2017. The year of entry into force of the BWM Convention and, for many shipowners and operators, the year that the 5 year countdown to fleet wide compliance commences. Aside, of course, from those pursuing the de-harmonisation strategy.
De-harmonisation is an interesting concept. On one hand, one can completely understand owners eagerness to engage this strategy. After all, with the continued uncertainty in the BWM industry, questions over the ability of existing BWMS to meet the revised G8 guidelines and, most crucially, the appalling charter rates across the shipping industry, kicking the decision to comply potentially 5 years down the line is an attractive “get out” that spares a big hit on today’s struggling bottom line.
However, it is not without its risks.
Firstly, if an owner de-harmonises their entire fleet, the vessels will all fall due for compliance within the same year (likely 2022). Setting aside the obvious commercial and cashflow issues with footing a fleet wide compliance bill in one calendar year, given a significant number of other owners will follow the same approach, there will undoubtedly be multiple, and significant, bottlenecks. The main bottleneck will predominantly be the BWMS themselves, however engineering/consultancy capacity, drydock slots and Class Approval timelines will all suffer.
Secondly, the relationship between IOPP renewal dates and BWM compliance has not yet been implemented, officially. The obfuscation during MEPC 70 has led to two, competing, compliance timetable proposals due to be debated further during MEPC 71 (which, coincidently, does not meet until July 2017 – a mere two months before entry into force). With neither timetable seemingly gaining unilateral support, IMO could, in theory, revert back to the original compliance timetable as written in the convention, or, alternatively, propose a completely different compliance mechanism – such as the next scheduled drydocking. Given the de-harmonisation process is essentially undermining the implementation of the convention, a convention that IMO has vigorously endeavoured to ratify; one would not be surprised if they do take a tough stance on this.
Third, and most importantly, IOPP de-harmonisation does not overcome the USCG compliance requirements. With the first, and long awaited, USCG Type Approvals finally being issued to Optimarin, Oceansaver and Alfa Laval, gaining any further extension is now highly unlikely, meaning once existing extensions start to run out, owners will need to start fitting systems.
So why does all of this matter?
Well its quite simple – owners may put off dealing with BWMS due to their plan to de-harmonise, but that doesn’t mean the door has been sealed for 5 years. If IMO move the goalposts again, if existing USCG extensions lapse within those 5 years or if a vessel without an extension relocates to the US, the vessel will need to comply.
Regardless of the strategy, it is imperative that owners start to plan for compliance.
Begin undertaking vessel surveys and feasibility checks on the compliance options available. Look at outline BWMS component locations, pipe runs and aim to arrive at a choice of BWMS for each vessel. It is a very low cost undertaking and places owners in advantageous position, with a solution “ready to go” for each vessel.
Similarly, if a vessel has a drydock coming up, install the necessary tie-ins to the existing ballast system. Not only does this get the intrusive, disruptive, and somewhat low cost, work out of the way, but it also enables a BWMS to be installed on the run, at a later date, if required.
Following this approach, owners will be well prepared for whatever the BWM industry throws at them over the next 5 years.
Chris McMenemy is General Manager at Cleanship Solutions, which is part of Malin Group – a collection of companies offering a comprehensive range of services to the marine industry. To keep up to date please follow us on LinkedIn (https://www.linkedin.com/company/malin-group), Facebook (https://www.facebook.com/malingroup/) or on our Instagram (@malin_group), for a steady stream of eclectic and interesting engineering images.