Posted: February 23, 2018

U.S. Coast Guard issues guidelines for evaluating potential courses of action when a U.S.-bound vessel has an inoperable ballast water management system


The U.S. Coast Guard this month issued a policy letter providing guidance to vessel masters, owners, operators, agents and persons in charge for evaluating potential courses of action when a vessel bound for a U.S. port has an inoperable ballast water management system (BWMS). The policy letter does not address situations where the inoperable BWMS is the result of an emergency situation caused by weather, vessel flooding or other such conditions.

The policy letter notes the U.S. is not a party to the International Convention for the Control and Management of Ships' Ballast Water and Sediments (BWM Convention) and will not accept BWM Convention certificates as equivalent to U.S. domestic requirements. U.S. domestic requirements are separate and different than those of the BWM Convention.

The guidance in the policy letter applies to ships using a Coast Guard approved BWMS, or a system accepted by the Coast Guard as an alternate management system.

The complete policy letter is available online.

The policy letter concludes: "Vessel owners and operators must maintain the BWMS onboard their vessels in accordance with the manufacturer's specifications, 33 CFR 151.2025(a)(1). Additionally, they must train the master and crew on the application of ballast water and sediment management and treatment procedures, 33 CFR 151.2050(h). For the BWMS to operate reliably, they must be used regularly by crews trained to use the BWMS. The Coast Guard also highly encourages vessels to use their BWMS regularly, even if not bound to or departing from the United States. During discussions with many people involved in the marine industry, we continually hear of how difficult BWMS are to maintain, yet we also hear that the systems are only used during voyages to the U.S. and that some crews receive little or no training in operating and maintaining the system. For the systems to operate reliably, they must be used regularly by crews trained to use the system. Regular usage improves crew operational knowledge of the BWMS, thereby improving the BWMS' reliability."