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BALLAST WATER MANAGEMENT

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BALLAST WATER MANAGEMENT

BIMCOs Position
The Ballast Water Management (BWM) Convention will establish a global legislative regime to control the
discharge of ballast water and in particular the discharge of invasive species into the sea. This requires
shipowners to install expensive management and treatment systems and train personnel to use them.
The IMO has adopted an Assembly Resolution on the application of the BWM Conventions implementation
schedule. This Resolution revises the Conventions compliance dates to allow for its future unknown entry into
force date. BIMCO appreciates the pragmatic revision, however, remains concerned that it may still not give
sufficient time to implement all of the requirements of the BWM Convention in practice.
The IMO guidelines for the approval of ballast water treatment systems (G8 guidelines) need strengthening to
ensure that acquired systems are fit for worldwide use and compliant performance is possible under real
operating conditions.
The BWM Convention extraordinarily calls for sampling of ships ballast water during port state inspections.
BIMCO however believes that port states should accept a ships International BWM Certificate as evidence that
its equipment fulfils the requirements of the Convention.
The work of IMO on the sampling and port state control guidelines should give due regard to the G8 guidelines
and their stringency and robustness. The additional measures necessary for compliant operation of treatment
systems should be made clear through a more rigorous type approval procedure rather than through
enforcement measures which go beyond the original testing regime of the system.
Sampling and testing by Port States or National Administrations should be cost neutral for shipowners, unless
the ship is found not to be in compliance with the BWM Convention or other similar regulations.
BIMCO finds that indicative testing and analysis obtained during port state control or other inspections can only
be used as a means of screening for detailed analysis. More stringent testing is needed to determine whether
or not a ship is in compliance. This is because the confidence level of any indicative analysis is low compared
with the detailed analysis described in the IMO guidelines.
Bringing the IMO Ballast Water Convention into force before US type approved treatment systems are available
would put shipowners in a difficult position as they would be required to first fit an IMO type approved system,
only to soon after potentially be required to fit a US type approved system, when it becomes available.
BIMCO calls on equipment-makers and governments to work together to ensure common sense prevails - to
ensure US type-approved ballast water management systems are available to ship owners when the IMO
Ballast Water Convention comes into force.

Discussion
On most ships, use of ballast water is an indispensable part of safe operation. In some circumstances ballast
water is capable of transporting invasive species around the world. To address that issue the BWM Convention
was adopted in IMO in 2004. It has, however, not yet entered into force.

28-06-2016 23:14