Legal Update: USCG – BWMS compliance date extensions

On 11 March 2019. the US Coast Guard issued a bulletin stating that it has reconsidered its previous interpretation of ‘next scheduled drydocking’ with respect to ballast water management system (BWMS) compliance dates.

Due to drydock slippage, the Coast Guard has determined that existing extensions with a compliance date stipulated as the ‘first scheduled drydock after (date)’ will not be affected by circumstances such as drydocking for emergency purposes or to install an exhaust gas cleaning system (scrubber) that did not involve a statutory out-of-the-water survey.

Language in originally issued extensions will be updated to reflect the intent of the originally issued extension, to tie the extension termination date to the vessel’s out-of-water statutory survey schedule, not to exceed five years. Where 2.5 year extensions from the date of the “first scheduled drydock after (date)” have been granted due to one of the abovementioned reasons, the USCG will be sending letters to clarify the beginning and the end of the originally issued extension period.

Members are directed to this bulletin for additional information. If Members have any questions relating to the USCG BWM Regulations, your usual Club contact will be pleased to assist you.