Compliance Strategy & USCG Extension Applications
Are you prepared for compliance with Ballast Water Management (BWM) discharge standards? With the Experience-building Phase of the BWM Convention nearing its end, it’s even more important to ensure all your documentation is in compliance.
In a recent report, the U.S. Coast Guard stated that BWM was one of the top reasons for increased deficiencies with ships by either operating the system incorrectly, improper documentation on board, and/or failures to report discharges or operational problems.
Compliance is made of many parts:
- Installation and operation of the Ballast Water Management System (BWMS)
- Ballast Water Management Plan (BWMP)
- Documentation for Port State Control (PSC) inspections
- BWM reporting
- Biofouling maintenance
Choice Ballast Solutions experts can provide an on board BWM compliance audit and will partner with you to provide compliance services for any one or all of these factors!
Ballast Water Management Plan
The BWM Convention, USCG BWM regulations, and the U.S. Environmental Protection Agency Vessel General Permit (VGP) all require ships in operation to have a BWMP on board. The requirements between the agencies are similar, but the approvals by flag State or Classification Society varies. The Guidelines for ballast water management and development of ballast water management plans (G4) established the mandatory and non-mandatory provisions of BWMPs. Few changes have been made since 2005 – except for Resolution MEPC.306(73) that amended G4 to include Contingency Measures in the non-mandatory options.
Recent issues found by PSC inspectors regarding BWMP have included:
- Improper identification of BWMS
- Lack of BWMS operational limitations
- Incorrect certificates or documentation
Our experts have researched the most up-to-date requirements by PSC inspectors in relation to discharges of ballast water in U.S. waters or any non-compliance in the BWMS operating manuals. We can review your current BWMP or create a new, concise Plan that is unique to your fleet of vessels and their operation. Choice Ballast solutions will:
- Review existing BWMPs and identify any issues
- Develop a BWMP that will reduce inspection issues and improve overall operation of the vessel.
Choice has completed BWMPs for the following fleets – BP Shipping, Scorpio, Eagle Bulk, Carnival – to ensure consistent messages for their fleet and inspectors.
Biofouling Management Plans
Many ships have overlooked requirements for Biofouling Management Plans (BfMPs). The IMO, USCG, US Environmental Protection Agency and many other localities are now requiring ships to have BfMPs – and even more requirements are now being developed.
BfMPs need to include more details than the basic templates provided by some maritime organizations and associations offer. Choice can provide your ships with a simple, efficient BfMP that will specifically address all the requirements for your ship’s area of operation.
BfMPs developed by Choice include:
- Specifications on the applied coatings
- Marine Growth Protection Systems (MGPS) information
- Cleaning practices that minimize or reduce biofouling
- Any details required by local authorities
Choice can also review your existing BfMPs to identify any missing or outdated information. Additionally, any biofouling measures undertaken will have a secondary benefit in helping to assess the fuel efficiency of your ship. BfMPs are an integral part of controlling invasive species with Choice helping to chart your path to compliance.
Extensions of a vessel’s BWMS compliance date are granted to shipowners who have documented that, as of the application date, compliance using a USCG Type Approved system is not possible. The USCG has not stopped considering extensions but now requires extra documentation to support the extension application as described in the NVIC signed on March 1. Currently, the process for applying for extensions has become far more difficult. Third-party verification is required for any extension applications submitted this year. The USCG wants proof that a shipowner is moving forward and committed to compliance with BWM requirements.
Choice can prepare and deliver the information required to submit an extension application with a timeline that outlines the steps to be undertaken. This includes:
- Technical issues
- Feasibility studies of available BWMS for your fleet or vessel
- Proof of BWMS acquisition
- Proof of contract with drydocking facilities
- Proof of contract with engineering firm with estimated timeline
- Detailed design
- Class approval and documentation