ItoRO no. 31 - Ballast Water Management Convention (BWMC) 2004

Introduction

This Instruction to Recognised Organisations no.31 (further: Instruction) covers various subjects of the Ballast Water Management Convention (BWMC) 2004. It replaces partly the Q&A Ballast Water Management Convention (BWMC) 2004 which was formerly used to inform the stakeholders. This former document has been amended in response to developments and recurring questions raised by the stakeholders (mainly ship owners and classification societies).

In addition to this Instruction, there is also an Information to Shipping on this topic.

Compliance of semi-submersible ships, heavy lift vessels and similar vessels

The large volumes of water needed to carry out lifting operations by these ships are usually taken in and discharged at the same location (in compliance BMWC regulation A-3(.5)) and in that case thus not subject to regulation D-2 (Ballast Water Performance Standard).

Ideally for these ships, the ballast system is split into a high capacity system for lifting operations and a separate system with a Ballast Water Treatment System (BWTS) complying with the 'D-2 standard'. The sediment management for the 'uncontrolled' tanks should be detailed in the Ballast Water Management Plan (BWMP) and may constitute regular tank inspections to assess the amount of sediment and a schedule for flushing or cleaning.

Possibilities for an exemption for ships on a fixed route

The procedures according to Resolution MEPC.289(71) – 2017 Guidelines for risk assessment under regulation A-4 of the BWMC (G7) should be followed. Any method or combination of methods may be applied, like the OSPAR/HELCOM protocols or the Same Risk Area (SRA) concept.

Possibilities for an exemption for ships on occasional voyages

Guidance is given in BWM.2-Circ.52 - Guidance on entry or re-entry of ships into exclusive operation within waters under the jurisdiction of a single Party, as revised. Upon agreement of the States involved, regulation D-1 (Ballast Water Exchange Standard) compliance may be sufficient.

Ballast Water Management Systems (BWMS), installation and commissioning

The use of freshwater as ballast water in order to comply with BWMC

For freshwater that is either being generated on board, or taken on board from ashore, and used as a ballast water, the BWMS in principal needs approval according to the Convention (Resolution MEPC.169(80) - Procedure for Approval of ballast water management systems that make use of Active Substances (G9)). The BWMP of a ship using this method shall detail the procedure for the initial cleaning of tanks, and the measures to prevent mixing with outboard water. Ballast operations conducted with freshwater shall be recorded in the Ballast Water Record Book (BWRB). This is considered an alternative method that requires type approval in accordance with resolution MEPC.279(70) – 2016 guidelines for approval of ballast water management systems (G8).

Possibilities for external treatment of ballast water

External treatment of ballast water is allowed, provided the installation complies with the relevant standards (type approval according to G8 / BWMS-Code). If external treatment is used as an alternative method of compliance, in lieu of fitting a treatment system on board, this needs to be included in the BWMP. Ballast operations, also in case these are conducted with external treatment, shall be recorded in the BWRB.

Specific recommendations and requirements for commissioning testing

The commissioning test shall be carried out to the satisfaction of the attending RO surveyor following a complete installation of the BWMS, and following a satisfactory technical commissioning of the system by the manufacturer or its representative.

With regards to BWM.2/Circ.70, as revised, paragraph 7, the NSI requires the commissioning testing to be conducted by a firm engaged in commissioning testing of BWMS. This firm is to be approved by the RO in accordance with Annex 1, paragraph 18 of IACS UR Z17, as revised.

For the analysis of the representative sample taken:

• an indicative analysis with direct measurement, in accordance with BWM.2/Circ.42, as revised. Solely one of the indicative analysis methods, as listed in table 3 of annex 1 to BWM.2/Circ.42, as revised, shall be used.

• equipment that operates via an indirect measurement, as defined in paragraph 2.4.1 of annex 1 to BWM.2/Circ.42, as revised, shall not be used, pending the development of a standard for Compliance Monitoring Devices.

For temporary acceptance in case, due to different reasons, non-compliances, occur reference is made to Instruction to Recognised Organisations no.7, item f.1., where the most common non-compliances are included.

(non- or partly) Applicability of the BWMC

1) Ships, not designed or constructed to carry ballast water

Ships, not designed or constructed to carry ballast water, are outside of the scope of the Convention and do not need a BWMP or a International Ballast Water Management Certificate.

The RO may, in such cases, issue a 'Statement of non-applicability', stating the reason: 'The ship is not designed or constructed to carry ballast water.'

2) Ships registered in the Netherlands and only operating in Netherlands' waters while they are not equipped with a BWMS

The RO may, in such cases1, issue a 'Statement of non-applicability', stating the reason: 'The ship is registered to a party and only operates in waters under the jurisdiction of that party'. In addition the same condition/restriction shall also be mentioned on the ships' Class Certificate.

3) Ships flying foreign flags and operating in Netherlands' waters only, while they are not equipped with a BWMS

In general, queries concerning foreign flagged ships must be processed through/via the Port State Control department2.

• Informatietype: Informatie voor uitvoering
• Documentsoort: Werkinstructie
• Toegangsrechten: Extern
• Identificatie: PUC_746589_14
• Versie: 1
• Datum beschikbaarheid: 07-08-2023
• Geldigheid van: 08-08-2023
• Wijzigingsdatum: 07-08-2023
• Titel: ItoRO no. 31 - Ballast Water Management Convention (BWMC) 2004
• Organisatie: Inspectie Leefomgeving en Transport
• Taal: Engels
• Thema: National Instructions