2019 BWM Checklist Rev 0
2019 BWM Checklist Rev 0
2019 BWM Checklist Rev 0
To discharge ballast water into the waters of the U.S., applicable vessels must employ ONE of the following
ballast water management methods:
Perform a complete ballast water exchange 200 nautical miles from any shore prior to discharging
ballast water in the US. This method will no longer be accepted if per the USCG and EPA
1
implementation schedule the vessel is required to have installed a BWTS, unless the vessel has
received an extension from the USCG.
Install and operate a ballast water treatment system (BWTS) that is type-approved by the USCG in
2 accordance with the USCG and EPA implementation schedule, included below. Use of the treatment
system is required for all discharges in US waters, regardless of where the ballast water is sourced.
There are now several ballast water treatment systems that have received USCG type
USCG approval. A complete list of the current USCG type approved systems is available on
TYPE CGMIX at: http://cgmix.uscg.mil/Equipment/Default.aspx.
APPROVED
SYSTEMS BWMS type approval certificates and status of pending applications are also available
on the USCG’s website – Homeport: Approved BWMS and Status of Applications
Install and operate an Alternate Management System (AMS) accepted by the USCG prior to the date
that the vessel is required to comply with the ballast water discharge standard (BWDS). Use of an AMS
3
will be allowed for up to 5 years after the vessel’s compliance date. Use of the treatment system is
required for all discharges in US waters, regardless of where the ballast water is sourced.
The USCG has stated that they will continue to consider extension requests, despite the
availability of USCG type approved systems. However, any owner/operator requesting an
extension must provide USCG with an explicit statement supported by documentation as to
why compliance with the current requirements is not possible for your vessel, as well as a
strategy for how the vessel will come in to compliance.
Any existing extensions will remain valid until the extended compliance date specified in the
USCG extension letter. Upon expiration of the extension, a vessel owner or operator will need to
implement one of the approved ballast water management methods listed above, or apply
EXTENSION for a supplemental extension.
REQUESTS
An extension will only be granted for the minimum amount of time needed to come into
compliance with the USGC requirements, as determined by the USCG, but not more than
12 months from the vessel’s original compliance date and will not be tied to the vessel’s
next scheduled drydock. The USGG will not issue extensions for vessels equipped with an
AMS approved treatment system, even if the system is inoperable.
Links to the USCG policy letters and application spreadsheet are included on the next page.
EXTENSION APPLICATIONS The following elements are required for USCG extension requests:
New applications should be submitted between 12-18 months before the vessels compliance
1 date. For supplemental extensions, the application should be submitted 12 months prior to the
expiration of the current extension.
2 Use the spreadsheet application provided by the USCG (linked below)
If either an AMS or USCG type approved system becomes suddenly inoperable while
the vessel is en route to a US port or during operation in US waters, you must report
the issue to the local USCG Sector office as soon as possible. Approval to carry
out ballast water exchange must be obtained from the District Commander of the
applicable Captain of the Port (COTP) prior to discharging in US waters. In the event
the BWTS becomes suddenly inoperable, the following actions should be taken:
• Report the issue to both the nearest COTP to where the issue was discovered and
the COTP for the US port call, as soon as possible.
• Identify the issue and the proposed repair timeline, including details on the
availability of repair parts and/or service technicians.
• Be prepared to discuss alternative ballast water management strategies available
REPORTING to the vessel based on the vessel capabilities, routing, and voyage duration.
INOPERABLE Alternative strategies may include–
TREATMENT o Retaining the ballast water onboard while in US waters
SYSTEMS TO o Discharging any untreated ballast outside of 12nm
USCG o Completing ballast water exchange outside of 200nm at 2000m depth
o Discharging to an onshore reception facility
o Obtaining ballast from a US public water supply
The USCG will determine what actions need to be taken for the vessel to be authorized
to discharge untreated ballast in US waters. The USCG has stated not having an
adequate supply of chemicals or other treatment materials will not be considered an
acceptable reason to use an alternative management method, including deep sea
exchange. The USCG may ultimately not allow the vessel to discharge ballast in
US waters, and any discharge of ballast will need to occur outside of 12nm.
The Ballast Water Management Report submitted to NBIC does not substitute for
notification to the COTP in the event a BWMS stops operating properly.
If you have any questions or concerns regarding the applicability of ballast water
QUESTIONS? management requirements, extension requests, or reporting inoperable systems,
please contact us at inquiry@wittobriens.com.
All vessels that are discharging ballast water treated with either a USCG type approved
or AMS system must conduct analytical monitoring required under the Vessel General
ANALYTICAL Permit (VGP). The VGP requires analytical monitoring for biological indicators, such as
MONITORING FOR E. coli, and for residual biocides for systems that use chemical treatment. These
BALLAST WATER samples are required to be taken two (2) times per year and can be conducted by any
laboratory that uses EPA approved analytical methods.
TREATMENT
SYSTEMS • Summary of the monitoring requirements for the VGP
• EPA Vessel Discharge and Sample Collection and Analytical Monitoring
Reference Guide
SAMPLING Every vessel MUST have a sampling port(s) to collect representative samples of the
PORTS vessel’s ballast water. Sampling ports must be located:
As close as practicable to the BWMS prior to treatment to determine concentrations of living organisms
1
upon uptake.
As close as practicable to the BWMS overboard outlet prior to the discharge point to determine
2
concentrations of living organisms prior to discharge.
3 Elsewhere as necessary to ascertain the proper functioning of the BWMS.
Vessels may continue managing ballast using deep sea exchange (at least 200nm
offshore and 2000m depth) until their original compliance date (per the USCG and
EPA implementation schedule), or revised compliance date if an extension has been
BALLAST WATER granted.
EXCHANGE
Vessels calling the U.S. Great Lakes, New York, Oregon, or Rhode Island with an
approved ballast water treatment system may be required to conduct deep sea
exchange in addition to using the treatment system prior to discharge.
Vessel are NOT required to deviate their voyages out to 200nm and 2000m depth to conduct a deep sea
ballast exchange, if the voyage does not take the vessel into waters 200nm or greater from any shore for a
sufficient length of time. For example, if arriving from a coastwise US or Gulf of Mexico port. Use of the route
exemption should be noted on the Ballast Water Management Report.
In such cases the USCG will only allow discharge of ballast sufficient for safe cargo operations. While not
mandatory, it is strongly recommended to conduct a full exchange at least 50nm offshore and at 200m depth
if a route exemption applies. It is ultimately at the USCG’s discretion to allow the vessel to discharge ballast
water in US waters.
This deviation exemption does NOT apply when calling California, Oregon, Washington, and the US Great
Lakes – see section below on state-specific requirements for details.
The USCG requires each vessel to maintain a ballast water management plan (BWMP)
that has been developed specifically for the vessel that will allow those responsible for
the plan's implementation to understand and follow the vessel's ballast water
management strategy. The BWMP must specifically address compliance with the
USCG requirements.
BWM The BWMP should include procedures for sediment removal and biofouling
PLANS maintenance. These procedures may be incorporated directly into the BWMP or in the
case of biofouling maintenance be kept as a separate plan/appendix (Biofouling
(BWMP) Management Plan) that is cross-referenced in the BWMP. Regardless, they must be
made available upon request during USCG inspections.
All vessels equipped with ballast water tanks and bound for ports or places in the United
BALLAST WATER States, except the Great Lakes or Hudson River north of the George Washington
Bridge, must submit ballast water reports no later than six (6) hours after arrival at a
MANAGEMENT port or place of destination in the US.
REPORTING
(BWMR) Vessels calling the Great Lakes or Hudson River north of George Washington Bridge
must submit the report 24-hours prior to arrival.
Submit the BWMR Form to the National Ballast Clearinghouse (NBIC) using one of the following current
methods:
• Web App online at: http://invasions.si.edu/nbic/onlineform.html
• New PDF Version: http://invasions.si.edu/nbic/forms/BallastWaterForm.pdf
For those who choose to use the Web App and internet connection will be required. Detailed
instructions on how to submit online are posted on the “Submit BW Report” tab of the NBIC
website at: http://invasions.si.edu/nbic/onlineform.html.
WEB
APP Users of the Web App BWMR form will be connecting directly to the NBIC BW Information
System via an internet browser, and will have access to their previous reports and to the most
up-to-date BWMR form versions. Web App users will also receive immediate confirmation that
their submitted report has been received by the NBIC.
Instructions for completing the new BWMR Form (PDF Version) are available at:
http://invasions.si.edu/nbic/forms/BallastWaterForm-Instructions.pdf
NEW
Both the form and instructions are also available at: http://invasions.si.edu/nbic/pdfform.html The
PDF PDF version may be submitted via email or directly online using the buttons at the bottom of the
VERSION first page once the form has been completed.
Adobe Acrobat or Adobe Reader, version 9 or later, is required to use the PDF BWMR form.
• Any vessel bound for the Great Lakes from outside the EEZ: Submit the new
BWMR form at least 24 hours before the vessel arrives in Montreal, Quebec.
YES N/A
EXCEPTIONS • Any vessel bound for the Hudson River north of the George Washington Bridge
entering from outside the EEZ: Submit the new BWMR form to NBIC at least 24
hours before the vessel enters New York, NY.
YES N/A
In September 2018, the USCG issued a final rulemaking that eliminated the annual reporting
ANNUAL requirement for vessels operating exclusively in a single COTP zone. These vessels are now
REPORT exempt from submitting ballast water management reports.
Please send questions regarding ballast water reporting directly to the NBIC at: nbic@ballastreport.org.
Additional information regarding BWM Reporting can be found at the NBIC website:
http://invasions.si.edu/nbic/
Do NOT send BWM Reports to O’Brien’s. We will NOT acknowledge receipt of BWM Reports.
• California – the new BWMR Form (PDF version) should be emailed as an attachment to:
bwform@slc.ca.gov at least 24 hours prior to arrival at a California port.
• Minnesota - the new BWMR Form (PDF version) should be emailed as an attachment to:
ballastwater@state.mn.us at least 24 hours prior to arrival or before departure for voyages shorter than
24 hours.
• Oregon – the new BWMR Form should be emailed as an attachment to: ballast.water@deq.state.or.us
at least 24 hours prior to arrival in state waters (3 nm miles from the baseline).
• Washington – the new BWMR Form (PDF version) should be emailed as an attachment to:
ballastwater@dfw.wa.gov at least 24 hours prior arrival in state waters (3 nm miles from the baseline).
Additional local and regional BWM documentation and reporting requirements can be found in the section
below on state-specific requirements for ballast water.
Vessels that are not using an AMS or USCG type approved ballast
water treatment system must conduct ballast water exchange outside
CALIFORNIA of 200nm if coming from outside the Pacific Coast Region
http://www.slc.ca.gov/Programs/MISP/InfoShts/LargePCRmap.pdf
• Vessels arriving from outside of the PCR with ballast sourced outside of the PCR are Yes No
required to conduct BWE at least 200 nm from land* at a depth of at least 2000
meters. (*This includes islands, such as those around Southern California. See
the map above for more details on the 200nm boundary for conducting exchange)
• Vessels arriving at a California port or place from within the PCR and carrying ballast Yes No
water sourced from within the PCR are required to conduct BWE at least 50 nm from
land at a depth of at least 200 meters.
The California Marine Invasive Species Act (MISA) does NOT provide for a vessel deviation exemption for
ballast water exchange even though the USCG does.
California State Lands Commission (SLC) has been very strictly enforcing the exchange requirement
for vessels coming from outside the PCR, and issuing significant penalties for violations. Please
ensure exchange is conducted at least 200nm from any land prior to discharging in California.
Annual Agents Letter 2017 (BWTS & HHF) –
1
http://www.slc.ca.gov/Forms/MISP/2017_LtrAgents_UPDATED.pdf
Ballast Water Reporting Form – http://www.slc.ca.gov/Forms/MISP/BallastWaterForm.pdf
This is the same new BWMR Form used by the USCG effective February 22, 2016, but it must
2 be submitted 24 hours in advance of arrival to California. If less a voyage is < 24 hours, it should
be submitted prior to departure from the last port of call prior to arrival.
Vessels calling California need to submit the Annual Vessel Reporting Form once per calendar
year. This replaces the Annual Hull Husbandry Form and the Ballast Water Treatment Annual and
3 Supplemental Forms.
Marine Invasive Species Program Annual Vessel Reporting Form (Revised 08/17)
The SLC has developed a series of comprehensive regulatory information sheets (linked below) to help
members of the shipping industry understand California’s requirements for preventing the introduction of
nonindigenous species: We recommend that a copy of each of these information sheets is downloaded,
reviewed, and maintained on board vessels that operate in California waters.
MISP Information Sheet – http://www.slc.ca.gov/Programs/MISP/InfoShts/General_Info.pdf
Biofouling and Ballast Water Management Sheet –
http://www.slc.ca.gov/Programs/MISP/InfoShts/BiofoulingBallastWater_Management.pdf
Ballast Water Reporting Form Submission and Annual Vessel Reporting –
http://www.slc.ca.gov/Programs/MISP/InfoShts/Reporting_RecordKeeping.pdf
All oceangoing vessels visiting ports in Michigan must follow Ballast Water
Control measures. The most important aspect of these rules is that vessels
MICHIGAN must either treat their ballast by a method approved by the Michigan State
Department of Environmental Quality (DEQ) before discharge or retain
ballast on board.
Apply for Ballast Water Control General Permit at least three (3) weeks prior to arrival in Michigan
waters. Michigan DEQ issues a new Ballast Water Control Permit in January 2017 that is valid
until January 2022. A copy of the new permit is available at –
http://www.michigan.gov/documents/deq/wrd-ballast-GP-M0G140000-2017_550366_7.pdf
For new accounts, you must mail a hard copy of the Certifier Agreement Form to Michigan DEQ
before you can submit the permit application form online. The form is available here -
http://www.michigan.gov/documents/deq/wrd-miwaters-certifiers-agreement_494118_7.pdf
A $75 USD application fee and $150 USD annual permit fee will apply, valid for 5 years.
2 Maintain a copy of the Certificate of Coverage (COC) issued by DEQ on board the vessel.
Complete and submit the Port Operations Notification Report at least 24 hours prior to port
operations without ballast water discharge to the designated District office.
Port Operations Notification Report – http://www.michigan.gov/documents/deq/wb-npdes-
3 ballast-PortOperationsReport_247263_7.pdf
A list of Michigan ports and their designated District Office electronic address (email and fax) is
attached to the Certificate of Coverage (COC).
If a vessel intends to discharge ballast water in Michigan waters, it must be treated by one of the following
methods:
• Hypochlorite treatment • Chlorine dioxide treatment
• Ultra violet radiation preceded by suspended
• De-oxygenation treatment
solids removal treatment
Vessels using the above methods must submit a daily discharge monitoring report. All records and information
resulting from the monitoring activities required by this permit, must be retained for a minimum of three (3)
years, or longer if requested by DEQ.
Michigan certified the EPA Vessel General Permit (VGP) with the following additional ballast
VGP water permit conditions/requirements when operating in state waters:
Oceangoing vessels covered by the VGP are prohibited from discharging ballast water in Michigan's
1 waters unless the vessel has obtained a Certificate of Coverage under the Ballast Water Control General
Permit detailed above (Permit No. MIG140000).
Oceangoing vessels that discharge ballast in Michigan waters must monitor ballast water discharge at
2 least once each year for living organisms and report a summary of the results to Michigan Department
Environmental Quality (MDEQ) no later than December 31 each year.
Vessels transiting the Minnesota waters of Lake Superior that are required to
submit a Notice of Intent to obtain coverage under the 2013 EPA VGP are
MINNESOTA required to obtain a Notice of Coverage (NoC) under the Minnesota permit
from the Minnesota Pollution Control Agency (MPCA).
Submit a permit application for coverage under the Permit as soon as you know you will be entering
Minnesota waters. Vessels that routinely transit Minnesota waters should submit a permit application
at least 180 days before an expected discharge.
It may be downloaded from the following site with instructions of how to complete it:
1 http://www.pca.state.mn.us/index.php/water/water-permits-and-rules/water-permits-and-
forms/vessel-discharge-ballast-water-program.html
A $1240 USD application fee and $345 USD annual permit fee due each March for coverage during
the previous calendar year.
2 The application must include a copy of the Ballast Water and Sediment Management Plan.
An original “wet” ink signature is required from the owner and operator to certify the completed
3 application.
4 A copy of the Notice of Coverage (NoC) issued by MPCA should be maintained on board.
The MPCA also requires submittal of the same ballast water report sent to the USCG be submitted
5 electronically to them via email at: ballastwater@state.mn.us at least 24 hours prior to arrival or
before departure for voyages shorter than 24 hours.
A record book must be maintained on board that tracks all ballast water and sediment discharges of
6
the vessel for the past three years.
Minnesota certified the EPA VGP with the following additional ballast water permit
VGP conditions/requirements when operating in state waters:
Vessel must obtain and comply with the existing Minnesota ballast water general permit
1
(MNG300000) detailed above or subsequent modifications of that permit issued by MPCA.
Vessels are required to conduct ballast water exchange for voyages originating outside the US EEZ
in water at least 200 nautical miles from any shore, in waters at least 2,000 meters in depth which
2
result in a salinity level of at least 30 parts per thousand prior to entering Minnesota waters regardless
of the installation of treatment systems.
New York certified the EPA VGP with the following additional ballast water
NEW YORK permit conditions/requirements when operating in state waters:
Existing ballast water exchange and flushing requirements for voyages originating outside the exclusive
1
economic zone (EEZ) remain in effect regardless of whether the vessel is equipped with a BWTS.
2 Annual monitoring and reporting of living organisms after a BWTS is installed.
Additional best management practices for Confined Laker vessels that operate exclusively in the Great
3
Lakes (see section 6.19.4 of the VGP).
Ohio certified the EPA VGP with the following additional ballast water permit
OHIO conditions/requirements when operating in state waters:
Vessels that operate outside the EEZ and more than 200 nautical miles from shore, and then enter
1 the Great Lakes via the St. Lawrence Seaway System must conduct salt water flushing of ballast
tanks. This condition applies both before and after treatment system deadlines in the VGP.
2 Vessels are prohibited from discharging ballast water sediment in Ohio waters.
All commercial vessels > 300 gross tons that enter Oregon state waters
are prohibited from discharging ballast water that has not undergone one
OREGON of the management methods listed below. (Effective March 1, 2017)
Oceanic salt-water flushing of empty tanks is required for tanks that will be used for ballasting or de-
ballasting while in Oregon state waters.
BALLAST The new BWMR form (PDF version) should be emailed as an attachment to
WATER ballast.water@deq.state.or.us at least 24 hours prior arrival in state waters (3 nm miles
REPORTING from the baseline).
For more information regarding the Oregon ballast water management regulations, pre-arrival reporting, and
ballast management arrival fee ($88) see:
http://www.oregon.gov/deq/FilterDocs/bwpFSballastmanage.pdf
http://www.oregon.gov/deq/FilterDocs/ballastFAQ.pdf
http://www.oregon.gov/deq/FilterDocs/BallastReportFormInstr.pdf
RHODE Rhode Island certified the EPA VGP with the following additional ballast
ISLAND water permit conditions/requirements when operating in state waters:
Existing ballast water exchange and flushing requirements for voyages originating outside the EEZ
1
remain in effect regardless of whether the vessel is equipped with a BWTS.
2 Annual monitoring and reporting of living organisms after a BWTS is installed.
All covered vessels > 300 gross tons that enter Washington state waters are
prohibited from discharging ballast water that has not undergone an open
WASHINGTON ocean exchange or other treatment [RCW 77.120.030 (4)].
All covered vessels > 300 gross tons are required to file a ballast water reporting form
BALLAST WATER (BWRF) at least 24 hours prior to arrival in state waters, between Oregon and
Washington ports on the Columbia River, and before transiting between Washington
MANAGEMENT
State ports. This is the same form required by the USCG. Therefore, the completed
REPORTING BWRF can be sent to both the USCG and Washington State. However, the USCG no
REQUIREMENTS longer requires it be submitted 24 hours in advance of arrival as the State of
Washington does.
Complete, save, and send the BWMR Form (PDF Version only) to the State of Washington as an
1 attachment via email at: ballastwater@dfw.wa.gov (preferred) or via fax at: +1 360 902 2845 at
least 24 hours prior to arrival in state waters.
For more information on the WA Ballast Water Program please visit: http://wdfw.wa.gov/ais/ballast/ where the
following is available for download:
• BWMP Brochure – includes information regarding exchange exemptions (waiver option and safety
exemption), inspections, and penalties.
• Waiver Request Forms
• Ballast Water Management Notices
Vessels (50 meters in length or greater and that have a ballast capacity
of at least 8 cbm) that operate within waters of the State of Wisconsin
WISCONSIN are required to obtain a Notice of Coverage (NoC) under the Wisconsin
WPDES Permit (WI-0063835-02-0) from the Wisconsin Department of
Natural Resources (WDNR)
To apply for coverage, submit a copy of the vessel’s eNOI to WDNR at least 30 days prior to
arrival in Wisconsin waters to:
There is $1200 USD application fee every five years and a $345 USD annual permit fee due each
March for coverage during the previous calendar year regardless of whether the vessel enters
Wisconsin waters.
Maintain a copy of the permit and the Notice of Coverage on board the vessel.
2
WDNR will issue a Notice of Coverage.
Follow the applicable requirements outlined in the permit for ballast water management and
sediment plans, ballast log books, ballast discharge and treatment standards.
3
A copy of the permit and its requirements can be found at:
http://dnr.wi.gov/topic/wastewater/generalpermits.html.
Wisconsin certified the EPA Vessel General Permit (VGP) with the following additional permit
VGP conditions/requirements when operating in state waters:
Vessels must obtain any permits required by the State of Wisconsin for vessel discharges (WDNR's
1
ballast water discharge general permit WI- 0063835-01-2).
Vessels that operate outside the EEZ and more than 200 nautical miles from shore, and then enter the
2
Great Lakes via the St. Lawrence Seaway System must conduct salt water flushing of ballast tanks.
3 Discharges of graywater or sewage into Lake Michigan, a NDZ, are subject to penalties.