Entry into Force – Stepping Across the Line in the Sand
The 8th September 2017 has, for the past 12 months, represented a theoretically significant moment in the lifecycle of the IMO’s much debated and much eluded Ballast Water Management (BWM) Convention. From this day forward, owners and operators are legally obliged to comply with the requirements of the legislation, starting, of course, with D-1 compliance.
But with us finally stepping across this line in the sand, what has changed from the simultaneously joyous (for some), and dreadful (for others), ratification day some 12 months ago?
Clarification on D-2 Compliance Dates
In what was most certainly a positive step in the right direction, MEPC, during its 71st meeting in July 2017, amended the D-2 compliance dates and finally provided the industry with certainty and guidance on planning for compliance.
Whilst interpreted by many protagonists on the environmental side of the debate as IMO recanting on their much stated dedication to protecting the oceans, the amendments were certainly an overall encouraging step for an industry that has been filled with uncertainty, particularly since the debacle that was MEPC 70, where the committee failed to agree a definitive D-2 compliance timetable at all.
Perhaps surprisingly, the amendments actually circumvented owner and operator’s hopes of gaining another two years, with a clause meaning that any vessel that had already de-harmonised between September 2014 and September 2017, would not gain any additional time. Those that are lucky, and conduct IOPP renewals between September 2017 and September 2019, may now have up until 2024 to comply with the D-2 standards.
Our compliance date calculator is perhaps the indsutry’s most useful tool for helping owners and operators identify not only their IMO compliance dates, but also their USCG compliance dates. Check it out at www.cleanshipsolutions.com.
USCG Type Approvals
Perhaps the most positive development over the past 12 months has been the issuance of Type Approval certificated by the USCG to, at the time of writing, five manufacturers, namely: Alfa Laval, Optimarin, Oceansaver, Ecochlor and Sunrui.
With such a spread of technologies and hence vessel applications, the USCG will likely now feel confident in refusing any further extension applications, and can finally start to protect their waters – something they set out to do all those years ago.
In more recent times we have also witnessed the USCG applying penalties to owners and operators caught out of compliance – so they are strongly setting a precedent that owners and operators should pay close attention to.
Clarification on D-1 Geographical Challenges
Addressing an issue that has been discussed and debated for many years, MEPC 71 finally approved updates to the D-1 aspect of the BWM Convention, specifically areas discussing the minimum requirements for water depths and distances to shore, for carrying out ballast water exchange.
Vessels unable to achieve the minimal water depth and distance criteria, due to geographical constraints of their voyage, shall not be expected to deviate from their voyage and can, now, simply log this justification in their ballast water record book, and proceed as normal.
This of course will only suffice until a respective vessel’s D-2 compliance date, but the benefits shall be felt by many – particularly those trading in short sea shipping, or areas without designated ballast water exchange zones.
Growth in the Retrofit Market
With owners and operators finally having certainty of their compliance requirements and, critically, the dates they need to meet these requirements, many are already commencing their fleet retrofit plans, to steal a march not only on their competition, but also the competitive pricing currently observed in the marketplace.
At Cleanship Solutions, we have witnessed at least a 400% increase in interest in retrofit assistance in the past 12 months – testament perhaps not only to the increase in demand as the retrofit market accelerates, but also to our impartial and honest approach to helping owners and operators comply.
One thing is for sure, however – the market is only going to continue to accelerate upwards as the D-2 and USCG compliance dates draw nearer, and all aspects of the supply chain are going to witness increased demand as a result. Our advice – plan ahead, engage a compliance partner early, and don’t wait until the last minute to attempt to address an entire fleet’s compliance issues.
Guidance & Information for Shipowners and Operators
One thing that hasn’t changed in the past 12 months, and, indeed, barely in the past 13 years since the inception of the IMO BWM Convention, is the volume of useful information, guidance and tools for owners and operators in achieving compliance for their existing fleet.
The retrofit market has been, and always will be, the most challenging aspect of ballast water management compliance yet, despite this, the level and quality of practical, useful information for owners and operators in achieving retrofit compliance is minimal.
Yes we have numerous conferences each year – with the same presenters making the same presentations flouting their own commercial interests, yes we have Class Society guides on achieving BWM compliance – including, predominantly, a re-hash of publicly available information, yet there has been very little in the way of tangible, practical, impartial guidance on the retrofit process.
Cleanship Solutions is today launching its Guide to Ballast Water Management compliance – The definitive hardback retrofit compliance guide including over 50 pages of compliance tips, practical retrofit guides, ludicrously useful planning tools and unique distinctions & considerations from over 5 years and tens of thousands of hours of helping owners and operators comply.
Not only does is our new guide the most useful and practical compliance guide on the market, but it’s also 100% free to the first 200 readers.
Our guide addresses topics such as:
Compliance methods – including exchange, treatment and crucially, alternative compliance methods
- Quick start guides to compliance – with unique and powerful compliance checklists
- The retrofit process – a deep dive into the six stage retrofit process, the benefits of feasibility studies, suggested retrofit installation approaches with associated timelines, and template project Gantt charts for compliance planning
- Ten step guides to selecting a BWM system – based on or extensive experience in helping owners and operators do just that, and avoid the common pitfalls and issues when selecting a system
- Developing ballast water management plans – including exchange, treatment, sediment control as well as approvals and documentation
It is the only guide to compliance you will ever need.