US 2013 Vessel General Permit VGP Ballast Water Sampling Analysis Requirements

Ballast 9

In their latest alert to their clients, ECM Maritime Services, LLC reports on clarification received from the EPA relating to the requisite frequency of sampling and analysis of treated ballast water discharges from USCG type approved Ballast Water Treatment Systems (BWTS) and Alternate Management systems (AMS)* onboard vessels subject to VGP requirements.

In brief, vessels with BWTS using chemical biocide will need to comply with (a) and (b) below while vessels with BWTS not using chemical-based treatment methods need only comply with (a) below.

a) Effluent Biological Organism Monitoring (VGP Part

b) Residual Biocide and Derivative Monitoring (VGP Part

Where applicable, the requirements under (a) and (b) must be conducted two times during the first year. If the sampling results for (a) are below VGP limits both times, effluent biological organism monitoring can be reduced to once per year in subsequent years. If the sampling results for (b) are below VGP limits both times, residual biocide and derivative monitoring must nevertheless still be performed twice per year in subsequent years. Members are recommended to take note of this clarification to avoid falling foul of these VGP requirements.

ECM’s Client Alert 7-2022  may be downloaded below for additional details. If Members have any questions relating to the above, please do not hesitate to reach out to your usual contact at the Club.

*AMS – BWTS approved under the IMO’s Ballast Water Management Convention 2004”


  • ECM Client Alert 72022 Vessel General Permit VGP Update on Ballast Water Sampling and Analysis Requ 100 KB


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Jacqueline Tan

Legal Services Manager