IMO ballast water convention set to enter force?

Indonesia ratified IMO Ballast Water Management Convention yesterday Indonesia ratified IMO Ballast Water Management Convention yesterday

NOVEMBER 25, 2015 — Indonesia yesterday became the 46th state to ratify IMO's Ballast Water Management Convention. Once Indonesia's gross tonnage data are verified, the convention will be set to enter into force worldwide from November 24, 2016.


The International Chamber of Shipping (ICS) says that the fixing of a definite implementation dategives 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.   

However, IMO has to finalize the much needed revision of its type approval guidelines for Ballast Water Treatment Systems (BWTS).

The International Chamber of Shipping says that this revision is needed "as soon as possible, in order to 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."

In other words, the IMO Type Approval process currently in place doesn't give absolute confidence that an IMO approved system will actually work. That, of course, is why the IMO approvals of BWTS have never been taken at their face value by the U.S., which has its own, tougher, approval system in place.

The International Chamber of Shipping has never been very happy about that and says that entry into force of the new IMO regime "does not resolve the extreme difficulties that still exist in the United States. There is still great uncertainty with respect to the more stringent United States approval regime for treatment equipment, which started to be enforced in January 2014 (the U.S. not being a Party to the IMO Convention). 

"The U.S. regulations require all ships that discharge ballast water in U.S. waters to use a treatment system approved by the Coast Guard. 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  $1 million -5 million per ship, might then have to replace the system completely after only five years. This is a particular concern for operators that have installed ultra-violet (UV) systems.

"There are over 50 treatment systems approved under the current IMO regime, but worryingly fewer than 20 manufacturers have so far indicated their intent to submit their systems for U.S. approval.   The conflicting IMO and U.S. requirements, when combined with the complete lack of systems fully approved by the USCG, could produce an impossible situation in which some ships might not be able to operate in U.S. waters when the IMO Convention enters in force."

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