As promised during the 4th Annual BWMTechnology North America Conference in September, USCG will launch a new ballast water series on November 27 from the Assistant Commandant for Prevention Policy, Rear Adm. John Nadeau.
Staff from the Coast Guard’s Office of Operating and Environmental Standards and the Marine Safety Center attended the 4th Annual Ballast Water Tech North America conference in Miami in September and provide conference goers with the latest USCG information on ballast water management system (BWMS) regulations and compliance.
Speaking in the conference, Regina Bergner from Coast Guard Headquarters explained that the Coast Guard has begun transitioning from program implementation to compliance enforcement, as the USCG is setting up the type approval and the alternate management system (AMS) program, and certifying independent labs.
After Ms. Bergner mentioned that ballast water should be viewed as any other type of pollution, she reminded the audience that the regulation requires ship operators to notify the nearest Coast Guard Captain of the Port (COTP) if they find their BWMS is inoperable.
She also added that the Coast Guard recommends the vessels to notify the Captain of the Port to which the ship is headed, because that port may have different conditions of entry.
“If you request an extension, we want to see an evaluation of why each of the type approved systems is not acceptable for your vessel, and we also want to see your strategy for compliance,” Regina Bergner said.
Bergner also discussed the various efforts underway to provide the maritime community more guidance for compliance, which include the following:
- Rear Adm. John Nadeau is planning an upcoming blog series for Maritime Commons to address many of the topics raised before and during the conference.
- A new Navigation and Vessel Inspection Circular in development that will replace the 2004 NVIC and provide guidance to Coast Guard and operators on recommended measures to implement and comply with the new regulations.
- The Coast Guard published CG-CVC Policy Letter 17-05 “Guidelines For Voluntary Compliance With The International Convention For The Control And Management Of Ships’ Ballast Water And Sediments, 2004,” that provides guidance to U.S. flagged vessels on how to comply with the IMO ballast water convention when on international voyages.
From her part, Lt. Maria Wiener, fromthe Marine Safety Center (MSC), outlined the four components of the U.S. type approval process:
- Design and engineering standards,
- Independent Laboratory certification,
- The testing program, to include land-based biological efficacy, shipboard operational trials, and component testing,
- Application review.
Continuing Ms. Wiener said that MSC looks for the presence of several primary documents and records, such as completed type approval checklist, content requirements of 162.060-14a, scaling verification documents, validation of biological or water quality parameter augmentation, and quality control records.
“When we receive a letter of intent from a manufacturer, we always reply back with a letter in return and provide an application checklist. I encourage you to fill in that checklist as thoroughly as possible, because it’s very helpful to the MSC as it provides us a good reference point,” Lt. Maria Wiener concluded.
