USCG clarifies operational limits advice
In response to a number of formal and informal inquiries requesting clarification on how an Independent Laboratory (IL) should be assessing manufacturers’ system design limitations, the US Coast Guard (USCG) has issued detailed guidance to ILs.
In an 8 page letter the USCG clarifies the responsibilities of the BWMS manufacturer, the Coast Guard-accepted IL, and the USCG itself, with regard to evaluating and assessing operational limitations of BWMS.
The letter says the process for evaluating and assessing operational limitations includes the following general steps:
- The manufacturer identifies relevant limiting conditions or parameters in the required “technical data package” submitted to the IL;
- In coordination with the BWMS manufacturer, the IL reviews, assesses, and as appropriate, identifies additional or missing limitations critical to the operation of the BWMS;
- Based on the manufacturer-supplied BWMS documentation, the IL develops comprehensive test plans for ship-board, land-based, and component testing;
- At the completion of testing, the IL provides the Coast Guard with a “Test Report” as part of the manufacturer’s type approval application;
- The Coast Guard accepts the IL statement of assessment as part of an approved application, and issues a type approval certificate that reflects the manufacturer-identified operating limits.
The letter also discusses the identification of limiting conditions referenced in type approval certificates, and how to amend these conditions.