Industry Issues


U.S. Type Approval: The Coast Guard final rule requires vessels discharging ballast water in the United States to treat that ballast water with U.S. type approved ballast water treatment technology. Use of an IMO type approved technology will not meet the U.S. requirements.  The Coast Guard explained in its final rule that it adopted its own, arguably more rigorous, type approval protocol due to concerns about the ability of the IMO type approval process to demonstrate that systems in fact meet the D-2 treatment standard.  Like the IMO type approval regime, the U.S. protocol requires that systems be tested in both land-based and shipboard testing environments.  The U.S. protocols also require that testing be performed by an independent laboratory (i.e. the laboratory cannot be affiliated with vendors), requires that all test runs—failing and passing—be reported, contains detailed procedural instructions regarding how the testing is to be performed, and requires that all system evaluations be subject to a quality assurance/quality control assessment.  The current Coast Guard approved independent laboratories include NSF International and DNV, each of which operates multiple test facilities.    During the 2 years and 2 months that have elapsed since the Coast Guard designated the first independent laboratory, the agency has received nine letters of intent to test with an independent laboratory, although not all of these vendors have begun testing.   While more than 50 treatment technology vendors have earned IMO type approval to date, none have yet earned U.S. type approval.  More information can be found here on U.S. Coast Guard type approved BWM systems.

Alternate Management Systems (AMS): The Coast Guard final rule allows a non-US (I.e. IMO) type approved system to be used to meet the U.S. reuirements for up to five years from the vessel's compliance date if that system has been designated an AMS for the U.S. Coast Guard. If an installed AMS does not earn U.S. type approval before the five-year term expires, the vessel will no longer be able to use that system to comply with the U.S. regulations and would need to be retrofitted with a U.S. type approved system.  The U.S. Coast Guard has noted that an AMS designation in no way indicates that a system will ultimately be U.S. type approved, since AMS designation is simply a determination, based on an existing IMO type approval, that the system is equivalent to ballast water exchange.  The list of Coast Guard designated AMS can be found on the Coast Guard's "Homeport" website at:  To access, select Environmental from the left menu and then find Alternate Managment Systems under Ballast Water Management Program on the Environmental page.