The US Coast Guard recently published a letter to the Coast Guard-accepted independent laboratories (ILs), providing guidance for evaluating manufacturer-identified operational limitations during type approval testing of ballast water management systems (BWMS).
The letter clarifies the responsibilities of the BWMS manufacturer, the USCG-accepted IL, and the Coast Guard, with regard to evaluating and assessing operational limitations of BWMS.
The process for evaluating and assessing operational limitations includes the following general steps:
- The manufacturer identifies relevant limiting conditions or parameters in the required “technical data package” submitted to the IL;
- In coordination with the BWMS manufacturer, the IL reviews, assesses, and as appropriate, identifies additional or missing limitations critical to the operation of the BWMS;
- Based on the manufacturer-supplied BWMS documentation, the IL develops comprehensive test plans for ship-board, land-based, and component testing;
- At the completion of testing, the IL provides the Coast Guard with a ‘Test Report’ as part of the manufacturer’s type approval application;
- The Coast Guard accepts the IL statement of assessment as part of an approved application, and issues a type approval certificate that reflects the manufacturer-identified operating limits.
