As a result, the USCG has provided additional guidance on what constitutes entry into drydock and the end of an extension period.
It said that it understood that vessel owners and operators face many challenges in selecting and installing a ballast water management system (BWMS) to meet USCG regulations.
A number of vessels have received an extension of the ballast water compliance date that was stipulated as the ‘first scheduled drydock after (date)’. The (date) was the date of entry reported to the USCG for the upcoming statutory out-of-the-water survey for the required inspection of the outside of the ship’s bottom.
Based on the schedule for statutory out-of-the-water surveys, these extensions were expected to extend the compliance date no more than five years.
Due to drydock slippage, some of these vessels entered drydock after the date originally reported to the USCG, while other vessels entered drydock before the ‘first scheduled drydock after (date)’ for emergency purposes or to install an exhaust gas cleaning system (scrubber), but with no change to the schedule of statutory out-of-the water hull surveys.
Under the terms of the extension letters and the guidance provided, these circumstances substantially affected the original extension period.
The USCG said it had received multiple requests from vessel owners and operators seeking to amend their extensions, due to drydock slippage or entry into a drydock either for an emergency or for the installation of scrubbers, but not for a statutory out-of-the water survey.
As a result, it has reconsidered and determined that existing extensions with a compliance date stipulated as the ‘first scheduled drydock after (date)’ will NOT be affected under the circumstances described above.
Vessels that have received an extension of the ballast water compliance date that was stipulated as the ‘first scheduled drydock after (date)’ and subsequently experience drydock slippage, enter a drydock for emergency reasons, or enter for the purpose of installing a scrubber, will retain the originally issued extension, provided there is no change to the next scheduled statutory out-of-the-water survey of the ship’s hull for the required inspection of the outside of the ship’s bottom, the USCG said.
A vessel’s statutory out-of-the-water survey for the required inspection of the outside of the ship’s bottom will be verified by vessel records, including the Certificate of Inspection, Passenger Ship Safety Certificate, Cargo Ship Safety Certificate, or Cargo Ship Safety Construction Certificate, as applicable.
The USCG will provide vessels with updated language that reflects the intent of the originally issued extension. This will tie the extension termination date to the vessel’s out-of-water statutory survey schedule, not to exceed five years.
For those vessels that already received 2.5 year extensions, due to one of the reasons listed above, the USCG will send letters to clarify the beginning and end of the originally issued extension period.