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Policy Letter: Multiple Independent Labs for Type Approval Testing of Ballast Water Management Systems

The Coast Guard’s Office of Operating and Environmental Standards has published a final Policy Letter on using multiple Independent Laboratories for evaluating Ballast Water Management Systems (BWMS). This clarifies the intent of the 2012 Ballast Water Management regulations, and provides guidance to BWMS manufacturers and testing facilities.

This guidance is in accordance with 46 CFR 162.060-10(b) and 46 CFR 162.060-16, and expands on the Coast Guard’s response to public comments in the 2012 Final Rule’s Federal Register Notice (77 FR 17273). A PDF of the Policy Letter is available on the CG-OES public website.

This Policy Letter provides clarification because the regulations do not specify criteria for the use of multiple Independent Laboratories (ILs). The specific provision, at 46 CFR 162.060-10(a)(2), requires the manufacturer to identify, in the Letter of Intent, any associated test facilities and subcontractors.  Thus, it was anticipated that an IL may have multiple sub-labs, and those sub-labs may conduct testing for multiple ILs.  For this reason, it is important that the application for initial type approval—as well as subsequent amendments—each have full oversight from a single IL with the ability to assess that the system was properly tested and meets all applicable requirements, as noted in Title 46 Code of Federal Regulations (CFR) Subpart 162.060.

For the initial type approval certificate, the manufacturer of a BWMS may use multiple ILs to conduct BWMS type approval testing.  However, a BWMS manufacturer must use one IL to coordinate and oversee all testing and reporting. This ensures consistency and provides a holistic understanding of the system’s performance.

For amendments to the type approval certificate, the manufacturer of the BWMS will follow the requirements in 46 CFR 162.060-16 for any changes to an approved BWMS.  This includes notifying the Coast Guard’s Marine Safety Center (MSC). The coordinating IL, as determined by the manufacturer, will be the only IL listed on the most current type approval certificate.

If you have questions, please contact the Chief of the Environmental Standards Division at

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 publications, such as the Federal Register, Homeport and the Code of Federal Regulations. These publications remain the official source for regulatory information published by the Coast Guard.

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