Regulation - BIMCO Bulletin

Regulation

REGULATION June 2020 Shipowners urged to rethink strategies as Covid-19 disrupts BWMS plans By Ashok Srinivasan, Manager, Maritime Safety & Security at BIMCO The bottleneck is back; the number of compliant ballast water management systems (BWMS) on the market will reduce sharply from 28 October 2020. Shipowners are, therefore, strongly encouraged to scrutinise their installation and retrofitting plans to assess if any changes are necessary. The urgency of the situation has been exacerbated by the disruption of retrofits caused by Covid-19. When the International Maritime Organizations (IMO) ballast water convention (Convention) came into force on 7 September 2017, shipowners were faced with several challenges when it came to the approved BWMSs on the market. These related to nonavailability of compliant systems, lack of services and spare parts, challenges in operating the system itself, crew training, and so on. However, the biggest problem for shipowners was that the countdown to compliance had begun: companies had to ensure their ships complied with the new D-2 standard1 of the Convention within the given timeline, which was linked to the renewal of their International Oil Pollution Prevention (IOPP) certificate. Shipowners are, therefore, strongly encouraged to scrutinise their installation and retrofitting plans During this period, the availability of approved BWMSs began to improve and shipowners had more options from which to choose. But, from 28 October 2020, the number of approved and compliant BWMSs will fall sharply. The reason: when the renewed G8 guidelines were adopted in 2016, it was decided that all new BWMSs must be tested in accordance with these new guidelines and that, from 28 October 2020, all BWMS installations on ships must be type-approved, based on the updated guidelines, as amended. Extra benefits in new BWMS code From 28 October 2020, the number of approved and compliant BWMSs will fall sharply In line with regulation D-3 of the Convention, the installed BWMS must be approved by the national administration in accordance with the IMO Guidelines for approval of ballast water management systems (G8). However, experience showed that many of the type-approved BWMSs suffered from operational problems, leading to inconsistency and unreliability in performance. To improve the situation for shipowners, BIMCO and other industry partners, called for two important changes. The first was a plea for a better and more robust set of type-approval guidelines to ensure shipowners could install a reliable BWMS, one that would work efficiently and fulfil all regulatory requirements. The second was a request to give shipowners more time to implement the Convention. Both industry proposals were positively received by the IMO. The result was a new and improved set of type-approval guidelines resolution MEPC.274(71), also called 2016 Guidelines which was later renamed a mandatory ballast water management system code (BWMS Code) by IMO resolution MEPC.300(72). Shipowners were given an extra five years to comply with the Convention linked to the renewal of the IOPP certificate. The new BWMS Code brings several benefits over the original G8 guidelines. These include: Ashok Srinivasan is Manager, Maritime Safety & Security at BIMCO. He is responsible for coordinating BIMCOs initiatives on a variety of technical, operational and regulation related matters and represents BIMCO at meetings held at the International Maritime Organization (IMO) and the International Association of Classification Societies (IACS) to name a few. He holds a master mariner education, dynamic positioning officer, marine lead auditor and an MBA from Copenhagen Business School and has been a visiting faculty at the marine colleges in India, teaching navigation, safety and cargo related courses. Ashok is also an experienced seafarer with 18 years in the maritime sector, starting his career with A.P. Moller Maersk. 1. BWMS should be tested at an independent test facility that has a quality control/quality assurance programme in place. 2. BWMS should be provided with a self-monitoring facility and should record data when the system exceeds compliant operational parameters. 3. Appropriate bypasses or overrides to ensure the safe operation of the ship need to be in place and used in the event of an emergency. Because of the Covid-19 pandemic, most testing facilities are facing delays and disruptions 4. The BWMS Code requires an installation survey and commissioning testing as part of the certification process. More systems available, but Covid-19 causes disruption According to the IMO2, more than 80 systems have been type-approved. However, of these, only six have obtained the type-approval based on the BWMS Code or 2016 G8 guidelines. Although BWMS manufacturers are working hard to get the latest type-approval for their systems, because of the Covid-19 pandemic, most testing facilities are facing delays and disruptions. This means that although there will be a few more BWMS available for installation by 28 October 2020, it is highly unlikely that all 80 systems will have been approved by this deadline. The Covid-19 situation has already disrupted the shipping industry and as soon as the situation improves, there will be a high demand for drydocking facilities, with the inevitable increase in price. However, if the pandemic disruption continues until 28 October, shipowners must ensure that the BWMS selected for installation is type-approved as per the BWMS Code. It should be noted that installation of a BWMS approved under the old G8 guidelines resolution MEPC.174(58) will not be in compliance with the Convention. Check of installation and retrofit plans necessary According to BWM.2/Circ.663, the word installed means the contractual date of delivery of the BWMS to the ship. In the absence of such a date, the word installed means the actual date of delivery of the BWMS to the ship. Photo (top): iStock / Bim As a result, BIMCO advises shipowners to check their current BWMS installation and retrofit plans and, if not they have not already done so, seriously consider the installation of a BWMS that has been typeapproved according to BWMS Code. Should shipowners decide not to change their selected systems, even if they have been type-approved according to old G8 guidelines, they can review their purchase and fitting contracts and make necessary adjustments to the installation date. However, keeping the superiority of newer BWMS in mind, it is recommended that shipowners plan and install a BWMS that has been type-approved according to the Code. Regulation D2 of IMO BWM Convention necessitates the installation of BWMS as one of the compliant measures. 2 http://www.imo.org/en/OurWork/Environment/BallastWaterManagement/Pages/ BWMTechnologies.aspx 3 BWM.2/Circ.66/Rev.1- Unified interpretation of Appendix I (Form of the International Ballast Water Management Certificate) of the BWM Convention, including installed date. 1 Connect with BIMCO Facebook Twitter Linkedin YouTube