United States Ballast Water Regulations

Vessels sailing in U.S. waters will be required to adhere with United States Coast Guard (USCG) ballast water discharge standards and the United States Environmental Protection Agency (USEPA) Vessel General Permit (VGP), in addition to State ballast water regulations.

Compliance Timelines Associated With USCG Regulations

New vessels All On or after December 1, 2013 On delivery
Existing vessels < 1500 m3 Before December 1, 2013 First scheduled drydocking after January 1, 2016
1500 - 5000 m3 Before December 1, 2013 First scheduled drydocking after January 1, 2014
> 5000 m3 Before December 1, 2013 First scheduled drydocking after January 1, 2016

Five Important Details to Remember

  1. The USCG’s final rule establishes a ballast water discharge standard which is the same as that adopted by the IMO in 2004. In addition, the USEPA 2013 Vessel General Permit has adopted numeric limitations within the permit that also align with the USCG rule.
  2. The final rule will affect all vessels – U.S. and foreign – that operate in U.S. waters, are bound for ports or places in the U.S., and are equipped with ballast tanks. These vessels are required to install and operate a USCG Type Approved treatment system before discharging into U.S. waters.
  3. The USCG Type Approval process is more stringent and rigorous than the IMO process. As a result, many existing IMO Type Approved systems may not meet USCG requirements, and will require retesting or redesign.
  4. The USCG has created an Alternative Management System (AMS) process whereby foreign Type Approved systems may be used on a vessel for up to five years after the vessel is required to comply with U.S. ballast water discharge standards.
  5. The AMS determination is intended to be an interim measure to allow the treatment system manufacturer sufficient time to obtain USCG Type Approval. After the 5-year period, the vessel owner must ensure that the system they have on board is USCG Type Approved. AMS determination provides no guarantee to the owner that the system will meet USCG Type Approval requirements.

Our Goal Is To Obtain USCG Type Approval

The Trojan Marinex product suite obtained IMO Type Approval from Det Norske Veritas (DNV) on behalf of the Norwegian Maritime Directorate in March 2014. Then, in August 2014, it was issued Alternate Management System (AMS) acceptance by the United States Coast Guard (USCG).

Based on the belief that USCG Type Approval will become the global standard in ballast water treatment certifications, we have utilized a number of tactics that will enable us to obtain it. In early 2015, a formal application for USCG Type Approval was submitted – this was the first application in the industry.

Testing completed at USCG-approved facilities Most of the existing IMO Type Approved systems (> 40) have not been tested in USCG-approved land- and ship-based test facilities. Most of these suppliers will be required to retest with an approved facility in order for this data to be accepted by USCG.
Tested under poor water quality conditions Many existing IMO Type Approved systems have been tested in higher clarity water (high UV transmittance). It is expected that these systems will not be able to treat lower clarity waters than to what they have been tested to under USCG regulations. The UV transmission value will be noted on the Type Approval certificate, significantly limiting the applicability of the system in poorer water qualities.
Tested under high flow conditions Many existing IMO Type Approved systems have been tested at relatively low flows (< 250 m3/h). However, certificates have been issued for very high flow rates, sometimes in excess of 3000 m3/h.
Tested in fresh water, brackish water and marine water Salinity in ports and harbors around the world vary, therefore it is necessary that systems be tested in all salinities, including fresh water. System suppliers that test in only two salinities may obtain USCG Type Approval, however, similar to issued AMS certificates, these systems will only be permitted to operate in water salinities that were tested and approved. If a system has not been tested in fresh water, it will not be permitted to ballast in fresh water.

As the IMO has reaffirmed its definition of “viable” allowing for the continued use of reproductive methods, the objective scientific evidence and international support for the MPN method has become increasingly apparent and as such we anticipate that the USCG will, with appropriate guidance from U.S. Congress, also soon apply standards and test protocols that facilitate Type Approval of eco-friendly UV-based ballast water treatment systems.