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Ballast Water Testing as per VGP Complaince

Introduction to Ballast Water Testing as per Vessel General Permit (VGP)

Vessels sailing in US waters must comply with the US maritime regulations on ballast water discharge and exchange, largely due to the fact that the US is not a signatory of the Ballast Water Management (BWM) Convention.

Ballast water compliance legislation in the US includes regulations relates to:

• the Vessel General Permit (VGP) for discharges incidental to the normal operation of vessels set by the United States Environmental Protection Agency (US-EPA) in 2013,
• the ballast water regulations set by the USCG; and lastly,
• the Ballast Water Management Convention from the International Maritime Organization (IMO)

The BWM commissioning testing regulations as specified in the BWM Convention from the IMO are similar, yet different to those of the US Coast Guard (USCG) with the main differences can be found in the equipment testing and verification protocols. At present, the IMO G8 Guidelines for the type-approval of Ballast Water Management Systems (BWMS) are only recommended guidelines but have not come into force as a mandatory code of practice yet.

Many states in the US have different requirements for ballast water exchange based on their different zones and many of the regulations are subject to change, following amendments to the BWM Convention being ratified. The US is the only country requiring type-approved systems in order to satisfy a standard other than the IMO’s own standards. It is also important to note that VGP requirements are only relevant to the USCG and not covered in the IMO regulations, and specific requirements of VGP testing are different to IMO biological sampling and testing.

UGSC Testing Requirements

Ballast Water-VGP testing applies to all ships of 1600 Gross Registered Tonnage (GRT) and above, discharging ballast water in the US. Vessels can meet the requirements of the standards of USCG discharge in one of the five following ways:

1. Using a USCG type-approved Ballast Water Treatment System (BWTS)
2. Temporarily using a foreign type approved BWMS which has been accepted by the USCG as an Alternative Management System (AMS).
3. Use and discharge of ballast water obtained from a US public water system
4. Discharging ballast water to a reception facility
5. Refraining from discharging ballast water within 12 nautical miles of the US coast

In some cases, it is possible for the vessel to apply for an extension of the compliance date for the USCG ballast water discharge standard when any of the above options are not viable. There are also some exemptions to having to carry out VGP testing, such as vessels embarking on short voyages less than 10 nautical miles or those operating within a single Captain of the Port Zone (COTP) zone.

What we do

We provide rapid, independent and scientific sampling and testing services to help vessels comply with US EPA VGP 2013. This includes testing and sampling of the following BWTS, their respective parameters and the test methods used, which are:

Project schedule

Our Ballast Water VGP testing schedule is delivered in three stages, which typically require the following number of estimated days and locations, as displayed in the table below:

Please note: depending on the availability and ease of obtaining documentation and your vessel(s) schedule the project schedule can vary and lead to additional days being required to complete the project. 

Testing frequency

Our testing programmes are carried out over the following terms, with respect to the type of BWMS in place on-board a given ship:

For more information about our Ballast Water VGP testing service, please contact the relevant Maritec office – contact details can be found here.