Understanding USCG Extensions, MSIB 14-20 and Compliance

On 9 April 2020, the USCG published Marine Safety Information Bulletin (MSIB) 14-20 “COVID-19: Ballast Water Management (BWM) Extensions” to deal with issues impacting ballast water management system (BWMS) installations worldwide due to the COVID-19 pandemic. The USCG MSIB provided different guidance based on extension requests for up to 12 months, or greater than 12 months.

Through my work as senior compliance engineer at Choice Ballast Solutions (Choice), I have assisted many shipowners in being granted extensions over the past few years. Each time the USCG issues a new MSIB regarding extensions the process changes a little. Recent submissions were impacted by the new guidance and required resubmissions, even though these requests were not directly related to COVID-19 issues.

I am pleased that the USCG showed their commitment to helping shipowners by issuing the MSIB to deal with questions and assist shipowners trying to comply with BWM compliance, but the MSIB leaves out some important details. For example, the MSIB states, “all extension requests should be scanned and sent in by email” but omits that some ship details are needed and that the USCG Extension application should still be used.

It is important for shipowners to understand the differences between the limited 12-month and longer extensions. While applications for up to 12 months are quite simple, the extensions granted will be limited to a one-time request and 12-month maximum – no further extensions may be requested. This limited extension may be sufficient for a ship needing to complete a BWMS installation or commissioning. The short-term 12-month extension may also have other advantages to shipowners with vessels near the end of their life, but a careful review of varying options should be considered. Currently, I am evaluating fleet information for many clients to see if the MSIB impacts their BWM compliance strategy as a result of COVID-19 restrictions.

“Shipowners must understand the differences between the limited 12-month and longer extensions”

For extensions greater than 12 months, shipowners are still required to provide proof that a BWMS was purchased and statements from BWMS makers or drydocks regarding the timeline to completing BWMS installations. In general, the USCG will not give extensions to the next drydock, so shipowners may need to be prepared to install the BWMS at the intermediate survey.

USCG extensions can also be used to have additional time to use a USCG-accepted Alternate Management System (AMS) (i.e., BWMS that do not have USCG type approval). Many BWMS manufacturers are still trying to complete USCG type approval testing. Choice has been successful in providing shipowners with additional time to use the installed AMS until USCG type approval is received.

Many shipowners are also attempting to come into compliance with the BWM Convention. COVID-19 impacts ship operations and supply chains worldwide – from equipment supply to drydock availability to surveys to maintenance. Unfortunately, the USCG MSIB only covers compliance with US BWM regulations. The unknown is how IMO’s Marine Environment Protection Committee (MEPC) will address delays in BWMS installations. The BWM Convention does not include any language for delays in compliance timelines. At present, many Flags are only issuing certificates with 90-day delays. This is useful to address short-term problems but not greater delays.

Unfortunately, the 75^th MEPC meeting has been postponed to an unknown date to address this and other issues. Over the past month, I have discussed with clients many issues impacting their BWMS installations. To get the best results, it is important that shipowners have experienced and knowledgeable sources to assist developing strategies and plans to navigate through these difficult times.