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Of course, the big news during SMM was the fact that Finland has signed up for IMO’s Ballast Water Management Convention (BWMC), thus pushing the number of ships on a world-wide basis to above the required 35% figure. Finland signed up on September 8th and therefore it is 12 months from that date that the Convention becomes mandatory. So the next drydocking operation after that date (September 8th 2017), a system must be installed. Many shipowners/managers decided to drydock early (especially during 2015) to give themselves time to consider which system after the 2017 deadline. However, many are still confused – this is the IMO ratification – but the US Coast Guard regulations, which are different to IMO, have not been ratified – so owners’ who operate on a world-wide basis, still do not know which system to install. BIMCO is “deeply concerned” that the IMO BWMC will enter into force leaving shipowners without treatment systems approved for global use. Lars Robert Pederson, Deputy Secretary General at BIMCO said, “The shipping industry need no longer speculate on a possible future date for the IMO BWMC. It will come into force on 8th September 2017, requiring ships to be fitted with approved treatment systems to prevent the spread of invasive species via ballast water. BIMCO is deeply concerned about the prospect of our members having to install treatment systems now which later may not be approved for use in US waters. This is because the US has not yet approved treatment systems that comply with its own, more stringent, national standards. “Shipping will have to invest significantly in the installation of BWTS by next September – only to find the investment is wasted if their system does not meet USCG standards. BIMCO is also concerned that systems approved to the present IMO standards are not robust enough to ensure that systems on-board real ships perform to the regulatory requirements to treat ballast water. “We therefore call upon IMO to expedite the revision of their G8 guidelines for approval of ballast water treatment systems.” Meanwhile, in the wake of the ratification of the IMO’s BWMC by Finland, Intertanko is advising its Members to remain focused and cautious in the months ahead as the industry makes plans for the installation of BWMS to meet the Convention’s requirements. Intertanko’s Managing Director, Katharina Stanzel, commented that, “The entry into force of an international Convention, providing global requirements, will always be welcomed. In practical terms this development provides certainty for owners with a firm date now in place from which installation and drydocking schedules can be determined. However, this must be balanced against the fact that the IMO has yet to complete its work on reviewing and revising the G-8 type approval guidelines for ballast water management systems.” In Washington, Intertanko’s Deputy Managing Director, Joe Angelo, noted that, “The early ratification adds a further complication when considering the lack of availability of any USCG type approved systems.” Mr. Angelo repeated the advisory issued earlier this year by Intertanko regarding the quandary that owners will be placed in if the IMO Convention is ratified when there are no USCG type approved systems available on the market. “This situation puts owners at the risk of having to install an IMO type approved system that may never achieve USCG type approval,” he said. “If the chosen system does not obtain USCG approval, it will have to be replaced within five years in order to continue to trade to the US. A shipowner, who in good faith wants to comply with international and national ballast water management requirements, therefore faces an unacceptable position of having to possibly invest twice in a BWMS through no fault of his or her own.” The International Chamber of Shipping (ICS) reiterates that it is now more vital than ever that IMO Member States finalise the revision of the G8 Type Approval Guidelines for treatment systems at the next session of the IMO Marine Environment Protection Committee this October.

ICS Chairman, Esben Poulsson said, “We must ensure that shipowners can have absolute confidence that the expensive equipment they will soon have to install will be effective in treating ballast water conditions normally encountered during worldwide operations and be regarded as fully compliant during Port State Control inspections. “The fixing of a definite implementation date, after so many years of delay, will at least gives shipowners some of the certainty needed to make important decisions about whether to refit the new mandatory treatment equipment or otherwise to start sending ships for early recycling” Mr Poulsson added. “Unfortunately, the entry into force of the new IMO regime will not resolve the extreme difficulties that still exist in the United States.” The US regulations require all ships that discharge ballast water in US waters to use a treatment system approved by the USCG. However, because no systems have yet been approved, ships already required to comply with the U.S. regulations have either been granted extensions to the dates for fitting the required treatment systems or else permitted to install a USCG accepted Alternate Management System (AMS), in practice a system type-approved in accordance with the current IMO Guidelines. However, an AMS will only be accepted for operation for five years, after which time a fully USCG approved system must be installed. But the USCG does not guarantee that an AMS will be subsequently granted full approval. Hence shipowners that may have installed an AMS in good faith, at a cost of between US $1-5m ship, might then have to replace the system completely after only five years. “The impasse in the US is a particular concern for operators that have installed ultra-violet systems” observed Mr Poulsson. ICS says that the situation has been compounded by the USCG announcing, at the end of last year, that it will not accept the methodology used by other IMO Member States to approve UV treatment systems when assessing the number of viable organisms in treated ballast water. ICS will therefore be working with IMO Member States to impress upon the United States the importance of coming to a pragmatic solution. Otherwise, once the IMO Convention finally enters into force next year, the shipping industry will be faced with real chaos.” said Mr Poulsson.