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George Kiadimos*: The challenges in Shipping Industry following the entry into force of the BWM Convention on the 8th September of 2017

It was back in 1973 when IMO in an embryonic stage, started researching the effects of the spreading of the epidemic disease bacteria through the discharge of ballast water and Sediment, with Resolution 18 of the International Conference on Marine Pollution.


Three resolutions were required by the IMO, namely: Res.50 (31)(1991), the Res. 774 (18)(1993) and Res. A. 868 (20)(1997), in order for the BWM Convention to be finalized on February  2004' which was (eventually) ratified on 8 September  2016 and will be entering into force the following year.
Although thirteen (13) years have passed for the Convention ratification, the Maritime community is still concerned about several points before the final implementation.
Until the next session of Marine Environment Protection Committee (MEPC) in July 2017, we have the following two proposed implementation programs regarding the installation of Treatment technology (D-2 Standards):
1.    Compliance with D-2 Standards, at the first IOPP* renewal survey after 8th September 2017.
2.    Compliance with D-2 Standards  at the first IOPP* renewal survey completed after 8th September  2017, unless that survey is completed prior to 8th September  2019, in which case compliance is at the first IOPP renewal survey completed after 8th  September  2019.
* The IOPP renewal survey refers to the renewal survey associated with the IOPP Certificate required under MARPOL Annex I.
It is understood that Vessels with keel laying date after the BWM Convention entry into force will be required to have an installed treatment system at delivery.
For the compliance of the ships with the BWM Convention required:
- Approved ballast water management plan.
- Keeping record book for ballast water operation procedures
- Using one of the applicable ballast exchanging methods or using an approved ballast water treatment system according to the timetable for compliance with the D-2 Standards.
- Survey for obtaining the ‘’International Ballast Water Management Certificate’’ for compliance with the Convention.
- Training and familiarization of the crew operating ballast water Treatment technologies, on-board the vessels.

In due course, Shipping Companies, Classification Societies, Flags of the Vessels and technical offices will face several technical challenges relating to the installation of the Ballast Water Treatment Units. Some of the technical challenges in question are as follows:
1.    The Revised G8 Guidelines and how this will affect the industry and the installation of such systems. The effective dates of Ballast Water installation Systems taking into account the revised G8 guidelines are as follows:
¬    The ballast water management systems installed on ships on or after 28 October 2020 should be approved taking into account the 2016 Guidelines.
¬    The ballast water management systems installed on board ships prior to 28 October 2020 should be approved taking into account either the Guidelines (G8) as adopted by resolution MEPC.174 (58) or preferably the revised 2016 Guidelines as per resolution MEPC. 279(70)

2.    De-harmonisation of the IOPP Renewal Surveys by performing it before the scheduled survey window, i.e. before 8 September 2017. This will give more time to Ship-owners for retrofitting a BWMS during the 5 year validity of the new IOPP certificate, but the truth is that same problem and perhaps shipyard unavailability for the installation with longer turnaround times will be one of the possible future challenges.

3.    The De-harmonising of the IOPP renewal survey will postpone the compliance dates of the BWM Convention but in the meantime USCG compliance dates for existing vessels are running, and based on scheduled dry-docking dates need to be considered separately. It must be underlined that since the first three USCG type approved BWT Systems have already been announced, it is expected that USCG will start to harden its position against the Ballast Water discharge and Extension Program policy. (Already initiated civil penalties on Ballast water discharge violations).  Reference is made to the New Marine Safety Information Bulletin on Ballast Water Management (BWM) Extension Program, dated 6th March 2017. (https://www.uscg.mil/msib/docs/003_17_3-6-2017.pdf)

4.    The Convention will require all ships to implement a Ballast Water Management Plan and most of them will be subject to D-2 Standards compliance (Installation of treatment technology), including yachts, barges, fishing vessels, etc.

5.    Shipping companies should establish training programs regarding the Ballast Water Treatment Technology management and continuous updating of Seafarers both on board and on land in order to avoid lack of knowledge due to crew rotation.

6.    The process of the on-board ballast water sampling method still remains unclear waiting for further instructions by the IMO.

7.    It will be interesting to see the reaction of other States having their Local legislation regarding the Ballast water requirements and their Ports States Control’s approach, regardless of the IMO BWM Convention, such as Australia, etc.
Many of these topics will be discussed at the next MEPC session but on the top of the agenda will be the possible extension with respect to the calendar for ballast water management systems installation (2nd Implementation program).
Therefore, we look forward to the final decisions of the next session of the IMO in July ‘17 predicting a very ‘hot’ summer.
*Lloyd’s Register Specialist, Technical Support Office, Marine & Offshore

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