The final letter includes the intent of the 2012 Ballast Water Management regulations, and provides guidance to BWMS manufacturers and testing facilities.
Moreover, it provides clarification as the regulations do not specify criteria for the use of multiple Independent Laboratories (ILs). The specific provision requires the manufacturer to identify, in the Letter of Intent, any associated test facilities and subcontractors.
It is highlighted that
For the initial type approval certificate, the manufacturer of a BWMS may use multiple ILs to conduct BWMS type approval testing.
Yet, a BWMS manufacturer must use one IL to coordinate and oversee all testing and reporting. This ensures consistency and provides a holistic understanding of the system’s performance.
For amendments to the type approval certificate, the manufacturer of the BWMS will follow the requirements for any changes to an approved BWMS. This also includes notifying the Coast Guard’s Marine Safety Center (MSC).