Ballast Water Management has been one of the most challenging regulatory issues over the past decade for the shipping industry and with the completion of one year of the BWMC implementation it is worth reviewing where we stand at the moment, considering the new developments throughout the year.
Since 8th of September 2017, new ships are required to install and comply with the D2 standard while existing ships, which are subject to the implementation schedule, have a deadline until September 8, 2024. By that time all ships must comply with the D2 standard.
MEPC 72 decisions
During MEPC 72, many issues concerning the BWMC were discussed and amendments related to the implementation of the treaty were adopted, effective from 13 October 2019. The amendments include the schedule for ships to comply with the requirement to meet the D-2 standard (section B) and others (sections A and D) make mandatory the Code for approval of BWMS, while further amendments relate to survey and certification (section E).
MEPC 72 approved BWM.2/Circ.33/Rev.1 on revised Guidance on scaling of ballast water management systems, providing a new way for approaching scaling and allowing Administrations to give enough attention to this important aspect of type approval of BWMS; however the date of application is unknown.
MEPC 72 was invited to consider whether detailed aspects of the validation of the compliance of individual BWMS with regulation D-2 of the BWM Convention in conjunction with their commissioning need to be addressed.
Also, the Committee considered that the inclusion of information on contingency measures in the Guidelines for ballast water management and development of BWM plans (G4) is important and should be done as soon as possible.
Contingency measures for tankers now available
INTERTANKO informed that 60% of its members with BWM systems, said that they experience difficulties in operating them or that the system does not work. Hence, the Association concluded to nine contingency measures requiring from its members to present to port authorities the reasons why a BWMS has failed, and provide them with the system’s maintenance history.
Based on the Contingency Measures listed in the ships’ BWMP, the following Contingency Measures are proposed by INTERTANKO:
- Repair BWMS at the ballast loading port
- Repair the BWMS en route
- Ballast water exhance (BWE) options (1. Mid-ocean BWE without BWMS; 2. Mid-ocean BWE through the BWMS)
- Ballast water exchange in a designated ballast water exchange area.
- Shore based mobile treatment systems at the ballast discharge port: These include Ballast water treatment boat or barge; Mobile treatment facility transported on a barge or truck; and Mobile ballast water treatment equipment.
- Discharge to a port reception facility at the ballast discharge port.
- Retain ballast water onboard.
- Use water from a public water supply.
- Partial ballast water discharge at 12nm from nearest land: This measure is applicable in the US only.
More applications for USCG Type- Approvals
In total, USCG has received 15 applications for BWMS Type Approval while 9 systems have been approved (as of June 2018). Namely, the manufacturers whom their systems have received USCG Type Approval, the final Certificate which acknowledges full compliance with the USCG requirements are: Optimarin (Norway), Alfa Laval (Sweden), TeamTec Ocean Saver (Norway), Sunrui (China), Ecochlor (USA), Erma First (Greece), Techcross (Republic of Korea),Samsung Heavy Industries (Republic of Korea) and BIO-UV Group (France).
BWM compliance in the US
USCG PSC Annual Report revealed that the number of BWM deficiencies doubled in 2017 compared to 2016, on broadly the same number of inspections. The majority of the deficiencies were related to logs/records, alternate management systems (AMS), mandatory practices and BWM plan. In some cases, the Coast Guard found that the BWMS was only used during voyages to the US and that crews received little or no training in operating and maintaining the system. Consequently, the USCG imposed operational control restrictions on 17 vessels due to the severity of deficiencies where some of these vessels were required to leave port in order to comply.
Inoperable BWMS
In February, USCG issued a policy letter to provide guidance for when a vessel destined for a US port has an inoperable ballast water management system. Key points of the guidance include, amongst others:
- Lack of consumables, training or operational experience will not be accepted going forward
- An inoperable BWMS must be reported and the USCG can accept a ballast water exchange 200 nm from shore
- Submission of a repair plan is suggested
- The BWMS must be repaired before the vessel returns to the USA after sailing in foreign waters
- Regular operation of the BWMS is recommended even if the vessel is not bound for the USA, in order to give the crew operational experience
Updated BWM NVIC
In March 2018, USCG issued NVIC 01-18 to provide guidance and ensure a more complete understanding of, and maximum compliance with, BWM requirements. USCG encourages shipping agents to assist with the communication and coordination process that takes place before a vessel arrives into a US port.
Updated FAQs for BWM
In April, USCG updated its frequently asked questions regarding BWM, involving minor wording clarifications as well as additional guidance for topics such as: obtaining recognition for a vessel’s potable water system as a U.S. Public Water system (PWS); compliance waivers for discharge of unmanaged ballast water; and, vessel compliance date extensions.
IOPP certificate amendments now effective
On 1 March 2018, the amendments to Form B of the Supplement to the IOPP Certificate, in relation to segregated ballast tanks, entered into force. These amendments make Form B of the Supplement to the IOPP Certificate, with respect to segregated ballast tanks and protective location arrangements on double hull tankers, and dedicated clean ballast tanks, easier for ROs to complete.
New Association formed
Manufacturers and stakeholders in the ballast water treatment equipment market have created a unified manufacturers’ association: the Ballast water Equipment Manufacturers’ Association (BEMA). This association aims to address issues about ballast water treatment technologies, and provide information on technical and environmental aspects of implementing BWM regulations worldwide.
