly unavailable’”.
In its blog post, the USCG also reminded vessel owners and operators “that there are several acceptable methods for managing ballast water listed in 33 CFR 151.1510 or 151.2025”. Those references relate to the relevant sections of the US Code of Federal Regulations that set out US BWM requirements. The USCG told LNGWS in a statement that it expects “shipowners and operators to read and become familiar with … 33 CFR Part 151, Subparts C and D if vessels they own or manage trade with the US”.