Ballast Water Management- update October 2016
On 4th October 2016, the US Coast Guard issued a notice on its Coast Guard Maritime Commons Blog in which it provided a recap of a presentation delivered by Lt. Cmdr. Jason Kling, of the Coast Guard Marine Safety Center, at the 2016 BWMTech Conference in Miami 26th-28th September. Lt. Cmdr. Jason Kling described the differences between the U.S. and IMO ballast water standards, and the process for U.S. type-approval of a BWM system. He explained that the Coast Guard uses four separate offices to manage the different areas of responsibility for the US Ballast Water Management Program, these being:
1. The Office of Operating and Environmental Standards
2. The Office of Design and Engineering Standards
3. The Marine Safety Center
4. The Office of Commercial Vessel Compliance
This notice provides a good overview of the complex US Ballast Water Management regulatory program. If Members have any questions, please do not hesitate to contact your usual contact at the Club.
The California State Lands Commission has released a Notice inviting comments from the public between September 23 to November 7, 2016 on the Commission’s proposal to amend the regulations of Article 4.5 of the Marine Invasive Species Control Fund Fee. We highlight this for the Member’s information. http://www.slc.ca.gov/Laws-Regs/Proposed-MISP4-5.html
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The US Coast Guard have issued a bulletin regarding the recent ratification of the International Convention for the Control and Management of Ships' Ballast Water and Sediments (BWM Convention).
ECM Client Alert 01-2020 - USCG: Implementation of MARPOL Annex VI - Revised Guidance CVC-WI-022
17/01/2020
The USCG’s Office of Commercial Vessel Compliance (CG-CVC) has issued an updated guidance outlining how it will enforce Marpol Annex VI requirements, including the IMO 2020 Sulphur cap, within the two US. Emission Control Areas (ECA). Initial guidance on enforcement is also provided to USCG units not within either ECA. Please see ECM Maritime Services.LLC’s Client Alert 1-2020 for full details. Members are asked to note that the guidance previously provided in CG-CVC Policy Letter 12-04 Change 1 has been cancelled with immediate effect.
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;