Commercial Vessel Compliance

10/17/2018: U.S. Ballast Water Management Requirements: Operational limitations in type approval testing

The Coast Guard recently published a letter to the Coast Guard-accepted independent laboratories (ILs) providing guidance for evaluating manufacturer-identified operational limitations during type approval testing of ballast water management systems (BWMS). The letter can be found under the Ballast Water Management System Switchboard on the Coast Guard website’s Marine Safety Center page.

The letter clarifies the responsibilities of the BWMS manufacturer, the Coast Guard-accepted IL, and the Coast Guard, with regard to evaluating and assessing operational limitations of BWMS.

The process for evaluating and assessing operational limitations includes the following general steps:

1) The manufacturer identifies relevant limiting conditions or parameters in the required “technical data package” submitted to the IL;
2) In coordination with the BWMS manufacturer, the IL reviews, assesses, and as appropriate, identifies additional or missing limitations critical to the operation of the BWMS;
3) Based on the manufacturer-supplied BWMS documentation, the IL develops comprehensive test plans for ship-board, land-based, and component testing;
4) At the completion of testing, the IL provides the Coast Guard with a “Test Report” as part of the manufacturer’s type approval application;
5) The Coast Guard accepts the IL statement of assessment as part of an approved application, and issues a type approval certificate that reflects the manufacturer-identified operating limits.

The letter also discusses the identification of limiting conditions referenced in type approval certificates, and how to amend these conditions.

Please consult the Coast Guard’s website for up-to-date information regarding the ballast water management regulations. As a reminder, compliance date extensions requests and other inquiries should be sent to Questions about type approval applications should be sent to

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.

Leave a Reply