12/2/2015: Ballast water series from the Coast Guard’s Assistant Commandant for Prevention Policy

This is the first post in a six-part series of blogs on Maritime Commons to provide updates and information about the Coast Guard’s ballast water regulations and implementation.

I look forward to sharing this information with you as we work hard to protect the environment while ensuring the safety and security of the marine transportation system.

From the desk of Rear Adm. Paul Thomas, assistant commandant for prevention policy

This blog series on Maritime Commons will provide information and updates for both those who are new to the subject of ballast water management and the more experienced maritime professionals. My staff recently participated in the 4th Annual Ballast Water Management Technology North America Conference, where they had comprehensive discussions with manufacturers, vessel owners and operators, independent labs and other stakeholders about all aspects of U.S. regulations and implementation of the ballast water program. During this conference, and several other recent engagements with the maritime industry, we noted several repeated areas of concern and confusion which prompted me to publish this series on Maritime Commons.

Over this six-part series I will provide basic details and clarify confusion about the U.S. ballast water regulations published in 2012, compare U.S. regulations and the International Maritime Organization ballast water Convention, summarize the Coast Guard type-approval process, discuss type-approval challenges, provide an overview of ballast water treatment systems technologies and other relevant topics.

First, I would like to highlight a few realities associated with addressing this complex issue. Innovative methods and technologies to effectively reduce the risks of harmful aquatic invasive species have advanced dramatically in the past decade. Despite these advances, many significant challenges remain unresolved. Multiple treatment systems must be developed to fit the variety of worldwide ships operating within diverse environments. Each environment contains diverse organisms that are transient by nature and react differently to various treatment methods at any given time. While these challenges remain, we are leveraging outside technical expertise to build a comprehensive and practical environmental testing and verification program. We are engaging with environmental stakeholders, non-governmental organizations and industry in the U.S. and international communities to ensure that all ballast water treatment initiatives align with Coast Guard requirements as much as practicable, and we continue to communicate with maritime stakeholders to identify and address compliance hurdles.

With the help of other federal agencies, ballast water manufacturers, ship owners, class societies and various industry stakeholders, the Coast Guard has undertaken substantial work to implement the 2012 ballast regulations.

Accomplishments to date include:

  • Implementation and administration of accepting alternative management systems – over 50 have been accepted;
  • Review and approval of independent laboratories, or IL, to conduct testing on Coast Guard’s behalf and submit type approval packages for approval – five ILs have been approved;
  • More than 30 letters of intent have been submitted to the Coast Guard indicating manufacturer intentions to test ballast water treatment systems;
  • Review and response to policy questions regarding design and testing of ballast water management systems during conceptual pre-approval stages;
  • Issuance of letters for more than 2,000 vessel extensions to compliance dates;
  • Engagement with interagency and international experts and stakeholders to evaluate implementation policies, including providing input to the IMO Convention G8 guidelines;
  • Publication of a marine safety information bulletin clarifying the definition of “first scheduled dry dock” and an update to the extension policy that extends vessel compliance dates until the next scheduled dry dock.

I hope you’ll find this series informative and useful. Although the path to type-approval that we have laid out will not be an easy one, the Coast Guard believes that it is achievable and realistic.

Outside of this six-part series, you can find ballast water management program guidance and updates on the Homeport website under ‘Ballast Water.’

Read the series:

Part 1: Ballast water series from the Assistant Commandant for Prevention Policy
Part 2: Shedding some light on 2012 ballast water regulations
Part 3: Ballast water – U.S. Regulations compared to International Convention
Part 4: Ballast water – Living vs. viable
Part 5: Ballast water type approval process
Part 6: Ballast water type approval challenges for industry

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.



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4 Responses

  1. Erik Schiffelbian says:

    We look forward to reading the series! As yacht operators, we hear from the industry that we are often looking for “special” treatment or consideration. The fact is that a yacht has a very different operating profile than a tanker or container ship. We have been wrestling with the subject of Ballast Water Management for some time now and we are no closer to finding an acceptable solution than we were 2 years ago. It could be said that a yacht owner can afford a ballast water treatment plant (BWTP), but that is not the issue. The real problem we face is finding the space.

    While it is not the norm on a yacht, several of our fleet yachts are unfortunate enough to have designated “Ballast” tanks. Not one of these yachts has ever put sea water in their ballast tanks. The tanks, when used, are filled with potable water directly from reverse osmosis water makers. Unfortunately the IMO, nor the USCG recognize RO water as benign.

    It may be possible to plan a BWTP installation in a new-build yacht, but our problem is dealing with the existing yachts with ballast tanks. I’d like to hear the CG’s comment on potable water and if there are any other operators in this smaller range of vessel that are looking at the same issue.

  2. LT Jodie Knox says:

    Thank you for your comment and question Erik. I have passed it to the appropriate program office and will get back to you with a response as soon as possible. Warm regards, Lt. Jodie Knox

  3. LT Jodie Knox says:


    This is the promised follow-on answer from the program office. Thank you for your question and comments.

    Based upon the background provided by your question, it appears the vessels in question are non-recreational vessels and are equipped with ballast tanks. Accordingly, the Coast Guard’s ballast water management regulations at 33 CFR Part 151 Subparts C and D apply to the vessels.

    For example, yachts which are time or voyage chartered, or yachts that carry passengers for hire or perform some other function for hire (i.e., used for non-recreational purposes) must comply with 33 CFR Part 151 Subparts C and D if they are equipped with ballast tanks and operate in U.S. waters.

    The Coast Guard’s regulations require a non-recreational yacht to comply with the ballast water management requirements of 33 CFR 151.2025 (up to the vessel’s compliance date) or 33 CFR 151.2035(a) (after the vessel’s compliance date). Please refer to 33 CFR 151.2035(b) to determine the vessel’s compliance dates.

    Potable water sourced from a U.S. public water system and used as ballast may be discharged in U.S. waters if the requirements of 33 CFR
    151.2025(a)(2) are also met. Potable water contained in tanks designated as potable water tanks (or “technical water tanks”), and which are not used for ballasting, may be discharged in U.S. waters. However, if the potable water placed into these tanks is used as ballast, even if that is not the primary purpose of the water, and the water is discharged into U.S. waters, the discharge would be subject to the requirements of 33 CFR Part 151 Subparts C and D.

    Potable water generated by a reverse osmosis (RO) unit onboard a ship does not qualify as water sourced from a U.S. public water system. As such, a vessel that uses an RO unit to produce ballast water would need to comply with 33 CFR Part 151 Subparts C and D. Such a system may be appropriate for smaller vessels which do not carry cargo, such as non-recreational yachts which might only need ballast when fuel supplies are low. In this case, the manufacturer of unit may submit their system to the Coast Guard for type approval as a ballast water management system (see 46 CFR 162.060 which contains procedures and requirements for approval of ballast water management systems).

    Alternatively, yachts that operate as “non-commercial recreational” vessels are not required to comply with the Coast Guard’s ballast water management regulations.

    I hope this helps. If you have additional questions, you are welcome to email me directly at .

    Warm regards,

    Lt. Jodie Knox

  4. Erik says:

    Hello Lt. Knox,
    Thank you for this information, which confirms what our understanding of the present policy is. We are disappointed by the Coast Guard’s rather narrow determination that reverse osmosis water from a potable water tank may be discharged in US waters, while the same water may not be discharged in US waters without treatment by an approved BW treatment plant.