Ballast Water Management Convention – Next Steps After MEPC 71
17 July 2017

The International Maritime Organization’s (IMO’s) Marine Environment Protection Committee (MEPC) 71 agreed to a compromise implementation schedule for ships to comply with the IMO’s International Convention for the Control and Management of Ships’ Ballast Water and Sediments (the “Convention), which enters into force (EIF) on 8 September 2017. The move, made at the conclusion of MEPC 71 (7 July 2017), means that ships constructed (as defined by the Convention) before 8 September 2017, to which the Convention applies, will not be required to meet the Convention D-2 standard (i.e. installing a ballast water management (BWM) system (BWMS)) until their first International Oil Pollution Prevention (IOPP) renewal survey after EIF, if this survey is completed on or after 8 September 2019 or, an IOPP renewal survey is completed on or after 8 September 2014 but prior to 8 September 2017; or, at the second IOPP renewal survey after EIF, if the first IOPP renewal survey is completed after the EIF and prior to 8 September 2019, provided that an IOPP renewal survey is not completed on or after 8 September 2014 but prior to 8 September 2017. Ships constructed (as defined by the Convention) on or after 8 September 2017, to which the Convention applies, will be required to meet the D-2 standard on delivery.   A ship constructed (as defined by the Convention) before 8 September 2017 to which the IOPP renewal survey does not apply shall meet the D-2 standard from the date decided by the Administration, but not later than 8 September 2024.

“For many existing ships, this is a practical solution to what had become an increasingly difficult issue for shipowners. However, some shipowners who received early IOPP renewals to address compliance with the previous implementation schedule feel penalized by this process and the Republic of the Marshall Islands (RMI) is reviewing this situation ” says Robert North, International Registries, Inc.’s (IRI’s) Maritime Consultant and a member of the RMI Registry’s dedicated BWM team.

“Shipowners whose vessels trade worldwide were faced with the nearly impossible situation of being required to invest in BWMSs that were not Type Approved by both the United States (US) Coast Guard (USCG) and under the Convention. We expect that this delay will allow shipowners to make long-term investments in dual Type Approved, established technology which will ultimately do more in the long-term to protect the environment,” he continued.

The Convention, which aims to stem the transfer of invasive species in ships’ ballast water, enters into force on 8 September 2017 and has been ratified by the RMI, as well as 60 other signatories. Collectively, the signatories now represent 68.46% of the world’s merchant fleet tonnage. All ships will be required to have a BWM Plan and keep a ballast water record book. Ships will be required to manage their ballast water to meet the so-called D-1 or D-2 standards.

The D-1 standard requires that ships conduct the exchange of at least 95% of their ballast water by volume, and under Convention Regulation B-4, as far away from the coast as possible and in all cases, at least 50 nautical miles from the nearest land in water at least 200 meters in depth. The more stringent D-2 standard sets a limit to the amount of viable organisms which are allowed to be discharged, as well as a limit to the discharge of specified indicator microbes deemed harmful to human health. The RMI co-sponsored a submission to MEPC 71, proposing a Circular as guidance to ships not yet required to meet the D-2 standard and operating in sea areas where ballast water exchange is not possible in accordance with Convention Regulations D-1 and B-4. MEPC 71 agreed to the proposed Circular and ships in this category should not be required to meet the D-2 standard until the date required to do so.

The RMI Registry has placed resources in overlapping time zones to guide shipowners through the complexities of ensuring compliance with the Convention. Leading experts form the BWM Team and are in place in Hong Kong, London, Piraeus, and Reston/Washington, DC. The significant technical resources of the flag are always available to owners and operators from IRI’s 27 worldwide offices.

Click here to view Marine Safety Advisory No. 29-17, which provides further guidance on the amended BWM Convention implementation schedule.