Specifically, according to Gard's local correspondents, Legat Odessa LLC, the Cabinet of Ministers of Ukraine published the Resolution No 367 dated 27.3.19 which changes the ballast water regulations in ports of Ukraine.

Before the changes, when visible traces of pollution were noticed, ecologists were permitted to sample and analyse the ship’s ballast water and compare results with the limits of polluted materials concentration.


Resolution No 367 dated 27.3.19 states that the mentioned cancellation is not permanent, but will remain in force until new protocols for sampling and testing of ballast water have been adopted. Until such time, ecologists are prohibited from sampling and/or testing vessel’s ballast water.

Yet, Gard's correspondents informed that it's correspondents will most likely continue inspections, log books and ballast water exchange logs, and look for evidence of documentary non-compliance.

Ecologists will also look for visible pollution hints, due to improper cleaning of the vessel’s "grey" water.

Therefore, Gard recommends vessels calling Ukraine ports:

  • All masters calling ports in the Ukraine should confirm with their agents that the designated berth does not have any visible traces of pollution prior to arrival. It is also important for the ship’s crew to ensure that the ship’s side is clear of any traces of pollutants while the vessel stays at berth.
  • The ship’s crew should periodically check over side of any traces or pollutants and report any issues to the authorities and at the same time inform their P&I club.
  • Although the ecologists may not sample or test the ballast water we would reiterate our previous recommendation that Members should strictly adhere to the SIPBS (State Inspection for Protection of the Black Sea) requirements, such as exchange of ballast water when entering the Black Sea, document the exchange in the appropriate logs and the IMO ballast water reporting form, and declare to the agent the quantity of ballast the vessel will discharge in port. Members should pay particular attention to tank maintenance, where the ballast is taken, draining of the tanks when emptied and sampling routines when SIPBS inspectors are on board.
  • As most port state control visits onboard vessels will normally start with an examination of relevant certificates and documents, it is also important to ensure that the vessel’s ballast water management documentation is complete and up-to-date prior to a port entry. Under the requirements of the International Ballast Water Management Convention, vessels must have onboard a ballast water management plan, a ballast water record book and an International Ballast Water Management Certificate. The certificate is required for ships of 400 GT and above under a flag which is a Party to the Convention, however, also other vessels will need to demonstrate compliance with the requirements of the Convention.