The USCG in its Marine Safety Information Bulletin (IMSB) dated 9 April 2020, notes that disruptions to supply chains and workforce availability in the current COVID-19 pandemic can lead to delays in the installation and the commissioning of ballast water treatment systems (BWTS). The Coast Guard is, therefore, adjusting its extension policy under the US Ballast Water Management Regulations for vessels which may be impacted by the pandemic, with BWTS compliance dates before 1 April 2021. In instances where the pandemic has made it impractical to perform necessary or scheduled work on a vessel;

• The USCG will extend all compliance dates up to 12 months, upon request. There is no need to provide any supporting documentation, but the vessel owner or operator will need to identify the vessels for the USCG to adjust the necessary documentation.
   
• In those instances where an extension of more than 12 months is needed, the owner or operator of a vessel may request an extension under 33 CFR 151.2036. Such requests should include documentation showing:
  • The purchase of a BWTS and previous arrangements to have it installed;
  • That the system could not be installed due to COVID 19 related restrictions, e.g. third-party verifications from the drydock or BWTS installer/manufacturer;
  • The plans for installing the system, including a list of previously performed and scheduled work and an estimate as to when and how installation and commissioning will be completed.
     
• In instances where arrangements were made to convert an Alternate Management System (AMS) to a USCG type-approved system but the conversion was not completed due to the pandemic, an extension may be requested to continue operating the AMS under 33 CFR 151.2026(c) until the conversion can be accomplished. Documentation showing details and third-party verification(s) that the arrangements for bringing a vessel into compliance were previously made but not possible due to the COVID-19 pandemic should be included with a request for any extension longer than 12 months.

The Coast Guard advises that its office of Operating and Environmental Standards is operating with all personnel working remotely. As such, all extension requests should be scanned and sent in by email at Environmental_Standards@uscg.mil to expedite review. The review and approval of an extension request could take as long as 30 days. To access the USCG’s IMSB Number 14-20 for full details of the guidance provided, please click here.

If Members have any questions on this update, or on the US Ballast Water Management Regulations generally, your usual contact at the Club would be pleased to assist you. For more Covid-19 updates, see our dedicated resource page.