As the US is not a party to BWM Convention, vessels in US waters should comply with the requirements of 33 CFR 151 Subparts C and D, as applicable.

Key points discussed include:

  1. A vessel that has not passed its compliance date and has an inoperable BWMS may use one of the others BWM methods outlined in 33 CFR 151.2025(a).
  2. If the vessel is unable to comply with 33 CFR 151.1510(a) or 33 CFR 151.2025(a), the person directing the vessel movement must ensure that the inoperable BWMS is reported to the nearest COTP or District Commander as soon as possible.
  3. The regulations in 33 CFR 151 Subparts C and D provide an exhaustive list of options for ships subject to these regulations for non-safety related situations.
  4. While 33 CFR 151.1515 and 33 CFR 151.2040 require the person directing the vessel movement to report the inoperable BWMS to the nearest COTP or District Commander, the USCG recommends the person also contact the COTP at the next port of call, if different than the nearest COTP, as soon as practicable.
  5. A lack of consumables that render a BWMS inoperable does not meet the intent of "stops operating properly" as used in 33 CFR 151.1510 or 33 CFR 151.2040 and will not be justification to employ alternative management method.
  6. Submitting a BWM report to NBIC does not fulfill the requirement to notify the COTP.
  7. A vessel passed its compliance date and reporting inoperable BWMS for the first time may be allowed to use BWE in lieu of using BWMS, provided the COTP is notified in advance and the BWE is acceptable to COTP.
  8. When entering the deficiency into MISLE, the USCG unit should ensure that both the deficiency and a MISLE Special Note are created.
  9. Any vessel past its compliance date must repair BWMS before returning to US after sailing foreign if the BWMS is the vessel's primary BWM method.

Vessel operators must maintain the BWMS onboard in accordance with the manufacturer's specifications, 33 CFR 151.2025(a)(1). The also must train the master and crew on application of BW and sediment management and treatment procedures, 33 CFR 151.2050(h). For the BWMS to operate reliably, they must be used regularly be crews trained to use BWMS. USCG also encourages vessels to use BWMS regularly even if not bound to or departing from US.

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This policy letter does not address situations where the inoperable BWMS is the result of an emergency situation caused by weather, vessel casualty, flooding.

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