Shipowners are worried about their obligations as they set their ballast management priorities, writes BIMCO deputy secretary general Lars Robert Pedersen
BIMCO’s members around the world include more than 800 shipowners that operate well over half of the world’s deadweight tonnage. BIMCO members are without doubt a large representative sample when it comes to experience using ballast water management systems (BWMSs).
They worry that they will be on their own to deal with the obligations and responsibilities that BWMSs bring because the yards that fit them accept little responsibility for them. On its own, that is a big and continuing concern but, on top of that, the Ballast Water Management Convention itself is not easy to understand.
Much of the talk since the convention was adopted in 2004 has been about equipment. One concern is that many shipowners that did the right thing and spent a lot of money on equipment now realise that it does not work very well.
Going forward, it is actually the US that will dictate what is installed. Systems must be suitable for global operations, and a US Coast Guard (USCG) type-approval means that a system should also be able to fulfil IMO’s revised G8 guidelines. We are not sure whether the opposite applies. If you know for sure that a ship will never go to the US at any time in its life, then G8 is good enough - otherwise, you have to think about this carefully.
But what matters most to owners and operators are their obligations under the convention, especially since certain jurisdictions have statutory requirements that go beyond the BWMC – which the convention allows them to have.
My advice to owners is that you need to have a plan for what you do on board your ship. As well as doing things right, you must do them according to your plan so your plan has to be right.
For example, it has to cover how you will comply with the various discharge standards but also – importantly – set out what to do if you do not comply. As well as covering ideal conditions, you must also cover all the variants and unknowns, and have some contingency plans.
Keep the plan simple and flexible. Make sure it is read, understood and implemented because one of the primary compliance issues we will face will stem from crews not following the plan. The plan must cover maintenance, servicing and record-keeping, using the ballast-water record book.
Designate an officer to oversee the plan, but remember that the officer is also part of your plan. If he or she is not sure of his or her responsibilities, that is a deficiency that could trigger an in-depth port state control investigation into non-compliance.
Make sure your plan is relevant. Some ships have equipment capable of meeting the BWMC’s D-2 treatment performance standard, and their plans state that they must achieve that simply because they have suitable equipment. But being so rigid may not be very smart from a compliance point of view if those ships do not yet need to comply with D-2 – some may have until 2024 before that is necessary.
Why force yourself into D-2 compliance, using equipment that may not work very well, when you have the option of meeting D-1 exchange standard instead? Shipowners that specify D-2 in their plan should update it to also include D-1, and take the opportunity to get experience using the BWMS before it becomes essential.
Lastly, I will briefly mention training because crew competency is vital. On board, the ballast water officer must understand what it means to implement the plan. Get the manufacturers involved in training the crew, and make sure you have effective handover procedures to subsequent crew – otherwise they will be the ones who will get into compliance issues.
Ashore, involve the superintendents, because they need to understand that ballast management involves more than just flicking a switch. Address ballast water compliance topics during officer seminars.
Shipowners’ concerns will remain for a long time, but my message is a simple one: we need to know how to comply, and we need to understand the enforcement machine that has been put in place so we can be prepared.