The Liberian Maritime Administration is to introduce a proposal to the meeting of the IMO Marine Environmental Protection Committee (MEPC70) in London on 24 October to allow certain ships additional time beyond 2020 to install adequate ballast water management systems as required under the Ballast Water Management Convention, which comes into force in September 2017. The proposal, says Liberia, would ensure that enough adequate systems and sufficient dockyard space are available.
With effect from 8 September, 2017, most oceangoing ships engaged in worldwide operations will be required to install a ballast water management (BWM) system approved in accordance with IMO guidelines. But it has emerged that the current IMO guidelines are not sufficiently detailed to ensure that BWM systems have been adequately challenged to provide the required confidence that they will meet the required discharge performance standard, regardless of where a ship may operate.
David Pascoe, Senior Vice-President, Operations & Standards at LISCR, the US-based manager of the Liberian Registry, says, “Having conducted additional assessments of IMO type-approved BWM systems intended for installation on Liberian-flag ships, the Liberian Administration has identified certain potential limitations, which have been listed on the Liberian Type Approval Certificate issued to manufacturers. This additional information helps shipowners make informed decisions in connection with BWM systems.
“Liberia actively promoted the revision of the IMO BWMS approval guidelines. It is participating in the revision to make them more transparent, robust and fit-for-purpose, and is offering its proposals for smooth implementation to MEPC 70. These have already attracted strong support from concerned IMO member states and other organisations, with the Marshall Islands reportedly among those electing to follow Liberia’s lead.
“The revised BWMS approval guidelines are expected to be roughly aligned with the robust type-approval regime of the United States, thus establishing a rigorous global standard for BWMS type-approval. But there are no BWM systems currently approved by the US, and it could take several years for equipment approved under the new IMO guidelines to be readily available for installation. In the meantime, tens of thousands of ships may be required to install existing systems that may not fully comply with the convention standards.
“The compliance dates for ships are linked to the date a ship’s International Oil Pollution Prevention (IOPP) certificate is renewed after 8 September 2017. In order to allow more time for new systems to become available and for shipowners to decide which system to invest in and install (bearing in mind that the cost to retrofit a BWMS is estimated to be up to $5m per ship) Liberia has proposed that shipowners may decide if they wish to renew a ship’s IOPP certificate earlier than scheduled in order to have an additional 4-to-5 years to see if new equipment becomes available.
“It is by no means certain that adequate new systems will be commercially available in sufficient quantities within this period. Additionally, based on a study by Liberia, the dockyard capacity to fit systems on board ships will fall well short of peak demand, expected to occur in 2020-2021.
“While the IMO roadmap for implementation of the BWM Convention provides for non-penalization by port states of ships that have installed BWM systems (so-called ‘early movers’), it may be that this equipment will require modification or replacement in the future, as will be the case in the US. It would therefore seem reasonable not to require continued installation of BWM systems which have not been approved under the new guidelines and to allow certain ships additional time beyond 2020 in order to ensure that adequate new systems are commercially available, along with the necessary dockyard space for installation. ”