The “IOPP Addiction” of the past 6 months has caused much of the shipping industry to focus its efforts on finding ways to push back, as far as possible, the critical IOPP renewal dates associated with D-2 compliance. The “de-harmonisation” approach is a case in point. However, what seems to have been largely overlooked by the industry is that from entry into force, 8th September 2017, owners/operators will immediately be required to comply with the legislation – and undertake, as a minimum, ballast water exchange (D-1).
But exchange isn’t perfect, far from it, and for a number of owners we are working with, exchange is indeed not a viable option for compliance.
If D-1 is not achievable for a vessel, regardless of the IOPP renewal date, D-2 compliance remains the only option. The need to investigate the compliance options and suitability of each for individual vessels is paramount.
This article aims to address some of the fundamental questions we are often asked about ballast water exchange, and will hopefully help owners and operators form a better understanding of what
is required ahead of entry into force on 8th September 2017.
What is involved in Ballast Water Exchange?
The process of ballast water exchange involves the substitution of the water in the vessel’s ballast tanks using one of the following methods:
• Sequential method
• Flow-through method
• Dilution method
The IMO requirements state that any exchange procedures must be carried out, whenever possible, at least 200 nautical miles from the nearest land, and in water at least 200 metres in depth. Where that is not possible, the procedures must be at least 50 nautical miles from the nearest land, and, again, in water at least 200 metres in depth.
What if I trade in waters that don’t meet these requirements?
Some Flag States have designated ballast water exchange areas, in accordance with the regulations, which vessels can use to carry out exchange procedures. If all else fails, IMO has included a specific clause in the BWM Convention, namely Regulation B-4 Item 3, which states:
“A ship shall not be required to deviate from its intended voyage, or delay the voyage, in order to comply with any particular requirement of paragraph 1.”
On paper, this essentially permits Flag States to exempt vessels from the D-1 requirements if it can be demonstrated that the vessel will have to deviate significantly from its trading routes in order to comply. However, it must be noted that to date, such exemptions have been few and far between, and more recently, there have been instances of Flag States essentially “ignoring” this clause, and very specifically, and unequivocally, requiring vessels to comply regardless of the impact to their trading routes.
Are there any risks associated with ballast water exchange?
In short yes. Ballast exchange procedures can have adverse effects on the shear strength and bending moments of the vessel, particularly on vessels which are sensitive to longitudinal strength – such as tankers and bulk carriers. In addition to this, the procedures could result in slack water within the tanks, with additional free surface moment impacting the vessel’s dynamic stability. It is therefore crucial that the ballast water management plans be developed, implemented and operated with the vessel’s safety in mind. It is for this reason that the IMO developed the G4 guidelines; titled “Guidelines for ballast water management and development of ballast water management plans,” which outline the specific stability and strength calculations that must be checked during the development of a vessel’s ballast water management plan.
What documentation do I need to have in place by 8th September 2017?
Each vessel will be required to have a ballast water management plan, ballast water record book and a ballast water management certificate / certificate of compliance, fully approved by the respective Classification Society, implemented and in use onboard. From the entry into force date, all vessels will thereafter be required to conduct, as a minimum, ballast water exchange in accordance with the D-1 standard, with all ballast operations logged in the ballast water record book.
Of course, many vessels already have ballast water management plans in place, covering the exchange procedures; hence these vessels will likely not require any additional documentation. However, those vessels without plans in place will require these be produced and approved by Class.
So what if my vessel(s) just cannot conduct ballast water exchange?
The IMO Convention is fairly explicit – from entry into force (8th September 2017), vessels can comply using either the D-1 or the D-2 standards. If compliance using the D-1 standard is not possible, it stands to reason that D-2 is the only plausible compliance mechanism. As outlined earlier, the D-2 standard typically requires the retrofitting of BWMS.
Indeed, in our recent experience with a number of owners/operators across a number of areas of the shipping industry, the inability to comply using D-1 has resulted in them bringing forward their BWMS retrofit plans in order to comply using D-2.
What about Same Risk Area – or similar regional exemptions?
It is understood that a number of Flag and Port States are having ongoing discussions regarding the implementation of “Same Risk Areas (SRA)” within specific bodies of water – potentially leading to local exemption options for regional vessels. Whilst the recent MEPC meeting addressed the SRA issue somewhat, it did not issue any further guidance on the timelines for approval of same. The dedication of same risk areas is likely some time away from becoming a reality, if at all, and hence we are continuing to advise clients to plan for compliance from entry into force.
So where should I begin?
With 8th September 2017 looming, planning is crucial. Developing fleet wide ballast water management plans is an involved process and will require time to produce, refine and submit to Class. It is suggested that owners look to either embark on the development of these plans in-house (resource & skillset permitting) or engage an external consultant as soon as possible. Owners / operators should bear in mind the longitudinal strength and dynamic stability requirements of the guidelines when engaging an external consultant – one with naval architecture capabilities is crucial.
With a significant number of ballast water management plans to review and approve, Class Societies may struggle to deal with the impending demand. We recommend owners / operators get these submitted as soon as possible to ensure approvals are in place prior to 8th September 2017. Many Class Societies will also insist on carrying out a survey of the vessel prior to issuing the Ballast water management certificate – so owners / operators should plan for this too.
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, Facebook or on our Instagram, for a steady stream of eclectic and interesting engineering images.