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Ballast water in 2018: what shippers need to know and need to do

The industry is much occupied with the challenges of complying with the laws of ballast water management of both IMO and the United States Coast Guard (USCG) and it will not be out of place and the context to say that the ballast water will be the hot topic for 2018.

Recently Ship-Technology has brought out an analysis of the problems in connection with the BWMS which attempts to draw attention to very significant factors that the industry must pay attention to.

The Ballast Water Convention requires all ships in international trade must so manage the ballast water that aquatic organisms and pathogens are removed or rendered harmless before the ballast water is released into a new location.

There are now two standards with the Convention: D1 and D2.  Relatively easy, D1 requires the ships to exchange their ballast water in open seas away from coastal areas, ideally at least 200 nautical miles from land and in water at least 200m deep. D2 expects them to carry a ballast water management plan which includes description of the actions to be taken to implement the requirements and a ballast water record book which must contain the details of ballast water taken on board, circulated or treated and discharged. And for ships weighing 400 giga tonnes and above, they must have in possession an International Ballast Water Management Certificate.

Regulations of both IMO and USCG with regard to D2 specify the same number of permitted organisms that can be carried and discharged; however, there is difference between them. The USCG regulations say that any organisms dumped into their waters must be already dead but IMO talks of “viable organisms” implying that those organisms that cannot survive the transition or they are unable to reproduce in the new environment.

From 8 September, new ships have had to conform to D2, but it won’t be until 2024, 20 years after the convention’s adoption, that all ships will. For most, this will involve the installation of special equipment to treat the ballast water.

The regulations of US are stricter than IMO’s.  “Since the US is not signatory to the BWM Convention, the USCG is not enforcing it,” explains USCG spokesperson LT Amy Midgett. “Rather, the USCG enforces its regulations on commercial vessels fitted with ballast water tanks.”

Existing ships must comply with these regulations at the first scheduled dry-dock after 1 January 2016, and newbuilds at delivery. Compliance involves either being equipped with a USCG type-approved ballast water management system or an approved Alternative Management System (AMS).

 After five years, the AMS must either achieve USCG type-approval or be replaced with a type-approved system. 

Again, unlike an earlier practice of documenting compliance with one of the accepted ballast water management methods cannot be done by an operator since six BWM systems have been type-approved by USCG and the enforcement of the regulations has become tougher with USCG.

“The CG has taken enforcement actions ranging from issuing warnings to taking civil penalty actions. The Captain of the Port may impose an operational control restricting the vessel’s movement or cargo operation, monetary penalty, and an increase in examinations,” says Midgett.

“Restrictions in cargo operations may cost a vessel owner anywhere from $30,000 to over $100,000 in port, agent, or pilot fees, fuel, cargo delays, or other penalties. There is also potential for prosecution if criminal intent is suspected.”

Uncertainty remains an irksome source of frustration in any walks of life, be it professional or personal. The industry as such is said to be frustrated with the stringent regulations of USCG in particular.

Particularly those who operate in US waters face a big challenge in selecting the right BWMS for their ships from the six type-approved systems and about hundred AMSs now on the market.

According to Midget, “We have learned that the successful use of a BWMS requires a company’s commitment to engineering design and installation, crew training, and matching the BWMS limitations with the ship’s operations. The Coast Guard is also strongly encouraging vessel owners and operators to plan for contingencies. A vessel’s ballast water management plan should provide directions and alternate measures to be taken if a ballast water management system becomes inoperable, or if the vessel’s intended compliance method is unexpectedly not available.”

Further afield, operators outside the US are struggling to overcome similar hurdles, according to Ed Wroe, technical manager at the International Association of Dry Cargo Shipowners (INTERCARGO).

“There are a number of challenges that owners face, including but not limited to: differences between regional and global requirements; the complexity and cost of retrofitting the systems onto existing bulk carriers; the suitability of available systems to meet operational requirements of the vessels; whether the systems do what they are meant to do; and post installation services/support provided by manufacturers,” he says.

Interestingly, INTERCARGO saw its membership numbers rise significantly from January to September 2017, and although it’s difficult to say how much of this growth is because of the BWM Convention or any other specific piece of legislation, Wroe does put it down in part to the increasing pace of regulatory developments within the sector.

“Shipping companies are more interested in being adequately informed on time and also being more involved in these developments,” he believes, adding that for INTERCARGO’s part, the hope is that BWMS manufacturers will form an association to help the industry overcome the inevitable challenges it will face over the coming months and years.

“That way associations such as ourselves who represent shipowners would be able to have a dialogue with a single body, representing the manufacturers, thus enabling constructive discussions on the needs of the owners and operators,” he concludes

In 2016, what Lloyds’ Maritime senior environment and sustainability consultant Yildiz Williams said appears to be a very pragmatic suggestion to the owners and operators; he asked them to be proactive to the ballast water management issues arising out of two different sets of regulations from IMO and USCG.

 “I always try to encourage any owners and operators to be proactive, which is very helpful,” Williams says. “So definitely start looking into how they can comply, maybe plan their compliance depending on their operational profiles, instead of waiting. I really do think that being proactive is one of the best things they can do.”

Being proactive underscores confidence that is ready to face challenges both expected and unexpected; it is being positive without being vainglorious; and it is taking life as it comes with open hands, an optimism based on the understanding of life as what is.


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