12/4/2015: Ballast water – U.S. Regulations compared to International Convention

This is the third 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

The discharge standards required by U.S. regulations are the same as the standards proposed in the International Maritime Organization, or IMO, Ballast Water Convention. However, there are differences found in the testing and verification protocols as well as confusion about the definition of “viable” as meaning living and non-viable as meaning dead. I will address the viability issue in the next blog post and will outline the Coast Guard type-approval process in the fifth blog post.

Testing and verification protocols
In 2005 and as updated in 2008, IMO released G8 Guidelines for the type approval of ballast water management systems, or BWMS, by flag administrators. These non-mandatory guidelines are open to wide interpretation by flag administrations because the guidelines do not specify that type-approval testing should be conducted by an organization independent of the manufacturer. U.S. type-approval testing procedures are mandatory and specify testing that is independent from manufacturers. Our procedures are also very detailed and require more testing than foreign type-approval procedures. As such, ship owners are concerned there could be significant variation in the robustness and quality of data generated during type-approval testing.

The IMO Marine Environmental Protection Committee is currently reviewing and revising the G8 Guidelines. IMO intends to provide more robust and standardized testing procedures. I expect that the G8 guidelines will better align with some aspects of Coast Guard test requirements. This may not be the case for all aspects because administrations seem to be supporting the continued use of “viable” rather than “alive” when evaluating BWMS efficacy. The next blog will discuss the living and viable criteria and how it is evaluated.

What happens when the IMO Ballast Water Management Convention is ratified?
The IMO announced that a number of countries recently acceded to the IMO ballast water management convention. Subject to verification of the gross tonnage data relating to their registered fleets, the convention may enter into force as early as fall of 2016. U.S. regulations will not change following enforcement of the convention. Ships operating in U.S. waters will have to comply with U.S. requirements, including using one of the ballast water management practices described in 33 CFR Part 151.2025 and 2050. The Coast Guard will continue to work out the intersection of the international treaty with our domestic laws and regulations, including ongoing efforts to support the update of the G8 Guidelines.

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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