Ballast Water Management Convention – IMO announcement July 2017

It has been announced that the dates by which ships must install ballast water treatment (BWT) plant have changed. The IMO announcement can be found here, but the following summarises the main points.

IMO.jpg

 

To recap briefly, nearly all internationally trading vessels will be required to install ballast water treatment plant. The dates by which this plant must be installed is staggered, and the IMO set this up so that installation was linked to each vessel’s 5- yearly International Oil Pollution Prevention (IOPP) renewal survey, thus allowing a 5 year spread of implementation dates for the global fleet. Prior to the recent announcement, vessels were required to have ballast water treatment plant installed before the next IOPP renewal survey that fell after 8th September 2017.

With the recent announcement, there is no change for most vessels unless their next IOPP renewal falls between 8th September 2017 and 8th September 2019, in which case BWT plant is not needed for a further five years. For existing vessels on which the next IOPP renewal falls after 8 September 2019, BWT plant will need to be installed before that renewal date.

In short, all ships that would have had to install BWT plant between 8th Sept 2017 and 8th Sept 2019 will be able to postpone this installation for up to 5 years. The net result is that global installation dates will now be spread through the period from 8th September 2019 to 8th September 2024, as opposed to 8th September 2017 to 8th September 2022.

There is no change to the date of Entry into Force (EiF) of the Convention, i.e. 8th September 2017. This means that all ships still need to have an International Ballast Water Management Certificate (IBWMC) from this date, along with a ballast water management plan and a ballast water record book. This will require Class survey before the EiF date, and the IBWMC will, in most cases be issued by Class.

Apart from allowing the postponement of BWT plant on ships with IOPP renewals between 8th September 2017 and 8th September 2019, the other implication of the announced changes is that decoupling* of the IOPP renewal after 8th September 2017 will no longer be of benefit. The rules say that ships must have BWT plant installed by either the first or second IOPP renewals after the date of EiF, and since decoupling will cause a renewal to be brought forward, this could likewise cause the date by which BWT plant is required to be bought forward for the vessel.

For any existing vessels that are due their IOPP surveys before 8th September 2017, these should go ahead as planned. For these ships, BWT plant will not need to be installed until their IOPP renewal surveys in 2022.

The announced changes do not affect the requirement to comply with US Coast Guard (USCG) ballast water treatment rules when in USA waters. Now that four BWT systems (Alfa Laval PureBallast 3, BalClor (by Sunrui), OceanSaver BWTS MKII, Optimarin Ballast System) have been approved by the US, further delays to the installation of this plant on US-trading vessels are unlikely to be acceptable.

*Decoupling (or de-harmonising) refers to the separation of the IOPP renewal survey from the main class renewal survey.

Andrew Crawley