Hellenic Mediterranean Panel April 25, 2013 Ballast Water Management JOSEPH ANGELO DEPUTY MANAGING DIRECTOR
Different regimes International National/Regional Local INTERTANKO Actions IMO Response
INTERNATIONAL IMO Ballast Water Management Convention Adopted in 2004 Entry into force requires ratification by 30 countries, 35% world s grt Currently, 36 countries, 29.07% grt
INTERNATIONAL BWM Plan and Record Book BWM System performance standard Compliance schedule to install BWMS Survey and certification requirements Port State Control procedures
NATIONAL US Coast Guard Final regulations issued March 2012 Main requirements include: BWM plan and record keeping; BWM standard (same as IMO) with review in 4 years; Compliance schedule (similar to IMO); Acceptance of Alternative BWMS for 5 years (9 BWMS accepted under AMS)
Regulatory schedule - IMO Ballast capacity Year of ship construction Before 2009 2009-2011 2012+ > 5,000 m3 Ballast water exchange or treatment until 2016 Ballast water treatment only from 2016 Ballast water treatment only Before 2009 Constructed 2009 + 1,500 5,000 m3 Ballast water exchange or treatment until 2014. Ballast water treatment only from 2014 <,1500 m3 Ballast water exchange or treatment until 2016. Ballast water treatment only from 2016 Ballast water treatment only Ballast water treatment only Enforcement 12 months after ratification i.e. - earliest October 2012 if ratified now - Installation at first Intermediate or Periodical Survey
Regulatory schedule - USCG Implementation Schedule for Approved Ballast Water Management Methods Vessel s ballast water Date Vessel s compliance date capacity (in cubic meters) constructed New vessels All On or after Dec. 1, 2013 On Delivery Existing vessels Less than Before 1,500m 3 Dec. 1, 2013 First scheduled drydocking after Jan. 1, 2016 1,500 Before 5,000 m 3 Dec. 1, 2013 Greater than Before 5,000m 3 Dec. 1, 2013 First scheduled drydocking after Jan. 1, 2014 First scheduled dry-docking after Jan. 1, 2016
NATIONAL US EPA Vessel General Permit (VGP) Dec 2008 BWM plan and record keeping; BWM exchange; Allows states to impose additional requirements; New VGP issued March 28, EIF Dec 19, 2013 BWM Standard the same as USCG Implementation dates the same as USCG No EPA approval process for BWM systems No extensions for new ships
LOCAL New York and California BWM standard that is 100x and 1000x greater than IMO and USCG Considerable lobbying by industry coalition EPA Science Advisory Board report standard not possible with current BWM technology Reason prevails, for the time being, in New York Uncertainty remains in CA
REGIONAL EU BWM equipment not included in the Marine Equipment Directive (MED) EU is considering amending MED to bring in the equipment required by the BWM Convention as a mandatory standard Possible EU approval regime could become reality in October 2013.
INTERTANKO Action The Key Challenges Technical treatment equipment and approval Regulatory BWM Convention implementation and its enforcement
May 2012 - INTERTANKO Council recommends comprehensive document detailing technical, operational and compliance challenges and proposing solution to be sent to IMO and proposing solutions be sent to IMO August 2012 Joint submission to IMO s MEPC 64 co-sponsored with Liberia, the Marshall Islands, Panama, BIMCO, CLIA, INTERCARGO, InterManager, IPTA, NACE and WSC
IMO MEPC 64 (Oct 2012) Submission Explains the challenges being faced for effective implementation of the BWM Convention and to provide proposals to address those challenges Submission covered FOUR key areas: 1. Guidelines for approval of ballast water management systems (G8); 2. Availability of Ballast Water Management Systems (BWMS); 3. Survey and certification requirements 4. Procedures for port State control
1. The need for revision of the Guidelines for approval of ballast water management systems (G8) to improve transparency and ensure appropriate robustness of Ballast water management systems (BWMS) Greater transparency of information on the Type Approval Certificate and its enclosures Total Rated Capacity, 60m3/hr tested but approved to 6000m3/hr Type Approval process needs to more accurately reflect real-world environment aboard Brackish and freshwater tests High sediment waters Proposals to strengthen Type Approval process To ensure that a BWMS works in practice as well as theory
2. The availability of BWMS and sufficient facilities to install BWMS As the BWM Convention dates are progressively surpassed the number of ships to which the requirements apply 12 months after full ratification continually increases Ship yards and BWMS manufacturers coming under increasing pressure to install systems within the time frame (implementation schedule) Recommend discussion of new BWMS installation dates BWM Convention cannot legally be amended until convention enters into force Problem was recognized in 2007 when limited technologies were available to meet first implementation date of 2009 IMO Assembly adopted resolution recommending acceptance by parties of delayed installation date
3. Survey and certification requirements for ships constructed prior to entry into force of the BWM Convention No phase-in period for survey and certification of ships following entry into force ROs required to review and approve BWM Plans as well as survey and certify ships within 12 month period Solution provided at MEPC 63 commence issuance of BWM Certificates prior to entry into force Proposal to issue circular in this respect to increase awareness through industry and maintain uniform implementation
4. Sampling and analysis procedures for port State control purposes Urge harmonised standard operating procedure for sampling and analysis of ballast water by PSC. Coupling of Type Approval process with the enforcement process Currently the Type Approval process is separate from the PSC process so an approved BWMS may not meet the PSC analysis once installed on board. Uncertainty in the PSC sampling and analysis process key impediment to further ratification
OUTCOME OF MEPC 64 1. Revision of the G8 Guidelines Decided not to amend the G8 guidelines (at this time), BUT agreed to develop additional guidelines on the application of the G8 guidelines which to address the issues raised in our submission 2. Availability of BWMS Established as correspondence group (lead by Japan) to develop an Assembly resolution regarding the implementation of Regulation B-3
OUTCOME OF MEPC 64 3. Survey and certification requirements Agreed with our proposal to issue an MEPC Circular 4. Sampling and analysis procedures for PSC Agreed with our proposal to instruct BLG (and FSI) Subcommittee that sampling and analysis procedures for PSC should be no more stringent than what is required for type approval of BWMS
BLG 17 (Feb 2013) Type approval. INTERTANKO joint submission on type approval guidelines accepted. Increased transparency of type approval process and more info provided to ship operators on BWM system capabilities and limitations. PSC procedures. Agreed to undertake a trial period for port state control sampling and analysis. The trial will commence once the BWM Convention has entered into force and will initially run for two years. During trial period, it is agreed that port state control officials will refrain from initiating criminal sanctions against the vessel and its crew should the sampling show that the discharged ballast water does not meet the standards in the BWM Convention.
Assembly resolution on implementation dates (MEPC Correspondence Group led by Japan) Agreement amongst a large majority of the group that there should be an extension of the implementation schedule for existing ships. Opposing views which were almost equally divided as to whether this extension should apply to new ships. Extension being considered for both new and existing ships is to delay the installation dates until the ship s first renewal survey after the entry into force of the BWM Convention. INTERTANKO will continue to push for the extension to apply to both new and existing ships.
Ballast Water Guidance To assist members during selection, assessment and installation for existing and new built vessels: INTERTANKO Guidance on the Selection and Installation of Ballast Water Management Systems for Tankers Physical Installation Pumping Control system approval and certification Treatment type Operating practicalities Released January 2012
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