Under the US Senate’s VIDA bill, the US Coast Guard (USCG) was given primary responsibility for enforcing regulations set by the Environmental Protection Agency regarding ballast water treatment
This includes testing ballast water treatment systems to meet type-approval in US waters and enforcing the regulations. The draft policy letter is open to the public and responses are invited.
The draft policy letter outlines the USCG position on testing for the current US standard of “permanently incapable of reproduction” (Title 46 Code of Federal Regulations (CFR) Part 162.060) and;
“..the process for accepting type-approval testing protocols for BWMS, if any, that render organisms in ballast water nonviable…”.
By way of explanation the draft policy letter states “At the time of this publication, the Coast Guard does not know of any type-approval testing protocols for BWMS that render nonviable organisms in ballast water that are based on best available science. Therefore, this policy letter establishes the process developed by the Coast Guard for accepting type-approval testing protocols.”
The draft policy letter goes on to explain the procedures by which manufacturers and independent laboratories can submit testing protocols and the validation of testing including field tests in specific regions of the USA.
In some ways, issuing a draft protocol letter is a step forward for those BWMS manufacturers that have been lobbying for an alternative to the current testing protocol used by the USCG. However, it also looks like the USCG is going to take a lot of convincing, but you can submit your responses here.
I would be interested in your views on the draft policy letter and what response, if any, you are submitting. Email me at firstname.lastname@example.org