Updated guidance has been issued by the US Coast Guard “to ensure a more complete understanding of, and maximum compliance with, ballast water management requirements,” according to notes published this week (4 March) on the USCG’s online blog.
It refers to a revised Navigation and Vessel Inspection Circular, NVIC 01-18, that replaces one issued in 2004. The new document is “long-awaited”, according to Debra DiCianna, senior compliance engineer at Choice Ballast Systems, writing on a LinkedIn forum.
In an email exchange with BWTT today (8 March), Ms DiCianna explained that one of the circular’s main implications is that compliance extensions for ballast water management systems (BWMSs) require additional documentation.
A follow-up blog posting yesterday addressed extension periods and reminded owners and operators of the situations in which extensions may be granted. But it 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 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 topic that Ms DiCianna highlighted from the 35-page circular relates to ships with inoperable BWMSs, which she said will have increasing difficulty when visiting US ports. The NVIC 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 ballast water management method “that was unavailable on a previous voyage and remains unavailable is not considered ‘unexpectedly unavailable’.”
Ms DiCianna commented that the USCG expects quick repairs on BWMS but said that “many manufacturers do not have well-developed service networks and thus shipowners are struggling with complying with the USCG requirements.”
• The USCG provided specific guidance about inoperable systems in February.