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Ballast Water ManagementConvention PSC Issues
SAFEMED III – Ballast Water Training
EMSA, Lisboa - 3rd /4th September 2014
Brian Elliott
Senior Project Officer for Environmental Protection
EMSA
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The bio-invasion of alien invasive species into the ballast water carried
by ships is not visible and does not alert the costal populations or
government or media (like in the case of accidental oil pollution from
ships)….. but the damages in the eco-system could be extremely serious
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The Ballast Water Management Convention
aims to stop this bio-invasion
Status
It will come into force one year after the ratification of the flag States
representing 35% of the world fleet.
According to the most recent data (Source: IMO at III 1 (July 2104)) 40 States
– the most recent being Germany, the Republic of Congo, Switzerland andTonga - have ratified the Convention for a percentage equal to 30.25% of the
world fleet.
Plus - coming soon - Argentina, Italy, Japan and Turkey = 34.2%
Finland and Belgium?
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Main technical issues and last development at 65 MEPC (May 2013):
Treatmentsystems
Ballast watersampling
Draft IMOResolution atthe 65 MEPC:
Installationpostponement
to the first IOPPrenewal for
existing ships
BWMCircular 42adopted by65 MEPC
3 years oftrials forseveral
samplingmethodologies
Cost?
Ships Owners
MaritimeAuthorities
Reliability?
Samplingprotocol?
Approvedat IMO
AssemblyNovember
2013
Afterentry intoforce of
the BWMC
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Ballast treatment systems
Draft Resolution adopted in 65 MEPC to be approved during
next MSC (November 2013):
The systems must be approved according IMO procedures:
Moreover both systems must undergo to biotoxicity testing
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Ballast treatment systems
Have the systems to be submitted to a double approval processbefore to be installed on EU ships?
Revised process under the new EC Biocides Regulation.
………But for EU member States what happens with
reference to:
the European biocides Regulation 528/2012/UE
Directive 96/98/EC on marine equipment
Moreover, it should be noted that USCG has issued its own rules already in force by June 2012. These are
applicable to new ships built from December 2013 and existing ones by 2016. All ballast water treatment
systems (BWMS) intended to be used in the waters of the United States will have to be approved by the USCG
although those approved according to IMO procedures may be accepted, but only after their verification.
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In the mean time FSI (III) isworking for PSC guidelines
• It is an Additional Guide for PSC Authoritiescovering the additional issues raised which focuson the preparation for PSC and on what to dowhen a discharge has been stopped.
• It is based on the draft created by TF 33 of the
Paris MoU• Problem Convention does not fit into “normal”
PSC format
• III 1 developed guidance for a usual PSCInspection
Inspections
Initial
Inspection
Clear
grounds
More
detailed
inspection
PSC Guidelines
• BWM Certificate
• Procedures on board according BWM Plan• Type approval certificate for BWMS
• Ballast water record book and records
• Appointment/familiarisation of the Designated Officer and other officers
• Overall condition of the ship• Steps to meet D-1 or D-2 standard
• Exceptions proof
• Type approval certificate
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Inspections
Initial
Inspection
Clear
grounds
More
detailed
inspection
PSC Guidelines
• Absence of one of the above mentioned documents• False entries in the WB Record book
• Condition of the ship not correspond with documentation
• Information from third parties
• Designated Officer not appointed and Crew not familiar with on board procedures• No familiarisation or No exception proof
• Operation of BWMS not in line with instructions
• Unreported accidents or Untreated discharges
Inspections
Initial
Inspection
Clear
grounds
More
detailed
inspection
Draft PARIS MoU Guidelines
• Actions based on the analysis of the B.W. Management Plan
• Check of the duties of the Designated Officer
• Check of the record-keeping applied on board (if in compliance with the Convention)
• Is the ballast water management on board the ship in accordance with the operationsoutlined in the ship’s BWMP
• has an unsanctioned change been made to the structure, equipment, fittings,
arrangements or material associated with the BWMP• Is the BWMS and associated equipment in good working order and being used
correctly
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Inspections - 4 Stage Approach
Stage 1
Initial
Inspection
Clear
grounds
Stage 2: More
detailed
inspection
Draft PARIS MoU Guidelines
Sampling
Stage 4:
Detailed
Analysis
Stage 3:
Indicative
Analysis
Draft PARIS MoU Guidelines
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Prevention Detention
New concept: partially included into
other PSC procedures (applicable even
at the end of the initial inspection)
In case of evidence of non-compliance
(e.g.: based on sampling findings)
Immediate mitigation measures
(including stopping of the discharge of
b.w)
Based on:
• Absence of certificate or
documents
• Failure of the BWMS
• Evidence from sampling results
In case of major non
compliance/detainable deficiencies:Prohibition of the discharge of b.w.
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Detention – Serious Nature• absence of an IBWMC, BWMP or BWRB;
• indication that the ship or its equipment does notcorrespond substantially with the IBWMC and BWMP;
• absence, serious deterioration or failure of properoperation of equipment required under the BWMP;
• the designated officers or crew are not familiar withessential BWM procedures including the operation ofBWMS and all associated BWMS equipment;
• no ballast water management procedures have beenimplemented on board;
• no designated officer has been nominated;
• the ship has not complied with the BWMP formanagement and treatment of ballast water;
• ballast water has been discharged other than inaccordance with the regulations of the BWM Convention
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Check BWRB entries – exchange and treatment
Check BWMP on board/
approved/implemented
Check BWRB on board
and completed
BWMS operated
correctly and
maintained.
Designated Officer?
PROHIBIT ANY FURTHERDISCHARGE
Inspection on the
BWM Convention
completed
NO - but still doubts about
the BWM Convention
implementation on board
Grant permissionto leave
Ship has left
the port
No grounds to
suspect non-
compliance
Non-
conclusive
Compliance
Proved?
Check IBWMC
In Order SAMPLING
Not in Order
YES
STEP 1: INITIAL INSPECTION
STEP 2: MORE DETAILED INSPECTION
Not Valid
STOP THE
DISCHARGE
STEP 1:
INITIAL
INSPECTION,
Article 9.1 of
the BWM Convention
Mitigationmeasures
Warn, detain orexclude, as
appropriate
Valid
Violation detected?
NO STOP THEDISCHARGE
Inform Flag and/or
next port forappropriatemeasures
Inspection
Completed
Inspection
Completed
Article 9.2
of the BWM Convention
Other More Detailed Inspection
Requirements NO
SAMPLING
Article 9.1 of the
BWM Convention
Clear
Grounds
PSC FLOWCHART
Yes STEP 4:
DETAILEDANALYSIS
STEP 3:
INDICATIVE ANALYSIS
Ship in port
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Check BWRB entries – exchange and treatment
Check BWMP on board/
approved/implemented
Check BWRB on board
and completed
BWMS operated
correctly and
maintained.
Designated Officer?
PROHIBIT ANY FURTHERDISCHARGE
Inspection on the
BWM Convention
completed
NO - but still doubts about
the BWM Convention
implementation on board
Grant permissionto leave
Ship has left
the port
No grounds to
suspect non-
compliance
Non-
conclusive
Compliance
Proved?
Check IBWMC
In Order SAMPLING
Not in Order
YES
STEP 1: INITIAL INSPECTION
STEP 2: MORE DETAILED INSPECTION
Not Valid
STOP THE
DISCHARGE
STEP 1:
INITIAL
INSPECTION,
Article 9.1 of
the BWM Convention
Mitigationmeasures
Warn, detain orexclude, as
appropriate
Valid
Violation detected?
NO STOP THEDISCHARGE
Inform Flag and/ornext port forappropriate
measures
Inspection
Completed
Inspection
Completed
Article 9.2
of the BWM Convention
Other More Detailed Inspection
Requirements NO
SAMPLING
Article 9.1 of the
BWM Convention
Clear
Grounds
PSC FLOWCHART
Yes STEP 4:DETAILED
ANALYSIS
STEP 3: INDICATIVE ANALYSIS
Ship in port
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What to do with a vessel in non-compliance
• retention of all ballast water on board;
• require the ship to undertake any repairs required to the BWMS;
• permit the ship to proceed to exchange ballast water in a locationacceptable to the port State providing ballast water exchange isstill an acceptable practice for the specific ship and such areas orestablished in accordance with Guidelines on designation of areasfor ballast water exchange (G14);
• allow the ship to discharge ballast to another ship or to anappropriate shipboard or land-based reception facility; or
• allow the ship to manage the ballast water or a portion of it inaccordance with a method acceptable to the port State.
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Thank you
[email protected] www.emsa.europa.eu
Ballast water sampling withthanks to Mahle and GoConsult
mailto:[email protected]:[email protected]