MEPC 71 Updates on Ballast Water Compliance Plans

MEPC 71
The Impact on Ballast Water Management Compliance Plans
Meet Your Presenters
MEPC 71 ‐ The Impact on Ballast Water Management Compliance Plans
Chris McMenemy
Managing Director
Naval Architect & Marine Engineer
 Involved in Ballast Water
Management for nearly 10 years
 Founding Member of IMarEST
Ballast Water Expert Group
 Widely Publicised on all Areas of
Ballast Water Management
 Retrofit Engineering Specialist
www.cleanshipsolutions.com
Webinar Contents
INTRODUCTION
& Overview of MEPC 71 Meeting
D‐2 STANDARDS of BWM CONVENTION
& Agreed Modifications to Implementation
D‐1 STANDARDS – BALLAST EXCHANGE
Updates for Vessels Struggling to Comply with D‐1 Due to Geographical Constraints
OTHER UPDATES & AMMENDMENTS
Including Same Risk Area, Experience Building Phase & Contingency Measures
SUMMARY
Of Impact on Compliance Planning
Specialists in Vessel Efficiency and Environmental Compliance
“Dedicated to helping shipowners & operators achieve environmental compliance in
as cost efficient a manner as possible..”
Environmental Compliance & Retrofit Services Include:
 Ballast Water Management
 Exhaust Gas Cleaning
 MRV & CO2 Reduction
 Ship Recycling
Over 35 Retrofits & Counting…
Experience
 Largest retrofitted vessel in world – 310,000
DWT VLCC
 ROPAX vessel retrofit installation in just 100
hours
 Wide range of vessel types & sizes
 Global operations & availability
A small selection of our clients…
Our Ballast Water Management Process
STAGE 1 – Vessel STAGE 3 – STAGE 5 –

and/or Fleet Detailed Installation &
Compliance Engineering & Project
Review Class Approval Management
1. 3. 5.
COMPLIANCE
2. 4. 6.
STAGE 2 –
STAGE 4 –
Vessel Survey, STAGE 6 ‐
Procurement &
3D Laser Scan & Commissioning
Pre ‐ Fabrication
Feasibility Study
BWM – 20 Years in the Making…
2017
IMO Ballast Water
2004 2012 Management
IMO Ballast Water USCG adopted and Convention enters
Management implemented their into force on 8th
Convention Adopted “Final Rule” September 2017
1 2 3 4 5 6 7
1997 2008 2016 2024
IMO’s “Guidelines for The first ballast water The IMO Ballast Final dates for
Control and treatment systems, Water Management compliance
Management of suitable for Convention finally
Ships’ Ballast Water compliance with the achieves its
to Minimise the D‐2 standard, are ratification
Transfer of Harmful installed requirements on 8th
Aquatic Organisms & September 2016
Pathogens”
MEPC 71 BWM Agenda – July 2017
D-2
Ballast Water
Implementation
Schedule Exchange
Contingency BWM – How to

Measures Do It Manual
Code for Experience Updates to

Approval of Building Guidelines &
BWMS Phase Circulars
Survey & Recent BWMS

Certification Approvals
MEPC 71 – Debunking the Myths!
• The BWM Convention has not been postponed..!
• The D‐2 requirements have not been pushed back until 2024..!
• Owners have not gained a 7 year reprieve..!
• D‐1 Ballast Exchange has not been postponed..!
• De‐harmonisation before September 2017 is no longer beneficial..!
Amendments to D‐2 Implementation
D‐2 Compliance Timeline for New Vessels (Regulation B‐3.5):
for "new ships" (ships constructed on or after 8 September 2017) : it is agreed to apply the entry‐into‐force date of the BWM Convention as
the date to conduct Ballast Water Management that at least meet the standard described in regulation D‐2
D‐2 Compliance Timeline for Existing Vessels (Regulations B‐3.1, 2 ,3, 4 and 10):
for "existing ships" (ships constructed prior to 8 September 2017):
• the first IOPP renewal survey after entry into force: this applies when that the first renewal survey of the ship takes place on or after 8
September 2019 or a renewal survey has been completed on or after 8 September 2014 but prior to 8 September 2017.
• the second IOPP renewal survey: this applies if the first renewal survey after 8 September 2017 takes place before 8 September 2019. In
this case, compliance must be by the second renewal survey (provided that the previous renewal survey has not been completed in the
period between 8 September 2014 and 8 September 2017).
D‐2 Compliance Timeline for non IOPP vessels (Regulation B‐3.8):
Existing Ships which are not subject to hold an IOPP certificate shall comply with the standard described in regulation D‐2 from the date
decided by the Administration, but not later than 8 September 2024. They will be required to comply with regulation D‐1 until such time.
Amendments to D‐2 Implementation
Sept 8, Sept 8, Sept 8, Sept 8, Sept 8, Sept 8, Sept 8, Sept 8, Sept 8, Sept 8, Sept 8,
2014 2015 2016 2017 2018 2019 2020 2021 2022 2023 2024
REG B-3/5 Ships not subject to IOPP Certification

D-2 Compliance no later than Sept 8, 2024
REG B-3/10.1.1 1st IOPP Ren Survey Completed > Sept 8, 2019
D-2 Compliance
OR
IOPP Ren Survey Completed 1st IOPP Ren Survey Completed > Entry Into Force
REG B-3/10.1.2 D-2 Compliance
REG B-3/10.2 APPLIES IF 1st IOPP Ren Survey > 2nd IOPP Ren Survey
REG B-3/10.1.2 DOES Entry into Force > Entry into Force
NOT APPLY
D‐2 Amendments – Impact on Planning
De-harmonisation is no Longer Beneficial Maintaining IOPP Renewals May be Prudent

Vessels with IOPP renewals between 8th September Vessels undertaking IOPP renewals after entry into
2014 and 8th September 2017 obtain no benefit from force but prior to 8th September 2019 can gain until up
the D‐2 amendments – the first IOPP renewal after to 2024 to comply – pushing back IOPP renewals as far
entry into force will remain their compliance date. as possible may be a sensible approach*
USCG Requirements Apply Regardless Newbuilds will Require D-2 Compliance

Regardless of how and when a vessel is required to comply All vessels built after entry into force will be
with the amended D‐2 standard, the USCG compliance required to comply with the D‐2 requirements
requirements will still apply – being the first drydocking immediately upon entry into service. Owners can
after January 2014, or 2016, depending on capacity. no longer simply leave space for a future retrofit.
D‐1 Standards & Ballast Water Exchange
Existing Ballast Water Management Convention Requirements:
Regulation B‐4 ‐ Ballast Water Exchange
1 A ship conducting Ballast Water exchange to meet the standard in regulation D‐1 shall:
.1 whenever possible, conduct such Ballast Water exchange at least 200 nautical miles from the nearest land and in water at least
200 metres in depth, taking into account the Guidelines developed by the Organization;
.2 in cases where the ship is unable to conduct Ballast Water exchange in accordance with paragraph 1.1, such Ballast Water
exchange shall be conducted taking into account the Guidelines described in paragraph 1.1 and as far from the nearest
land as possible, and in all cases at least 50 nautical miles from the nearest land and in water at least 200 metres in
depth.
BUT WHAT IF MY VESSEL TRADES IN WATERS THAT CANNOT MEET THIS CRITERIA..?
D‐1 Standards & Ballast Water Exchange
MEPC 71 Approved the following:
Under BWM.2/Circ.62 – Application of the BWM Convention to ships operating in sea areas where ballast water exchange in accordance
with regulation B‐4.1 and D‐1 is not possible:
• Vessels that cannot meet the requirements of Regulation B‐4.1, due to geographically constrained voyages, should record the reason why
a ballast water exchange was not conducted
• Vessels that cannot meet the requirements of Regulation B‐4.1, shall not be expected to meet the requirements of D‐2
• Vessels shall not be expected to deviate from their intended voyage, or delay the voyage, in order to conduct ballast water exchange
It should be noted that vessels undertaking voyages within waters that do meet the requirements of B‐4.1, or through waters in which local
Port States have designated specific ballast exchange areas, will be expected to comply with the D‐1 standard.
D‐1 Exchange– Impact on Planning
Coastal / Short-Sea will Benefit Ports May Have the Final Say
Vessels operating in coastal areas or short‐sea Ports may hold all the aces, and insist that vessels not
operators that seldom, if ever, trade in waters that conducting ballast exchange meet specific local
meet the requirements of Regulation B‐4.1 can now requirements. This may well be likely in port areas
avoid having to carry out exchange. sensitive to invasive species – such as Republic of Ireland.
D-1 is not Acceptable Under USCG Newbuilds will Require D-2 Compliance
For sea‐going vessels trading into the US, ballast water All vessels built after entry into force will be required to
exchange and the D‐1 standard is not an acceptable comply with the D‐2 requirements immediately upon entry
method of compliance under USCG requirements. Owners into service. D‐1 compliance will not be acceptable for a
should ensure they meet the requirements of USCG. newbuild vessel built after entry into force.
Other Updates & Amendments
Experience Building Phase:
MEPC 71 adopted a resolution on the experience building phase associated with the BWM Convention – including activities such as:
Gathering of data Subsequent review of
related to the the BWM Convention
implementation and and consideration of
Non ‐ Penalisation operational experience Data Analysis
possible amendments
of BWMS based on experience
Non – penalisation of

Analysis of data
vessels that install
reported – considering
BWMS in advance of
the implementation of
D‐2 compliance date Data Gathering Subsequent Review
the convention and
that experience non
any unforeseen safety
compliance despite
or environmental
proper use and
concerns
maintenance of system
Contingency Measures:
MEPC 71 approved guidelines on Contingency Measures which provide guidance to owners, operators and port States when dealing with a
vessel arriving with non‐compliant ballast water. Contingency measures may include:
Managing all or part of
the ballast water in a Other operational
method acceptable to actions
the port
Ballast Water
Discharge to another Exchange as agreed by
vessel or shore facilty the vessel or port
State
Same Risk Area:
MEPC 71 adopted amendments to the G7 Guidelines for undertaking risk assessments in accordance with Regulation A‐4 of the Convention –
including, it is understood, guidelines on how risk assessments for same risk area can be supported by numerical & scientific evidence.
It is worth noting that same risk areas still remain a distant reality– and the amendments to the G7 Guidelines do not off much in the way of
simplification of the requirements of Flag States.
Revised G8 Timeline:
MEPC 71 agreed that BWMS approved in accordance with earlier versions of the G8 Guidelines, not later than 28th October 2018, may
continue to be installed onboard vessels until 28th October 2020.
Other Amendments ‐ Impact on Planning
Moving Early May be Beneficial Ports May Have the Final Say
Under the experience building phase and the agreed approach to Ports may hold all the aces, and insist that vessels not
non‐penalisation of early movers, owners may benefit from conducting ballast exchange meet specific local
installing early. Those who install a system at a later date are requirements under the guidelines for contingency
unlikely to receive the same leniency regarding non‐compliance. measures.
Same Risk Area is a Risky Bet Revised G8 Guidelines

Owners and operators hoping to take advantage of same risk areas to avoid With MEPC 71 agreeing to allow BWMS approved under existing G8
the need to comply with the D‐2 requirements may be taking a big gamble. guidelines to be installed onboard until 28th October 2020, Owners may
Whilst the G7 guidelines have been updated, it still remains prohibitively benefit from moving early and installing current systems, with fewer
expensive and complicated to achieve a same risk area exemption. “limitations” on Type Approval certificates.
Summary of Impact on Compliance Plans
Summary of D-2 Amendment Impact: Summary of Other Updates’ Impact: Summary of D-1 Exchange Impact:
De-harmonisation is no Longer Beneficial Moving Early May be Beneficial Coastal / Short-Sea will Benefit
Vessels with IOPP renewals between 8th September 2014 Under the experience building phase and the agreed approach to non‐ Vessels operating in coastal areas or short‐sea operators that
and 8th September 2017 obtain no benefit from the D‐2 penalisation of early movers, owners may benefit from installing early. seldom, if ever, trade in waters that meet the requirements
amendments – the first IOPP renewal after entry into Those who install a system at a later date are unlikely to receive the of Regulation B‐4.1 can now avoid having to carry out
force will remain their compliance date. same leniency regarding non‐compliance. exchange.
Maintaining IOPP Renewals May be Prudent D-1 is not Acceptable Under USCG
Ports May Have the Final Say
Vessels undertaking IOPP renewals after entry into force but For sea‐going vessels trading into the US, ballast water exchange
Ports may hold all the aces, and insist that vessels not conducting
prior to 8th September 2019 can gain until up to 2024 to and the D‐1 standard is not an acceptable method of compliance
ballast exchange meet specific local requirements under the
comply – pushing back IOPP renewals as far as possible may under USCG requirements. Owners should ensure they meet the
guidelines for contingency measures.
be a sensible approach* requirements of USCG.
USCG Requirements Apply Regardless Revised G8 Guidelines Newbuilds will Require D-2 Compliance
Regardless of how and when a vessel is required to comply With MEPC 71 agreeing to allow BWMS approved under existing G8 All vessels built after entry into force will be required to comply with
with the amended D‐2 standard, the USCG compliance guidelines to be installed onboard until 28th October 2020, Owners may the D‐2 requirements immediately upon entry into service. D‐1
requirements will still apply – being the first drydocking after benefit from moving early and installing current systems, with fewer compliance will not be acceptable for a newbuild vessel built after
January 2014, or 2016, depending on capacity. “limitations” on Type Approval certificates. entry into force.
Newbuilds will Require D-2 Compliance Same Risk Area is a Risky Bet
All vessels built after entry into force will be required to Owners and operators hoping to take advantage of same risk areas to
comply with the D‐2 requirements immediately upon avoid the need to comply with the D‐2 requirements may be taking a
entry into service. Owners can no longer simply leave big gamble. Whilst the G7 guidelines have been updated, it still remains
space for a future retrofit. prohibitively expensive and complicated to achieve a same risk area
exemption.
Further Resources – Cleanship Website
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MEPC 71 Updates on Ballast Water Compliance Plans

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MEPC 71

STAGE 1 – Vessel STAGE 3 – STAGE 5 –

Contingency BWM – How to

Code for Experience Updates to

Survey & Recent BWMS

REG B-3/5 Ships not subject to IOPP Certification

De-harmonisation is no Longer Beneficial Maintaining IOPP Renewals May be Prudent

USCG Requirements Apply Regardless Newbuilds will Require D-2 Compliance

Non – penalisation of

Same Risk Area is a Risky Bet Revised G8 Guidelines

Over 55 BWMS available to

Direct contact details to

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