Getting real: US gears up for compliance
Changes in US Coast Guard (USCG) policy may introduce new challenges in aligning compliance between US and IMO regulations, says Evon Li, senior engineer, advisory services, ABS
After many years of delays, ballast water discharge regulations globally and in the United States are finally becoming real for shipowners. While the IMO has agreed to some limited delays in entry into force of the Ballast Water Management Convention, US Coast Guard policy is evolving from implementation of its discharge requirements to enforcement.
Shipowners trading in US waters have until recently been able to defer installation of a Ballast Water Management System (BWMS) on existing vessels by obtaining a USCG extension. Vessels with dry docking in 2016 or 2017 were previously able to obtain an extension to the next scheduled dry docking in five years’ time due to insufficient availability of USCG Type Approved BWMS.
However, based on the recently-published USCG NVIC 01-18 circular, shipowners can no longer rely on this system of extensions to delay implementation.
The USCG has indicated that the six BWMS already approved should be able to cover nearly all classes of vessels and are compatible with a broad range of operational requirements.
The timescale has become very limited – with a duration of a year or less from the date of an upcoming drydock – unless there are extraordinary circumstances justifying more than 12 months’ extension. For vessels with dry dock in 2018, the extension period has been reduced to 30 months from five years due to the increasing number of USCG Type Approved systems available.
These changes could become problematic for shipowners and operators of ‘mid-life’ vessels who are trying to align USCG compliance with the later IMO D-2 compliance date for commercial reasons.
Vessels drydocked in 2016, as well as those with scheduled drydocking through 2018, with extensions, are in a better position to align US and IMO compliance dates. Vessels with scheduled drydocking in 2019 onwards are unlikely to align the two, meaning they would need to opt for earlier installation of a BWMS.
These points should be taken into account when planning for the installation and execution of BWMS retrofit projects.
In addition to selecting the right system, owners are faced with making decisions on their retrofit plan which can also include developing compliance timelines, extension requests, crew training and other necessary steps to meet the requirements.
To help clients understand their options and obligations for compliance with IMO and USCG regulations, since 2015 ABS has offered a BWMS Technology Evaluation service, supporting shipowners during the transition and in the evaluation of a BWMS that is suitable for their vessels.
The ABS service covers two key aspects; pre-selection or shortlisting of suitable BWMS and support for requesting USCG extensions. For the former, an interactive, multi-phase process uses an extensive database of BWMS including technologies, design capabilities/limitations, installation requirements, power requirements, operating considerations and restrictions on equipment use. The USCG extension support service aims to assist clients in understanding their current situation and provides guidance for applying for a USCG extension.
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