We know we’re not the only ones wondering what is happening with the US Coast Guard’s (USCG) Ballast Water Management (BWM) regulations. Since 2018, the Environmental Protection Agency’s (EPA) Vessel General Permit (VGP) was expected to be updated (Vessel Incidental Discharge Act, VIDA). The vital changes needed are to test for compliance of all factors defined in the standards. At the time of writing (2026), VIDA is still in the works, with a plan to implement it this year – however we are awaiting updates.
So, for now, we’re sharing takeaways from recently published articles on this topic.
Frequency and practice of ballast water testing – experiences from the VGP
The VGP has required the USCG to perform annual ballast water testing. “Notably, the United States is the only country to date to require routine sampling, analysis, and reporting of ballast water discharges in federal waters.” Steenhover, 2025
“Despite the constraints, the VGP has played a pioneering and constructive role. It has demonstrated the commercial viability of its sampling frequencies and their acceptance among shipowners .” Read more in this article, which our CEO is co-author on together with other experts in ballast water management regulations.
The experiences showcase how it can be for port state control authorities to perform annual testing to ensure compliance with BWM standards. However, the data itself has not been enough to document compliance, as the VGP was developed before reliable, accurate sampling and analysis methods were available. The tests used for the VGP have been bacterial and therefor not checking compliance with regulations for microbes 10-50 um and >50um in size.
Quality of ballast water compliance testing – IMO approved compliance monitoring devices (CMD)
Previously, we outlined some of the key differences between the current standards for ballast water compliance defined by the USCG (VGP) and the IMO (D2). Since then, an important change has occurred. In 2023, the IMO published a protocol for validating compliance monitoring devices (CMD), and in 2025, the first CMD has been approved following this protocol.
References
U.S. Environmental Protection Agency (2013) VESSEL GENERAL PERMIT FOR DISCHARGES INCIDENTAL TO THE NORMAL OPERATION OF VESSELS (VGP). https://www.epa.gov/system/files/documents/2025-07/2013-vessel-general-permit.pdf
U.S. EPA (2024) Vessel Incidental Discharge National Standards of Performance. https://www.federalregister.gov/documents/2024/10/09/2024-22013/vessel-incidental-discharge-national-standards-of-performance
Stehouwer P. & Drillet G. & Gianoli C., Gang L., Zacharopoulou A., Bonamin V., Drake L. (2025). A Decade of Ballast Water Data Submitted to the U.S. Epa: A Trend Toward Improved Compliance. 10.2139/ssrn.5369810.
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