Move intended to relieve Ballast Water Management Convention implementation burden on shipowners.
21 October 2016
Recognizing the implementation challenges posed by the International Convention for the Control and Management of Ships’ Ballast Water and Sediments (BWM), the Luxembourg Maritime Administration recently announced it will consider requests for early renewal and de-harmonization of IOPP certificates from other statutory certificates covered by the Harmonized System of Survey and Certification (HSSC). The Administration highlighted the heavy burden on shipowners to comply with the Convention’s D-2 standard.
The International Convention for the Control and Management of Ships’ Ballast Water and Sediments (BWM) will enter into force on 8 September 2017. From 8 September 2017, ships to which the BWM Convention applies are required to carry on board an approved ballast water management plan, ballast water record book and conduct ballast water management in accordance with regulation B-3, as amended. Ships to which the BWM Convention applies, excluding floating platforms, FSUs and FPSOs, are also required to be surveyed and issued a certificate
The BWM Convention’s deadline for the installation of approved ballast water treatment systems (BWTS) meeting the D-2 Standard is the first International Oil Pollution Prevention (IOPP) renewal survey following 8 September 2017. As a signatory to the 1988 SOLAS Load Line Protocols, Luxembourg surveys are performed under the Harmonized system of Surveys and Certification (HSSC), including the IOPP survey.
Implementation Challenges
Shipowners are currently faced with a number of challenges related to the implementation of the BWM Convention. There are concerns regarding the commercial availability of type-approved BWTS. No systems are currently approved by the United States and it could take a number of years for equipment approved under the IMO guidelines to be ready for installation. Shipowners installing systems not currently authorized in the United State run the risk of having to incur significant costs to modify or replace installed equipment in the near future. Moreover, the dockyard capacity to fit ballast water treatment systems on board ships is also questionable.
The Luxembourg Maritime Administration has therefore stated that it will not object to the adjustment of Luxembourg vessels’ IOPP Renewal Survey to extend the date for D-2 compliance under the approved draft amendments to the Convention’s implementation scheme. On the basis of a positive report from the vessel’s Recognized Organization, Luxembourg will authorize the RO to perform an IOPP renewal survey and issue a new full term IOPP certificate with a 5-year validity. Owners are however invited to reintegrate the IOPP survey into the HSSC at their earliest convenience.
This pragmatic approach will afford shipowners more time to identify and install BWTS which comply with global type-approval standards within the Convention’s deadlines.
Download Circular CAM 10/2016 – Entry into force of the Ballast Water Management Convention