Implementing Ballast Water Management Plans
From entry into force of the IMO Ballast Water Management Convention, until each vessel’s D-2 compliance date, it will be expected to have in place and operate a Class Approved Ballast Water Management Plan. Developing and implementing ballast water management plans requires careful consideration and thought for each vessel individually, particularly when the vessel is planning to achieve temporary compliance through ballast water exchange.
It is worth remembering that implementing ballast water management plans is not just to simply tick the legislative box. These plans are intended to give the vessel crew comprehensive guidance on how to achieve compliance with the legislation. Lack of clear guidance, or half-hearted attempts at developing and implementing the plans helps nobody – and could ultimately lead to the vessel, and hence the owner / operator, being met with fines for lack of compliance.
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IMO G4 Guidelines – “Guidelines for ballast water management and development of ballast water management plans” goes into great detail on what a plan should include, and its intended purpose. It does, also, include a telling paragraph from the outset:
“…For a Plan to be effective and to comply with Regulation B-1 of the Annex of the Convention, it must be carefully tailored to the particular ship for which it is intended..”
Whilst implementing a plan across sister vessels may be suitable, endeavouring to develop a single plan to implement across a fleet is very unlikely to be accepted by Class Societies. Differences in ballast systems, operations, stability, longitudinal strength, amongst others, make this highly unachievable, and potentially dangerous.
Concept of the Ballast Water Management Plan
The main concept of the ballast water management plan is to guide the vessel crew in the safe operation and/or execution of the compliance method utilised onboard. Specifics vary depending on the compliance method employed, however, the following is required in all circumstances:
- Details of existing ballast system, tanks, pumps and equipment
- Details of safety procedures for ballast water management onboard the vessel
- Details of actions to be taken to implement ballast water management practices onboard
- Details of procedures for control of sediments onboard
- Designation of officer onboard charged with ensuring plan is implemented
- Provisions for crew training & familiarisation
- Details of reporting requirements & copies of the appropriate reporting forms / sheets
Ballast Water Exchange
If ballast water exchange is identified as the compliance method of choice for a given vessel, additional information is required within the plan, including:
- Stability implications of exchange procedures
- Longitudinal stress implications of exchange procedures
- Bridge visibility implications of exchange procedures
- Procedures for avoiding tank over-pressurisation
In many cases, particularly for larger vessels with large tank volumes, or vessels with lower stability margins, detailed stability analysis is required to ensure the ballast water exchange procedures do not cause an unacceptable lack of stability. The same is true of longitudinal strength checks – particularly for larger vessels sensitive to longitudinal bending stress.
Ballast Water Treatment Systems
Implementing ballast water management plans on vessels fitted with ballast water treatment systems is perceived as being somewhat simpler than those undertaking ballast water exchange, however, there are many aspects that have to be considered and captured within the plan.
In particular, comprehensive details of the functionality, operation and troubleshooting of the ballast water treatment system are critical to the crew’s ability to ensure compliance is achieved consistently. With many ballast water treatment technologies employing complex, or highly sensitive treatment processes, it is imperative that crews are adequately trained and knowledgeable in the operation of them.
Operational and maintenance manuals are mandatory, as one would expect, along with details of the manufacturer’s service centers and technical support helpdesks.
Sediment Control & Disposal
The control and disposal of sediments is an often forgotten aspect of ballast water management, however this is a critical aspect of the purpose of the legislation. In implementing ballast water management plans, owners and operators should ensure that the plans include detailed procedures for the removal of sediments from the tanks, along with any associated health and safety considerations when accessing the tanks themselves.
The plan should outline the methodology of controlling sediment, as well as the procedures of disposing of the sediment to port reception facilities.
Developing Ballast Water Management Plans
Whilst developing ballast water management plans appears a daunting task, there are industry standard templates available from various Class Societies. Many of these templates are drafted with ballast water treatment in mind, however they do form a useful baseline for development of any ballast water management plans.
Owners / operators should accumulate all of the required information from their archives and the vessel itself, to build an understanding of the current ballast water operations onboard. From this position, owners and operators can determine the most suitable ballast water management solution – whether it be ballast water exchange, ballast water treatment, or an alternative compliance solution – many of which are discussed in our recent article: Alternative Methods for Ballast Water Management Compliance.
From a vessel’s IOPP renewal survey after entry into force (8th September 2017), ballast water exchange will no longer be a suitable compliance method, and owners / operators should plan their compliance with this in mind.
Approvals and Implementing Ballast Water Management Plans
Once drafted, ballast water management plans should be submitted to the vessel’s respective Class Society and/or Flag State. These parties will review the contents of the plans, comparing them with the requirements of the IMO Ballast Water Management Convention, as well as the IMO G4 guidelines, and ensuring the plans meet the minimum requirements and intent of the legislation.
Once approved, owners and operators can implement the plans onboard.
It is recommended that owners and operators review the plans on an ongoing basis, in conjunction with the vessel crew, to ensure that the crew are operating in line with the requirements of the convention, and that the plan remains suitable for the vessel.
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