Anna Ziou, Policy Manager to the UK Chamber of Shipping gave her view on the implications of the Ballast Water Management (BWM) Convention at the recent Ballast Water Implementation Forum, hosted jointly by the UK Chamber of Shipping and Fathom Maritime Intelligence.
One of the key issues Ziou drew upon was the decision that was made at MEPC 70 to not penalise early movers. As Ziou stated, the regulation says that ship owners will not be required to replace a ballast water treatment system (BWTS) for the life of either the vessel or the system itself if they have already installed one prior to the implementation of the Convention. However, the key problem lies in that if the BWTS life outlives the ship, it cannot be installed to another ship and still remain compliant. Therefore, the system could have a reselling value of zero as once the ship it was installed on comes out of operation, the system has no value as it cannot be installed to the owners newbuild and still be in compliance with the regulation.
This therefore illustrates the problem will the regulation and reiterates Ziou’s comment that a regulation and Convention is needed, but whether this is the right one is questionable.
As echoed by other speakers, Ziou drew upon the difficulties owners face with two different requirements set by the International Maritime Organization (IMO) and the United States Coast Guard (USCG). While the IMO focusses on assessing the feasibility of a BWTS using a viable/non-viable organism approach, the USCG requires organisms to be either dead or alive in order to pass or fail its Type Approval testing. The fact that there are no USCG Type Approved systems to date, while the Coast Guard doesn’t look like it will align its regulations with the IMO any time soon, makes this an increasingly challenging hurdle to jump.
Other difficulties of implementing the Convention also lie in the fact that there is still much uncertainty as to whether the second text will be accepted and if so, it may not benefit many and just add more uncertainty, Ziou confirmed. Ship owners need to add contingency measures into their BWM plans, but often the options to take are difficult to decipher and as ports are not included in the Convention, this can be challenging Ziou stated. If ship owners decide on a plan following the breakdown or faulty functioning of their BWTS, they can implement contingency plans to deal with it. However, if ports decide not to accept the contingency, then what are ship owners to do, Ziou asked.
In order to enable ship owners to work with the Convention, an enforcement schedule needs to be designed, short sea shipping needs an IMO unified interpretation, and Type Approval of USCG systems is required, stated Ziou. She also urged members to come to the UK Chamber of Shipping with their issues in order to allow the Chamber to look for clarification and put pressure on the IMO and other organisations to come up with standard, unified and appropriate decisions. Collaborations are also vital to facilitate exemptions where required, concluded Ziou.
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