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USCG Policy Letter on Nonviable Organism Testing

On July 31, 2019, the USCG published the long-awaited draft policy paper on Acceptance of Type Approval Testing Protocols for Ballast Water Management Systems (BWMS) that Render Organisms in Ballast Water Nonviable.

The policy paper describes the standard and the process for acceptance and use of new protocols. The “Instructions for Submitting Testing Protocols” outlines the requirements for proposed testing protocols that include:

  • Explanation of why the proposed protocol is the best available science;
  • Documentation that the protocol can be implemented in a “replicable manner” and the precision and accuracy need to be relevant to existing standards;
  • Validation of data pursuant to Method Validation of U.S. Environmental Protection Agency (EPA) Microbiological Methods of Analysis (Rev. 21 December 2016) that includes distinguishing between organisms that are temporarily rendered nonviable and those permanently rendered nonviable.

Protocols are to be submitted to the USCG Office of Operating and Environmental Standards by independent laboratories.

The draft policy letter also provides how type approval of BWMS may be impacted by any accepted protocols.  The Operation, Maintenance, and Safety Manuals and type approval certificates will need to identify if the BWMS was designed and intended to “render nonviable organism” or “kill organisms”.

The draft policy paper makes no immediate change to type approval of any BWMS.  Based on the information provided by the USCG, it will take some time to impact the type approval of BWMS.

Comments on the USCG draft policy paper may be submitted at http://, type [USCG– 2019–0477].  The comment period closes on September 30, 2019.