- Keywords: Statutory, Maritime
Relevant for design offices, shipyards, suppliers, owners/managers, flag states.
With two months to go before the entry into force of the international Ballast Water Management Convention on 8 September 2017, MEPC 71 reached a highly anticipated compromise agreement on the implementation dates for the so-called D-2 discharge standard.
Generally, compliance with the D-2 standard translates to the date individual ships must have a ballast water treatment system installed. The agreement ensures full global implementation by 8 September 2024 and contains the following key elements:
Ships constructed (keel-laid) on or after 8 September 2017 need to comply with the D-2 standard upon delivery.
Existing ships should be D-2 compliant 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.
Furthermore, the ship should be D-2 compliant 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.
This means that a ship which is due for an IOPP renewal survey between 8 September 2017 and 8 September 2019 cannot decouple its IOPP survey for a second renewal before 8 September 2019 without then having to comply with the D-2 standard.
Ships constructed before 8 September 2017 and delivered (including the initial IOPP survey) after that date, need to comply with the D-2 standard at the first IOPP renewal survey after delivery.
It was also agreed that a ship to which the IOPP renewal survey does not apply (generally ships less than 400 GT in size) shall be D-2 compliant no later than 8 September 2024.
The agreement implies that vessels with the last IOPP renewal carried out before 8 September 2014 have nothing to gain by decoupling, but instead actually risk losing up to two years on the D-2 implementation date by doing so.
An MEPC resolution text to ensure that this agreement is effective from the convention’s entry into force date, 8 September 2017, was also agreed to.
Please note from entry into force on 8 September 2017, all vessels for which the convention is applicable, shall conduct ballast water exchange in accordance with an approved BW management plan until compliance with the D-2 regulation becomes mandatory.
The US legislation is not affected by this. Vessels trading, or planning to trade, in the US should make sure they are compliant with the US BW management requirements.
Notwithstanding changes to the D-2 implementation schedule, the D-1 deadline stays firm, i.e., 8 Sept 2017. By this date, affected ships should have onboard an International BWM Certificate. This means you must submit the plan for approval and order the initial survey in due time before 8 September. It should also be noted that the applicable USCG implementation requirements on ballast water is totally unaffected by these recent MEPC discussions/decisions.
This decision is set, and the uncertainty surrounding the implementation date is now resolved. The agreed text will be circulated as an amendment to the Ballast Water Management Convention. All our customers are advised to carefully examine and consider their ship’s individual IOPP renewal dates so as to ensure compliance in due time. Save time and money by preparing and submitting your BWMP with our free-to-use BWMP Generator.
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