Under the convention, all applicable ships over 400gt are required to have Certification, confirming compliance with, as a minimum, the D-1 (i.e. ballast water exchange) requirements of the BWM Convention, prior to entry into force on 8 September 2017.
The requirements are unchanged. That is, ships constructed (keel lay date) on or after 8 September 2017, to which the Convention applies, will be required to be fitted with a ballast water treatment system at delivery.
The amendments delay the treatment system mandatory installation schedule for two years after entry into force of the Convention, giving vessels 2 to 7 years from entry into force before needing to fit a treatment system, depending on their IOPP renewal survey dates. Ships, constructed (keel lay date) before 8 September 2017, are required to be fitted with BWTS:
- No later than the first IOPP renewal survey on or after 8 September 2017. Providing that this survey takes place on or after 8 September 2019; or that the vessel has undertaken an IOPP renewal survey on or after 8 September 2014 but prior to 8 September 2017.
This means that, if the completion date of the vessel’s last IOPP renewal survey was between 8 Sept 2014 and 7 Sept 2017, then treatment system installation is required at the next IOPP renewal survey on or after 8 Sept 2017.
- No later than the second IOPP renewal survey on or after 8 September 2017. Providing that the first IOPP renewal survey on or after 8 September 2017 takes place before 8 September 2019, and the vessel has not undertaken an IOPP renewal survey on or after 8 September 2014 but prior to 8 September 2017.
Putting it in simpler terms, if the completion date of the last IOPP renewal survey was between 8 Sept 2012 and 7 Sept 2014, then BWTS installation is required at the second IOPP renewal survey on or after 8 Sept 2017.
Existing Ships (without IOPP surveys)
Ships constructed (keel lay date) before 8 September 2017, to which the BWM Convention applies, which are not subject to Marpol Annex I surveys (i.e. oil tankers <150gt, and other ships <400gt), a ballast water treatment system is required to be fitted to vessels from the date decided by the Administration, but not later than 8 September 2024.
However, it is noted that the Convention does not normally apply to:
- ships not carrying ballast water,
- domestic ships,
- ships that only operate in waters under the jurisdiction of one party and on the high seas,
- warships, naval auxiliary or other ships owned or operated by a state (although states are encouraged to adopt appropriate measures to ensure that the ships act in a manner consistent with the Convention), or
- permanent ballast water in sealed tanks on ships, which is not subject to discharge.
Please note that if your ship(s) trade to/from USA, the applicable USCG treatment system implementation schedule is unaffected by these changes, and in many cases is the more onerous regime.
The table below show the new implementation schedule for existing ships