The US Coast Guard’s Office of Operating and Environmental Standards has published a policy letter to provide guidance on testing and validating alternate components for type-approved ballast water management systems
The latest policy letter explains the position of ballast water management systems (BWMS) that have been type-approved by the US Coast Guard and may require change of components after approval.
Under the US Coast Guard rules, these alternate components require the entire BWMS to be re-approved.
For example, ERMA FIRST has certified its FIT BWMS with three different filter options Filtersafe, Filtrex and Hydac, to provide clients with a wider range of filters.The USCG defines alternate components as including any components not listed in the BWMS Operation, Maintenance, and Safety Manual.
The policy letter states that in lieu of dictating specific testing protocols for individual alternate components, 46 CFR 162.060-16(c) defers the determination of testing requirements to the US Coast Guard’s Marine Safety Center.
In addition, an Independent Laboratory previously accepted by the Coast Guard under 46 CFR 159.010 must ensure that any alternate components meet the requirements of 46 CFR 162.060-34.
The only alternate components addressed by this policy letter are filters. The policy letter does suggest other components such as UV lamps and total residual oxidant sensors may be included at a later date. The full text of the policy letter is available here.