Commercial Vessel Compliance

Policy Letter: Testing Alternate Components for a Type-Approved Ballast Water Management System

The Coast Guard’s Office of Operating and Environmental Standards has published a Policy Letter to provide guidance on the testing and validation of alternate components requested to be used with a type-approved Ballast Water Management System (BWMS). A PDF of the CG-OES Policy Letter 03-20 is available on the CG-OES public website.

The Coast Guard’s type approval regulations provide requirements that a BWMS must meet to obtain type approval (46 CFR 162.060). Increasingly, manufacturers seek to include alternate components in the system bill of materials to give their customers more options for the wide range of circumstances under which BWMS are used. Alternate components include any components not listed in the BWMS Operation, Maintenance, and Safety Manual (OMSM). The only alternate components addressed by this policy letter are filters.

In lieu of dictating specific testing protocols for individual alternate components, 46 CFR 162.060-16(c) defers the determination of testing requirements to the Coast Guard’s Marine Safety Center (MSC). In addition, an Independent Laboratory (IL), previously accepted by the Coast Guard under 46 CFR 159.010 must ensure that any alternate components meet the requirements of 46 CFR 162.060-34. The scope of
work necessary for the IL to evaluate an alternate component varies widely, based on the role of the component within the BWMS and its relation to the original component.

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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