In the wake of the forthcoming legislation on ballast water, the UK P&I club has published an updated report highlighting a number of key issues that need to be addressed before the Ballast Water Convention countdown starts.
The UK P&I club is one of the largest mutual marine protection and indemnity organisations with over 200 million tonnes of owned and chartered ships insured. For this reason, it has a keen interest in assessing how the changes and challenges of the industry will shape the market in years to come.
The Ballast Water Convention, with Germany as its latest member, is now very close to fulfilling the minimum ratification requirements: It must be ratified by countries representing a total minimum global tonnage of 35%, after which point the Convention comes into force 12 months later.
“There are many stages to compliance and shipowners are urged to start familiarising themselves with the requirements of the Convention if they have yet to do so,” Tan writes.
“The cost of compliance is very high and the necessary finance will therefore need to be organised. A ballast water treatment system can cost from half a million to four million dollars. In addition to the cost of the actual system, there will also be ancillary costs such as the cost of developing a ballast water management plan, drydocking cost and installation cost,” she continued.
The update breaks the steps down towards compliance in the following ways:
- Understanding the standards of compliance – standards of compliance vary depending on the category of ship, date of construction and ballast capacity. It’s important to be aware of the fact that the BWE standard does not require BWMS whereas BWP does; BME will be phased out by 2019. However, the paper points out that BWMS “complying with the D-2 standard may still fall foul of more stringent standards set in other jurisdictions such as the US.”
- Develop a ballast water management plan – this should include a description of the ballast system, including safety and operational procedures, as well as the name of the designated Ballast Water Management Officer who ensures details of all ballast water operations are recorded in a Ballast Water Record Book.
- Select and install a ballast water treatment system – BMWS must be approved by the Administration; there are over 30 ‘type approved’ treatment systems available, which are either use active substances that kill the organisms, chemical disinfection (eg. Chlorination, ozonation) or physical disinfection (eg. UV irradiation, heat, deoxygenation). Some allowances are made for vessels testing prototype BMWS.
- Develop training for ship’s staff – The Convention requires officers and crew to be familiar with their duties in the implementation of ballast water management for the ship on which they serve, which is all the more reason to develop operational experience in advance. A detailed staff training scheme will need to be rolled out.
- Survey, certification and inspection – An initial survey grants an International Ballast Water Management Certificate or Certificate of Compliance is issued to the ship, with an intermediate survey two to three months after installation, an annual survey, and an interval survey every five years. In addition, Port State Control officers can inspect a ship to verify that the ship has a valid certificate, inspect the ship’s Ballast Water Record Book and/or sample the ballast water. If any concerns are raised, a detailed inspection may be carried out.