Вопорос об имплементации Конвенции по управлению балластными водами как никогда актуален, ведь вступление ее в силу мы можем ожидать уже с приходом 2017 года. Основные требования акта состоят в следующем: установление дорогостоящего оборудования по обработке балластной воды, проверка проб воды инспекцией порта, в случае необходимости, то есть при наличии явных оснований, обучение моряков управлению балластной водой. Стоит отметить, что конвенция имеет конкретные сроки по поводу вступления в силу стандарта D2 (обработка балласта) – 2017 год. Некоторые компании уже приобрели системы обработки балластной воды, но те кто не успел будут вынуждены сделать это в кратчайшие сроки при условии вступления в силу Конвенции в конце 2016 года. Хорошая новость в том, что учитывая технический прогресс, все дорогостоящее оборудование постепенно падает в цене, а уже установленное оборудование может быть использовано и в дальнейшем.
The introduction of the Ballast Water Management (BWM) Convention and the time frame for its implementation form one of the most interesting topics in the maritime community at the moment – and one with massive implications for owners, managers and seafarers alike.
Although it was first signed in 2004, the BWM is still in the process of ratification. Bv the 69th session of the IMO’s Marine Environment Protection Committee (MEPC 69) in April this year, the number of parties to the convention had reached 49, representing 34.79% of the world’s tonnage. By mid-June, 51 parties had signed the convention, bringing total tonnage to 34.87% of the world fleet. A further 0.13% is needed to reach the 35% of the world fleet that will trigger the convention’s entry into force. This means that it is more than likely that it will enter into force within the next year – the remaining 0.13% could be made up by almost any IMO member state. What can we expect next year?
Implementation dates
Many companies have already implemented BWM requirements, so they will have fewer surprises to cope with. The main way in which the BWM Convention differs from other IMO conventions is that the D-2 Standard requiring onboard ballast water treatment equipment will come into force for certain vessels within the next year, rather than depending on the exact date of convention’s entry into force. Implementation of this standard is one of the main obstacles for the convention: such equipment is very expensive and it can be difficult to retrofit it on existing ships.
The mattter has provoked a lot of discussion, which was continued at MEPC 69. It was proposed to move the deadline for the implementation of the D-2 Standard to a later date to be determined by the committee. The idea was simply to give ship management companies extra time to install the necessary equipment. However, it is probable these amendments will only be discussed at IMO level after the BWM Convention has entered into force. Meanwhile, the MEPC Committee has requested the Ballast Water Review Group (BWRG) to work out the final draft of the amendments to Regulation B-3 {the implementation schedule) at the next meeting of the MEPC.
This means the timetable for the implementation of the D-2 Standard could be quite complicated. As soon as the standard comes into force there will be tough requirements for treatment equipment on board – which could then be postponed after just a couple of months, lo be on the safe side, ship managers should install treatment equipment now, it was suggested.
Many shipping companies have already installed treatment units on board their ships… and some may have regretted it. Within the past few years, treatment technologies have made big steps forward, and first-generation treatment equipment has rapidly become out of date. IMO had to make a special decision allowing ships to continue operating with their existing equipment in order to get past this obstacle to implementation.
It is a bit early to say the problem is completely solved. The USA has established its own rules and regulations regarding ballast water treatment units. This is one of the reasons why the process of ratifying the BWM Convention is so slow – the flag states are waiting for a more or less unified approach to emerge. Any expectation of a unified approach will be in vain, however, because the United States is not going to ratify the BWM Convention in the near future. Ship managers trading in US waters will have to buy equipment that complies with both IMO and US regulations.
Sampling procedures
Another problem was connected to sampling procedures. The convention initially required sampling of all ships’ tanks during routine port inspection. Of course ship managers could not accept a situation where every’ ballast tank on every vessel had to be sampled at every port of call. After interminable discussions a solution was found. Sampling will be carried out at a single point (close to the ballast water outlet, after pump, while deballasting), and in the process of a detailed inspection only; a routine inspection should not include sampling.
A detailed inspection will be required only if the inspector has clear grounds to demand it. IMO has approved this approach as the most efficient one that is not likely to compromise the safety’ of the marine environment. In practise, this should mean that routine inspections will not be onerous for Captain or crew. However, if in the process of a routine inspection the port state control (PSC) officer finds any sign of non-conformity, that routine inspection will immediately become a detailed inspection.
You may well ask what constitutes clear grounds for a detailed inspection. These include:
- Absence of an international ballast water management certificate on board;
- Data recorded on the international BWM certificate do not reflect the actual situation on board;
- Absence of a BWM plan on board;
- Procedures in the shipboard BWM plan are not implemented or not fulfilled;
- Absence of, or poor recording in, the BWM record book;
- Absence of BW treatment equipment on board (if required);
- Treatment equipment is fitted, but the type approval certificate is absent;
- Poor general condition of the ship;
- Visible damage to hull or machinery’;
- Information about a collision or accident;
- Non-conformities in ship’s safety management and marine environment protection system;
- Ship’s dew is not familiar with the duties set out in the ships BWM plan;
- Information from the ship’s previous port of call;
- Information, report or complaint from crew member, professional organisation, trade union or other source interested in ship’s safety and marine environment protection.
This list is not exhaustive, and it is important to remember that while some of these points may seem minor compared with others – such as poor knowledge of BWM duties by crew – any one of them can trigger a detailed inspection. The PSC officer can also check the records in the ballast water record book and compare them against the previously completed BW reporting form, ship’s or engine log book, or any other documents related to the ballast water system or mechanisms. The PSC officer also has the right to check treatment equipment in operation. Any discrepancy may lead to detailed inspection. There are no ‘minor’ or ‘less important’ items.
One more ‘hidden obstacle’ needs consideration. As mentioned above, sampling must be conducted while deballasting, so some volume of the ballast water will have to be pumped out before die results of sampling analysis can be obtained. Should sampling results be negative, this may cause problems for the ship. However, this is the only method of detecting ballast water pollution, as there is no way to find such pollution by taking samples from sea water. This is in contrast to oil pollution, for example, where we can detect not only the guilty ship, but even the specific tank that is the source of pollution.
Operational issues
Implementation of the BWM Convention requires more than just fitting treatment equipment on board. The seafarers must know how to operate this equipment safely. Some of the technologies are already familiar to seafarers – liquid filtering is used on all ships, UV treatment of fresh water is also well known. However, some other technologies, especially those employing active substances, are brand new and require special training. That’s why it is very important to include such training in the curricula of the educational institutions and seafarer training centres. Training should be arranged not only for engine staff, but for the deck officers as well, because they need to understand the procedures, influence of BW management on the ship’s stability, importance of correct record-keeping and other important issues.
Maintenance
To summarise, there are some factors that will simplify the implementation of the BWM Convention: treatment equipment is becoming cheaper due to technological progress, existing equipment can still be used, sampling is to become a special procedure rather than a routine one.
Does all of this mean ships’ crews can relax and await cleaner seas?
It seems not, and there are several tasks that will require very careful attention from the crew:
- Operation and maintenance of the equipment;
- Proper record-keeping;
- Assisting in sampling (if necessary).
.All of these are likely to require training before joining the ship.
At first glance, it would seem that maintenance is something that could be done by the manufacturer. In fact, this is not entirely true: filters and UV lamps must be cleaned from time to time. Other systems will require particular safety precautions (in the case of systems using active substances, for example). Treatment procedure requires attention not only from the engine staff, but the deck staff as we!!. In most cases treatment will involve the movement of the ballast water from one tank to another, which definitely affects the ship’s trim and stability. The process itself may take a long time, and watch officers and engineers should be on constant alert while carrying out the process.
Although many management companies have implemented BWM procedures already, there is always room for improvement – especially taking into account the sophisticated nature of the subject and the convention itself. In spite of the simplification of requirements and procedures, the implementation of the BWM Convention will require careful attention from management companies and ships’ crews as well. Be ready, and good luck!
Автор:
Captain Alexander Sagaydak, FNI
Источник:
Seaways. – 2016. – August. – P. 25 – 26.