Preparatory work to ensure timely compliance with IMO’s Ballast Water Management Convention should not be postponed as it is thought the convention will soon be ratified by a sufficient number of states to pass the entry into force tonnage threshold.
The International Convention for the Control and Management of Ships’ Ballast Water and Sediments (the Ballast Water Management or BWM Convention) was adopted by the IMO in February 2004 and is set to enter into force 12 months after ratification by 30 states, representing 35 per cent of the world’s merchant shipping tonnage. The number of ratifications currently stands at 51, representing 34.87 per cent of the world fleet tonnage, and the maritime industry therefore considers it likely that the BWM Convention will soon be ratified by states having sufficient tonnage to pass the tonnage threshold.
Key requirements
The BWM Convention will apply to all ships and offshore structures that carry ballast water and are engaged in international voyages. Upon its entry into force, shipowners and operator must ensure that:
- an approved ballast water management plan is available and implemented onboard;
- all shipboard ballast operations are carried out according to the plan and with due regard to the safety of the vessel, e.g. by exchanging ballast mid-ocean, treating it onboard before discharge or discharging it to a reception facility/barge;
- a competent officer is assigned to ballast water management and the officer and crew are trained in order to carry out their respective duties;
- a ballast water record book is available onboard and is kept up to date at all times; and
- a vessel of 400 gross tonnes and above, is surveyed and issued with an international ballast water management certificate.
The Convention imposes a challenging ballast water discharge standard which will be phased in over a period of time. The exchange of ballast water mid-ocean is an intermediate solution and most vessels will need to install an approved ballast water treatment system eventually.
Compliance schedule
In April 2016, at its 69th session, the Marine Environment Protection Committee (MEPC) approved draft amendments to regulation B-3 of the BWM Convention setting out deadlines for the installation of type approved ballast water treatment systems onboard vessels. It is understood that, in principle, MEPC maintains the decision given in Resolution A.1088(28) and that a vessel’s date of compliance will be determined by her construction date and the date of her IOPP (International Oil Pollution Prevention certificate issued under MARPOL Annex I) renewal survey. Hence, once the date of the BWM Convention’s entry into force (EIF) has been set:
- vessels constructed (keel laid) before EIF must comply by first IOPP renewal survey after this date; and
- vessels constructed (keel laid) at or after EIF must comply at delivery.
According to the MEPC 69 meeting summary, the draft amended regulation B-3 will be held in abeyance and circulated upon entry into force of the BWM Convention for subsequent adoption.
Recommendations
Members and clients planning to install a ballast water treatment system are advised to start the preparatory work as soon as possible. Although, in most cases, a vessel must be taken out of service for the period of installation, proper planning of the installation period well in advance can save time and money, especially if the installation can coincide with a scheduled dry docking. Some of the key elements of the preparatory work will be to:
- Ensure that the obligations under the BWM Convention, and under other national and local regulations, are fully understood and develop a thorough strategy for complying with the applicable standards. Particular attention should be paid to the position in the US, which has its own regulations and where, up to now, no ballast water management system has been approved by the US Coast Guard. Also, since the US Environmental Protection Agency has published its own regulation, which still need to be harmonised with the US Coast Guard’s regulation, two separate pieces of legislation currently apply to ballast water discharges in the US both of which differ from the IMO’s BWM Convention requirements.
- Carry out a feasibility study for each vessel to evaluate the suitability of available ballast water treatment system solutions. Issues to consider are: vessel type and operating profile, ballast capacity and rates, space requirements (e.g. footprint/volume of treatment system as well as provisions for safe storage of substances), integration with existing systems (e.g. power requirements and electrical equipment protection), health and safety (e.g. chemical hazards) and additional crew workload (e.g. operation and maintenance requirements), etc.
- Consider the “time factor” – availability and delivery times for approved treatment systems will vary depending on demand, as will shipyard capacity. The time it takes to involve the vessel’s classification society and/or flag state should also be taken into account. And, since many shipowners may opt to conduct the IOPP survey ahead of time to postpone the installation of a ballast water treatment system, there may be future time periods that will be particularly busy for yards and classification societies.
Once a ballast water treatment system solution has been selected, officers and crew must be properly trained and be competent to carry out their assigned ballast water management duties and functions. Procedures for training and familiarisation for the BWM Convention should be incorporated in the company’s safety management system (SMS) and should include, but not be limited to, the following:
- introduction to ballast water management and all relevant rules and regulations;
- familiarisation with the vessel’s ballast water management plan and assigned duties;
- operation and maintenance of the vessel’s ballast water management treatment system;
- emergency procedures; and
- making entries and recordkeeping in the vessel’s ballast water record book.
Further information is available on IMO’s ballast water management website and a link to the current list of IMO approved ballast water management systems can be found here. Members and clients should note that the BWM Convention and its guidelines are still under review by the MEPC and the progress of proposed amendments should be followed closely.
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Source: Gard
