Essential Preparations for compliance and contingency options

Abstract

Even though the Ballast Water Management Convention (BWMC) (referred to herewith as the Convention) has been ratified and a few ballast water management systems (BMWS) have received US Coast Guard (USCG) type approval, many shipowners and operators are reticent to begin the significant process of planning for compliance with ballast water discharge and performance standards. This delay is most probably due to the uncertainty in the implementation dates in the BWMC and limited options of USCG type approved BWMS. These delays may result in significant ramifications for shipowners if the process for compliance is not fully evaluated. This process includes selecting, designing installation, purchasing, start-up and commissioning of BWMS. Clarity on the implementation schedule should be determined at the 71st session of the Marine Environmental Protection Committee of the International Maritime Organization (IMO MEPC 71) and allow shipowners to plan for compliance. An important aspect of implementation is developing a strong compliance plan. A central part of compliance is identifying possible problems and contingency options that may alleviate any potential port State control issues. The paper will identify possible problems and contingency measures to ensure ship operations are not impacted. An important issue is that the BWMC does not include provisions for contingency measures. The paper will also outline needed contingency measures to be addressed by the IMO in any amendments to the BWMC.