Marine Advisory: 02/2017 - Revised USCG Policy on US Ballast Water Discharge Standards

3 March 2017

Marine Advisory 02-2017

SUBJECT: Revised USCG Policy on US Ballast Water Discharge Standards

Ref:

1. CG-OES MSIB Number 14-16 dtd 02DEC2016
2. Marine Advisory: 14/2016 Dear Shipowner/Operator/Master:

The U.S. Coast Guard recently issued revised guidance, ref (a), following its type approval of ballast water management systems (BWMS). The guidance includes changes in the USCG’s extension program and vessel compliance verification. The USCG is still accepting requests for extensions; however, now that USCG type approved BWMS are available, requests must include an explicit statement supported by documentary evidence that installation of a type approved system is not possible for purposes of compliance with the regulatory implementation schedule.

Under USCG regulations, ships without a valid exemption or with an expired exemption are required to manage ballast water in one of five ways:

1. Use a U.S. type-approved BWMS to meet the discharge standard;
2. Temporarily use a foreign type-approved BWMS that has been accepted by the U.S. Coast Guard as an Alternate Management System (AMS);
3. Use and discharge ballast water obtained exclusively from a U.S. Public Water System (PWS);
4. Discharge ballast water to a reception facility;
5. Do not discharge ballast water inside 12 nautical miles.

Note: The USCG recently initiated a civil penalty case against a ship that had an expired exemption and discharged ballast water inside 12 nautical miles of the US. The USCG also cited the vessel for not adhering to its ballast water management plan since the method used to exchange BW was identified as not applicable to the ship.

Owners, operators and Master’s operating vessel’s with valid extension letters are encouraged to ensure that during the extension period, the vessel is operated in accordance with Coast Guard regulations:

1. Perform complete ballast water exchange in an area beyond 200 nautical miles from any shore prior to discharging ballast water into the waters of the U.S., unless the provisions of 33 CFR 151.2040 apply, or otherwise if so required by a U.S. state;
2. Adhere to the ballast water management plan, including the method of BW exchange;
3. Adhere to recordkeeping and reporting provisions; and
4. Comply with all other applicable ballast water requirements.

Failure to implement any of the above methods may result in civil penalty proceedings against the operator.

In order to prevent delays to vessel schedules, owners, operators and Master’s should keep BWM records onboard the vessel and immediately available for review by USCG officials. Such records may include, but are not limited to: BWM plan, current extension letter granted to the vessel, vessel certificates, contracts and/or records verifying the date the vessel entered its last dry dock, BWMS installation documents.

For more information or if you have questions please contact us by email at safety@liscr.com or by telephone to +1-703-790-3434 and ask for the Safety Department.

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