COMPLIANCE STRATEGY & USCG EXTENSION APPLICATIONS
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.
The process 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 Ballast Solutions (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
Ballast Water Management Plans
The Ballast Water Management (BWM) Convention, USCG BWM regulations, and the U.S. Environmental Protection Agency Vessel General Permit (VGP) all require ships in operation to have a ballast water management plan (BWMP) on board. The requirements are similar, but the need for approval by Flag or Class 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.
Our experts have developed content required by port State inspectors related to no discharge of ballast water in US waters or additional text to address possible non-compliance in ballast water management system (BWMS) operating manuals.
Our qualified consultants can provide a concise BWMP that is unique to your fleet of vessels and their operation. Choice Ballast solutions can:
- Review existing BWMPs and identify any issues
- Develop a BWMP that will reduce inspection issues and improve overall operation of the vessel.
Choice has developed BWMPs for the following fleets – BP Shipping, Scorpio, Eagle Bulk, Carnival – to ensure consistent messages for their fleet and inspectors.