Shipping is crucial to global trade, accounting for over 80% of the world’s commodities and transferring approximately three to five billion tonnes of ballast water annually. While ballast water plays a vital role in the safe operation of vessels, it also presents significant ecological, economic, and health risks due to the potential transfer of invasive aquatic species.
Contents of Ballast Water
Ballast water harbors various organisms, including bacteria, viruses, and both adult and larval stages of marine life. Most of these organisms will not survive the discharge process; however, some may endure and establish themselves in new environments. The introduction of these non-native species can lead to severe impacts on local ecosystems, economies, and public health.
Global Response to Invasive Species
Recognizing the threat posed by invasive marine species, the United Nations Conference on Environment and Development (UNCED) convened in Rio de Janeiro in 1992. In its Agenda 21, it urged the International Maritime Organization (IMO) and other bodies to take action. The IMO had already been working on solutions for over a decade.
In 1991, the IMO issued Guidelines for Preventing the Introduction of Unwanted Organisms and updated them in 1993. By 1997, the IMO introduced Guidelines for Control and Management of Ships’ Ballast Water (Resolution A.868(20)). A significant milestone was achieved in February 2004 when the International Convention for the Control and Management of Ships’ Ballast Water and Sediments (BWM Convention) was adopted. This convention aims to regulate ballast water discharges to mitigate the risks of introducing non-native species and came into force on 8 September 2017.
Technological Advancements and Regulations
In response to the challenging discharge standards set by the BWM Convention, various technologies have been developed. Many of these solutions originated from land-based water treatment applications and have been adapted for maritime use. Compliance with relevant IMO Guidelines is essential for these systems.
In addition to the IMO's efforts, national bodies, such as the United States Coast Guard (USCG), have introduced regulations to combat the spread of aquatic nuisance species. The USCG's final rule, published in March 2012, became effective on 21 June 2012.
This publication provides an overview of the BWM Convention requirements and offers guidance on selecting, procuring, and installing ballast water treatment systems. It also includes a frequently asked questions section and useful references for further information.
The contributions from technology suppliers that provided valuable information for this publication are greatly appreciated.
Applicability
The BWM Convention is applicable to all ships, including submersibles, floating craft, floating platforms, FSUs, and FPSOs. However, it does not cover:
Ships without ballast water
Domestic vessels
Ships operating solely in waters under one party's jurisdiction and the high seas
Warships and state-operated vessels (though states are encouraged to follow the Convention's guidelines)
Permanent ballast in sealed tanks, which is not discharged
Compliance Schedule
The BWM Convention came into force on 8 September 2017. All ships are required to manage ballast water on each voyage through exchange or treatment using an approved system. Vessels of 400 gross tonnes (gt) or more must have an approved Ballast Water Management Plan and a Ballast Water Record Book on board, and must undergo surveys for an International Ballast Water Management Certificate. For vessels under flags that have not ratified the BWM Convention, a Certificate of Compliance may be issued.
Prototype Technologies
Ships enrolled in an approved program may utilize prototype technologies for up to five years before needing to install an approved system. These systems are under evaluation to meet regulation D-2 requirements.
Surveys and Certification
All vessels over 400 gt are subject to surveys, while those under are managed by national regimes. Upon successful initial surveys, ships receive an International Ballast Water Management Certificate, valid for five years, contingent on annual, intermediate, and renewal surveys.
Exemptions
Exemptions may apply to ships operating between specified ports, valid for five years, subject to review. A risk assessment must be completed as per IMO Resolution MEPC.162(56).
Applicability
All vessels calling at U.S. ports that intend to discharge ballast water must perform ballast water exchange or treatment, alongside sediment management.
Definition and Importance
The European Commission defines invasive alien species as plants and animals that are introduced, either accidentally or deliberately, into environments where they are not typically found. This introduction can have serious negative impacts on the local ecosystem and biodiversity. To address these challenges, the European Union (EU) has established regulations aimed at preventing and managing the spread of these species.
EU Regulation 1143/2014
Regulation (EU) No 1143/2014, enacted on January 1, 2015, aims to tackle the issue of invasive alien species in a comprehensive manner. Its primary goals include:
Protecting native biodiversity and ecosystem services.
Minimizing and mitigating the human health and economic impacts caused by these species.
Key Provisions
The regulation highlights that a significant number of invasive species enter the EU unintentionally. Therefore, it is essential to improve the management of these unintentional pathways. The regulation outlines a phased approach, recognizing that experience in this area is still developing. Key components include:
Voluntary measures, such as those suggested by the International Maritime Organization (IMO) regarding ships’ biofouling control.
Mandatory measures, which build on existing experiences and conventions, including the International Convention for the Control and Management of Ships’ Ballast Water and Sediments established in 2004.
The EU Commission encourages Member States to ratify relevant conventions to enhance cooperative efforts against invasive species. For further information on the regulation, visit the European Commission's website.
Other Regulations and Guidelines
Additional national requirements are detailed in the National Ballast Water Management Requirements guidance document, which can be downloaded from the Lloyd's Register website.
Regulation D-2 of the BWM Convention
The Ballast Water Management (BWM) Convention sets forth treatment standards that must be adhered to, specifically through Regulation D-2. The standards ensure that ballast water treatment systems achieve the following discharge limits, summarized in the below table:
Key Points of the BWM Convention
Ballast water treatment systems are required to obtain a type approval certificate in compliance with the IMO Guidelines for the Approval of Ballast Water Management Systems (Resolution MEPC.296(72) and MEPC.300(72)). It's essential to note that the U.S. Coast Guard (USCG) treatment discharge standards align with the BWM Convention D-2 standards; however, the BWM Convention specifies the measurement of reproductive organisms, while the USCG focuses on living organisms.
Approval Processes
Technologies developed for ballast water treatment must undergo rigorous approval through specific IMO processes and testing guidelines. These processes ensure that the technologies:
Meet IMO standards.
Are robust and environmentally friendly.
Function effectively in a shipboard environment.
According to the BWM Convention, systems must be approved by the Administration, considering the Guidelines for Approval of Ballast Water Management Systems (G8). These guidelines were revised in 2016 and formalized into the BWMS Code, which was adopted in April 2018 and came into effect in October 2019.
Testing Requirements
Approval involves both:
Shore-based testing of a production model to confirm compliance with D-2 discharge standards.
Shipboard testing to ensure operational effectiveness.
Mandatory Requirements for Ships
All ships of 400 gross tons and above must have an approved, ship-specific Ballast Water Management Plan on board, along with a Ballast Water Record Book. The Ballast Water Management Plan must:
Facilitate compliance with international regulations to reduce the risk of transferring harmful organisms.
Identify the ship’s Ballast Water Management Officer.
Consider safety elements and provide information to Port State Control (PSC) officers regarding ballast handling systems.
Include training on operational practices for ballast water management.
Be written in the ship’s working language, with translations into English, French, or Spanish if necessary.
In July 2017, the IMO issued BWM.2/Circ.62, providing guidance on contingency measures under the BWM Convention to assist ships and Port States in handling scenarios where ballast water management cannot be performed as per the approved plan.
Guidelines for Compliance Testing
The IMO’s guidance on ballast water sampling and analysis is detailed in the G2 Guidelines. These guidelines offer recommendations for methodologies to test for compliance with BWM Convention standards D-1 and D-2. Compliance testing typically involves two steps:
An indicative analysis of ballast water discharge to preliminarily assess compliance.
A detailed analysis following successful indicative testing.
USCG Regulations for Compliance
The USCG conducts compliance assessments during regular vessel inspections. Inspectors review documentation, including type approval certificates and AMS acceptance letters, and verify the crew’s knowledge of equipment usage. If compliance is not satisfactory, the USCG may take ballast water samples to ensure the treatment system's effectiveness.
The USCG is also working on developing faster and more accurate sampling methods to enhance compliance monitoring.
In 2011, the U.S. Coast Guard (USCG) and the Environmental Protection Agency (EPA) signed a Memorandum of Understanding to enhance compliance with the EPA’s Vessel General Permit (VGP) program, effective from December 2013. This collaboration enables the sharing of information and streamlining of compliance efforts. Under the VGP, ship operators are required to self-monitor their ballast water treatment systems, which includes conducting functional tests and analyzing ballast water samples to ensure biological performance and that chemical residues remain within acceptable limits.
For more information on the USCG’s ballast water treatment technology verification, visit USCG MSC.
The Ballast Water Management (BWM) Convention mandates that ships are subject to inspections by port states to verify compliance. In 2014, the International Maritime Organization (IMO) adopted guidelines (Resolution MEPC.252(67)) for port state control inspections to ensure adherence to the Convention's requirements. These guidelines serve as a framework and do not restrict the rights of port states to verify compliance.
Additionally, prior to entering a U.S. port, ships must submit a report to the USCG Captain of the Port (COTP) 24 hours in advance. The ship must also allow the COTP access to conduct ballast water and sediment sampling, review documents, and make inquiries to assess compliance with USCG regulations.
For detailed national and regional requirements, download the National Ballast Water Management Requirements at Lloyd's Register.
Ensuring Compliance with the BWM Convention
Achieving compliance with the Ballast Water Management (BWM) Convention is crucial for ship operators. This chapter outlines a comprehensive approach to planning and executing compliance, ensuring adherence to both national and international regulations.
Understand Your Obligations
Familiarize yourself with the requirements of the BWM Convention and applicable national regulations. Key obligations include:
Ballast Discharge Compliance: Ensure all ballast discharges meet the standards set in Regulation D-1 or D-2, which mandates ballast water exchange or treatment. This requirement applies to discharges at both sea and port.
Adherence to Procedures: Always follow the procedures detailed in the Ballast Water Management Plan.
Record Keeping: Maintain accurate records in the Ballast Water Record Book.
System Operation and Maintenance: Operate and maintain ballast water treatment systems according to the manufacturer’s specifications.
Review Shipboard Arrangements
Conduct a thorough review of onboard ballast tank, pumping, and piping arrangements to identify necessary changes for compliance with the BWM Convention. Focus on:
Multi-Use Tanks: Ensure tanks used for both ballast and the storage of grey or black water do not mix different types of water, and discharge is conducted according to relevant regulations.
Eductors in Stripping Operations: Be cautious when using local seawater for eductor drive water during stripping. Ballast water discharged during these operations may not accurately represent the contents of the tanks since it is mixed with drive water. As a result, sampling should not occur during stripping.
Develop a Ballast Water Management Plan
Create a robust Ballast Water Management Plan that outlines compliance strategies and can be amended as preparations progress. The plan should include:
Details of the selected treatment system.
Identification of safety issues and necessary mitigation measures.
Crew training requirements and the appointment of a designated Ballast Water Management Officer.
Select and Install a Treatment System
Carefully choose and install a ballast water treatment system. Ensure adequate resources are available, and submit plans for approval to the classification society in a timely manner. The system and any associated equipment must be delivered as scheduled.
Develop Staff Training Programs
Implement a comprehensive training program for the crew, which should be incorporated into the Ballast Water Management Plan. Training should cover:
Responsibilities under the BWM Convention.
Specific ballast operations on the vessel.
Operation and maintenance of the ballast water treatment system.
Safety risks and mitigation measures associated with these operations.
Finalize and Submit Your Ballast Water Management Plan
Prepare a final version of the Ballast Water Management Plan, obtain any necessary internal approvals, and submit it to the relevant Recognized Organization (RO) or Flag for approval. Ensure submission is done promptly to avoid delays.
Survey and Certification
Organize an initial survey of the vessel to issue an International Ballast Water Management Certificate or Certificate of Compliance.
Understand USCG Regulations
If your vessel calls at U.S. ports, be aware that ballast water exchange or treatment is required, along with sediment management. Note that ballast water exchange is permissible only until treatment system implementation deadlines are reached. The U.S. Coast Guard (USCG) accepts potable water from the North American municipal system for ballast water management, provided that ballast tanks are cleared of sediments beforehand. Additionally, a Ballast Water Management Plan must be in place, and tanks must be free of sediments. A report must be submitted to U.S. authorities 24 hours before arriving at a U.S. port.
Manage Ballast Water and Sediments
Ensure all ballast and sediment discharges comply with the BWM Convention and follow the approved Ballast Water Management Plan. Keep meticulous records in the Ballast Water Record Book.
Update the Management Plan and Record Book
Regularly review and update the Ballast Water Management Plan as necessary, obtaining approval for amendments when required.
Conduct Required Surveys
Schedule the necessary annual, intermediate, and renewal surveys well in advance, ensuring they occur within the permitted range of dates.
Maintain Equipment Properly
Operate and maintain the ballast water treatment system in accordance with the manufacturer’s guidelines, as reflected in the Ballast Water Management Plan.
Monitor System Performance
Use installed monitoring equipment to track the treatment system's performance. Key parameters to monitor may include:
Flow rate and back flush frequency.
Active substance dosage rate.
Neutralizer dosage rate.
Power consumption.
Total Residual Oxidant (TRO) levels.
pH levels (acidity/alkalinity).
Regular servicing and checks by the manufacturer, along with periodic biological efficacy assessments, will help ensure the system operates as intended.
Comply with National Requirements
If applicable, manage ballast water and sediments according to relevant national and regional ballast water management requirements. Maintain proper records in the Ballast Water Record Book.
While most deep-water vessels are expected to comply by installing fixed ballast water treatment systems, some may opt for alternative compliance methods. According to the BWM Convention, the role of alternative methods is as follows:
Alternatives: Regulation B3-6 states that the compliance requirements (D-1 or D-2) do not apply to ships that discharge ballast water into a reception facility designed according to established guidelines.
Other Methods: Regulation B3-7 permits other methods of ballast water management as alternatives to ballast water exchange and performance standards, provided these methods ensure at least the same level of protection for the environment, human health, and resources, and receive approval from the IMO’s Marine Environment Protection Committee.
By following these steps, ship operators can effectively plan for and achieve compliance with the BWM Convention, ensuring the protection of marine environments and adherence to regulations.
