In anticipation of the IMO BWM Convention entry in force on September 8th 2017  many Shipowners choose to de-harmonize the IOPP Certificates from HSSC.

The IMO MEPC.71 has adopted new time frames for implementation of the Convention and essentially postponed the BWTS retrofit requirements till after September 8th 2019. 

The revised Regulation B-3 of the BWMC, expected to be adopted at MEPC 72.

The revised Regulation B-3 requires that existing ships with IOPP certificates due for renewal between September 8th  2017 and September 8th  2019, must comply with the D-2 standard no later than at the first IOPP renewal survey after September 8th 2019.

The new revised timelines will require vessels with de-harmonized IOPP Certificates to comply earlier than if they were on the original IOPP Certificate renewal schedule.  In some cases, as early as two years.

 

Albion Marine recommend to their clients - Shipowners in such cases to review a new compliance schedule and consider to re-harmonize the IOPP Certificates. Essentially, consider reverting to the original schedule.

 

Many Flag States on request from the Shipowners would allow to reharmonize the survey schedule of the decoupled IOPP certificate with the HSSC.

Reharmonizing the survey schedule of the IOPP certificate with the HSSC shall be granted :

 

  • In case the IOPP Certificate de-harmonization was performed within the HSS window - The renewal survey shall be carried out concurrently with an annual or intermediate survey as applicable. The new IOPP Certificate will be subsequently issued, with the same expiry date as the original certificate.
  • In case the IOPP Certificate de-harmonization was performed outside the HSS window – The new occasional survey shall be carried out, reinstating the original schedule and to re‐issue the full term IOPP Certificate.

Albion Marine recommends to approach Flag States (Class on their behalf as appropriate) to discuss the options pertaining to each specific vessel. As always we are available to assist.

IMO  MEPC.71 reached a compromise agreement on the Convention  implementation schedule.

Existing ships should comply with the D-2 discharge standard on the first IOPP renewal following entry into force if:

  • This survey is completed on or after 8 September 2019, or

  • A renewal IOPP survey is completed on or after 8 September 2014 but prior to 8 September 2017.

Vessels should be compliant with the D-2 discharge standard on the second IOPP renewal survey following entry into force, if the first renewal survey following the date of entry into force of the convention is completed prior to 8 September 2019 and if conditions 1 or 2 above are not met. That effectively removes the option of IOPP de-coupling as a means of compliance postponement. 

Albion Marine Solutions participated in MEPC.71 meetings and is pleased that agreement has been reached and industry can move on with planning and implementation. Shipowners of over twenty four thousand vessels will benefit from new implementation schedule for IMO Ballast Water Management Convention as they now have more time for the equipment selection. This is beneficial, especially considering an economic impact and latest developments with G8 Guidelines and USCG Type Approval process.   

This compromised decision is also good for the industry – according to Albion Marine Solutions Director Sergiy Yakovenko.  New schedule will move the peak of retrofits by two years and will spread over a period up to year 2024. By that time many older vessels will be replaced with new build vessels with  already installed  treatment systems. BWTS makers will need to be ready to satisfy a highly competitive new build market  instead of  more fragmented retrofit market. First generation of treatment systems will be phased out very quickly.  This put more pressure for sooner completion of certification according  to new IMO G8 and USCG Type Approval. 

 While 2019 seems far away, but it is not. Generally it takes 9 to 12 months from date the BWTS selected till equipment reaches the yard. In addition Shipowners should allow few months for Shipboard Survey, Equipment Selection and Feasibility Studies. Time to act is now.New timelines are also in line with USCG ballast water compliance policies, which generally aim that all ships dry docking in 2019 and later should have USCG TA BWTS fitted.

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