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Mrs. Paillette Palaiologou*: How does BV help with ballast water regulatory compliance?

BV is focused on serving both owners and ballast water system manufacturers.

There are a number of uncertainties with the BWM Convention affecting both. Two of the most important are revisions to the guidelines for approval (G8) and requests for changes to the entry into force date.

The first causes problems with already installed equipment approved in line with the "old" or original guidelines, and that are less onerous than the new ones. Although studies have shown few problems with existing approved BWM systems, owners who have already installed these systems feel penalized due to their early implementation of the convention requirements.

Regarding the entry into force date, under strong pressure from different players, IMO has left the door open for possible postponement. Postponement now seems likely. This has resulted in confusion in the market. On the one hand, we have aggrieved manufacturers who have invested huge amounts of money and, on the other, owners in poor markets happy for further delay.

Our role in this is to provide clear information and in-time services. We certify ships against D-1 method (ballast exchange) - a transitory solution before D-2 (installation of the BWM system) is into force. We provide updates, guidance and training. Most manufacturers already have their products type approved with BV. We assist them to commence re-approval against revised G8 guidelines.

IMO has issued guidelines for type approval (G8). But flag states and recognized organizations may apply their own rules and methods for approval of the BWM system is a statutory matter, we do the job on behalf of the flag. All flags have the right to carry out approval by themselves or to authorize Recognized Organizations, such as BV. Mutual recognition should be straightforward. BV accepts BWM system approvals by other leading societies if the manufacturer holds a class certificate with flag agreement
 
Addressing the most common questions
We approve BWM manuals and equipment installation only on BV classed ships. There are instances where owners apply to one society for approval and certification of an entire fleet to reduce costs. However, this is contrary to our delegated flag state responsibilities. BWMS approval is complex, it affects both class and statutory matters and numerous drawings and information are needed. It is not a matter of ‘one book’ approval only.

The most common question we receive from owners are on costs and the time needed for plan approval and are always doing our best to be in line with their expectations. Also, de-harmonization of the IOPP certificate was a hot topic but most owners are well informed now. Questions about retrofits on existing ships, and how BV can assist, are common, too and we can provide such services through our technical consultancy.

Aligning IMO and USCG standards
The procedure to align these two regimes is quite complicated. G8 requirements are defined by the Convention, all the changes must be ratified by the members (about 168 countries) and that is not an easy process. The G8 was revised recently, but the biggest difference between the G8 and USCG remained: the criteria for remaining organisms after the water has been treated. G8 talks about "viable and no-viable" organisms, while USCG says "live or dead”.

Training
BV provides BWT training for shipowners, mostly in-house. These courses are organized locally and are client-oriented. Our surveyors' training is also important and we have successfully completed a program for all our surveyors. We are close to finalizing an E-learning module which can be also offered to the clients.

*Vice President Regional Chief Executive Hellenic & Black Sea Region BV

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