In an effort to create a more holistic reporting process, the US Coast Guard (USCG) has issued a policy letter allowing the use of multiple Independent Laboratories but with only one entity providing the final report
The USCG has responded to a commentator on the CG-OES Policy Letter 01-20 regarding the use of multiple Independent Laboratories to conduct approval testing of ballast water management systems.
BWMS manufacturers are not prevented from using more than one Independent Laboratory to conduct testing. There is no criteria laid down in the guidance and the USCG agrees that a BWMS vendor may use the services of more than one entity to most effectively conduct the required tests.
However, in the interest of organisational and administrative efficiency, the US Coast Guard requires that one Independent Laboratory co-ordinates and oversees all testing and reporting for each type-approval application.
This requirement is now formally enshrined in the policy letter.
For amendments to the type-approval certificate, the manufacturer of the BWMS will follow the requirements in 46 CFR 162.060-16 for any changes to an approved BWMS.
This includes notifying the Coast Guard’s Marine Safety Center.
Therefore, the co-ordinating Independent Laboratory is the one named on the current BWMS type-approval certificate.
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