Why We Need to Harmonize International Regulations and Testing Procedures
It’s incredibly important that we harmonize international regulations and testing procedures. When one system of regulation or scale is different from another, work and progress in the maritime industry is hindered. Uniformity allows for the development of products and systems that may be sold and utilized anywhere around the world – a crucial factor for this globally-focused industry. One such testing method that hasn’t reached universal harmonization is the most probable number (MPN) method for ballast water treatment systems. The MPN method is currently accepted worldwide but has not yet been approved as an appropriate alternative in the U.S.
MPN Method Appeals
The MPN method is used to find out how likely organisms are to reproduce but the USCG have said they don’t meet their requirements for an adequate alternative. Specifically, it estimates the number of cells of a species and the conditions or requirements necessary for it to reproduce. The United States Coast Guard has denied appeals from manufacturers of ballast water treatment systems seeking to use the method to determine the effectiveness of ballast water treatment systems. These four manufacturers seek to use the testing method as an alternative to the current testing methods already put into place by the USCG. All of their appeals were denied.
What Comes Next?
The USCG reviewed the legal and technical aspects of the appeals in addition to examining over 20,000 pages of legal documents! This was in conjunction with reviewing research analysis conducted independently by the Naval Research Laboratory. The research resulted in finding the MPN method to be an insufficient alternative to current ballast water treatment system requirements.
Ultimately, the MPN method was rejected because the USCG found that none of the four manufacturers could actually prove their systems met current regulatory requirements. It was also found that the Marine Safety Center was not the appropriate organization for the approval of an alternative testing method. Although the alternative testing method was rejected, the USCG is testing other UV-based treatment systems. To add, the Environmental Protection Agency (EPA) is also considering the efficacy of the MPN method in waters featuring mixed-organisms. The USCG is not denying the MPN method, however, it denies the method as a proposed alternative testing method as presented by these manufacturers.
Harmonization and standardization across industries is incredibly important so we don’t think this is the end of the story. We will likely see more manufacturers present the alternative in different ways until we are able to find harmony with the testing methods of the U.S. and those of nations abroad.
Source: The Maritime Executive
08-08-2016 at 3:51