Ballast Water management – How to comply


With the ratification of the IMO Ballast Water Management Convention on 8 September 2016, the convention will enter into force on 8 September 2017. With only some months to go, this Technical & Regulatory News is intended as a supporting document for the BWM implementation phase, focusing on compliance.

D1 – Ballast Water Management Plan (BWMP): an approved BWMP and a BWM Certificate or Statement/Certificate of Compliance must be on board the vessel before 8 September 2017, hence an early submission for approval is recommended to avoid last-minute approvalю

D2 – The deadline for installation of the ballast water treatment system is the first IOPP renewal survey after 8 September 2017

The convention refers to two standards for discharged ballast water that aim to prevent harm to the marine ecosystem: the D-1 standard covers ballast water exchange, while the D-2 standard stipulates the maximum number of organisms that can be discharged, usually achieved by ballast water treatment systems. The convention requires either the D-1 or D-2 standards to be complied with after entry into force date (8 September 2017).

The aim is that all vessels to which the convention applies will comply with the D-2 standard by the end of 2022. There will be a transitional period from the date of entry into force, when compliance with the D-1 standard is required, until compliance with the D-2 standard becomes mandatory. This date is firmly linked to the first IOPP renewal survey after the BWM Convention enters into force. The D-1 and D-2 requirements:

D-1 standard

  1. The approved BWMP must be available on board.
  2. The BWM record book must be provided on board to document all ballast water operations from 8 September 2017 onwards.
  3. An initial survey must be carried out to verify the compliance of the structure, equipment, systems, arrangements, etc. according to the BWM Convention requirements.

The BWM Certificate confirming compliance with the D-1 standard must be available on board.

D-2 standard (for an installed BWM treatment system and in addition to the requirements for D-1)

  1. A type-approved BWM treatment system installed and covered by a type-approval certificate issued by the administration.
  2. Approved technical documentation for the BWM treatment system.
  3. Operation manual for the BWM treatment system.
  4. An initial survey must be carried out to confirm compliance with the D-2 standard.
  5. The BWM Certificate confirming compliance with the D-2 standard must be available on board. For both D-1 and D-2, the following applies: In the case that the vessel’s flag has not yet ratified the convention, a Statement of Compliance (SoC) shall be issued and available on board.

US Coast Guard requirements

All ships calling at US ports and intending to discharge ballast water must carry out either exchange or treatment in addition to fouling and sediment management. The exchange of ballast water will only be allowed until the implementation deadlines for treatment systems come into force.

The US Coast Guard has introduced deadlines for the installation of BWM treatment systems that are different from those stipulated in the BWM Convention referring to the vessel’s regular dry-docking. The deadlines could be found here.

At the time of publication of this news, a limited number of BWM treatment systems have been approved meeting the US Coast Guard (USCG) requirements. Some treatment systems with a type-approval certificate according to IMO standards are temporarily accepted by the USCG Alternative Management System (AMS) for a period of five years, with the possibility of a further five-year extension, allowing these treatment systems to be used in US waters.


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