Due to the major disruptions in the supply chain and workforce that COVID-19 has resulted, USCG understands that owners and operators may find it difficult to be in line with the Coast Guard Ballast Water Management Regulations set forth in Title 33 of the U.S. Code of Federal Regulations (CFR), Part 151, Subparts C and D (33 C.F .R . 151 Subparts C and D).
In light of the lockdown situation and the "Do Not Travel" orders resulting in closed country borders, closed drydocks, equipment/parts being downed warehouses and unable to be shipped, minimal international flights impacting technicians’ travel to locations where ships are drydocked, limited port or drydock availability, and social distancing requirements, the Coast Guard decided to extend the BWTS compliance dates before 1 April 2021.
In fact, USCG noted:
The Coast Guard is adjusting its extension policy, as shown below, for those vessels impacted by the COVID-19 pandemic with BWTS compliance dates before 1 April 2021, recognizing the impact of public health policies and the importance of a the continued flow of commerce in our Maritime Transportation System.
Moreover, the Coast Guard estimates that the installation and commissioning of BWTS will be completed as scheduled for any vessel which conducts a credit drydock (inspection of the outside of the ships bottom) before 1 April 2021.
In cases where the COVID-19 pandemic has affected the vessel's ability to perform all the necessary or scheduled work, the following guidance concerning an extension is provided:
- The Coast Guard will extend all compliance dates up to 12 months upon request. There is no need to provide any supporting documentation, however vessel owner or operator will need to identify the vessels in order for the Coast Guard to adjust the necessary documentation. It should be understood that this is not an interim extension, and additional time to accommodate operational or regulatory schedules should not be expected. For ships that undergo a credit drydock but cannot complete installation of a BWTS, owners and operators are encouraged to complete as much work as possible during the credit drydock to avoid the need for future drydock availability.
- In those instances where an extension of more than 12 months is needed, the master, owner, operator, agent, or person in charge of a vessel may request an extension in accordance with 33 CFR 151.2036. Requests for more than 12 months should include: a) Documentation that a system was purchased, and arrangements were made to have it installed. As is normally provided in extension requests, contractual documents or third party correspondence that include the previously arranged date and location of installation is adequate. b) Documentation that the system could not be installed due to COVID related restrictions. Please include third-party documentation, typically from the drydock facility or BWTS manufacturer. c) The plan for installing the system, including a list of previously performed and scheduled work, and an estimate as to when and how installation and commissioning will be completed.
In instances where arrangements were made to convert an Alternate Management System (AMS) to a Coast Guard type approved system, but the conversion was not completed due to the pandemic, an extension may be requested to continue operating the AMS under 33 CFR 151.2026(c) until the conversion can be accomplished. As noted above, requests for an extension longer than 12 months should provide details and third-party verification(s) that the arrangements for bringing a vessel into compliance were previously made but not possible due to the COVID-19 pandemic.
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