Last minute reminder about the BWM Convention key issues

Overview

The IMO International Convention for the Control and Management of Ships' Ballast Water and Sediments (BWM Convention) enters into force and all ballast water to be discharged on or after 8 September 2017 must be either D-1 or D-2 compliant.


The IMO International Convention for the Control and Management of Ships' Ballast Water and Sediments (BWM Convention) enters into force on 8 September 2017 – here’s a reminder of the key issues:

All ballast water to be discharged on or after 8 September 2017 must be either D-1 or D-2 compliant.

The Installation or retrofitting of a ballast water management system (BWMS) before an existing ship's compliance date is not required under the Convention to be operational for compliance purposes. Ballast water exchange (BWE) will suffice as a means of compliance until the ship’s D-2 compliance date (in general terms pending the International Oil Pollution Prevention (IOPP) certificate renewal date after 8 September 2017).

Ships are not subject to compliance with the BWM Convention Regulation D-2 Ballast Water Performance Standard before the ship’s specified date of compliance, under the current draft Regulation B-3 Ballast Water Management for Ships - also known as the D-2 implementation schedule. This should be reflected in the BWMP in order to avoid being forced to use an installed BWMS before the ship’s compliance date - if not desired.

As always, national regulations might dictate otherwise so it is recommended to check with local agents for the current regulations regarding BWM.

All ships must have the following documentation on board before 8 September 2017: 

  • an International BWM Certificate(IBWMC)
  • a properly kept BWM record book(BWMRB)
  • a ballast water management plan (BWMP)
  • evidence of relevant BWM reporting.

It is recommended that the ship’s approved BWMP is firm in terms of being ship specific but flexible in terms of BWM operations, providing the ship with options in case of unforeseen circumstances. Furthermore, it is recommended to have and/or keep the D-1 Ballast Water Exchange procedure in the BWMP as this option might be needed both for exchanging treated ballast water in open sea, as well as part of the ship or port’s contingency planning.

Recommended initiatives

  • The ships’ Safety Management System should be updated to include the BWMP
  • Familiarisation and training for relevant officers and crew must be carried out
  • A copy of an installed BWMS’s type approval certificate should be carried on board.

 

International Oil Pollution Prevention Certificate recoupling or re-harmonisation
Some flag states have taken a pragmatic approach to ships that have decoupled or de-harmonised the IOPP certificate before the entry into force of the BWM Convention. Due to the draft revised D-2 implementation schedule, some ships now face an earlier compliance date than anticipated. This pragmatic approach allows recoupling or re-harmonisation of the IOPP certificate to its original renewal date and is therefore realigned with the ship’s survey schedule of the harmonized system of survey and certification (HSSC). If this applies it is recommended to investigate the options and impact of such recoupling or re-harmonisation.

A new BIMCO publication the "Shipmaster's Ballast Water Manual" will be published shortly. The manual is intended for use by seafarers as a quick reference guide on how to implement and comply with the International Convention for the Control and Management of Ships’ Ballast Water and Sediments.

 

For further information related to the IMO BWM issues please refer to the following relevant articles and guidance:

The Little Blue Book on Ballast Water
To assist Danish shipping companies implement the Ballast Water Convention, Danish Shipping has produced the “The Little Blue Book on Ballast Water” in September 2017.

This brochure is a guideline on the various aspects of implementing the Ballast Water Convention and is intended to be used by the vessels’ masters, officers and the shore based personnel involved in the implementation of the convention. 

The Little Blue Book on Ballast Water was initiated by Danish Shipping and developed by LITEHAUZ through a donation from the Danish Maritime Fund.

Peter Lundahl Rasmussen
By Peter Lundahl Rasmussen
in Copenhagen, DK
 

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