This is the fifth post in a six-part series of blogs on Maritime Commons to provide updates and information about the Coast Guard’s ballast water regulations and implementation.
I look forward to sharing this information with you as we work hard to protect the environment while ensuring the safety and security of the marine transportation system.
From the desk of Rear Adm. Paul Thomas, assistant commandant for prevention policy
In this blog I’ll describe the U.S. type-approval process. There are two pathways available for manufacturers to receive type-approval for their systems: an existing data review and type-approval testing.
Existing data review
Manufacturers considering an application for U.S. type-approval may use test data generated during foreign type-approval testing in accordance with the International Maritime Organization’s G8 guidelines if that prior data and testing meet the Coast Guard requirements in 46 CFR 162.060. Sometimes additional testing will be required because the IMO protocols differ from the U.S. protocols. It may be possible to significantly reduce the time and cost of U.S. type-approval through the use of data obtained in the course of foreign type-approval. The following chart shows the sequence of events manufacturers should follow to utilize this option.
Manufacturers and independent laboratories, or ILs, may send existing data review inquiries by email to U.S. Coast Guard, Systems Engineering Division, or CG-ENG-3, using the address: typeapproval@uscg.mil
Type-approval testing
The second option available to manufacturers is to enter directly into the type-approval process without the use of previously generated data. The type-approval process begins when the manufacturer contracts with an IL for evaluation and testing in accordance with 46 CFR 162.060. Prior to beginning formal land-based or shipboard tests, the manufacturer submits a letter of intent to the Coast Guard expressing its intention to start testing its ballast water treatment system. The following chart shows the sequence of events manufacturers should follow to utilize this option.
Manufacturers and ILs may submit their letter of intent by email to U.S. Coast Guard Marine Safety Center using the address: MSC@uscg.mil
Additional information on the type-approval process is available at the Marine Safety Center’s ballast water management system website. See in particular the relevant documents posted under “FAQs” (frequently asked questions). In the next blog, I’ll discuss some of the challenges associated with the type approval process.
Current status
Currently, manufacturers have filed 30 letters of intent with the Coast Guard, expressing their intention to start testing a ballast water treatment system. The Coast Guard estimates about half that number are presently at some stage of testing with one of the five approved ILs.
Independent laboratories have indicated that the test facilities are booked through the end of 2015 and for most of 2016 (plans and schedules change, so interested manufacturers should contact an IL directly regarding the availability of ‘testing slots” in the IL schedule). Ballast water management systems, or BWMS, type-approval procedures and tests are described in 46 CFR 162.060, along with requirements for approval of test organizations as ILs.
Look out for my next blog regarding U.S. type approval challenges.
Read the six-part ballast water series:
Part 1: Ballast water series from the Assistant Commandant for Prevention Policy
Part 2: Shedding some light on 2012 ballast water regulations
Part 3: Ballast water – U.S. Regulations compared to International Convention
Part 4: Living vs. viable
Part 5: Ballast water type approval process
Part 6: Ballast water type approval challenges for industry
This blog is not a replacement or substitute for the formal posting of regulations and updates or existing processes for receiving formal feedback of the same. Links provided on this blog will direct the reader to official source documents, such as the Federal Register, Homeport and the Code of Federal Regulations. These documents remain the official source for regulatory information published by the Coast Guard.
