Maritime Commons received a few questions from our Twitter followers regarding the Ballast Water Management System type approval certificate issued to Echoclor Ltd., Aug. 11, 2017. In order to be as transparent as possible, we are sharing the answers to those questions through the blog in the event other readers have the same questions. We encourage you to submit questions or comments on any Maritime Commons content in the comment section below, through our Twitter feed @maritimecommons, or directly to any point of contact listed in the post.
1.Why is Echoclor permitted a 0.2mg/L MADC when clearly the rule is 0.1mg/L?
Table 3 of the 2013 VGP identifies the maximum ballast water effluent limits for residual biocides in discharged ballast water. There is a difference between chlorine dioxide, where the maximum allowable discharge concentration (MADC) is 200 micrograms/L (0.2 mg/L) and chlorine which has an MADC of 100 micrograms/L (0.1 mg/L).
2. Does the decreased dose from 5 to 4.25 affect the IMO TAC?
The USCG Type approval certificate (TAC) is separate from the IMO TAC. The Coast Guard cannot comment on what effect the US type approval might have on certificates issued under the Ballast Water Management Convention.
See our July 26 post for Frequently Asked Questions and other guidance regarding ballast water management systems:
7/26/2017: Updated Ballast Water Management FAQs now available
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.