1. U.S. Ballast Water Regulations
A rule published by the U.S. Coast Guard in March 2012, and effective as of June 21, 2012, established a standard for the allowable concentration of living organisms in ships' ballast water discharged into waters of the U.S.
The rule also established Coast Guard requirements for type approval of ballast water management systems, or BWMS for short.
The U.S. ballast water discharge standard aligns with the International Maritime Organization's Ballast Water Management Convention adopted in A 2011 report by the U.S. Environmental Protection Agency Science Advisory Board concluded the standard specified in the final rule is the most stringent standard that vessels can practicably implement and the Coast Guard can enforce at this time.
As technologies advance and as treatment efficacies improve, the Coast Guard plans to revisit the standard to determine if more stringent requirements are practicable and enforceable.
U.S. Coast Guard Headquarters
Office of Operating and Environmental Standards

2. Complex Challenge Invasion biology Salinity & Turbidity
Naval engineering
Fleet operations and management
Compliance strategies
Maintenance and Repairs
Port operations and facilities
Installation requirements
Operational requirements
Volume/frequency of discharge
Regulations leading technology
Cost
Ballast Water Management is very complicated. The source of this water contains transient dynamic living organisms of varying salinity, temperature, biota. Consequently, finding a BWTS that meets all operating conditions requires research and planning.
The complications are numerous:
e.g., the regulations are leading technology development
e.g., the commercial industry is providing solutions of various technologies
e.g., technologies such as UV, cavitation (sound), chemical treatment are distinct and have distinct advantages and disadvantages that buyers need to research
e.g., the technology focuses on biology, organism counts in various size classes. Biology is infinitely more complex then the chemical issues we have dealt with on oil and air pollution.
The commercial technologies and the shipping industry with its various vessel designs and operational needs results in diverse stakeholders with diverse interests.

3. You should know….. Coast Guard is in compliance mode
Best option: CG Type Approved System
Need a contingency plan
Invasive species impact environment & economy

4. BW Regs: 2012 to now…… 5 CG Approved Independent Labs
Modified MSIBs for extensions: 12,000+
New MSIB in March, synching down
5 CG Type Approved Systems
More systems coming on the way
Industry feedback is shaping implementation
More CG Guidance is coming
With all of the challenges, there is good news. We have made progress.

5. USCG v IMO
U.S. is currently not part to the IMO Convention. There are no plans to change our regulations due to changes to the IMO Convention.
USCG Regulations are not the same as the IMO Implementation.
Discharge standards are similar but not exactly the same - Viable (IMO) v. Living (USCG) organisms
Differences between IMO and U.S. type approval testing
The USCG regulations are based on domestic statutes. The U.S. is not a signatory to the IMO Convention, and our requirements or implementation dates will not change as a result of the Convention coming into force.
IMO’s revised G-8 Guidelines were adopted by MEPC 70 as Resolution MEPC.279(70). These are intended to become a mandatory code after entry into force on Sept 8, 2017.
There is no direct comparability between USCG and IMO with regard to evaluation and approval of active substances. USCG does NOT approve active substances for use in BWMS; instead, BWMS must comply with several other EPA requirements under the Vessel General Permit.
It is not immediately clear whether the U.S. could consider a foreign type-approved system to have met equivalent criteria, or vice versa. A system-specific evaluation would be required to determine equivalency.

6. U.S. Ballast Water Program
Regulation - 33 Code Federal Regulations 151
- effective June 2012
Options for Compliance:
a.) Alternate Management Systems (AMS)
b.) Extensions to Compliance Dates
c.) US type approved BWMS
USCG compared to IMO Type Approval
Compliance and Enforcement
Next Steps
Convention comes into force in September 2017.
U.S. is not a party to the convention.
Refer to Homeport for more info on these topics, and link will be repeated at end of presentation.

7. Options for Compliance
Two Temporary Compliance Alternatives
1. No BW Discharge
2. Coast Guard Approved Ballast Water Management System
1. Alternate Management System (AMS) – Temporary Designation for up to 5 years
It is important to know that a vessel does NOT need to install a Ballast Water Management System to meet the discharge standard.
The Final Rule has several options to meet the discharge standard:
Retain ballast water on board while in waters of the U.S. (i.e., within 12 nm),
Install a Coast Guard-approved Ballast Water Management System,
Discharge to a facility onshore or to another vessel for purpose of treatment, or
Use ONLY water from a U.S. Public Water System (PWS).
There are also two temporary compliance options:
Use an Alternate Management System, or AMS. (This is a foreign-approved BW treatment system reviewed and accepted by the Coast Guard.) Or,
A vessel may receive an extension to its compliance date from Coast Guard.
3. Discharge to Facility Onshore or to
Another Vessel for Purpose of Treatment
2. Receive an Extension to Vessel’s Compliance Date - extension period will vary depending upon TA system availability
4. Use only water from a U.S. Public Water System

8. Options for Compliance
Two Temporary Compliance Alternatives
1. No BW Discharge
2. Coast Guard Approved Ballast Water Management System
1. Alternate Management System (AMS) – Temporary Designation for up to 5 years
It is important to know that a vessel does NOT need to install a Ballast Water Management System to meet the discharge standard.
The Final Rule has several options to meet the discharge standard:
Retain ballast water on board while in waters of the U.S. (i.e., within 12 nm),
Install a Coast Guard-approved Ballast Water Management System,
Discharge to a facility onshore or to another vessel for purpose of treatment, or
Use ONLY water from a U.S. Public Water System (PWS).
There are also two temporary compliance options:
Use an Alternate Management System, or AMS. (This is a foreign-approved BW treatment system reviewed and accepted by the Coast Guard.) Or,
A vessel may receive an extension to its compliance date from Coast Guard.
3. Discharge to Facility Onshore or to
Another Vessel for Purpose of Treatment
2. Receive an Extension to Vessel’s Compliance Date - extension period will vary depending upon TA system availability
4. Use only water from a U.S. Public Water System

9. Temporary Compliance: Alternate Management Systems
A BWMS is accepted for use as an AMS based on its type approval by a foreign administration.
AMS may be used for 5 years after expiration of the vessel’s extended compliance date
Vessels with AMS can comply and must operate the AMS once their original/extended compliance date has passed.
Intro:
AMS is a bridging program for vessels that installed foreign type-approved systems:
Prior to publication of the US regulation
Prior to availability of US type approved BWMSs
The manufacturer must work with the Coast Guard to update its AMS acceptance letter to reflect any changes to its foreign type approval, including renewals, revisions, restrictions, and additional equipment or configurations approved.
AMS supports the development of a healthy marketplace for these new treatment technologies (60+ systems can be used in US waters).

10. Temporary Compliance: Alternate Management Systems
More than 60 systems are now accepted as AMS for use in U.S. waters.
(Select: Environmental Mission;
Ballast Water Management Program;
Alternate Management Systems (AMS))
Intro:
AMS is a bridging program for vessels that installed foreign type-approved systems:
Prior to publication of the US regulation
Prior to availability of US type approved BWMSs
The manufacturer must work with the Coast Guard to update its AMS acceptance letter to reflect any changes to its foreign type approval, including renewals, revisions, restrictions, and additional equipment or configurations approved.
AMS supports the development of a healthy marketplace for these new treatment technologies (60+ systems can be used in US waters).

11. Options for Compliance
Two Temporary Compliance Alternatives
1. No BW Discharge
2. Coast Guard Approved Ballast Water Management System
1. Alternate Management System (AMS) – Temporary Designation for up to 5 years
A vessel does NOT need to install a Ballast Water Management System to meet the discharge standard.
The Final Rule has several options to meet the discharge standard:
Retain ballast water on board while in waters of the U.S. (i.e., within 12 nm),
Install a Coast Guard-approved Ballast Water Management System,
Discharge to a facility onshore or to another vessel for purpose of treatment, or
Use ONLY water from a U.S. Public Water System (PWS).
There are also two temporary compliance options:
Use an Alternate Management System, or AMS. (This is a foreign-approved BW treatment system reviewed and accepted by the Coast Guard.) Or,
A vessel may receive an extension to its compliance date from Coast Guard.
3. Discharge to Facility Onshore or to
Another Vessel for Purpose of Treatment
2. Receive an Extension to Vessel’s Compliance Date - extension period will vary depending upon TA system availability
4. Use only water from a U.S. Public Water System

12. Temporary Compliance: Extensions
Marine Safety Information Bulletin (March 6, 2017) – Updated Guidance.
Request Form is online:
(Select: Environmental Mission;
Ballast Water Management Program; Regulations and Policy Documents)
As stated before, the Extension Program is a temporary strategy available to owners/operators until type approved BWMS, or other approved BW management methods, become available for a ship.
The basis for the issuance of 12,000+ extensions has been that there are no Coast Guard type approved systems available for ship owners to install.
Now that multiple Type Approval Certificates have been issued, the Coast Guard has transitioned its process for granting extended compliance dates.
The Coast Guard may grant an extension to the implementation schedule (original compliance date) when the vessel master, owner, operator, agent, or person in charge can document that, despite all efforts, compliance with the requirements under 33 CFR is not possible. The Coast Guard has posted the procedures for requesting compliance date extensions on Homeport at The goal of the Coast Guard compliance extension procedure is to provide reasonable flexibility to ship owners and operators, where appropriate, while ensuring steady progress toward achieving statutory intent in enhancing protection of U.S. waters from invasive species in ballast water that can damage the environment and harm our economy. The dynamic nature of this challenge, including the number, type, and operating profile of approved systems, the capacity of manufacturers and shipyards, and the demands of the global fleet, calls for constant review and update of our procedures. Accordingly, the Coast Guard will publish updated compliance extension procedures as needed. Stakeholders should be aware of the following principles that guide Coast Guard extension request procedures:
Previously established compliance dates will be honored.
Extensions are no longer linked to the vessel dry dock cycle. Instead the length of extension will be based on the analysis provided in the extension request and limited as set forth in the procedure.
While the Coast Guard understands that no single system is appropriate for every vessel, it is incumbent upon vessel owners/operators to employ engineering and operational solutions in order to install approved systems at or before the vessel’s compliance date. Where engineering and operational accommodations can be made, the Coast Guard may consider extending the compliance date based on an installation plan. Where installation of an approved system is not reasonable, the Coast Guard needs the owner/operator to provide a detailed analysis of how the owner/operator intends to match the vessel with an approved BWMS at a future date before considering any extension request. Vessel owners/operators should be working closely with BWMS manufacturers to ensure the systems in development meet the needs of their vessels.
Ballast water extension requests should be submitted by to Commandant (CG-OES) at
While not required by regulation, requests for extension should be maintained onboard the vessel as a best practice and be available for inspection and validation by Coast Guard Marine Inspectors and Port State Control (PSC) Examiners. If inconsistencies are detected, or a vessel, which is otherwise required to be in compliance lacks the appropriate documentation, the marine inspector or PSC examiner should expand the PSC Exam.

13. Temporary Compliance Extensions
No longer align with scheduled dry docking dates.
Extensions will grant:
6 months to conduct an analysis of BWMS.
Up to 30 months to accommodate installation plans.
Compliance is expected after extensions expire and the temporary allowable 5-year use of AMS terminates.

14. Temporary Compliance Extensions
Extensions granted after March 6, 2017, will be considered the final extension to the vessel’s compliance date.
Extension letters will be honored and may be transferred to new owners.
Failure to plan ahead may result in ship delays or lapse in eligibility to trade in U.S. waters.
Compliance is possible now that numerous commercial BWTS are available.

15. Options for Compliance
Two Temporary Compliance Alternatives
1. No BW Discharge
2. Coast Guard Approved Ballast Water Management System
1. Alternate Management System (AMS) – Temporary Designation for up to 5 years
A vessel does NOT need to install a Ballast Water Management System to meet the discharge standard.
The Final Rule has several options to meet the discharge standard:
Retain ballast water on board while in waters of the U.S. (i.e., within 12 nm),
Install a Coast Guard-approved Ballast Water Management System,
Discharge to a facility onshore or to another vessel for purpose of treatment, or
Use ONLY water from a U.S. Public Water System (PWS).
There are also two temporary compliance options:
Use an Alternate Management System, or AMS. (This is a foreign-approved BW treatment system reviewed and accepted by the Coast Guard.) Or,
A vessel may receive an extension to its compliance date from Coast Guard.
3. Discharge to Facility Onshore or to
Another Vessel for Purpose of Treatment
2. Receive an Extension to Vessel’s Compliance Date - extension period will vary depending upon TA system availability
4. Use only water from a U.S. Public Water System

16. Type Approved BWTS Type Approval Certificates issued for:
Optimarin OBS/OBS Ex
Alfa Laval PureBallast 3
OceanSaver BWTS MKII
Sunrui BalClor
Ecochlor BWTS
ERMA FIRST BWTS FIT
Additional manufacturers have submitted Letters of Intent stating they intend to apply
51 Letters of Intent
5 approved systems (as of October 2017)
More type approvals anticipated.
Timeline: 2-5 months after type approval application received for approval

17. Type Approved BWMS Details
Company
Method
Flow Rate (m3/hr)
TeamTec OceanSaver AS
Electro-chlorination
200 – 7,200
Alfa Laval Tumba AB
Ultraviolet
85 – 3,000
Optimarin AS
167 – 3000
Sunrui Marine Environmental Engineering, Co.
170 – 8,500
EcoChlor , Inc.
Chemical injection
500 – 16,200
Erma First ESK Engineering Solutions SA
90 – 3,740
Samsung Heavy Industries , Co. (Applied)
250 – 10,000
Current range of flow rates: 85 to 16,200 m3/hr – but only 1 over 10k
(EcoChlor is first system type-approved for very high flow rates)

18. Typical Ballast Pumping Rates
Vessel Type
Flow Rate
(m3/hr)
Tanker
5,000 – 20,000
Float-on, float-off
10,000 – 15,000
Ore
10,000
Liquefied-gas
5,000 – 10,000
Dry bulk
Heavy lift
5,000
Barge-carrying cargo
1,000 – 2,000
Roll-on, roll-off
General cargo
Current range of flow rates: 85 to 16,200 m3/hr – but only 1 over 10k
(EcoChlor is first system type-approved for very high flow rates)

19. Plug-N-Play Myth Ship owners/operators want to :
-Buy, install, use: Plug and Play
Frustration with installed BWTS
-Source water is not right (salinity, murky, etc.)
-Replacement parts, repair, training issues
Concerns prior to investing
BWTS is a cargo management system
Over the last several months, the Coast Guard has heard from many shipowners who are frustrated with the quality of equipment and the availability of technical support and timely resolution of issues in the global BWTS market. As we've transitioned to a compliance regime within the U.S., and are now requiring operators to use the equipment approved by type approval or as Alternative Management Systems, vessel operators will bear the burden of familiarization with new technologies. As we've listened to the well-meaning owners, one phrase inevitably comes up in every conversation. Invariably, vessel operators state that they need a system that is "Plug and Play".
This phrase comes up many times, in many different ways. Owners who bought new ships in the last several years, wrote BWTS ready specifications into the contracts in order to ensure that there was adequate space, power, piping available for a future "plug and play" system. Owners who bought/installed BWTS describe problems with the system not effectively treating water in ports where the ships operate because either the water doesn't have enough salt or its too murky. These owners express frustration that the system doesn't seamlessly integrate into their existing operations...that it is not "plug and play". As these owners begin to realize that the systems are not "plug and play", they also express further frustration with the lack of training, repair and maintenance follow-up for the installed systems...the support side for these systems are also not "plug and play" with owners' operations. Lastly, the owners who have not yet invested in a BWTS, and who are seeking extensions, point to the lack of "plug and play" capability--for any of the reasons described above--as their primary concern for not investing.
The Coast Guard understands the frustration. While many shipowners want to do the right thing, market forces haven't incentivized them to spend the necessary capital to fully invest in BWTS. Hence, instead of "owning" this problem, they are looking for vendors and partners who can integrate into their operations and provide this capability without disruption. Herein lies the problem. The breadth of BWTS's impact on vessel operations means that a "plug and play" solution is not possible for many ships. In order to comply with the BWTS regulations, all ships will have to modify their design, operations and support to some extent; some ships will require more fundamental changes. This is unlike what we've seen before when addressing environmental regulations.
If you look at BWTS through the lens of other environmental standards, there are interesting parallels. Whether its oily water separators, air emissions, or other waste management there are things that we can learn from past examples of when regulations led change. However if you look closer, the comparisons between BWTS and the other environmental regulations quickly fade away. In most cases, cargo loading and discharge weren't dependent on the operation of an OWS, exhaust scrubber, or tank cleaner in the same way that BWTS are. So while the mindset and desire for "plug and play" was reasonable for these types of environmental technologies, it is not adequate for BWTS. Because BWTS is so closely linked to the ability to load or discharge cargo in real time, owners shouldn't expect "plug and play" and instead should require the same level of diligence and integration as any other cargo management system onboard.
In the same conversations, we often hear owners/BWTS manufacturers acknowledge that the market is not ‘there’ yet with respect to integration and that more time is needed. While we appreciate that it will take time for integration to occur, the Coast Guard is not convinced that it will occur without a forcing function. Postponement is not the answer. We suspect that if the compliance dates were postponed (assuming we could without regulatory changes), market forces would simply stall and we would find ourselves in a similar situation several years from now. We know that for the regulations to meet the societal expectations to prevent the spread of invasive species, that continued integration, familiarization, and technology development are necessary. Owners and manufacturers who can navigate this market and adjust their design, operations and support to sustainably achieve the intended results will ultimately prevail.

20. Type Approval Review Process
Six-step application review process:
1. Application screening
2. Engineering review
3. Land-based test review
4. Shipboard test review
5. Component test review
6. Scaling review
Engineering Review:
IL assess BWMS compliance with design and construction of §
Bill of Materials and drawing to verify
46 CFR Subchapter F- Mechanical Engineering
46 CFR Subchapter J- Electrical Engineering
USCG recognized class society rules
ATEX certification
Not accepted by CG as equivalent to Subchapter J
May not be installed on US flagged vessels in hazardous locations
Biological efficacy testing is conducted at land based test facilities to ensure treatment systems do in fact kill organisms.
Shipboard testing takes place for 6-month trials aboard commercial ships to verify systems work as designed.
Component testing is performed on electrical and electronic parts to prove long term marine use.
Ships come in many types and sizes, and so must treatment systems. This is problematic because testing durations and costs make it impractical to test all versions of the system. Most manufacturers plan to offer multiple sizes and variations of their base unit. Filters are key components that vary with different size models. Manufacturers want to offer many sizes of treatment systems with filter options without having to test each variation. Scaling may be used to assess the system adequacy.

21. How Type Approval Works
Per 46 CFR 162, an Independent Laboratory (IL) will evaluate:
a.) Test Data & Information from type approval testing by a foreign administration. Additional testing and evaluation by an IL may be required.
b.) Test Data & Information produced and submitted by an IL.

22. Independent Lab Program
USCG is working with ILs to ensure quality results, including regular teleconferences to discuss technical issues, certification reviews, and laboratory oversight. The IL program focuses on:
Consistency in testing
Best practices
Lessons learned

23. Accepted Independent Labs
NSF International (Ann Arbor, MI)
Det Norske Veritas-Germanischer Lloyd (DNV-GL; Norway)
Korean Register of Shipping (ROK)
Control Union Certifications (Netherlands)
Lloyd’s Register EMEA (UK)
Coast Guard is in contact with other test organizations interested in acceptance as IL for BWMS testing.
NSF International in Ann Arbor, MI includes:
For biological testing – the Great Ships Initiative (GSI) in Superior, WI, and Maritime Environmental Resource Center (MERC) in Baltimore, MD.
For environmental testing – Retlif Labs, which has locations in the eastern U.S.
DNV GL in Hovik, Norway (merger of Det Norske Veritas and Germanischer Lloyd in 2013) includes:
Danish Hydraulic Institute (DHI) in Denmark
California Maritime Academy’s training ship GOLDEN BEAR.
Korean Register of Shipping, which includes:
Korea Marine Equipment Research Institute (KOMERI), Busan Techno Park (BTP), Korea Testing Laboratory (KTL), SDS Korea, Korea Testing and Research Institute (KTR), Lab Frontier (LF), Marine Eco-Technology Institute (MEI), and NLP Co.
Control Union Certifications, includes
Lloyd’s Register EMEA (Europe – Middle East – Africa), includes DHI (Denmark), DHI Singapore, and Delta (Denmark).

24. Type Approval Process USCG v IMO
U.S. is currently not party to the IMO Convention. There are no plans to change our regulations due to changes to the IMO Convention.
USCG Regulations are not the same as the IMO Implementation.
Discharge standards are similar but not exactly the same - Viable (IMO) v. Living (USCG) organisms
Differences between IMO and U.S. type approval testing
The USCG regulations are based on domestic statutes. The U.S. is not a signatory to the IMO Convention, and our requirements or implementation dates will not change as a result of the Convention coming into force.
IMO’s revised G-8 Guidelines were adopted by MEPC 70 as Resolution MEPC.279(70). These are intended to become a mandatory code after entry into force on Sept 8, 2017.
There is no direct comparability between USCG and IMO with regard to evaluation and approval of active substances. USCG does NOT approve active substances for use in BWMS; instead, BWMS must comply with several other EPA requirements under the Vessel General Permit.
It is not immediately clear whether the U.S. could consider a foreign type-approved system to have met equivalent criteria, or vice versa. A system-specific evaluation would be required to determine equivalency.

25. Type Approval Similarities
1. Readiness evaluation 2. Land-based testing 3. Shipboard testing 4. Environmental/ Component testing 5. Treatment system scaling
In these areas, the G8 Guidelines and U.S. testing requirements are similar.

26. Technical Differences
1. Discharge Standard 2. Shipboard Testing 3. Hold Time 4. Component / Environmental Testing
There are 4 key technical differences in the type approval process, including discharge standard, shipboard testing, hold time, and component or environmental testing.
This picture shows a treatment system component undergoing inclination testing at a test lab.

27. Summary of Technical Differences
IMO G8
USCG
Discharge Standard
< 10 Viable Organisms
< 10 Living Organisms
Shipboard Testing
3 Test Cycles
5 Test Cycles
Hold Time
> 5 Days
> 24 Hours
Component /
Environmental Testing
2 Hour Endurance Test
4 Hour Endurance Test
The Hold Time refers to the procedure that samples are “held” for a time before measuring organisms to observe and measure if re-growth occurred.

28. Compliance and Enforcement
Regular vessel inspections include ballast water management (BWM)
- BWM exams on foreign vessels: 9,300/year
Follow existing compliance approach
- Documentation, Equipment Condition and Operation, & Crew knowledge
Deficiencies issued since 2012 Final Rule: ~600
Enforcement actions: ~20 (warnings to $5,500 fines)
The Coast Guard will assess compliance as part of regular vessel inspections.
This compliance approach will follow a similar regime in place for all other CG equipment inspection (OWS, MSD, etc.) A Coast Guard inspector will review documentation including the type approval certificate, AMS acceptance letter. The inspector will verify the crew’s knowledge regarding use of the equipment and also verify the equipment’s condition.
If an inspector is not satisfied by these results, he or she can take samples of the ballast water discharge.
The Coast Guard continues to develop more rapid and accurate methods for sampling and analysis.
Navigation and Vessel Inspection Circular (NVIC) is expected in late 2017.

29. Compliance and Enforcement
Story time
Non-compliance is costly
Diverted voyages, modified cargo ops, pilot fees, launch fee, fuel fees, lost income, penalties, etc
$35,000 to $150,000 for one port
Civil & criminal penalties
The Coast Guard will assess compliance as part of regular vessel inspections.
This compliance approach will follow a similar regime in place for all other CG equipment inspection (OWS, MSD, etc.) A Coast Guard inspector will review documentation including the type approval certificate, AMS acceptance letter. The inspector will verify the crew’s knowledge regarding use of the equipment and also verify the equipment’s condition.
If an inspector is not satisfied by these results, he or she can take samples of the ballast water discharge.
The Coast Guard continues to develop more rapid and accurate methods for sampling and analysis.
Navigation and Vessel Inspection Circular (NVIC) is expected in late 2017.

30. What do you do if it breaks?
Report immediately to the cognizant COTP
Present your plan
COTP may allow other methods in regulations
A inoperable BWMS needs to be fixed
Might require voyage deviation for BWE
The Coast Guard will assess compliance as part of regular vessel inspections.
This compliance approach will follow a similar regime in place for all other CG equipment inspection (OWS, MSD, etc.) A Coast Guard inspector will review documentation including the type approval certificate, AMS acceptance letter. The inspector will verify the crew’s knowledge regarding use of the equipment and also verify the equipment’s condition.
If an inspector is not satisfied by these results, he or she can take samples of the ballast water discharge.
The Coast Guard continues to develop more rapid and accurate methods for sampling and analysis.
Navigation and Vessel Inspection Circular (NVIC) is expected in late 2017.

31. Next Steps
USCG R&D - Sampling and analysis method and tools in development
New NVIC in development for field units, industry
Address challenges to type approval
Modification of system components (filters)
Scaling (size, flow rates)

32. USCG Prevention Long-Term Strategy
“Now, in addition to protecting against the risk of accidental release of pollutants, vessel designers and operators must also address the impact of waste streams including ballast water and air emissions. These changes have resulted in the incorporation of innovative design thresholds, new operational practices and additional engineering equipment. The drive for optimization and efficiency has generated environmental benefits, but has also created additional challenges for marine safety from new failure modes and increased complexity.”
Slide sets context – At highest levels, we understand the challenges facing the shipping industry
- Rear Admiral Paul Thomas,
Asst. Commandant for Prevention Policy

33. Resources Coast Guard Internet Portal
Code of Federal Regulations
33 CFR Part 151 – Ballast Water Management
46 CFR Subpart – Type Approval
Main points of ongoing outreach to maritime industry:
The Coast Guard recognizes that a range of BWM options are necessary for the global fleet to manage ballast water effectively, including a range of BWMS sizes and treatment types.  Even as we continue to focus on type approving additional BWMS, vessel owners and operators need to look beyond type approval to the challenges associated with fitting and operating the systems and planning for compliance with U.S. and International standards. I strongly urge vessel owners/operators to work closely with system manufacturers to evaluate potential BWMSs to ensure the system they choose adequately fits their needs and the needs of their fleet. Operators can no longer request an extension simply citing there is no Coast Guard type approved system available. Each extension request requires an explicit statement supported by documentary evidence that one of the accepted methods in the regulations, including installation of a Coast Guard type approved system, is not possible for purposes of compliance with the regulatory implementation schedule.

34. USCG Program Offices Operating & Environmental Standards (OES)
Regulation & policy program manager
Design & Engineering Standards (ENG)
3rd Party Independent Lab manager
Marine Safety Center (MSC)
Type approval manager
Commercial Vessel Compliance (CVC)
Compliance manager

35. Questions? Points of Contact: Vessel Compliance: cgcvc@uscg.mil
Type Approval:
AMS/Extensions:
In general, the Coast Guard's Office of Commercial Vessel Compliance (CG-CVC) is the appropriate point of contact for questions about current USCG requirements:
Extension letters and other BWM program guidance are available at the USCG public Internet portal
Extension requests for compliance dates under Ballast Water Management regulations should be directed to
The USCG Marine Safety Center manages the U.S. Type Approval process, and applicants should send questions to
Questions about testing facilities and acceptance as Independent Labs for the purpose of evaluating Ballast Water Management Systems should be sent to
Details regarding USCG approved equipment can be found at the Coast Guard Maritime Information Exchange (CGMIX) at
NOTE:
The Coast Guard does not administer the Vessel General Permit (VGP) program. Please visit the U.S. Environmental Protection Agency's website for more information at or