From the desk of Rear Adm. Paul Thomas, assistant commandant for prevention policy
In November 2015, my staff published CG-OES Policy Letter 13-01, Revision 2, which provided guidance to vessel owners and operators seeking to extend compliance dates for implementing ballast water management (BWM) methods. It also cleared up much confusion surrounding the term “compliance date” by creating two different categories of compliance date: “original compliance date” and “extended compliance date.”
Since the publication of the new policy, the Coast Guard has granted nearly 6,000 extensions, surpassing the number of all previous extensions by over 200 percent. My staff continues to communicate with maritime stakeholders at conferences, conventions, and within the IMO to address the myriad complex challenges that surround regulation of ballast water. One of these issues concerns the use of alternate management systems (AMS) onboard vessels that have chosen to install them as ballast water management systems (BWMS).
The AMS provision allows proactive shipowners who have already installed BWMS onboard their vessels, to continue using them until Coast Guard type-approved systems become available. In order to qualify for Coast Guard acceptance as AMS, the systems must first be approved by foreign governments under the standards set forth in the International Convention for the Control and Management of Ships Ballast Water and Sediments, and the Coast Guard must determine that the BWMS is at least as effective as ballast water exchange. As of the date of this publication, the Coast Guard has determined that 58 BWMS have met the criteria for acceptance as AMS.
The U.S. regulations permit the use of an AMS for up to five years after the vessel is required to comply with the ballast water discharge standard. CG-OES Policy Letter 13-01, Revision 2, did not specify to which compliance date category the AMS provision applied. As a result, many shipowners were left wondering if their installed AMS could be used for five years from their “original compliance date” or from their “extended compliance date.” An installed AMS can be used for five years from the “extended compliance date” if the AMS is installed prior to the expiration of the vessel’s extended compliance date.
Additional discussion on this and other Coast Guard AMS policy interpretations are provided in CG-OES’s Marine Safety Information Bulletin OES-MSIB 10-16.
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.