Dimitris Dedepsidis, Customer Service Manager, DNV GL, addressed the “Challenges in the forthcoming implementation of the BWMC” at the 2017 GREEN4SEA Conference. He mentioned that this July at IMO MEPC 71 is the “last chance” for getting further postponement while already “alternative solutions” are considered – like the IOPP de-harmonization. He also noted that BWM is no longer an ad-hoc operation for the future. So, it is essential for shipping companies to be prepared and competent, both ashore and onboard. Therefore, Master, BWM officer and crew need to be well trained and have well assigned key responsibilities while ballasting operations should be cautiously planned. Ballast Treatment is passing from theory to reality and shipping industry regretfully does not look ready.
BWM is not something new; it exists for over 20 years. It came in 1997 with the first IMO’s “Guidelines for Control and Management of Ships’ Ballast Water to Minimize the Transfer of Harmful Aquatic Organisms and Pathogens”. IMO’s BWM Code was adopted in 2004. From 2008 to 2010 the first systems were installed on board. On 2012 the USCG adopted and implemented its own Ballast Water regulations. And finally, IMO Ballast Water Convention ratified in 2016. The requirements were for 30 countries and 35 % gross tonnage globally. Till today, 54 have ratified the convention; 53% more from the gross tonnage. Finland was the country that triggered the verification with 0.14%. Then, Panama acceded the Convention and New Zeeland was the latest one to accede the Convention. Summing up, the regulation adopted in 2004, ratified in 2016 and as defined, it is due to enter into force twelve months after the ratification. Indeed, it is not yet in force, it will formally enter into force on September 08 of 2017. However, it is something that needs a lot of time.
A lot of plans and scenarios have been made about what is going to happen. The IMO has decided to simplify the request. It is the first IOPP renewal survey after entry into force of the Convention. All the other plans have been obsoleted. From a classification society’s point of view, the market cannot stay as it is till the day of the entry into force. A lot of vessels have not even approved a ballast plan onboard yet. It is of much importance that between “EIF” and “first IOPP survey after EIF”, D1 compliance is required. So, Approved BWMP for D1 (exchange standard) has to be on board.
The image below shows some key points on the way forward BWMC implementation.
The de-harmonization of the IOPP is the hottest topic about the implementation. For instance, considering the plan of 12 months between the ratification and the entry into force for a vessel built on 15 Nov 2007 with date of compliance on 15 Nov 2017, it is clear that when the vessel will go to the special survey, automatically has to comply. The alternative, which is very commonly discussed into the market, is either to go all the Renewal / Bottom Survey in the dry-dock within the window but this does not give any added value because the IOPP survey is to be done or to move only the IOPP renewal three months in order to take place before the September of 2017. Automatically, this will offer to the vessel a grace period of 5 more years.
Ballast water treatment system is required:
- first IOPP renewal survey after entry into force of the Convention
- USCG – first scheduled dry-docking after 1 January 2016
Some flags have already accepted this de-harmonization of IOPP without any further request; among them are Liberia, Marshall Islands, Hong Kong, Isle of Man, India, Singapore, Greece, UK and few others. However, other flags such as Bahamas, Cyprus, Malta, Panama and few others will handle applications for de-coupling. However, the decision will be made on a case-by-case basis. Australia does not accept the de-harmonization of IOPP.
In all cases a written ship’s flag acceptance is required. Additionally, it is uncertain if de-harmonized certification is accepted by some PSCs (eg. China, Japan).
Regarding the USCG implementation schedule there are not changes. The main difference is that instead of IOPP renewal survey, USCG plans for dry-docking. The BWMS must hold a USCG type approval. Only three systems are available at the moment while some other on way. For this reason, an extension is still given, however, if the number of the USCG type approved systems increase then maybe USCG will not be willing to give further extension.
The alternatives in this case is the AMS (Alternate Management System); either to use BWMS approved by other flag, limited to use for up to 5 years which uses of ballast water obtained exclusively from a U.S. public water system or to discharge of ballast water to a reception facility. In addition, the Convention gives further options but they are not realistic. Vessel’s management may apply for a USCG extension letter whose maximum extension may be 18 or 30 months – based on availability of systems and time needed for installation.
As far as the installation challenge is concerned, the DNV GL has made an analysis about 33.000 ships to be retrofitted; more than 1 billion G/T; which means that 16 ships have to be retrofitted per day. But what we have to do? Planning and preparation;
Key points before the installation process
- Make sure mandatory documentation is in place before 8th of September 2017
- Decide on a strategy for implementation
- Choose treatment technology based on feasibility for your fleet
- Plan your retrofit, and ensure that all documents are forwarded to class as early as possible
- Raise awareness and train your crew for operation of the system
There is need to focus on the alternative options for the operator to decide whether to follow the original schedule or advance the complete class renewal survey or advance the IOPP renewal survey.
Further attention is needed regarding the documents that needed on board
- Type Approval Certificate
- BWMS installation details
- Commissioning procedure
- BWM Operation Manual
- BWM Plan (for D2 or D1/D2)
In terms of the training and implementation plan, it is essential that the Master, BWM officer and crew have an understanding of ballast water management. BWM is no longer an ad-hoc operation. Personnel need to be well trained and assigned key responsibilities. Ballasting operations should be planned.
DNV GL performed a survey during the DNV GL Greek Technical Committee Meeting, on February 2017. Below are presented the information gathered from 4 questions during the survey process.
International organizations and regulators should recognize the need for more time until implementation of the BWM Convention
BWM convention will force significant number of vessels of all types, above 15 years to go for scrap
To delay the installation of BWT systems as per IMO req., significant no. of owners will go for advancement of renewal class and statutory surveys
The no. of installed BWTS, their so far utilization and the competence of the crews are giving confidence in the safe and effective use of the systems
Above text is an edited article of Dimitris Dedepsidis’ presentation during 2017 GREEN4SEA Conference & Awards
You may view his presentation video by clicking here
| Click here to view all the presentations of 2017 GREEN4SEA Conference & Awards |
The views presented hereabove are only those of the author and not necessarily those of GREEN4SEA and are for information sharing and discussion purposes only.
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Dimitris Dedepsidis, DNV GL, Customer Service Manager
Dimitris Dedepsidis, is a Customer Service Manager & Ship Type Expert for Bulk Carriers of DNV GL Piraeus. Graduated on 1992 from National Technical University of Athens (NTUA) with an M.Sc.Eng at Naval Architecture and Marine Engineering. After a fruitful 6-years working experience in major consulting and shipping companies, has devoted to Class Societies Services since 1998. Dimitris has worked at American Bureau of Shipping and Germanischer Lloyd, mainly in plan-approval and service-delivery assignments. Since 2006 is holding leading and managing positions, with primary focus in problem-solving and client-support. Currently in DNV GL, is part of the Regional Business Development team and the Global Network of Ship Type Experts.
