leading the way; making a difference lunchtime seminar october 10, 2012 ballast water management...

Leading the way; making a difference

Lunchtime Seminar October 10, 2012

Ballast Water Management

JOSEPH ANGELODEPUTY MANAGING DIRECTOR


Different regimesInternational

National/RegionalLocal

INTERTANKO Actions

Guidance documents


INTERNATIONALIMO Ballast Water Management Convention Adopted in 2004 Entry into force requires ratification by 30 countries, 35% world’s grt Currently, 36 countries, 29.06% grt


INTERNATIONAL BWM Plan and Record Book BWM System performance standard Compliance schedule to install BWMS Survey and certification requirements Port State Control procedures


NATIONAL – US Coast Guard Final regulations issued March 2012 Main requirements include:

BWM plan and record keeping; BWM standard (same as IMO) with review in 4 years; Compliance schedule (similar to IMO); Acceptance of “Alternative”BWMS for 5 years


NATIONAL – US EPA Vessel General Permit (VGP) Dec 2008 Main requirements include:

BWM plan and record keeping; BWM exchange; Allows states to impose additional requirements; VGP required to be renewed in 5 years


REGIONAL – EU BWM equipment not included in the Marine Equipment Directive (MED) EU is considering amending MED to bring in the equipment required by the BWM Convention as a mandatory standard Legal amendments to MED to include BWM equipment is scheduled for October 2012 Possible “EU approval regime” could become reality in October 2013.


LOCAL – New York and California BWM standard that is 100x and 1000x greater than IMO Considerable lobbying by industry coalition EPA Science Advisory Board report – standard not possible with current BWM technology Reason prevails, for the time being


INTERTANKO Action

Identifying the Key Challenges

Technical – treatment equipment and approval

Regulatory – BWM Convention implementation and its enforcement


Policy background1. ISTEC and Environmental Committee – March 2012

• Details technical, operational and compliance challenges

2. Council – May 2012

• Recommends comprehensive paper covering the challenges and proposing solutions be sent to IMO

Submission to IMO’s MEPC 64 (October 2012)• Jointly with Liberia, the Marshall Islands, Panama,

BIMCO, CLIA, INTERCARGO, InterManager, IPTA, NACE and WSC - submitted August 2012


IMO MEPC 64 Submission

Explains the challenges being faced for effective implementation of the BWM Convention and to provide proposals to address those challenges

Submission covers FOUR key areas:

1. Guidelines for approval of ballast water management systems (G8);

2. Availability of Ballast Water Management Systems (BWMS);

3. Survey and certification requirements

4. Procedures for port State control


– Greater transparency of information on the Type Approval Certificate and its enclosures

• Total Rated Capacity, 60m3/hr tested but approved to 6000m3/hr

– Type Approval process needs to more accurately reflect real-world environment aboard

• Brackish and freshwater tests• High sediment waters

– Proposals to strengthen Type Approval process• To ensure that a BWMS works in practice as well as theory

1. The need for revision of the Guidelines for approval of ballast water management systems (G8) to improve transparency

and ensure appropriate robustness of Ballast water management systems (BWMS)


– As the BWM Convention dates are progressively surpassed the number of ships to which the requirements apply 12 months after full ratification continually increases

– Ship yards and BWMS manufacturers coming under increasing pressure to install systems within the time frame (implementation schedule)

– Recommend discussion of ‘new’ BWMS installation dates– BWM Convention cannot legally be amended until convention enters

into force– Problem was recognized in 2007 when limited technologies were

available to meet first implementation date of 2009– IMO Assembly adopted resolution recommending acceptance by

parties of delayed installation date

2. The availability of BWMS and sufficient facilities to install BWMS


2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020

Newly constructed Vessels (less than 5,000 cubic metres)

1,740 1,740 1,740 1,740 1,740 1,740 1,740 1,740 1,740 1,740 1,740 1,740

Newly constructed Vessels (greater than 5,000 cubic metres)

0 0 0 1,690 1,690 1,690 1,690 1,690 1,690 1,690 1,690 1,690

Existing Vessels (between 1,500 and 5,000 cubic metres)

0 0 0 0 0 0 2,500 2,500 2,500 0 0 0

Existing Vessels (less than 1,500 or greater than 5,000 cubic metres)

0 0 0 0 0 0 0 0 8,800 8,800 8,800 0

Vessels constructed from 2009 to 2011 (greater than 5,000 cubic metres)

0 0 0 0 0 0 0 0 1,690 1,690 1,690 0

TOTAL 1,740 1,740 1,740 3,430 3,430 3,430 5,930 5,930 16,420 13,920 13,920 3,430

MEPC 61/2/17 by Japan

Current Estimated Installation Schedule Dates


– No phase-in period for survey and certification of ships following entry into force

• ROs required to review and approve BWM Plans as well as survey and certify ships within 12 month period

– Solution provided at MEPC 63 – commence issuance of BWM Certificates prior to entry into force

– Proposal to issue circular in this respect to increase awareness through industry and maintain uniform implementation

3. Survey and certification requirements for ships constructed prior to entry into force of the BWM Convention


– Urge harmonised standard operating procedure for sampling and analysis of ballast water by PSC.

– Coupling of Type Approval process with the enforcement process

• Currently the Type Approval process is separate from the PSC process so an approved BWMS may not meet the PSC analysis once installed on board.

– Uncertainty in the PSC sampling and analysis process key impediment to further ratification

4. Sampling and analysis procedures for port State control purposes


OUTCOME OF MEPC 64

1. Revision of the G8 Guidelines

Decided not to amend the G8 guidelines (at this time), BUT agreed to develop additional guidelines on the application of the G8 guidelines which to address the issue raised in our submission

2. Availability of BWMS

Established as correspondence group (lead by Japan) to develop an Assembly resolution regarding the implementation of Regulation B-3


OUTCOME OF MEPC 64

3. Survey and certification requirements

Agreed with our proposal to issue an MEPC Circular

4. Sampling and analysis procedures for PSC

Agreed with our proposal to instruct BLG (and FSI) Subcommittee that sampling and analysis procedures for PSC should be no more stringent than what is required for type approval of BWMS


Finding, installing and operating systems on tankers?

Ballast Water Guidance


To assist members during selection, assessment and installation for existing and new built vessels:

INTERTANKO Guidance on the Selection and Installation of Ballast Water Management Systems for

Tankers

Physical InstallationPumpingControl – system approval and certificationTreatment typeOperating practicalitiesReleased January 2012

Ballast Water Guidance


Summary1. “Positive” developments at MEPC 64, but more work needs to

be done2. Members learning on a day-by-day basis3. Sharing of experience and information between owners

essential1. Does the BWMS work?2. Does it work as it was approved to work?3. Does it meet the discharge standards?

4. Propose amendments to IMO’s BWM Guidelines based upon experience gained, while supporting their international and uniform approach


Thank you!

www.intertanko.com

leading the way; making a difference lunchtime seminar october 10, 2012 ballast water management...

Documents

bwm exchange

california bwm standard

master title styleimo

current bwm technology

main requirements

additional requirements

imo considerable lobbying

compliance challengescouncil