BWM CONVENTION: OBJECTIVES, STRATEGIES, AND ACTIONS Villa Doria d Angri, Naples 28 April 2017 Presented by: Simon Bonnett Safety & Technical Manager
AGENDA Introduction to the International Convention for the Control and Management of Ships Ballast Water and Sediments (BWM Convention) and its Objective Recent International Maritime Organization (IMO) Activity Marine Environment Protection Committee (MEPC) 71 BWM Agenda D2 Compliance Date Alternatives Applicability to Ships Standards for Ballast Water Management (BWM) Other Options for BWM Port State Control (PSC) Before 8 September 2017 After 8 September 2017 Summary of Recommendations 2
BWM CONVENTION The Parties to this Convention, RESOLVED to prevent, minimize and ultimately eliminate the risks to the environment, human health, property and resources arising from the transfer of Harmful Aquatic Organisms and Pathogens through the control and management of ships' Ballast Water and Sediments, as well as to avoid unwanted side-effects from that control and to encourage developments in related knowledge and technology. Entry into force (EIF) date of 8 September 2017 3
BWM CONVENTION (continued) BWM Convention text (Articles and Annex) MEPC Circulars - Guidelines for uniform implementation G1 to G14 Recently revised, the Guidelines for Approval of Ballast Water Management Systems (G8) could become a mandatory Code G7 of interest to those seeking exemptions Resolution MEPC.252(67) - Guidelines for PSC BWM Circulars (BWM.2/Circ.44, BWM.2/Circ.46, and BWM.2/Circ.52) IMO Assembly Resolution 1088(28) recommending enforcement date extensions to Convention Parties based upon EIF date. Significant information available beyond the Convention text 4
RECENT IMO BWM ACTIVITY A revised G8 Guideline Type Approval testing protocol was agreed by MEPC 70. A BWM System (BWMS) installed after 28 October 2020 must meet these revised Guidelines. Limited operational experience of BWMS, hence a proposal for an Experience Building Phase (EBP), details to be agreed by MEPC 71. A significant proportion of Type Approved BWMS utilize technology which may, or may, not leave organisms alive. If they re alive then they should not be able to do harm (viable).the Sub-Committee on Pollution Prevention and Response (PPR) 4 made some steps to provide guidance on how to enumerate organisms which are viable when monitoring discharges for compliance with the D2. 5
MEPC 71 - BWM AGENDA Consider if G8 Guidelines should be made into a mandatory Code. Decide upon the BWMS installation date schedule given the MEPC 69 and MEPC 70 proposals draft amendments to regulation B-3 of the BWM Convention. Finalize the EBP for BWM Convention data collection and analysis. Consider the PPR 4 proposed draft guidance for methodologies that may be used for enumerating viable organisms. Develop guidance on contingency measures under the BWM Convention. 6
D2 COMPLIANCE DATE ALTERNATIVES Current Situation MEPC 69 (IMO Res. A.1088(28)) Possible Future Situation MEPC 70 Alternative (to be discussed at MEPC 71) Ships constructed prior to 8 September 2017 Ships constructed on or after 8 September 2017 Ships constructed prior to 8 September 2019 Ships constructed on or after 8 September 2019 By the first IOPP renewal survey following the date of EIF of the BWM Convention if the survey is completed on or after 8 September 2019; or By the first International Oil Pollution Prevention (IOPP) renewal survey after 8 September 2017 At Delivery By the second IOPP renewal survey following the date of EIF of the BWM Convention if the first renewal survey following the date of entry into force of the BWM Convention is completed prior to 8 September 2019 At Delivery 7
APPLICABILITY TO SHIPS (Article 1.12) Definition of Ship means a vessel of any type whatsoever operating in the aquatic environment and includes submersibles, floating craft, floating platforms, floating production units (FPUs), and floating production, storage and offloading units (FPSOs) The BWM Convention applies to all ships, except those, in accordance with the BWM Convention Article 3, that: are not designed or constructed to carry ballast water; only operate in waters of the Party; only operate in waters under the jurisdiction of another Party, subject to the authorization of that Party of such exclusion; only operate under the jurisdiction of one Party and on the high seas; carry permanent ballast water in sealed tanks that is not subject to discharge. BWM.2/Circ.52 - Guidance on entry or re-entry of ships into exclusive operation within waters under the jurisdiction of a single Party 8
APPLICABILITY TO SHIPS (continued) Regulation A3 - Exceptions ensuring the safety of a ship in emergency situations or saving life at sea the uptake and subsequent discharge on the high seas of the same Ballast Water and Sediments the discharge of Ballast Water and Sediments from a ship at the same location where the whole of that Ballast Water and those Sediments originated and provided that no mixing with unmanaged Ballast Water and Sediments from other areas has occurred. If mixing has occurred, the Ballast Water taken from other areas is subject to Ballast Water Management in accordance with this Annex. BWM.2/Circ.46 - Application of the BWM Convention to Mobile Offshore Units - gives examples of same location exception use 9
APPLICABILITY TO SHIPS (continued) Regulation A4 - Exemptions A coastal State may grant exemptions to any requirements to apply regulations B3 (BWM) or CI (Additional Measures) Exemptions shall not be effective until communicated to the IMO A ship operator can apply to a coastal State (form in G7) Any organization can perform the risk assessment (G7), but only the coastal State can evaluate the assessment and grant the exemption Other coastal States which are affected need to be involved Exemptions must be recorded in the Ballast Water Record Book (BWRB) 10
STANDARDS FOR BALLAST WATER MANAGEMENT Regulation D1 - Ballast Water Exchange Standard At least 95% volumetric exchange of ballast water Regulation D2 - Ballast Water Performance Standard Specifies acceptable number of organisms in a given volume of ballast water Requires a treatment system to achieve this It s analogous to MARPOL Annex I and the 15 parts per million (ppm) limit - difference is we cannot measure the 15 ppm in real time 11
STANDARDS FOR BALLAST WATER MANAGEMENT(continued) Ships constructed before 8 September 2017 D1 or D2 until their first IOPP renewal survey after 8 September 2017 Ships may decouple IOPP survey/certificate from other certificates After the IOPP renewal they must meet the D2 Ships constructed after 8 September 2017 Must meet the D2 12
OTHER OPTIONS FOR BWM Discharge ballast water to a reception facility taking into account the Guidelines developed by the IMO for such facilities Other methods of BWM, provided that such methods ensure at least the same level of protection to the environment, human health, property or resources, and are approved in principle by the Committee. (MEPC) 13
PSC Guidelines for PSC Under the BWM Convention Resolution MEPC.252(67), adopted on 17 October 2014. Sampling - the PSC Officer (PSCO) can undertake sampling of the ship's ballast water, carried out in accordance with the guidelines developed by the IMO. However, the time required to analyze the samples shall not be used as a basis for unduly delaying the operation, movement or departure of the ship (Article 9). Sampling and analysis trial period - A ship should not be penalized (sanctioned, warned, detained, or excluded) solely due to an occasional exceedance of the D2 standard following use of a BWMS approved by an administration under Guidelines (G8) (MEPC.174(58)), which has been correctly maintained and operated. 14
PSC (continued) Initial inspection focusing on documentation and crew responsibilities/familiarization. Ensuring that an officer has been nominated for BWM. More detailed inspection" where the operation of the BWMS is checked and the PSCO clarifies whether the BWMS has been operated adequately according to the BWM Plan (BWMP) and the self-monitored operational indicators verified during Type Approval procedures. Third stage sampling which relies on indicative analysis, to identify whether the ship is meeting the performance standard described in regulation D2. Fourth stage if necessary, incorporates detailed analysis to verify compliance with the D2 standard. 15
Develop BWM strategy BEFORE 8 SEPTEMBER 2017 Consider carrying out the IOPP Renewal Survey and Certificate Renewal BWMP Develop Ship Specific BWMP that fits with the BWM strategy Have BWMP approved by the Recognized Organization (RO) on behalf of the Republic of the Marshall Islands Maritime Administrator Implement BWMP on board BWRB Install a BWRB (may be electronic) and record all ballasting operations Survey and Certification RO to carry out survey to confirm the BWMP is implemented on board RO to issue the International Ballast Water Management Certificate (IBWMC) 16
AFTER 8 SEPTEMBER 2017 Between 8 September 2017 and first IOPP Renewal Conduct ballasting operations in accordance with the approved BWMP Record all ballasting operations in the BWRB RO to carry out periodic surveys for maintenance of the IBWMC By first IOPP Renewal after 8 September 2017 Prepare for any changes in how compliance with requirements for BWM are achieved after the first IOPP renewal e.g., installation and use of an approved BWMS or other means RO to approve any equipment that is installed RO to approve any changes to the BWMP As necessary, RO to resurvey on board arrangements and reissue the IBWMC 17
SUMMARY OF RECOMMENDATIONS Determine the BWM strategy that fits your operations (may be ship and/or location specific), including necessary actions to meet stages of implementation and any local requirements Depending on business decision, ensure IOPP renewal survey is carried out prior to 8 September 2017 Take necessary actions to meet the 8 September 2017 deadline for approved BWMP Closely monitor MEPC 71 and its outcomes Take necessary actions to meet deadline of first IOPP renewal survey after 8 September 2017 18
Chris Lewis THANK YOU www.register-iri.com 19