BIMCO, ICS submit proposals to IMO for certification of in-water cleaning processes

In particular, the 2023 Guidelines for the control and management of ships’ biofouling to minimise the transfer of invasive aquatic species (2023 Biofouling Guidelines) provide a framework for when in-water cleaning might or might not take place related to the level of fouling. 

Aron Soerensen, Head of Marine Environment, Copenhagen, Denmark, highlights that development of guidance on matters relating to in-water cleaning with therefore be an area of focus for the IMO until 2025.  

To remind, in November 2023, BIMCO and ICS in consultation with industry experts undertook a review of the existing Approval process for in-water cleaning.

To support the member states in their deliberations and to ensure that by capturing waste substances, in-water cleaning can be undertaken in more ports in a practical, safe and environmentally-sound manner, BIMCO and ICS have submitted two papers to the 11th session of the Pollution Prevention and Response Sub-Committee.  

The overall aim is to establish a certification system for in-water cleaning that gives shipowners confidence that a particular cleaning company is certified and provides safe and environmentally sound services. 

The proposal is practical in the sense that its starting point is the current system where cleaning systems and processes are tested and certified consistently, and that test results can be utilised by cleaning companies to apply for local permissions from ports and other relevant authorities to operate within their jurisdictions. 

Activities before, during and after cleaning to ensure that the in-water cleaning is conducted efficiently, safely and in an environmentally sound manner

Operational procedures

The cleaning company should develop a standard operating procedures (SOP) manual covering at least the following:

1. specific operational procedure to be followed by the personnel involved when undertaking cleaning activity; this should include specific procedures
   followed in the use of the cleaning equipment, guidance of diver along the hull to provide complete coverage of cleaning as required, camera and/or
   video operation;
2. if the above includes a remotely operated vehicle (ROV), procedures to follow for the operation of ROV, methods and equipment to ensure the ROV
   operator can determine the ROV’s location and orientation in relation to the ship;
3. maintenance and calibration of equipment involved in accordance with the instructions of the manufacturer;
4. training requirements of the operators/technicians/inspectors/divers – these should as a minimum cover the points mentioned under “training of
   personnel” below;
5. supervision and verification process to ensure compliance with operational procedures;
6. recording and reporting of information such as collection of photographs of AFS condition, biofouling status, use of biofouling coverage scale,
   development of cleaning and service reports;
7. periodic review of near misses, work processes, procedures, complaints, corrective and preventive actions;
8. process of issuance, maintenance and control of documents; and
9. contingency plans based on risk analysis for breakdowns, accidental discharges, and any other untoward incident that the cleaning company
   anticipates during the cleaning process.

Pre-cleaning preparations

When the decision to clean the ship’s hull and/or niche areas has been taken, the shipowner should request a list of cleaning companies from the port.
The shipowner should send the following information to the appointed cleaning company:

1. date, time and location within port (berth/anchorage);
2. details of AFS on board, including its type and the coating manufacturer’s advice on cleaning;
3. age of AFS and its expected service life timespan;
4. previous damage to the AFS if any;
5. list or drawing arrangement of reference areas;
6. the area(s) of the ship to be cleaned (for example, does the ship need a full cleaning or has another company previously done a partial cleaning?);
7. if niche areas need to be cleaned, information should be provided in the following categories:
   1. niche areas present on the vertical side or the bottom of the ship that can be readily cleaned;
   2. propellers; and
   3. niche areas that need special cleaning equipment and procedures;
8. latest inspection/cleaning reports;
9. available amount of time for cleaning;
10. other operations planned by the ship such as repairs, bunkering, storing, etc;
11. transfer of the ship within the port area, alongside and at anchorage, if relevant; and
12. any other relevant information, such as idle periods, special precautions to be taken while cleaning, etc.