News

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.

Albion Marine Solutions is pleased to participate  in the  IMO MEPC.71 meeting as part of Canadian delegation.

Number of important issues being discussed : BWM Convention, Air Pollution and Energy Efficiency, GHG Emission Reduction and Amendments to Mandatory Instruments.

Here are some key points in relation to IMO Ballast Water Management Convention:

• Probably a topic which attracts most of the attention is a proposal by Brazil at al to extend the implementation timelines for existing vessels by another two years – compliance  would require by first IOPP renewal after September 8, 2019.  With some additional provisions this proposal is backed up by submissions  from China and Greece .
• Extension of the IMO BWM Convention to vessels below 400 GRT.
• Code for Approval of BWMS will likely will be made mandatory. A number of guidelines will need to be updated accordingly.
• Submissions for  IMO Approval and Final Approval:
  • Type Approval: Damen Invasave 300, Semb-Eco LUV 500 and 1500, Kurita BWMS, ATPS-BLUEsys
  • Basic Approval: Microfade II BWMS, Envirocleanse inTank BWTS
  • Final Approval: ECS-Hybrid BWMS
• Guidance on System Design Limitations as part of the  revised G8 will be discussed. It is aimed to assist Shipowners to consider the equipment limitations in selection process.
• Changes to Type Approval  - Guidelines G8 and G9. 11 documents pertaining to this topic have been submitted .
• Experience Building Phase document  developed by working group led by Canada will be discussed. Implementation of Regulation B-4.
• Review number of proposals related  to operation in areas where ballast water exchange can not be performed due to distance to shore or depth. is as important as taking a decision on the implementation schedule  and
• Contingency measures when a ship cannot meet the D-2 standard. 

Please stay tuned for an update on outcome of the IMO MEPC.71  discussions. 

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

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.   

 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.

13 years since Convention has been adopted in 2004.

3 months till Convention enters into force.

3 days till IMO MEPC.71 meeting which may or may not extend the implementation time line. In any case it will be interesting meeting. I am looking forward to attending MEPC.71 as part of the Canadian delegation.

IMO Ballast Water Convention is ratified and will enter into force on 8th of September 2017. It is a fact, and there will be no coming back.

It has been long journey: over 40 different Guidelines, Circulars and Resolutions pertaining to the implementation of IMO BWM Convention have been developed. 69 BWTS have received  IMO Type Approval Certificate. Thousands of BWTS  have been fitted and hundreds have been in operation, some since 2009.

Here are two simple steps Shipowner need to take  to get ready.

Step 1:

After Convention  enters in force,  all vessels must comply with ballast water discharge standard D-1 (ballast water exchange).

Prior to  8th of September 2017 a vessel  must:

• Implement an Approved Ballast Water Management Plan
• Implement and maintain  a Ballast Water Record Book
• Order an Initial  Class Survey and
• Receive an International Ballast Water Certificate (D-1)

Step 2:

After Convention enters into force and on IOPP Certificate renewal, all existing vessels must comply with D-2 standard (ballast water treatment).

In order to comply with D-2 Shipowner must:

• Choose  IMO Approved  Ballast Water Treatment system
• Complete an engineering retrofit design
• Request Class  Plan Approval
• Carry out a  retrofit
• Request a Class  Acceptance  Survey and
• Receive  an International Ballast Water Certificate (D-2)

Maritime industry has a considerable experience with installation and operation of various Ballast Water Treatment Systems. This experience has prompted several proposals to postpone the implementation deadline which will be discussed on  3rd to 7th July, 2017  at MEPC.71.

• MEPC/71/12 - Proposal by Brazil , Cook Islands, India, Liberia, Norway and UK  
• Ships constructed on or after 8 September 2017 shall comply on delivery
• For existing ships, link to IOPP retained with up to two years delay depending on IOPP renewal date. It means, all ships compliant by 8 September 2024.
• MEPC/71/17 – Proposal by China to support previous MEPC.70 proposal with flat 2 years delay.
• MEPC/71/19- Intercargo and Intermanager propose an exemption for top side tanks of  bulk carriers.
• MEPC/71/28-Submission by   Japan  does not support any delays in principle – but ships without IOPP certificate (i.e < 400 GT) to be compliant by 8 September 2024.
• MEPC/71/30- Greece supports proposal by Brazil at all. and adds two years for new builds.

In order to change the existing schedule qualified  2/3 majority vote is required.

Many Shipowners have decided to not wait for the outcome of MEPC.71. They have planned for a retrofit according to the original schedule or have arranged to de-couple the IOPP Certificate and therefore postpone a retrofit for another five years.

Many have taken advantage of buyer’s market and secured supply of BWTS and engineering services for future retrofits. Albion Marine Solutions is busy with inquiries regarding our optimized Shipboard Survey / 3D Scan and “turn key” retrofit engineering  package.