Testing to USCG is all about doing your homework before you start. Several makers have started testing for USCG Type Approval and got aborted. They realised that their system needed changes so as to be able to meet the requirements. After making these changes, they have lined up for new tests. Many changes have been made to filter with higher grade of filtration, to electrolysis systems with higher of oxidants levels which again require more power and to UV systems with more UV exposure to the species also requiring more power.
USCG has a long-established USCG program for type approval of ships’ equipment. While making this program they started looking into what has IMO done so far and then they incorporated the EPA and the Environmental Technology Verification (ETV) program in the test protocols which is different from IMO.
The test facilities have to be totally independent places and also to be independent of BWMS vendors and manufacturers. Also they must have the capability and ability to conduct and follow the ETV test protocols and rigorous QA/QC programs.
The basic requirements from IMO and USCG are actually the same. However, there are some differences.
Concerning the specified species in the list below, IMO requires the rest of the species to be dead or viable , meaning that they cannot reproduce. From the other hand, USCG requires the rest of the specified species to be dead. This little difference has started the dispute between USCG and BWTS makers using UV. There are also differences when it comes to water qualities upon different limits. IMO requires salinity levels slightly different from the USCG. USCG is much more restrictive and they define fresh water really close to potable water. Brackish water is a little bit different from what IMO is claiming. Furthermore, there is a difference between fresh and seawater species. USCG actually tests fresh water species which look like quite different from each other and some of them are really hard to kill.
Additionally, there are also some key areas between USCG and IMO, which differ in the way they test such as in holding time, in the number of sea tests, in the way they report tests. For instance, IMO can carry out sea tests eight times but only the successful ones are reported. In USCG, everything is reported and you can really read everything that system has performed right after the moment that somebody has the approval of USCG to perform sea tests. Testing under USCG also differs in key areas from IMO. All is done by a certified Ιndependent Laboratory. USCG Type Approval covers both design and efficacy while IMO Type Approval only covers efficacy. USCG Type Approval efficacy matches IMO
According to USCG Final Rule, all new-buildings after Dec 1st 2013 must have a BWTS on delivery and all existing ships (keel laid before EIF) must install on their first scheduled DD after Jan 1st 2016. USCG has been issuing extensions until January 2018, but still there is no system been approved. However it looks like it is coming.
Above text is an edited article of Leif Eric Caspersen presentation during the 2016 GREEN4SEA Conference & Awards.
You may view his presentation by clicking here
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The views presented hereabove are only those of the author and not necessarily those of GREEN4SEA and are for information sharing and discussion purposes only.
About Leif Eric Caspersen, International Sales Director ERMA FIRST
Leif Erik Caspersen is the International Sales Director of ERMA FIRST. He is specialized in Business to Business marketing and industrial sales. He has worked for several years in marketing and selling products to the offshore and land based industry. During the past 20 years he has been actively involved in the marine pints and coating business . He acted as the Vice President and Chairman of Jak. J. Alveberg AS, one of the oldest paint companies in Norway, promoting specialized coatings designed for refurbishing of ballast tanks on older ships, among many other applications . As the Managing Director in Orca Maritime AS, a company specialized in innovative and long lasting solutions for corrosion protection , he succeed in introducing products for offshore installations, hull and superstructures on ships. Since 2006 , he has been actively involved in the ballast water treatment industry promoting systems all over the world. Since 2014 , he joined the ERMA FIRST team, leading the international sales division.