The USCG Maritime Commons is posting recaps of a recent presentation at the BWMTech North America conference titled, “Walking the Walk” on enforcement and compliance.
Cdr. Alan Moore, with the Office of Commercial Vessel Compliance, provided keynote remarks on Coast Guard ballast water management regulations, how to achieve compliance, and enforcement aspects. Read the complete post on http://mariners.coastguard.dodlive.mil/2018/10/02/10-2-2018-ballast-water-technology-north-america-conference-recap-of-presentation-walking-the-walk-on-enforcement-and-compliance/
Moore noted that accurate ballast water reporting via the National Ballast Water Information Clearinghouse website is integral for verifying compliance, and he highlighted the resources available through the NBIC website such as forms and reporting requirements.
From the Port State Control point of view, BWMS operational performance and compliance with standards is treated the same as other shipboard systems and discharges. “Treating the BWMS with the same importance as all vital shipboard systems will enable the ship to arrive and conduct efficient cargo operations,” Moore said. “Maintaining regular communications and coordination with all PSC safety net stakeholders is important, especially when operational or technical issues arise. This leads to efficient and effective coordination for resolving any issues encountered.”
When a ship is due for a PSC exam, international procedures call for first verifying survey certificates, records, logs, and conducting a cursory walk through to see if there are any obvious issues. If isn’t right then we proceed with conducting a more detailed inspection per IMO procedures for Port State Control. If the Coast Guard identifies an issue, the Port State Control officers will discuss the issue with the master. Depending on the severity, options may include issuing a deficiency, such as requiring repairs prior to departure or return to U.S. waters.
For a complete breakdown of the top deficiencies, resulting operational controls, and enforcement actions, review the 2017 Port State Control Annual Report.
Policy Letter 18-02, “Guidelines for Evaluating Potential Courses of Action When a Vessel Bound for a Port in the United States has an Inoperable Ballast Water Management (BWM) System,” and Navigation and Vessel Inspection Circular 01-18, “Ballast Water Management For Control of Non-Indigenous Species in Waters of the United States.”