Maritime

Ballast Water Management

Frequently asked questions

Below you find a collection of FAQs in the fields of convention basics, USCG, local restrictions, technical questions, laid up vessels, FSRU/FSU and tankers.

Click on the questions to read the answers:

Convention basics

Does the BWM Convention apply to all vessels?

Answer:
Answer:
The BWM Convention applies to all ships with ballast water capacity and active in international trade, except ships mentioned in Article 3:

a. Ships which are not designed or constructed to carry ballast water.
b. Ships that only operate in the local waters of a single authority (party), or in local waters of a single authority and on the high seas.
c. War ships, naval auxiliary, or other ships owned and operated by a state and used only on government non-commercial service, as stated in Article 3.2(d) of the convention.
d. Ships with permanent ballast water in sealed tanks that is not subject to discharge.
e. For ships operating usually only in local waters, single international voyages may be granted an exemption under regulation A-4 by following the IMO guidance circular BWM.2/Circ.52/Rev.1. The countries of origin and destination must be approached for consent to the single voyage.

What are the requirements for vessels which are subject to the BWM Convention?

Answer:
Answer:

a. From date of entry into force (EIF), 8 September 2017, all ships shall have and implement a BWM Plan (BWMP) and record all ballast water operations in the BWM record book. The BWMP shall be approved by the administration
b. Vessels above 400 GT (excluding floating platforms, FSUs and FPSOs) are subject to a BWM survey and are required to hold a BWM certificate, as per regulations E-1 and E-2.
c. At the first IOPP renewal on or after 8 September 2019 at the latest, vessels shall meet the D-2 standard by having a ballast water treatment system (BWTS) approved, installed and commissioned. From the point of time where a vessel has to comply with D-2, the International Ballast Water Management Certificate will indicate the D-2 method only.

What are the requirements for vessels below 400 GT and floating platforms, FSUs and FPSOs?

Answer:
Answer:

If the vessel is in international voyage and the BWM Convention is applicable as per Article 3 of the convention, the vessel and also floating platforms, FSUs and FPSOs must comply with D-1 (exchange) or D-2 (treatment) regulations. According to the convention, such vessels shall be required to have an approved BWM Plan (BWMP) and a record book. But a BWM certificate is only required if the flag administration has their own national requirements.

The D-2 compliance date for these vessels is the completion of first IOPP renewal after 8 September 2019.

If the vessel does not have an IOPP certificate, then the compliance date is 8 September 2024 at the latest, if not otherwise given by the flag administration.

If the BWM Convention is not applicable as per Article 3, for instance in the case that the vessel is reasonably permanently positioned, then an approved BWMP for the D-1 standard and a BWM record book should be available in the case of single voyages, by following the IMO guidance circular BWM.2/Circ.52/Rev.1.

What is the BWM Plan?

Answer:
Answer:

The Ballast Water Management Plan (BWMP) is the document that details the procedure for the discharge of ballast water and the handling of sediment in accordance with regulation D-1 (exchange), and/or regulation D-2 (treatment), and regulation B-5 (sediment management). Conducting ballast water discharge and the cleaning of sediments in accordance with the BWMP ensures compliance with regulations D-1 or D-2, and B-5.

This plan must be specific to the vessel and equipment and approved for each vessel by the flag administration or Class if authorized. The plan may include procedures for both D-1 and D-2 if the vessel employs both methods, or D-2 only if D-2 is mandatory for the vessel. A chapter for contingency measures in the event that the treatment system malfunctions is recommended. Some flags do require a chapter for contingency measures. DNV GL has developed a template for the BWMP, which can be found here.

When do vessels need to comply with the ballast water discharge standard in accordance with regulation D-2 (treatment)?

Answer:
Answer:

The D-2 standard becomes mandatory for all existing vessels2 at completion of the first IOPP renewal on or after 8 September 2019. Vessels keel-laid or having underwent a major conversion after 8 September 2017 (EIF date) shall comply with the regulation D-2 upon delivery.


2 For which BWM convention is applicable

Does a vessel need to install a ballast water treatment system in order to comply with regulation D-2?

Answer:
Answer:

The intention of the D-2 regulation (treatment) is to prevent the discharge of harmful microorganisms into new locations. However, the convention is open regarding how this can be achieved, such as by discharging the ballast water at a reception facility (reg. B-3.6). The port state should have the final decision as to whether they accept any equivalent to D-2 and allow discharging in their waters. For most vessels, a treatment system will be the best way to comply with regulation D-2. Such a system must be approved by the administration.

I have a ship with a potable/fresh water generator, and I would like to use this water as ballast on my ship. Will my ship then be in compliance with the convention?

Answer:
Answer:

Even fresh water used as ballast water shall be treated according to the BWM Convention. Regulation B-3.7 accepts other methods of ballast water management as alternatives, but a fresh water generator is not accepted by the IMO for the D-2 standard.

However, such an alternative method has to be approved according to the MEPC Resolution 206(62), which essentially means the alternatives require type approval according to the G8 guidelines.

Do I have to mention both methods, treatment and exchange, in the BWMP of a retrofit project?

Answer:
Answer:

As part of the approval process for retrofitting a vessel with a ballast water treatment system, the owner will be required to submit the BWMP for approval with information regarding the treatment system and its application. Until the vessel has to comply with the D-2 standard (at the first IOPP renewal survey after 8 September 2019), the BWMP may list both methods in the BWMP as approved BWM methods. Once the vessel has to comply with the D-2 standard, only the treatment method shall be listed as the approved method. The exchange procedure (D-1) can remain in the BWMP, but may only be carried out as a contingency measure.

DNV GL has prepared a BWMP template for the D-2 standard, which can be found on our website. This template includes a chapter for contingency measures, which also lists the approved D-1 method. We encourage ship owners to use the BWMP template for D-2 for retrofit projects.

My vessel only operates on the Baltic Sea and the North Sea. Do I still have to comply with the convention?

Answer:
Answer:

Yes, but the convention is open for exemption for vessels voyaging only between specified ports or locations within the same risk area.

An exemption may be given by parties in waters under their jurisdiction (local authorities). The exempting parties shall communicate the exemption to the IMO. This exemption can be given for a period of maximum five years and is subject to intermediate review (reg. A-4). A full overview of the application procedure is given in the Guidelines for Risk Assessment Under Regulation A-4 of the BWM Convention (G7).

For intra North Sea traffic, the IMO guidance circular BWM.2/Circ.56 gives guidance and defines designated ballast water exchange areas.

Within Norwegian territorial waters and economic zone, the Norwegian national regulation applies.

But when the D-2 standard has become mandatory for the specific ship at completion of the first IOPP renewal on or after 8 September 2019, then even a vessel in intra North Sea traffic and intra Baltic Sea traffic has to comply with the D-2 standard.

Can I use an electronic BWM record book for recording my ballast operations?

Answer:
Answer:
In principal, yes. The convention allows the use of an electronic record book (reg. B-2). The BWM record book may even be integrated into another record book or system on board. It is required that each entry is signed by the officer in charge of the operation and each completed page is signed by the master. An electronic record book must therefore be able to make use of an electronic signature.

I need to sail a single voyage between two locations. Can I apply for an exemption?

Answer:
Answer:

A ship operating exclusively under the jurisdiction of one party to the convention, pursuant to Articles 3.2(b) to 3.2(d), may be granted an exemption under regulation A-4 for a single voyage on the condition that the ship performs ballast water exchange in accordance with regulations B-4 and D-1 and an approved BWMP. The requirements of regulation A-4.1.4 (risk assessment) should be addressed to the satisfaction of the countries of origin and destination of the ship.

The IMO guidance circular BWM.2/Circ.52/Rev.1 can be applied with consent of the countries of origin and destination.

Can a vessel have both the D-1 and D-2 standard on the BWM certificate at the same time?

Answer:
Answer:

Yes, the D-1 standard may be maintained in parallel with the D-2 standard on the BWM certificate until the vessel’s D-2 due date, by completion of the first IOPP renewal on or after 8 September 2019. The precondition is that the BWMP is approved for both D-1 and D-2, or the vessel has two approved BWMPs: one for D-1 and one for D-2.

After that date, only the D-2 standard is applicable on the BWM certificate.

What should I do if the treatment system malfunctions?

Answer:
Answer:

Scenario 1

When: Before the vessel’s D-2 compliance date

Type of BWM certificate on vessel: D-1 certificate

Answer: Not applicable, as the treatment system is not mentioned on the certificate. The vessel shall continue to use the approved exchange procedure (D-1).


Scenario 2

When: Before the vessel’s D-2 compliance date

Type of BWM certificate on vessel: D-2 certificate

Answer: The vessel shall have a repair plan and must contact the port authority and flag state administration immediately to discuss contingency measures (see separate question on contingency measures).

Exchange is a possible contingency measure but must be carried out according to an approved exchange method (BWMPwith D-1 approval). It is therefore recommended to obtain D-1 approval and certification beforehand.

We advise ship owners to follow the IMO guidance circular on contingency measures BWM.2/Circ.62.

If time allows, a vessel without D-1 certification may submit a BWMP, including exchange for approval, to DNV GL.

Once the BWMP is approved, and DNV GL receives the Master’s declaration that the BWMP is on board, DNV GL can issue a new certificate including D-2 and D-1. No survey is needed.


Scenario 3

When: Before the vessel’s D-2 compliance date

Type of BWM certificate on vessel: D-1 and D-2 certificates*

Answer: The vessel has the option to carry out ballast water operations either according to the D-1 or D-2 standard until the vessel’s D-2 compliance date.

When there is a malfunction of the treatment system, the vessel needs to perform exchange until the ballast water treatment system (BWTS) has been repaired.

Nevertheless, if the BWTS has a malfunction, then the BWM certificate is limited to D-1 only and therefore D-2 is not fully applicable. So, any PSC might claim the BWM certificate issued for both D-1 and D-2. Thus, the vessel shall have a repair plan and contact the flag state directly or via DNV GL for advice regarding the validity of the certificate and conditions to performing exchange.**

We advise ship owners to follow the IMO guidance circular on contingency measures BWM.2/Circ.62.

*Contact DNV GL with the nature of the BWTS’s malfunction. The convention requires a survey before a repaired BWTS can recommence operation. DNV GL will determine if a survey is required.

**If the vessel also has the class notation BWM(T), or the Clean design notation, and the treatment system malfunctions, the vessel’s owner must inform class as soon as the BWTS is taken out of service.


Scenario 4

When: After the vessel’s D-2 compliance date

Type of BWM certificate on vessel: D-1 certificate

Answer: Not applicable. The vessel must perform treatment after the D-2 compliance date. A retrofit project must have been organized before the D-2 compliance date for approval of documentation, installation and commissioning. The D-1 certificate is to be withdrawn.


Scenario 5

When: After the vessel’s D-2 compliance date

Type of BWM certificate on vessel: D-2 certificate

Answer: The vessel must contact the port authority and flag state administration immediately to discuss contingency measures (see separate question on contingency measures).

We advise ship owners to follow the IMO guidance circular on contingency measures BWM.2/Circ.62.

Exchange may be offered as a contingency measure but cannot be performed without permission from the port authority and flag state. The vessel must obtain approval of the exchange method before proposing exchange as a contingency measure.


Scenario 6

When: After the vessel’s D-2 compliance date

Type of BWM certificate on vessel: D-1 and D-2 certificates

Answer: Not applicable. The vessel must perform treatment after the D-2 compliance date. The D-1 certificate is to be withdrawn.


Scenario 7

When travelling in US waters

Type of BWM certificate on vessel: D-1 certificate

Answer: The USCG treatment discharge requirements have already entered into force.

A vessel must have applied for an extension in treatment compliance from the USCG in order to operate with exchange only.


Scenario 8

When travelling in US waters

Type of BWM certificate on vessel: D-2 certificate

Answer: The USCG requires that the BWMP contain vessel-specific contingency methods. The BWMP should also include procedures for contacting the Captain of the Port (COTP) and reporting to the National Ballast Information Clearinghouse (NBIC) in the event of a BWTS malfunction

The vessel must contact US authorities as soon as possible and ask for instructions. US regulations require that the vessel inform the nearest COTP, but it is recommended that the destination COTP also be informed.

More information on contingency measures in the USA can be found here.

The vessel must obtain D-1 certification before proposing exchange as a contingency measure.


Scenario 9

When travelling in US waters

Type of BWM certificate on vessel: D-1 and D-2 certificates

Answer: See above for the protocols for contacting US authorities.

The D-1 standard can be offered as a contingency measure. It is the decision of the USCG to accept or reject such a proposal.

In case of treatment system malfunction, what contingency measures does the IMO recommend the vessel operator to consider?

Answer:
Answer:

The IMO has established a generic guidance in BWM.2/Circ.62 for situations where ballast water to be discharged from a ship is determined to be non-compliant. In such cases, communication between the ship and the port state should occur. The ship and the port state should consider the following as possible contingency measures on a case-by-case basis:

  1. Actions predetermined in the BWMP of the ship
  2. Discharging ballast water to another ship or an appropriate shipboard or land-based reception facility, if available
  3. Managing the ballast water or a portion of it in accordance with a method acceptable to the port state:
  4. Operational actions,such as modifying sailing or ballast water discharge schedules, internal transfer or ballast water other retention of ballast water on board the ship. The port state and the ship should consider any safety issues and avoid possible undue delays.

Having considered all options above, the ballast water may be discharged in the port or any suitable area, as acceptable to t he port state.

Port state consideration may include environmental, safety, operational and logistical implications of allowing or disallowing the discharge.

The discharge of ballast water is subject to any conditions of the port state. In any case, the ship is required to do its best to correct the malfunction of the BWTS as soon as possible and submit its repair plan to the PSC authorities and the flag state.

Do I need to discharge ballast water in accordance with regulation D-1 or D-2 and perform the records in the BWM record book if my vessel is trading in waters of non-signatory countries or under a non-signatory flag?

Answer:
Answer:
The BWM Convention is international. And even if there are a number of countries that have not ratified the convention and do not require a vessel to fulfil the requirements, DNV GL recommends following the convention at any time to avoid possible comments from the PSC of the signatory state.

Are there additional requirements beyond the convention in certain countries?

Answer:
Answer:
Yes, some countries, such as the Ukraine and the USA, have stricter requirements than those listed in the convention. DNV GL recommends clarifying local requirements prior to conducting discharge of the ballast water in a new port.

Are there any limitations or local prohibitions for chemical treatment systems?

Answer:
Answer:

The type approval process covers the possibility of toxic discharge according to the IMO and/or USCG standards. Chemical treatment systems are required to satisfy minimum toxicity requirements like all BWTSs.

The requirements related to toxic discharge for different US states are addressed in the 2013 VGP and the US EPA’s Generic Protocol for the Verification of Ballast Water Treatment Technology, known as the ETV Protocol.

From when is biological testing at commissioning of a BWTS a requirement and what is DNV GL doing to address this new requirement?

Answer:
Answer:

MEPC 74 (May 2019) approved amendments to regulation E-1 of the BWM Convention. This amendment requires biological efficacy testing when commissioning a BWTS on board a vessel. This amendment will come into effect at the earliest in October 2021, but the MEPC has encouraged flag administrations to start with commissioning testing as soon as possible. As the first administration explicitly requiring commissioning testing, Singapore published on 1 July 2019 shipping circular no. 9 making commissioning testing mandatory for vessels sailing under the flag of Singapore for treatment system installations after 8 September 2019. Other flag administrations have so far not published similar explicit requirements, but Norway indicated that commissioning testing is already required through the HSSC guideline s (Res. A.1120(30)).

For the biological efficacy testing, a test organization needs to go on board the ship to take samples (both at ballasting and de-ballasting). The analysis of the samples is typically performed on board the ship (organism counts have to be carried out within a few hours after the samples were taken). Some bacteriological sample analysis might be required to be done at the laboratory.

If this test confirms that the treated ballast water meets the discharge standard D-2, the DNV GL surveyor will be able to issue a full term International Ballast Water Management Certificate. There is no separate certificate for the test itself, but the test results need to be summarized in a report. DNV GL has recently published a template for such a report, and the template is available at www.dnvgl.com/bwm.

How many biological commissioning tests are needed to be carried out as per the IMO?

Answer:
Answer:

A biological test for the IMO is only required once, at the commissioning of the BWTS and before the International Ballast Water Management Certificate is issued. Please find in our DNV GL website a report template covering IMO requirements for testing and reporting.

Which test facilities can ship owners contact for the biological commissioning test and are there any approved portable test kits available?

Answer:
Answer:

DNV GL has invited potential test facilities to apply to become accepted by DNV GL for performing biological efficacy testing at BWTS commissioning. DNV GL will publish on its website a list of accepted test facilities by the end of 2019.

For becoming an accepted test facility, DNV GL will review the test facility’s standard operating procedures (SOP), including detailed step-bystep sampling methodology and analysis procedures and the relevant QA/QC procedures that are applied by a test facility for sampling and analysis. DNV GL will evaluate if the SOP (for indicative or detailed analysis) meets the requirement of the guidance on ballast water sampling and analysis (BWM.2/Circ.42/Rev.1) and best practises for sampling developed by the EMSA for

  • representative sampling and sampled volumes,
  • analyses of samples for all size classes included in the D-2 standard using reliable and accurate (indicative or detailed) analysis methods,
  • reliable QA/QC procedures for sampling and analysis, and
  • reporting of as per the guidance for commissioning testing (BWM.2/Circ.70).

Analysis methods, including indicative methods, listed in the guidance on ballast water sampling and analysis (BWM.2/Circ.42/Rev.1) may be applied. A test facility may use a portable test kit, given that the reliability and accuracy of this test kit has been validated.

The use of a test kit by the vessel’s crew or the manufacturer of the BWTS is not an acceptable alternative to biological efficacy testing performed by an independent test facility.

Are contingency measures required to be approved by class?

Answer:
Answer:

The contingency measures chapter is required in the BWMP if the administration of the vessel has decided to implement it or if desired by the owner. DNV GL strongly recommends to include in the BWMP a chapter on contingency measures instructing crew on the procedure in the event of a BWTS malfunction where D-2 compliance is required. This shall be according to the IMO guidelines as described in the guidance circular BWM.2/Circ.62.

In case of BWTS malfunction, well-planned BWM contingency measures allow ship owners to avoid unnecessary downtime for the vessel. The port authority of destination and the flag administration are usually to be informed about the malfunction of the BWTS.

DNV GL has prepared a BWMP template for D-2 with a chapter on contingency measures, which can be found here.

Contingency measures are not included in the approved BWMP for D-2. Is it necessary to amend the existing BWMP and to have the plan re-approved?

Answer:
Answer:

If the only change for the BWMP is to include contingency measures, an annex or appendix will be enough to send to class for approval. There is no need to send the approved BWMP for D-2 for re-approval.

What is the procedure for a BWMP that is approved for D-1 and D-2 after the vessel’s next IOPP renewal survey after 8 September 2019?

Answer:
Answer:

There will be no need to send the approved BWMP for re-approval. However, the BWMP can get a note to reflect that after the next IOPP renewal survey, treatment (as per D-2) is the only approved method. If this implies just a small revision to the BWMP, a class surveyor can check and endorse the BWMP during the renewal survey. The approved exchange procedure (as per D-1) can still be in the approved BWMP; but after the IOPP renewal survey, D-1 can only be used as a contingency measure.

USCG

How does a vessel sailing in US waters comply with USCG requirements?

Answer:
Answer:
Vessels may meet the USCG discharge standard in one of five ways:

1. Use of a USCG type-approved BWTS
2. Temporarily use of a foreign type-approved BWMS that the USCG has accepted as an Alternative Management System (AMS).
3. Use and discharge of ballast water obtained from a US public water system.
4. Discharge of ballast water to a reception facility.
5. Refrain from discharging ballast water within 12 nautical miles of the US coast.

It is also possible to apply for an extension, but the vessel’s management must document that none of the options above are viable.

Apart from the USCG standard, are there any other special local regulations in the USA?

Answer:
Answer:
Some territorial waters may be divided into different zones for exchange. An exhaustive list of special regulations is not available, and additional regulations may be subject to change now that the convention has been ratified. It is recommended that vessel operators contact the relevant flag administrations.

The US is the only country which requires type-approved systems that satisfy a standard other than the IMO.

Certain states have specific ballast water requirements:


Arizona

California

Connecticut

Hawaii

Illinois

Indiana

Maine

Michigan

Minnesota

New York

Ohio

Oregon

Rhode Island

Vermont

Washington

Wisconsin

With the exception of Oregon, the requirements of these states are found in the 2013 VGP.

Are there any special regulations in Californian waters?

Answer:
Answer:
The discharge requirements for ballast water in California are stricter than federal requirements. However, no treatment systems are available which can satisfy the California requirements, and compliance is not currently required.

Does the VGP sampling requirements cover the IMO requirements?

Answer:
Answer:
VGP requirements are only for the USCG and are not covered in the IMO. “The Vessel Discharge Sample Collection & Analytical Monitoring, A How-To Reference for EPAs, 2013 Vessel General Permit (VGP)” final report covers the frequency of testing and the parameters to test. Please note that the VGP requirements are different than IMO biological sampling and testing.

Technical questions

Is it true that species impacted by UV irradiation are able to reproduce within a few days after treatment?

Answer:
Answer:
The main mode of action of UV irradiation is to damage the organisms’ genetic material (DNA and RNA) so that they are not able to reproduce. Common to the filtration and UV technology-based systems used for treatment of ballast water is that while the filter component mainly has effect on the >50 micron organisms, UV affects all organisms but with the highest impact on those in the 0 to 50 micron-sized range, mainly algae, due to the size-related penetration depth. Algae that are irreversibly damaged by UV appear to be “live”, even if they are doing nothing useful and they are not able to reproduce. Without any reproductive capability, colonization o f a new environment is not possible.

Do we need personal gas monitors such as chlorine detectors when entering the rooms housing this equipment?

Answer:
Answer:

The BWTSs on DNV GL-class vessels shall include gas detector sensors. BWTSs that are type approved by DNV GL already include these sensors. In case of a leakage, a warning should be given and, if necessary, a shutdown should take place. Location installation also requires ventilation arrangements. If the BWTS is in a dedicated room, ventilation changes are required depending on the type of vessel and location.

What are the safety requirements prior to entry to ballast tanks?

Answer:
Answer:

DNV GL has not detected any hazardous gas generated by the BWTS type approved by DNV GL in the ballast water tanks. However, confined space entry precautions are always to be followed before entering a ballast water tank regardless of the BWTS installed.

Additionally, DNV GL requests a procedure for safe tank entry in the BWMP of a vessel with a system that generates hazardous gases.

What can I do in case the filter is clogging during ballasting operations?

Answer:
Answer:

Please consult the manual of the BWTS for any troubleshooting procedures in such situations. The treatment system may be operated at a lower flow rate.

In case the treatment system cannot be used for ballasting operations due to filter clogging, this must be handled like a treatment system malfunction, and contingency measures must be discussed and agreed upon with the port state where the ballast water is planned to be discharged.

What can I do in case there are alarms by the BWTS informing me that the treatment system is operating outside the system’s performance claim (e.g. UV intensity or TRO is too low)?

Answer:
Answer:

In case ballasting operations were carried out with alarms indicating that the treatment system is operating outside the system’s performance claim (e.g. UV intensity or TRO is too low), the treated ballast water may not comply with the D-2 standard, and contingency measures must be discussed and agreed upon with the port state where the ballast water is planned to be discharged.

Laid up vessels

I have a vessel that is laid up. What are my options?

Answer:
Answer:

For vessels laid up for longer periods (cold lay-up), all statutory certificates are not maintained by periodical surveys, while the class status is maintained by periodical surveys with a limited scope. In the background and in the DNV GL systems, the normal survey schedule is dormant and will be reinstated with the original dates after the lay-up by performing the periodical surveys due at that time.

Some laid-up vessels have decoupled their IOPP.

In relation to the implementation of the BWM Convention, in any case the installation of the BWTS (D-2 compliance) is mandatory at completion of the first IOPP renewal on or after 8 September 2019; in worst case, immediately at the recommissioning survey after the lay-up.

If I have a vessel that is laid up, can I get a single voyage declaration?

Answer:
Answer:
Such declaration/exemption will be subject to the port state and flag state in question (See question ‎"I need to do a single voyage between two locations. Can I apply for an exemption?" under Convention basics).

Questions for specific vessel types

I have a ship lying as FSU, FSRU or similar. What are my options with respect to the installation of treatment plants?

Answer:
Answer:
Tankers operating as Floating Storage Units (FSUs) and Floating and Regasification Units (FSRUs) and similar may be exempted from the BWM operation and construction requirements. The flag administration and the competent shore state determines if they are exempted from compliance with the convention.

If an owner would like to change the status of these vessels to normal seagoing vessels, this needs to consider that such a change could lead to the need for the immediate installation of a BWTS.

I have a fishing vessel with a Refrigerated Sea Water (RSW) tank. Is the water in the RSW tank subject to treatment?

Answer:
Answer:

RSW tanks are not considered ballast tanks by some flag administrations. So the flag administration shall be contacted in this situation. However, if the vessel is using RSW tanks also for stability purposes, with only ballast water inside the tanks, it meets the definition of a ballast tank according to the BWM Convention.

The below is DNV GL’s interpretation on how fishing vessels may comply with the BWM Convention. DNV GL recommends ship owners to contact the flag of the vessel in regards to this requirement.

  • The RSW tanks, when used as ballast tanks, can only discharge according to the D-1 (exchange) or D-2 (treatment) standards
  • When in RSW mode (i.e. containing fish), the tanks are cargo tanks and discharge with regard to the BWM Convention does not need to be considered.
  • All other ballast tanks, anti-roll tanks, etc. must follow the BWM Convention as usual.
  • Such ships would need to have a BWTS installed. Administrations/class should require a BWMP that explains in detail to the captain when he must use the treatment system.
  • The total ballast water capacity as defined in regulation A-1.2 must include the RSW tanks for ships that use them as ballast water tanks in some conditions.

Do MOUs need to carry out ballast water discharge in accordance with the D-1 or D-2 regulations as well?

Answer:
Answer:
Yes, MOUs are affected by the convention as soon as they move to a new location (in-transit condition). However, while operating within the local waters of the authority, vessels can apply for exemption from all requirements of the BWM Convention based on Article 3.2 of the BWM Convention. Authorization shall be granted by the local authority, and the vessel’s flag administration has to be informed.

For single voyages, the IMO guidance circular BWM.2/Circ.52/Rev.1 can be applied with consent of the countries of origin and destination.

I have a pleasure craft, or a craft used primarily for search and rescue, which is less than 50 metres in length overall and with a maximum ballast water capacity of 8 cubic metres. Will my ship be required to comply with the convention?

Answer:
Answer:
Yes,regulation A-5 of the convention allows for an equivalent compliance with the requirements, but not for exceptions.Equivalent compliance must be determined by the administration taking into account the G3 Guidelines: Guidelines for ballast water management equivalent compliance.

What about ballast water carried in the cargo tank of an oil tanker. Does it need to be treated?

Answer:
Answer:
No, during the MEPC 70 it was concluded that such cases will be covered only by MARPOL Annex I and there will be no amendment for the BWM Convention.

What about ballast water tanks used in connection with the treated wastewater or grey water system?

Answer:
Answer:
If there is a connection between the ballast system and sewage system, some port states will not accept the use of such connections. Additionally, the BWTS may be sensitive towards contamination. While not in contradiction with MARPOL Annex IV, this is potentially in conflict with the BWM Convention. Combined ballast and treated wastewater (TWW) or grey water (GW) tanks are not recommended; however, they may be accepted through non-permanent connections (spool piece) and signboard for the transfer connection between the TWW/GW system and the ballast tank(s).