This is a busy week for the Ballast Water Review Group at IMO’s Marine Environment Protection Committee (MEPC 74). And possibly a frustrating one: ballast water topics were originally listed for discussion on Monday but my report of that day gives an idea of how time was swallowed up. Tuesday (14 May) began with the chairman saying that we were already a day behind schedule and it was gone lunchtime before we finally turned to ballast water, with 36 documents listed for discussion, not to mention outputs from the previous two meetings of MEPC’s Sub-Committee on Pollution Prevention and Response (PPR 6 and PPR 5).
Fortunately, the review group had been released on Monday morning to start its work early, so it has a chance of delivering its report back to the plenary session on Thursday or Friday.
That report, of course, may not support all of the proposals sent for review and some were nominated to be passed to PPR 7 early next year.
Most of the papers were available before the meeting on the IMODOCS website and they will all be available after the meeting so this brief review looks at just some of those that came up for discussion in the plenary session.
Before that, however, the secretariat presented a summary of the information so far gathered during the Ballast Water Management Convention’s experience-building phase. Since December 2018 there has been a dedicated area for this in IMO’s Global Integrated Information System (GSIS) but no data has been received so far, the meeting heard, although some member states plan to start submitting information in the near future.
This is disappointing; it is essential that any future amendments to the convention are based on practical experience. It is also worth noting that the cost of analysing the data requires its own funding but, as of Tuesday, just four IMO member states had contributed towards that, with a fifth declaring a planned contribution during the meeting.
As for the topics covered during the session, the first one up for discussion involved the International Ballast Water Management Certificate (IBWMC), addressed in a joint paper by China and IACS (MEPC 74/4/14, if you would like to read it in full via IMODOCS).
Its current form is too simple, its backers said, with very few options offered, leading to inconsistencies in how it is completed and confusion for port state control inspections. The paper includes a proposed alternative certificate format. This may seem an esoteric point, but most of the comments during discussion were supportive, with one delegation saying that there was “a compelling need” for more clarity. Others had concerns about some of the proposal’s details and it was referred to the review group for its consideration.
Another paper (MEPC 74/4/12) that was passed to the review group aims to make it a requirement that ballast water management systems are tested during their commissioning, something that the BWMS does not require. IACS had highlighted this anomaly at MEPC 72, describing it then as “a fundamental problem” and MEPC 73 had invited proposals for an amendment, which the Bahamas had responded to for this meeting.
It has proposed an amendment to regulation E-1 in the BWMC to specifically mention the commissioning test and an indicative analysis, both for initial and additional surveys when a BWMS is installed on an existing ship. There would also be a corresponding amendment to the BWMS Code.
But these would probably not come into force until 2021, one delegation pointed out, and urged the committee to reiterate some previous encouragement that tests are conducted “to avoid confusion and ensure the validation of tens of thousands of installations” that will begin later this year.
IACS welcomed the proposal; “we are very grateful for this paper,” its delegation said.
A third topic I will mention concerns a new concept, introduced by Nigeria: a ‘port with acceptable risks’ (MEPC 74/4/8). This is intended to provide an exemption from fitting a BWMS for ships that operate between ports that have installed onshore type-approved BWMS facilities from which a ship could pre-load treated ballast water that could be discharged on arrival. This would “enhance compliance with the convention, especially in developing countries,” its submission said.
In discussion, delegates raised concerns over some details, such as the risk of contamination of the loaded ballast or regrowth during a voyage, which could make the water non-compliant on discharge, but were generally supportive of the concept and it was referred to the review group to consider if it had time.
Finally, a joint paper by China and South Korea (MEPC 74/4/15) offered comments based on their experience of trying to establish a same risk area (SRA) for the waters between those two countries and finding a number of difficulties in doing so. They proposed setting up a correspondence group but the conference chair declared that the presentation did not constitute a specific request to do that and asked China to submit a concrete proposal to a future meeting.