The Environment is at Risk
If UV treatment and the MPN method are used to protect human lives in the United States and throughout the world, why isn’t it good enough for ballast water?
Chamber of Shipping of America Weighs In
“If senior USCG officials affirm the preliminary decision to disallow BWMSs that use UV technology measured by the MPN method, it will cause uproar and confusion in the international shipping industry.”
Read the full letter [pdf: 104 KB]
The Government of Canada Issues Statement, Supports MPN Method
“Canada is calling for U.S. legislators and U.S. federal and state administrations to maximize compatibility between the implementation of U.S. requirements and the Convention.”
- When nonindigenous aquatic species found within ballast water are discharged from ships into waters near ports, they may reproduce, grow, spread and destroy native ecosystems, having disastrous environmental and economic effects.
- For over a decade, the entire international community, along with the U.S., has agreed upon the need to solve this issue, and has created regulations to treat ballast water to prevent the spread and infestation of ecosystems by aquatic invasive species.
- While the rest of the world is harmonized through the International Maritime Organization (IMO) in certifying the equipment needed to treat ballast water, the United States Coast Guard (USCG) has developed its own certification program for ships entering U.S. waters.
- This lack of harmonization between the U.S. and the rest of the world has delayed implementation, ultimately hurting the environment and creating significant confusion and frustration among those in the shipping industry.
- Shipowners will be required, by all other countries in the world, to treat ballast water to IMO standards and testing protocols, creating conflict and confusion for the shipping industry on how to simultaneously meet different U.S. and international regulations and testing requirements.
- A significant difference between the U.S. and the rest of the world regarding ballast water treatment is the acceptability on how organisms should be measured to verify treatment efficacy.
- A key scientific test method that is used worldwide to evaluate the viability of organisms to reproduce, colonize and spread is called Most Probable Number (MPN). However, the USCG has rejected the MPN method.
Critical Ballast Water Treatment Denied
On December 14, 2015, the USCG announced its decision to not approve four ballast water management systems that have been developed, extensively tested and known to be effective in eliminating the ability of aquatic invasive organisms from growing, colonizing and infesting U.S. waters. The basis given by the USCG for this decision is the USCG’s interpretation of its own regulations to require ballast water management systems to be evaluated based on their ability to “kill” certain organisms, and not to assess the “viability” of organisms in ballast water to colonize after treatment. This interpretation is inconsistent with the USCG regulations and the statute under which the ballast water regulations are authorized.
Specifically, the decision found that the MPN method is not equivalent to the Environmental Technology Verification (ETV) Protocol vital stain method in measuring the efficacy of ballast water management systems. This decision essentially prohibits the practical and efficient use of ultraviolet (UV) light-based systems for vessels that deballast in U.S. waters, and has the potential to impose widespread detrimental effects on the global shipping industry. It also disregards the USCG’s own mandate to establish and enforce regulations to prevent the introduction and spread of aquatic nuisance species.
The MPN method is a well-established, sound scientific measurement method that has been utilized for decades to demonstrate effective organism neutralization. It measures the reproductive capability of organisms in water, and is relied upon by governing organizations throughout the world’s highest risk water treatment applications, including drinking water, food & beverage, and pharmaceutical. UV treatment – utilizing reproductive measures like the MPN method – is trusted to protect the human health of over one billion people in the world, from New York City to Paris to Beijing.
6 Reasons the USCG Needs to Accept the MPN Method
2. Low-energy UV-based ballast water management systems are safe, well-established for protecting human health and the environment, and more “green” than other systems. Read more…
4. MPN is an appropriate test method for all ballast water management systems, and is widely-recognized as accurate, practical, and protective. The vital stain method is not practicable or applicable for UV. Read more…
5. Accepting the MPN method will harmonize U.S. and international ballast water regulations, and benefit the shipping industry. Read more…
6. Accepting the MPN method is consistent with the USCG’s public representations, and will promote innovation and competition. Read more…