Lack of robustness of the current IMO type-approval process
In advance of next week’s meeting of the IMO Marine Environment Protection Committee (MEPC), the International Chamber of Shipping (ICS) has suggested a number of steps by which IMO Member States might address implementation problems associated with the Ballast Water Management Convention, which has yet to enter into force.
As previously highlighted in a submission to the MEPC (made by ICS in conjunction with other international shipowner organisations), the implementation problems which ICS urgently seeks to address include the lack of robustness of the current IMO type-approval process for new treatment equipment, and the criteria to be used for sampling ballast water during Port State Control inspections.
ICS believes that the legal changes needed to make the ballast regime fit for purpose are relatively straight forward and could be agreed in principle quickly by IMO Member States. ICS has therefore suggested that the MEPC might agree a road map’ using the mechanism of an MEPC Resolution which – if agreed – could make it easier for additional IMO Member States to decide to ratify the Convention.
“If so decided, this Resolution would provide greater confidence for owners and operators installing treatment equipment, and could help end the current impasse.” said ICS Secretary General, Peter Hinchliffe.
ICS suggests that the proposed MEPC Resolution might take into account thefollowing provisions and understandings: Before the Convention enters into force 1. Agreement should be sought amongst Parties so that the G8 Guidelines willbe given a mandatory status, as soon as possible after the Convention entersinto force and amendments can be adopted; 2. A comprehensive and exhaustive review of the G8 type-approval Guidelinesshould be undertaken and that this review of the G8 Guidelines shouldcommence before the Convention enters into force; and 3. In the interim, the existing G8 guidelines would apply, on the understandingthat they will be fully adhered to pending any change to mandatory status assoon as possible after the Convention enters into force. After the Convention enters into force 4. ‘First generation’ type-approved equipment, installed in good faith prior to theConvention entering into force and before the G8 Guidelines have beenreviewed and amended, should be grandfathered for the life of the ship, and anew category of ‘gross non-compliance’ be defined and applied to thesesystems to allow for some variation in treatment efficacy during normaloperation; 5. Agreement should be sought amongst Parties so that, as soon as theConvention has entered into force, the agreed fixed period moratorium onnon-compliance penalties during the sampling and analysis ‘test period’ willbe viewed as an experience-building phase, not as a vehicle to ban typeapproved equipment already fitted; 6. During the fixed period moratorium as has been agreed, penalties should belimited to deliberate attempts at non-compliance; 7. It should be recognised that many perceived problems would be avoided if, assoon as the Convention enters into force:
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ICS fervently hopes that MEPC 66 will consider the adoption of a resolution alongthe lines described above. Following the adoption at MEPC of such a resolutionthen the ICS Board will be invited to review its position on recommending ratification. The new ICS Position Paper, prepared by the ICS Board of Directors, is being communicated to maritime administrations by ICS’s member national shipowners’ associations, and can be foundhere. |
Also read ICS previous proposal for harmful aquatic organisms in ballast water
Source: ICS