Ballast Water Regulations by the International Maritime Organizations and the US Coast Guard
A (new) challenge for shipowners and charterers
Ballast Water Treatment is a topic that has recently gained new attention among shipowners and charterers due to up-dated guidelines and decisions from the IMO and the USCG.
On September 08th, 2016, the IMO ratified the Ballast Water Convention which has entered into force recently on Septem-ber 08th, 2017. From that date on each vessel above 400 Gross Registered Tonnage (GRT) will be required to have on board:
1 An approved Ballast Water Management Plan (BWMP) according to a. D-1 Standard Ballast Water Exchange, b. D-2 Standard Ballast Water Treatment; 2 A Ballast Water Record Book (BWRB); 3 An International BWM Certificate (according to D-1 or D-2 Standard).
For you - on board of our Briese vessels - basically nothing will change until 2019 because over the last years we have already executed the ballast water exchange voluntarily. Anyhow, we need to take care about the ballast water exchange and the records related to that intensively because Port State Controls worldwide will put a greater focus on ballast water as they have done until now.
Having this in mind, Briese like to call your attention on the following:
- The BWRB shall be maintained on board the ship for a minimum period of two years, and shall contain each operation concerning ballast water (complete traceability!) including accidental or exceptional discharge of Ballast Water not otherwise exempted by this Convention, describing the circumstances of and the reason for the discharge. • At least a 95% volumetric exchange of ballast water is needed. • For ships exchanging ballast water by the pumping- through-method, pumping through three times the volume of each ballast water tank shall be considered to meet the standard. • At least 200 nautical miles from the nearest land and in water at least 200 metres in depth ballast water may be discharged.
Exceptions: A ship shall not be required to deviate from its intended voyage, or delay the voyage, in order to comply with any particular requirement of the D-1 Ballast Water Exchange Standard. Furthermore, a ship conducting Ballast Water ex-change shall not be re-quired to comply with the D-1 stand-ard, if the master reasonably decides that such exchange would threaten the safety or stability of the ship, its crew, or its passengers.
Anyhow, please note that local authorities can always refuse the discharge of ballast water when the D-1 Standard is not met for any of the aforementioned reasons! Please inform your inspection group immediately in case you cannot meet the D-1 Ballast Water Exchange Standard. • Consider the dedicated ballast water exchange zones, e.g. in Intra North Sea traffic:
Red areas = No Ballast Water Exchange
According to IMO regulations a vessel has to be compliant with D-2 standards with the next IOPP re-newal survey after 08th September 2017. It has been agreed with classification societies and flag states to decouple IOPP surveys before the entry into force date to give ship owners more time to be compliant. Therefore Briese decoupled many IOPP sur-veys over the last half year.
Below an example for better understanding: A scheduled IOPP renewal survey is due on 15th April 2018.
Due to the new ballast water regulation the vessel should have been compliant with D-2 Standards on this date. But the survey has been decoupled on 27th July 2017. The new compliance date is still the next IOPP renewals survey but which is now on 27th July 2022.
End of June 2017, in the last MEPC meeting, the IMO post-poned the D-2 compliance date for two years and published a new implementation schedule. All IOPP surveys after 08th September 2017 until 08th Septmeber 2019 need to be complaint with next IOPP renewal survey. This new imple-mentation schedule gives ship owners two more years. But what impact has the new decision on the already decoupled IOPPs?
It has been decided that all IOPP surveys which are sched-uled after 08th Septmeber 2019 should stay decoupled. All vessels with a scheduled IOPP renewal survey in the new range (8th September 2017 – 08th September 2019) can do the survey in normal way and no decoupling is necessary.
Furthermore it is possible to re-couple the already decou-pled IOPP surveys if the actual renewal scope is between 08.09.2017 until 08.09.2019.
Therefore Briese re-coupled all IOPP surveys back into the normal window to which this applies. Due to these different actions Briese has the first vessel due for IMO D-2 standards earliest in 2019.
But the USCG regulations are different to the IMO ones. According to USCG a vessel needs to be compliant as follows: • First scheduled dry-docking after 01.01.2014 for vessels with ballast water capacity between 1.500m³ – 5.000m³ • All others first scheduled dry docking after 01.01.2016
After these dates the vessel has to implement a ballast wa-ter treatment system which is approved by the USGC. The regulation is already in force since December 2013. But as many systems and manufacturers did not have an USGC ap-proval on this date the USGC issued exemptions to the ship owners. All of you which are sailing worldwide should have an exemption on board:
A further requirement is that at least three manufactures with USGC approval are on the market. Since beginning of this year the requirement has been fulfilled and therefore the USCG rejected most of the requests for further exemptions.
The chart below gives a brief overview about the IMO and USCG Ballast Water Regulations to comply with the D-2 treatment standard.
Briese created also an own chart to get an overview on which date a vessel is due according USGC regulation and IMO regulation. At the moment the first vessel has to be compliant in January 2019.
With regard to the new USCG policy of rejecting exemption requests, Briese has recently been successful by presenting an overall installation plan including a preferred BWTS and a concrete timeline to the USCG. By that we succeeded in getting considerably extended exemptions for our vessels M/V BBC Jade, M/V Hollum, M/V BBC Marmara and M/V BBC Atlantic.
Regarding the noble objective of clean ballast water and our management measures, one might ask why Briese puts so much effort into the postponement of the BWTS installa-tion. Two simple aspects can clarify that immediately. Most importantly, the BWTS currently on the market are techni-cally not yet mature regarding the treatment capacity or the reliability of all components, e.g. UV-lamps.
Furthermore, the installation of a BWTS is still very costly, a com-mon characteristic of new developments. Assuming falling prices parallel to an increase of the number of USCG-approved BWTS manufacturers, an installation as late as possible is evaluated as the best case for our Briese fleet.
Finally it is our objective to gain more experience with the BWTS which are already on board of our vessels. Today we operate BWTS from five different manufacturers that work with UV or Electro-chlorination plus a filter (pure chemical solutions are not represented in our fleet) which can be seen in the graphic below.
To line out all current options of ballast water treatment, Briese want to keep secret that there are two other possibilities available of (1) port ballast water treatment facilities as well as (2) mobile solutions (e.g. a BWTS onto a mobile container by the company DAMEN). Even though these solutions might be an option from a technical point of view, the high costs as well as the integration into the processes of an operating fleet lead to the evaluation of these solutions as purely theoretical today.
In a nutshell, one can resume that the installation of a BWTS is a cur-rent issue for all shipowners, at least with a medium- and long-term view. Briese focuses on the topic closely both technically and finan-cially to be ready to respond to any developments. Our objective is to get the best BWTS solution paying a considerable price to make the Briese fleet IMO- and USCG-compliant and thereby fit for future!