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Every time a new regulation is in force, companies, and

seafarers inevitably wonder if this is the last major regulation
that they have to worry about.

We have seen this before with Marpol Annex VI, ECDIS, EU

MRV, and many others.
It’s a fair question to ask, though.

After all, everyone is managing regulations these days

instead of managing ships.
While we may or may not be critical of new regulations each
year the truth is we have to comply with these regulations.

And the first step to compliance is understanding the

regulation inside out.

The regulation we will discuss today is “Ballast water

management”.

Let us start.

Ballast water management convention?

In 1988, Canada and Australia raised the issue of invasive
species brought to their waters through the discharge of
ballast water by ships.

What could be the problem with these invasive species or

with ballast water, one may ask.

The problem is highlighted in the below video by IMO.

The problem was real and IMO started the work to address
this issue.

After more than 14 years of complex negotiations between

the IMO Member States, the  International Convention for
the Control and Management of Ships’ Ballast Water and
Sediments (BWM Convention) was adopted on 13 February
2004.
And after another 13 long years, the BWM Convention
finally entered into force on 8 September 2017.

Application of ballast water management

convention

So the first question is to which all ships this convention

applies?
Well, the convention applies to all the ships of a state that
has ratified the convention and that carry ballast.

There are few logical exemptions such as a ship that carries

permanent ballast in sealed tanks on ships, that is not
subject to discharge.

Ballast water convention does not apply to such ships.

Ballast water standards

Ballast water convention is all about pollution from ballast

water from one location discharged into different ecology.
So it is obvious that ballast water management convention
would require us to treat the ballast water in ways that it
becomes less harmful or not harmful at all.
Ballast water management (BWM) convention provides two
ways of doing that.
These methods are provided in section D of the ballast water
management (BWM) convention.
Ballast water exchange standard (regulation D1)
The first standard is to replace the ballast water in mid sea.

This method is based on the fact that the invader species

from coastal water cannot survive in deep waters and deep
water species cannot survive in coastal waters.

When replacing the ballast water at deep sea, BWM

convention regulation D1 requires that at least 95% of the
ballast water need to be exchanged.

And there are two ways to do that.

The first method is to deballast at least 95% of the volume of
ballast water from the tank and then re-fill it. This is called
the “Sequential method or simply Pump-in, pump-out
method)”.

For example, let us say we need to exchange the ballast

water from a ballast tank that has 1000 m3 of ballast.

In this case, we need to deballast at least 950 m3 of ballast

and then refill it.

Actually, we need to deballast as much as possible. 5% is

just allowed for the unpumpable ballast.

The second method is to keep on ballasting the ballast tank

and keep on overflowing the ballast water from ballast tank
through air pipe or other openings of the ballast tank.
For the flow-through method, BWM convention regulation D1
requires to pump in 3 times of the ballast tank capacity to
achieve 95% of the volumetric exchange.

Ballast water performance standard (Regulation D2)

The first ballast water standard is temporary and ultimately
all ships need to arrive at ballast water performance
standard (regulation D-2).

This second ballast water standard is more scientific in

words.

It aims to control the number of actual species (in simpler

word micro-organisms) that can be discharged.

If you are interested in knowing the numbers, here are the

numbers as per the BWM conventions, regulation D-2.2.
And as you may have guessed it right, this can only be
achieved by a Ballast water treatment system.

This system is fitted before the ballast overboard and it

treats the ballast water to the required standards before the
ballast water goes overboard.
Criteria for ballast water exchange
(Regulation B-4)

To achieve ballast water standard as per regulation D-1, the

vessel needs to exchange the ballast in the mid sea.

BWM convention regulation B-4 provides the criteria for deep

sea where the ballast exchange need to be carried.

And as per regulation B-4, the ballast water exchange need

to be carried at

 200 Nautical miles from nearest land in a minimum

water depth of 200 meters.

 Where above is not possible, then as far as practicable

from the nearest land but not less than 50 NM from
nearest land and in a minimum water depth of 200
meters

Regulation B-4.3 also clarifies that the ship need not deviate
from the intended route for the purpose of complying with
this requirement.

So then here is the million dollars question that everyone

has.
What if distance or depth requirements are not met during
the voyage, especially for a short voyage between two
countries?

Well, the best way is to communicate with the agent to know

the local requirements from the port authority.

For example, for the voyage from a Brazilian port to

Argentina: the vessel would not comply with the
requirements if the general route is followed.

But Argentinian port authorities have special instructions

related to ballast water exchange for the vessels arriving
from Brazilian ports.

Regulation D-1 or D-2: Which one applies to

which ships?

Vessels need to either comply with regulation D-1 (Ballast

exchange) or Regulation D-2 (Ballast water treatment
system).

BWM convention regulation B-3 provides this information.

The original regulation B-3 was amended by MEPC

circular to amend the compliance dates.
Below is the amended schedule for compliance with the D-2
regulation.
The above schedule may look confusing because the
reference date is taken as the ballast water convention
ratification date (08 Sept 2017).

But we can simplify it a bit.  So in simple terms, as per

the revised regulation B-3
 New ships (built on or after 08 Sept 2017) must meet
D-2 standards.

 Existing ships (built before 08 Sept 2017) must meet D-

2 standards at first IOPP renewal survey after 08 Sept
2019.

 All vessel must comply with D-2 standards before 08

Sept 2024.
Ballast water management plan

BWM convention, regulation B-1 requires the ships to have

an approved Ballast water management plan.
The ballast water management plan is a ship specific plan
and has all the details related to the compliance with BWM
convention.

For example, it lists if the regulation D-1 is applicable to the

vessel or regulation D-2.

In the case of regulation D-1, the approved process of

achieving 95% of volumetric exchange of ballast will be
provided in the BWM plan.

It would also contain the safety consideration for ballast

water exchange.

For example the information about the set of ballast tanks

that can be exchanged together along with the ship’s stability
during this process.

If regulation D-2 is applicable then the BWM plan would

contain the information about Ballast water treatment
system.

And the BWM plan provides information about the handling

of sediments from the ballast water tanks.
Ballast water record book

Yes, another record book.

BWM convention regulation B-2 requires the ships to have on

board a “Ballast water record book”.

An entry needs to be made for each activity related to the

ballast water.

Below are the entries that need to be made

 When Ballast Water is taken on board

 Whenever Ballast Water is circulated or treated for

Ballast Water Management purposes

 When Ballast Water is discharged into the sea

 When Ballast Water is discharged to a reception facility

 Accidental or other exceptional uptake or discharges of

Ballast Water

 additional operational procedure and general remarks

Codes given in the beginning pages of the ballast water
record book need to be used for making entries.
This is not much different from the entries we make for oil
record book or cargo record book on tankers.

International Ballast water management

certificate
BWM convention regulation E-2 requires that the ship that
complies with the requirements of the conventions be issued
with a certificate.

The International Ballast water management certificate is

issued after the successful initial survey of that vessel.
The initial survey is carried out to verify that
  the ship’s ballast water management plan complies with
the requirements of the convention.

 The equipment and procedures comply with the

requirements of the convention.

The ballast water management certificate is valid for 5 years

subject to the annual surveys.

The annual survey is carried out each year within three

months before or after each anniversary date.

Apart from that, an Intermediate survey is carried out within

three months before or after the second or third-anniversary
date of the certificate.
Compliance with BWM convention

Sometimes we do not need to know the entire convention.

We just want to hear what is required from us.

So here I summarise what is required from seafarers to

comply with BWM convention.

This will also help during port state control inspections.

First, we need to have on board

  A valid “International Ballast water management
certificate”; and

 An approved “Ballast water management plan”.

Check that these two documents are on board.

Second, we need to know if the vessel is required to comply

with D-1 standards or D-2 standards.

The ballast water management certificate provides this

information.

If the method employed is as per regulation D-1, then we

must ensure that ballast is exchanged as per the procedures
mentioned in the BWM plan.
If the method employed is as per regulation D-2, that is, the
vessel is fitted with a BWM system then we must have a type
approval certificate for such a system.
Vessel needs to record all activities related to the ballast
water in the “Ballast water record book”.

And finally, ship’s crew need to be aware of and trained

about their responsibilities as per the ballast water
management convention.

A training record for the training of all of those involved with

ballast operations would help show compliance.

Once these points are taken care of, the vessel can be
expected to comply with ballast water management
convention.

Conclusion

We like it or not but there is one more regulation that we

have to comply.

Port state controls are now focussing on verifying

the compliance with ballast water management convention.
And it is time that we know in and out about the convention
and how we can ensure compliance.

Once we know that, demonstrating compliance with BWM

convention would not be difficult.

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About Capt Rajeev Jassal

Capt. Rajeev Jassal has sailed for over 19 years mainly on crude oil,
product and chemical tankers. He holds MBA in shipping & Logistics
degree from London. He has done extensive research on quantitatively
measuring Safety culture onboard and safety climate ashore which he
believes is the most important element for safer shipping.

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