Accepting the MPN Method will Harmonize U.S. and Global Ballast Water Regulation, and Benefit the Shipping Industry
The USCG recognizes the importance of the IMO, thus its Final Rule permits an Alternate Management System (AMS) approved by foreign governments under the standards set forth in the IMO BWM Convention. 33 CFR §151.2026
The USCG has accepted dozens of systems and hundreds of models (as AMS) for use in U.S. waters, including the ones subject to the decision to reject the MPN method.
Thousands of vessels already employ UV-based ballast water management systems that have been certified by the IMO and issued Type Approval. For many years, the IMO has recognized MPN as an appropriate method to determine treatment system efficacy. If the USCG’s position on the MPN method is maintained, low-energy UV-based systems capable of treating poor quality water at ports throughout the world will be deemed unsuitable, and shipowners may have to bear the substantial financial and operational burden of uninstalling their existing system.
Consistent enforcement between U.S. and IMO would avoid harm to shipowners and the parts of the U.S. economy that depend on shipping in U.S. waters.