IMO MEPC 73 Ballast Water Management Review
The International Maritime Organization 73rd Marine Environmental Protection Committee (MEPC 73) meeting was a busy session with most of the focus on the 2020 Sulfur Cap date and Greenhouse Gas (GHG) Emissions. Significant actions were taken for ballast water management as well as some new discussions for the marine industry. A summary of the resulting actions is provided.
An MEPC resolution was approved to amend the Guidelines for ballast water management and development of ballast water management plans (G4) to include contingency measures in the ballast water management plans (BWMPs) as a non-mandatory item. It is up to the discretion of each Member State as to the timing of incorporating the contingency measures in BWMPs. Specifics items to be included as part of the contingency measures will be discussed at future meetings. Regardless of this amendment, Choice Ballast Solutions will continue to include contingency measures in all BWMPs developed – based on the previous information within the MEPC and USCG publications.
MEPC approved circulars on Guidance on System Design Limitations of ballast water management systems and their monitoring and Guidance for the commissioning testing of ballast water management systems. The Guidance on System Design Limitations of ballast water management systems is meant to support the Ballast Water Management System (BWMS Code) for type approval testing of ballast water management systems (BWMS). The Guidance for the commissioning testing of ballast water management systems is to support the survey guidelines under the Harmonized System of Survey and Certification (HSSC).
The Survey Guidelines under the International Convention for the Control and Management of Ships’ Ballast Water and Sediments (BWM Convention) state that surveys should be conducted “verifying that an operational test of the ballast water management system was carried out based on the installation commissioning procedures and that documented evidence is provided which shows compliance of the treated discharge ballast water during the above mentioned test with regulation D-2 through sampling and analysis based on applicable guidelines developed by the Organization”.
For validating compliance of BWMS, the following steps are recommended at the end of the BWMS commissioning:
- A sample should be collected during a ballast water uptake to characterize the ambient water, by any means practical (e.g. in-line sample port or direct harbor sample). The ambient water should be accepted for testing regardless of the level of challenge it poses to the BWMS.
- A sample should be collected during the corresponding ballast water discharge after the full treatment has been applied. Samples should be taken in accordance with the Guidelines on ballast water sampling (G2).
- Samples should be analyzed for all size classes included in the D-2 standard using indicative analysis methods listed in table 3 of BWM.2/Circ.42/Rev.1.
- The applicable self-monitoring parameters (e.g. flow rate, pressure, TRO, UV intensity, etc.) of the BWMS should also be assessed and the correct operation of all sensors and related equipment should be confirmed.
The BWMS validation is successful if the indicative analysis indicates that the discharge sample does not exceed the D-2 standard and the self-monitoring equipment indicates correct operation. The vessel’s International Ballast Water Management Certificate will not be issued for Regulation D-2 until the vessel’s flag is satisfied with the results. This may impact the ability for a vessel to operate.
It is important to note that the HSSC survey guidelines are currently under review and due to be updated in 2019 to specifically address surveys for retrofits of BWMS. The survey items are not mandatory. Therefore, the International Association of Classification Societies requested submissions to MEPC 74 (May 2019) to amend the BWM Convention to make the commissioning procedures and testing mandatory. MEPC agreed. Further information will come on this matter.
The International Maritime Organization is working to improve efficiency and focus actions on those most needed. MEPC approved a means for future outputs to be developed, such as the development of additional training for seafarers on the BWM Convention and items identified from the ballast water experience-building phase (EBP). Any outputs from the EPB may be addressed either at the end of the EPB in 2023 or more quickly for items identified as urgent.
A long discussion occurred this week with regard to an experience-building phase for the 2020 Sulphur Cap. MEPC decided that further information was needed and invited submissions for MEPC 74.
MEPC also agreed work on future actions for:
- Biofouling maintenance (to be addressed in 2020),
- Reduction of PFOS in fire-fighting systems,
- Underwater Noise, and
- Marine plastic litter.
Submitted by Debra DiCianna, Choice Ballast Solutions, Senior Compliance Engineer. Debra is a delegate for the U.S. at the International Maritime Organization (IMO) and serves on the U.S. Environmental Protection Agency Environmental Technology Verification (ETV) Ballast Water Tech Panel. Contact Debra at email@example.com.