Legend / Explanation of abbreviations:
- BWMC: Ballast Water Management Convention, 2004
- BWMP: Ballast Water Management Plan
- BWMS: Ballast Water Management System
- BWRB: Ballast Water Record Book
- BWE: Ballast Water Exchange
- EU: European Union
- GT: Gross Tonnage
- ItoS: Information to Shipping
- IMO: International Maritime Organization
- IOPP: International Oil Polution Prevention
- MED: Marine Equipment Directive
- MEPC: Marine Environment Protection Committee
- NSI: Netherlands Shipping Inspectorate
- RO: Recognised Organisation
- RSW: Refrigerated Seawater
- TRO: Total Resistant Oxidant
- UV-T: Ultraviolet Ballast Water Treatment
Definition ballast water and exceptions
Ballast water means water with its suspended matter taken on board a ship to control trim, list, draught, stability or stresses of the ship (as per BWMC article 1, sub 2).
Therefore, water carried in moon pools, wash water from cargo hold cleaning, a sea water sanitary system, the contents of RSW tanks on trawlers, the hopper content on a dredger and similar volumes of water are not to be considered as ballast water. Also, ballast water in heeling- and trimtanks, provided they are fully contained in a closed system, is not to be considered as ballast water.
Procedure in case of poor performance of the BWMS due to challenging water qualities
The issue of ports with challenging water qualities is currently under discission in IMO. So far, no final conclusions was reached after several MEPC meetings. It is however likely that some guidance may be developed to handle these situations, including the following provisions:
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By-passing of the BWMS is allowed when:
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the system is unable to treat the water, for the flow rate is reduced below 50% for more than 30 min, or the UV-T is below approximately 40%; and
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when the self-monitoring of the BWMS indicates that the system is not working properly.
Evidence of the above must be provided through the alarm log of the system. The minimum amount of water necessary for safe navigation shall be taken in, into as few tanks as possible.
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Ballast water to be treated, where possible by using the BWMS in full. When the flow-through exchange method is to be performed this shall be done under the conditions of B-4.1 (distance from ashore and water depth) or B-4.2 (designated area)
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All actions shall be recorded in the BWRB, whereby it is helpful to add a hardcopy of the alarm log that necessitated the above actions.
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The standard of regulation D-2 is the goal, and therefore regulation B-4.3 (no delay, no deviation) will no longer be applicable.
For Netherlands' flagged ships the shipowner shall contact their RO with a well-founded proposal, while using the above information.
Netherlands contacts for the request for acceptance of the exception according to BWMC regulation A-3.5 (same location)
For foreign flagged ships: contact psc@ilent.nl
For Netherlands flagged ships: contact nsi-tez-kv@ilent.nl
Ballast Water Management Plan (re-)approval
The BWMP needs to be re-approved by the Classification Society if the management methods changes (e.g. because D2 standard becomes mandatory). It is also recommended to implement contingency measures in the BWMP (e.g. for malfunction of BWMS or in case of poor performance BWMS due to challenging water qualities).
Discharge of ballast water at the repair yard
The discharge of ballast water in dock or at the repair yard is also subject to the Convention. Discharges of water are the responsibility of the shipyard and subject to local regulations / instructions.
Ballast Water Exchange
Unmanned non-propelled ships that cannot exchange ballast water
Unmanned non-propelled ships are unable to exchange ballast water during the voyage. Typically, the master will apply regulation B-4.4 on the basis of safety issues. Therefore, during the interim period of ballast water exchange, unmanned non-propelled ships are not required to exchange the ballast water. This is also subject to acceptance of the Port State concerned. When the D-2 standard becomes applicable to these ships, alternative methods of treatment will need to be applied, like external treatment, the use of drinking water or in-tank treatment.
Application of regulation B-4.3 of the convention when conducting BWE
According to BWMC regulation B4-3, a ship shall not be required to deviate from its intended voyage, or delay the voyage in order to perform ballast water exchange conform regulation D-1. This is also reflected in the BWM.2/Circ.56 on BWE where the North Sea exchange area is designated. If any of these conditions cannot be met, only the tanks which can be exchanged completely need to be exchanged. For the remaining tanks, BWE is not required and should not be carried out. This is of particular importance since partial exchange may revive organisms in the ballast water and have an adverse effect.
When there are no opportunities for BWE during the complete voyage, no additional measures need to be taken. The reason for not conducting BWE shall be recorded in the BWRB.
When the D-2 standard has become mandatory for the ship the D-2 standard must be complied with and regulation B-4.3 is considered not applicable anymore.
Type approval
Type approval of a BWMS installed on board according to the 'old G8 guidelines'
Upgrading of a BWMS to the 'new G8 guidelines' (as per resolution MEPC.279(70)) or the Code for approval of BWMS is not required for existing (type-approved) systems. These systems may continue in service under its existing type-approval (as per resolution MEPC.174(58), the 'old G8 guidelines') until replacement. The installation of such a BWMS, type-approved according to the 'old G8 guidelines', may continue until 28-10-2020.
Type approvals that are accepted by the Netherlands' Administration
A BWMS must have a National Type Approval certificate until these systems are placed on the MED list. However, taking the Regulation 789/2004/EC into account, type approvals issued by other EU Member States are also accepted. Exceptions to the above have been agreed due to special circumstances. In that case the NSI shall be contacted beforehand through/via the RO's branch office.
Survey and certification
Due date of application for ships below 400GT
These ships may have a disadvantage with regards to implementation of the regulation D-2 standard since they are not in the possession of an IOPP certificate. Therefor the due date for application is 8-9-2024, which is the ultimate date allowed for Convention ships.
Recommendations for commissioning testing
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It is recommended to clean all ballast tanks and discharge any sediment to reception facilities, and to check all valves (especially cross-over valves to other systems for tightness) before commencing the commissioning test.
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For the characterization of the intake conditions it is recommended to take an inlet sample of 500 litres and analyse this for organism abundance. This in order to better prove proper functioning of the system, and to make trouble shooting easier in case of non-compliance
Overflow of ballasttanks
The practice of overflow during filling of ballast tanks cannot be continued, if a system operating with active substances is installed. The TRO, which is the typically chlorines content, of the ballast water entering the tanks in that case is too high to be discharged overboard without neutralization.
Lockout-tag-out principle
The lockout-tag-out principle is also acceptable in case of retrofitting a BWMS on an existing ship, in order to maintain operational system functionality (e.g in case combined general service pump, fi-fi/bilge-duty). This however only when this has been specially considered and accepted by the ships' RO. This shall be documented in the approved BWMP.
The lockout-tag-out procedure instead of blanking off tanks is also acceptable; but this only after special consideration and acceptance by the ships' RO and with final approval by the NSI.