The North P&I Club says that US is ‘getting tough’ on Ballast Water extension according to local sources which indicated that USCG officers focus on BWM compliance issues during their routing PSC inspections. The Club advises that all ships calling at US ports and intending to discharge ballast water must either carry out ballast water exchange or treatment, in addition to fouling and sediment management.
Up to now, USCG has granted type-approval to three BWTS while a further two systems are currently awaiting USCG type-approval. Several more are currently undergoing type-approval testing. The availability of type approved systems has led to the USCG taking a much more robust approach to granting an extension. The USCG will no longer automatically consider that a ship cannot comply with the discharge standards. Additional justification and reasons need to be provided, which the USCG will consider before granting an extension.
When considering a request for extension, the USCG will pay particular attention to how the Shipowner matches the profile of those vessels that have already been fitted with a USCG type-approved system. The USCG will also require the Shipowner to provide a detailed strategy and timeline to come into compliance.
The Club provides examples of additional documentation needed for an extension request:
- Written correspondence between the Shipowner and the applicable BWM systems manufacturer(s) that confirms there are no available systems for installation on that type or class of vessel until after the compliance date.
- Vessel has design limitations with type-approved BWM systems that are currently available.
- Safety concerns related to installing type-approved BWM systems currently available.
- Any other situation that may preclude a vessel from being fitted with a type-approved system.
USCG inspectors have reported that the most compliance issues apply to : Discharging ballast water with expired extension letters; Inoperable AMS; Operating past compliance date with no extension or AMS; Discharging untreated BW in US water ; Inaccurate BWM records. The North P&I Club reminds that (NVIC) 07-04 CH-1 details a range of enforcement measures available to USCG inspectors.
