Compliance with the requirements
To prove that a Ballast Water Management System (BWMS) complies with the requirements, ballast water has to be sampled and analysed two times in the first year after installation. If sampling results are below permit limits for two consecutive events, sampling may be reduced to one time per year. However, if the vessel exceeds the limits, it should return to monitoring twice a year. Analyses should be conducted on Total heterotrophic bacteria, E. Coli and Enterococci.
For those BWMS making use of active substances, additional analyses are required, depending on the type of BWMS and active substance. More information can be found in this brochure from the EPA.
Besides ballast water, VGP also requires sampling and analyses for bilge/oily water separator effluent, gray water and scrubber washwater. Those analyses can also be conducted in mutual consultation.
In 2023 the VGP will be replaced by the Vessel Incidental Discharge Act (VIDA). The new VIDA provisions are under assessement. This is due to the fact that the USCG (U.S Coast Guard) is still working on the development of the implementation, compliance and enforcement of the new EPA standards. Although the expectation is that this will be very similar to the present VGP, it is not sure yet how this exactly will look like in terms of sampling and analyses and intervals.