VGP Compliance Sampling

US Coast Guard calls that vessels sailing to the United States must have the VGP. Mr. Marine technicians can perform the VGP compliance testing on any BWTS brand. Your next service is at a click distance!
VGP Compliance Sampling
VGP Compliance Sampling

What is VGP Compliance Sampling?

US Coast Guard (USCG) calls that vessels sailing to the United States must have the Vessel General Permit (VGP) Compliance Sampling performed to validate that their Ballast Water Treatment System (BWTS) complies with the imposed standards. During the first year, it is required to test the water between 2 to 4 times. Once samples meet the discharge requirements in two consecutive tests, sampling can revert to annual VGP sampling and therefore annual reports.

In case of subsequent failure, vessels are required to revert to biannual testing until two consecutive tests have been achieved. Analyses should be conducted on Total heterotrophic bacteria, E. Coli and Enterococci. U.S. Environmental Protection Agency (EPA) administers compliance with these VGP discharge standards and sets testing guidelines and chain of custody reporting. Such annual compliance testing is currently not mandatory for IMO, however, Port State inspectors are responsible for the enforcement of IMO regulations.

The VGP, which was issued in 2008 and then updated to a stricter version in 2013, provides nationwide National Pollutant Discharge Elimination System (NPDES) permit coverage for incidental discharges from commercial vessels over 79 feet in length. 

Mr. Marine is your reliable partner for professional compliance testing, calibration and servicing in more than 375 ports worldwide. Contact our team for a quote today!

What could a noncompliant BWTS mean for you?

Failing VGP ballast compliance sampling requirements could see your ships denied entry to US ports. This would inevitably cost you many thousands in fines and lost cargoes. More serious violations can result in fines ranging from around $20,000 to $40,000.

Companies should review their compliance programs and ensure they comply with VGP requirements. The compliance programs should be practical and straightforward for crewmembers to follow and include procedures for reporting non-compliance. Companies must act immediately if they discover a violation and report it accordingly. Note that although self-sampling is permitted, strict procedures are required to ensure correct handling and timely transportation of samples. All of which must be correctly logged within specified timeframes.

What are the requirements for VGP Compliance?

The EPA has recently increased its scrutiny of vessels and their compliance with the current VGP rules. This includes reviewing vessel records, conducting inspections and using its authority to issue information requests under the Clean Water Act to investigate potential violations. The EPA is focusing on failures to comply with annual inspection requirements, failure to file Notices of Intent and non-compliance with BWMS. The EPA has indicated that this is just the beginning and that companies need to comply with Vessel General Permit discharge requirements to avoid significant penalties.

For US waters, USCG/EPA requirements for VGP compliance are:

  • Annual system checks – all components, alarm log, software update (or more frequently if warranted or recommended by the maker)
  • Annual system tests – all functions 
  • Annual calibration – sensors for UV, flow, temperature and pressure 
  • EPA expects that many sensor types (e.g. pH probes, TRO sensors, turbidity sensors) will need to be calibrated more frequently. This can be done aboard or ashore but the vessel must not discharge ballast water when the sensors are inoperable.
  • Annual water sampling for bacteria 
  • Bi-annual residual biocide sampling
  • Annual crew training

From VGP to VIDA

In December 2018, the Vessel Incidental Discharge Act (VIDA) was signed to establish uniformity, consistency, and certainty in the regulation of incidental discharges from U.S. and foreign-flag vessels. 

The VIDA applies to:

  • Commercial vessels greater than 79 feet in length; 
  • Other non-recreational, non-Armed Forces vessels; and
  • Ballast water only from small vessels (less than 79 feet in length) and fishing vessels of all sizes.

Even if the initial timeline to ratify the uniform performance standard was two years, the standards have not been developed until now. The EPA mentioned that the new enforcement for the federal discharge limits will be communicated in the autumn of 2024.

How can Mr. Marine help?

We perform VGP compliance testing and maintenance on all BWTS and ensure your BWTS is compliant with the current regulations. Mr. Marine Ballast provides a fully project-managed service, whereby samples are taken by trained specialists and tested in certified laboratories. Entrusting your VGP sampling to Mr. Marine Ballast ensures that your BWTS samples are taken from optimum locations and transported according to EPA guidelines. By following these procedures, Mr. Marine Ballast contains the risk of contamination or multiplying of bacteria which minimises the risk of a negative test. The final report will also include a Chain of Custody (COC) which is a specific EPA requirement.

VGP compliance ensures the protection of the global waters and the reduction of invasive species. This measure contributes to environmental protection and the health of the maritime ecosystem.  

Contact us for a quotation and availability using the form below. It’s fast and easy.

For additional information about VGP compliance sampling, please visit the following pages:

VGP Compliance Testing

Your 2023 Guide for VGP

You can also view all our BWTS services here.

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