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Latin American PanelOctober 31, 2012
Ballast Water Management
JOSEPH ANGELODEPUTY MANAGING DIRECTOR
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Different regimesInternational
National/RegionalLocal
INTERTANKO ActionsIMO Response
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INTERNATIONALIMO Ballast Water Management Convention Adopted in 2004 Entry into force requires ratification by 30 countries, 35% world’s grt Currently, 36 countries, 29.06% grt
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INTERNATIONAL BWM Plan and Record Book BWM System performance standard Compliance schedule to install BWMS Survey and certification requirements Port State Control procedures
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NATIONAL – US Coast Guard Final regulations issued March 2012 Main requirements include:
BWM plan and record keeping; BWM standard (same as IMO) with review in 4 years; Compliance schedule (similar to IMO); Acceptance of “Alternative”BWMS for 5 years
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Regulatory schedule - IMO
Enforcement 12 months after ratification i.e. - earliest October 2012 if ratified now - Installation at first Intermediate or Periodical Survey
Ballast capacityYear of ship construction
Before 2009 2009-2011 2012+
> 5,000 m3 Ballast water exchange or treatment until 2016 Ballast water treatment only from 2016
Ballast water treatment only
Before 2009 Constructed 2009 +
1,500 – 5,000 m3 Ballast water exchange or treatment until 2014. Ballast water treatment only from 2014
Ballast water treatment only
< ,1500 m3 Ballast water exchange or treatment until 2016. Ballast water treatment only from 2016
Ballast water treatment only
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Regulatory schedule - USCG
Implementation Schedule for Approved Ballast Water Management Methods
Vessel’s ballast water capacity (in cubic meters)
Date constructed
Vessel’s compliance date
New vessels All On or after Dec. 1, 2013
On Delivery
Existing vessels
Less than 1,500m3
Before Dec. 1, 2013
First scheduled drydocking after Jan. 1, 2016
1,500 – 5,000 m3
Before Dec. 1, 2013
First scheduled drydocking after Jan. 1, 2014
Greater than 5,000m3
Before Dec. 1, 2013
First scheduled dry-docking after Jan. 1, 2016
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NATIONAL – US EPA Vessel General Permit (VGP) Dec 2008 Main requirements include:
BWM plan and record keeping; BWM exchange; Allows states to impose additional requirements; VGP required to be renewed in 5 years
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LOCAL – New York and California BWM standard that is 100x and 1000x greater than IMO Considerable lobbying by industry coalition EPA Science Advisory Board report – standard not possible with current BWM technology Reason prevails, for the time being
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REGIONAL – EU BWM equipment not included in the Marine Equipment Directive (MED) EU is considering amending MED to bring in the equipment required by the BWM Convention as a mandatory standard Legal amendments to MED to include BWM equipment is scheduled for October 2012 Possible “EU approval regime” could become reality in October 2013.
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INTERTANKO ActionThe Key Challenges
Technical – treatment equipment and approval
Regulatory – BWM Convention implementation and its enforcement
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Policy background1. ISTEC and Environmental Committee – March 2012
• Details technical, operational and compliance challenges
2. Council – May 2012• Recommends comprehensive paper covering the
challenges and proposing solutions be sent to IMO
Submission to IMO’s MEPC 64 (October 2012)• Jointly with Liberia, the Marshall Islands, Panama,
BIMCO, CLIA, INTERCARGO, InterManager, IPTA, NACE and WSC - submitted August 2012
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IMO MEPC 64 SubmissionExplains the challenges being faced for effective implementation of the BWM Convention and to provide proposals to address those challenges
Submission covers FOUR key areas:
1. Guidelines for approval of ballast water management systems (G8);
2. Availability of Ballast Water Management Systems (BWMS);
3. Survey and certification requirements
4. Procedures for port State control
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– Greater transparency of information on the Type Approval Certificate and its enclosures
• Total Rated Capacity, 60m3/hr tested but approved to 6000m3/hr
– Type Approval process needs to more accurately reflect real-world environment aboard
• Brackish and freshwater tests• High sediment waters
– Proposals to strengthen Type Approval process• To ensure that a BWMS works in practice as well as theory
1. The need for revision of the Guidelines for approval of ballast water management systems (G8) to improve transparency
and ensure appropriate robustness of Ballast water management systems (BWMS)
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– As the BWM Convention dates are progressively surpassed the number of ships to which the requirements apply 12 months after full ratification continually increases
– Ship yards and BWMS manufacturers coming under increasing pressure to install systems within the time frame (implementation schedule)
– Recommend discussion of ‘new’ BWMS installation dates– BWM Convention cannot legally be amended until convention enters
into force– Problem was recognized in 2007 when limited technologies were
available to meet first implementation date of 2009– IMO Assembly adopted resolution recommending acceptance by
parties of delayed installation date
2. The availability of BWMS and sufficient facilities to install BWMS
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2009 2010 2011 2012 2013 2014 2015 2016 2017 2018 2019 2020
Newly constructed Vessels (less than 5,000 cubic metres)
1,740 1,740 1,740 1,740 1,740 1,740 1,740 1,740 1,740 1,740 1,740 1,740
Newly constructed Vessels (greater than 5,000 cubic metres)
0 0 0 1,690 1,690 1,690 1,690 1,690 1,690 1,690 1,690 1,690
Existing Vessels (between 1,500 and 5,000 cubic metres)
0 0 0 0 0 0 2,500 2,500 2,500 0 0 0
Existing Vessels (less than 1,500 or greater than 5,000 cubic metres)
0 0 0 0 0 0 0 0 8,800 8,800 8,800 0
Vessels constructed from 2009 to 2011 (greater than 5,000 cubic metres)
0 0 0 0 0 0 0 0 1,690 1,690 1,690 0
TOTAL 1,740 1,740 1,740 3,430 3,430 3,430 5,930 5,930 16,420 13,920 13,920 3,430
MEPC 61/2/17 by Japan
Current Estimated Installation Schedule Dates
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– No phase-in period for survey and certification of ships following entry into force
• ROs required to review and approve BWM Plans as well as survey and certify ships within 12 month period
– Solution provided at MEPC 63 – commence issuance of BWM Certificates prior to entry into force
– Proposal to issue circular in this respect to increase awareness through industry and maintain uniform implementation
3. Survey and certification requirements for ships constructed prior to entry into force of the BWM Convention
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– Urge harmonised standard operating procedure for sampling and analysis of ballast water by PSC.
– Coupling of Type Approval process with the enforcement process
• Currently the Type Approval process is separate from the PSC process so an approved BWMS may not meet the PSC analysis once installed on board.
– Uncertainty in the PSC sampling and analysis process key impediment to further ratification
4. Sampling and analysis procedures for port State control purposes
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OUTCOME OF MEPC 641. Revision of the G8 Guidelines
Decided not to amend the G8 guidelines (at this time), BUT agreed to develop additional guidelines on the application of the G8 guidelines which to address the issues raised in our submission
2. Availability of BWMSEstablished as correspondence group (lead by Japan) to develop an Assembly resolution regarding the implementation of Regulation B-3
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OUTCOME OF MEPC 643. Survey and certification requirements
Agreed with our proposal to issue an MEPC Circular
4. Sampling and analysis procedures for PSCAgreed with our proposal to instruct BLG (and FSI) Subcommittee that sampling and analysis procedures for PSC should be no more stringent than what is required for type approval of BWMS
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Summary1. “Positive” developments at MEPC 64, but more work needs to
be done2. Members learning on a day-by-day basis3. Sharing of experience and information between members
essential1. Does the BWMS work?2. Does it work as it was approved to work?3. Does it meet the discharge standards?
4. Propose amendments to IMO’s BWM Guidelines based upon experience gained, while supporting their international and uniform approach
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Finding, installing and operating systems on tankers?
Ballast Water Guidance
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To assist members during selection, assessment and installation for existing and new built vessels:
INTERTANKO Guidance on the Selection and Installation of Ballast Water Management Systems for
Tankers
Physical InstallationPumpingControl – system approval and certificationTreatment typeOperating practicalitiesReleased January 2012
Ballast Water Guidance
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Thank you!
www.intertanko.com
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