IMO approved the proposed amendments to regulation E-1.1 and E-1.5 of the Ballast Water Management Convention (BWM Convention) which will apply at a later date. The amendments mandate the installed ballast water management system (BWMS) to carry out a commissioning test during the initial or additional ballast water management survey.

The target of the commissioning test is to verify that the mechanical, physical, chemical and biological processes of the installed BWMS are working efficiently, considering guidelines developed by the IMO. The commissioning test does not aim to validate the type approval of the BWMS.

What is more, the commissioning test must be performed for BWMS that is installed on board applicable SRS2 of 400GT and more after 8 September 2019. Applicable SRS of no more than 400GT may undergo the commission test voluntarily.

In addition, the commissioning test must be conducted to the satisfaction of the attending RO surveyor after a complete installation of the BWMS, and after all ballasting equipment has been fully tested as necessary.


The representative ballast water samples gathered for the commissioning test must be analysed using at least an appropriate indicative analysis method. The commissioning test is considered successful if the analysis shows that the sample does not surpass the D2 standard and the self-monitoring equipment of the BWMS presents correct operation of all sensors and related equipment.

Moreover, a written report including methods and detailed results of the commissioning testing should be provided to the attending RO surveyor for verification prior an International Ballast Water Management Certificate (IBWMC) can be issued.

The arrangement for carrying out the test and any commercial dealings pertaining to the commissioning test should be between the shipowners/manager/shipyard/contractor and the manufacturer.



The Administration of Singapore MPA, however, highlights that it does not perform approval of any specific testing facility. The testing facility engaged to carry out the commissioning test must be independent of the manufacturer of the BWMS and accepted by the RO which issues the IBWMC.

If the commissioning test cannot be successfully performed because of the equipment's system design limitation, a short term IBWMC may be issued for a period of not more than three months. This is to provide time for the commissioning test to be conducted to the satisfaction of the attending RO surveyor. No authorisation from MPA is required for such cases provided that the attending RO surveyor ensures the following:

  • Reasons for the commissioning test not being completed successfully are recorded in the ballast water record book;
  • The attending RO surveyor is provided with arrangements for the commission test (e.g. date, time, location);
  • The ship’s ballast water management plan (BWMP) has incorporated appropriate contingency measures in line with the “Amendments to the Guidelines for ballast water management and development of ballast water management plans (G4)” (Resolution MEPC.306(73));
  • The ship’s Master and the designated ballast water management officer are aware of the “Guidance on contingency measures under the BWM Convention”, BWM.2/Circ.62, as may be amended, in particular on the communication between the ship and the port State;
  • The ship’s Master and the designated ballast water management officer are aware of the reporting requirements to the competent port Authority as per regulation E1.7 of the BWM Convention when the vessel is calling a foreign port and shall comply with any additional requirements that the port State may impose.

If the commissioning test is not completed within the three months of the short term IBWMC, MPAs approval for an extension is to be sought.

See more information in the following PDF