В частности и особенности, автор капитан Alexander Sagaydak FNI, освещает вопросы контроля государства порта, процедуры взятия проб водяного балласта. Особый интерес представляют рекомендации опытного капитана по работе на судах в условиях действия упомянутой Конвенции.
On 8 September 2017, the Ballast Water Management (BWM) Convention came into force. As is usual with IMO Conventions, this seems to raise as many questions as it does answers. The main one: Is it necessary for all ships to have ballast water treatment equipment on board, as defined in Regulation B-3?
The answer is no. MEPC71 decided to extend time frames for the implementation of the D-2 Standard. The deadlines for implementation depend on the date of the International Oil Pollution Prevention (IOPP) survey (see diagram in Seaways, October 2017). So we have a situation where the ballast water exchange standard will still be in force for many ships. However, this does not mean there will be no changes.
One of the main consequences of the BWM Convention coming into force is that inspection on BWM matters is now an obligatory part of Port State Control (PSC) inspections for the country the Party of Convention. In other words, if the port state has signed up to the convention, they must include it in their programme of inspection. Therefore be ready for it!
Routine inspections are to be limited to checking the International BWM Certificate and ballast water record book. (Note that ballast water sampling is not a part of routine inspection!) However, if the PSC officer has clear grounds to consider the ship is substandard, the inspection could be expanded.
What might be considered as clear grounds for a detailed inspection?
• General condition of the ship. If there are signs of poor maintenance, the PSC officer will definitely want to conduct a detailed inspection;
• Documents are absent or poorly maintained;
• Actual condition of the ship does not correspond to the records.
Poor knowledge of crew duties according to the BWM Plan will also
lead to detailed inspection.
A detailed inspection will definitely include sampling, to be carried out during the ballast water discharge. Samples will be taken at the very least at the beginning, in the middle and in the final stage of the process. The sampling point is considered to be at the ballast water outlet (after the ballast water pump), and should be recorded in the ship’s BWM Plan. The sampling point itself must be shaped to ensure constant water flow and speed. Needless to say, PSC officers can check records in the ship’s log and other documents (e.g. charts) and compare them to the ballast water record book.
I have found that many acting navigators and engineers still do not have any experience with ballast water treatment equipment. From those who have experience, I have learned that the most useful type seems to be UV treatment, with filtering at the first stage.
However, there are many more sophisticated systems using active
substances — it is very important to know how to use these. Spend some time learning your treatment system in order to avoid surprises.
So, what should you do in view of the BWM Convention, when you take over the ship as Master? Some practical suggestions:
• First, check if the International BWM Certificate is available on board. If it is not, check if there is any other relevant certificate, Letter of Compliance or other document.
• If the IBWM Certificate is present, pay close attention to which method of BWM is to be used on board.
• Check the ship’s BWM plan. It should be authorised by flag or Recognised Organisation (classification society);
• Learn the BWM plan, paying attention to any exemptions granted.
• Check local BWM requirements with the agent in your next port of call. There could be specific requirements with regard to ballast water exchange (e.g. special areas to exchange water) and to ballast water treatment (e.g. some active substances may be forbidden);
• Check whether the ship has had any deficiencies on BWM matters in the past. If so, check what actions were taken and their results.
If the ship has to comply with the D-1 Standard only:
• Pay special attention to the stability booklet. Also, learn which methods of exchange are recommended, taking into account the limitations of this method;
• Learn the ship’s ballast water system, paying special attention to weak points such as air pipes;
• Study the ballast water record book, and compare it to the records in the ship’s log. If ballast is on board, pay attention to where it was taken, where to be discharged, etc. If you see signs of poor record keeping, take measures immediately. Brief your staff, keeping in mind that proper record keeping can save a lot of time and avoid many problems during inspection;
If the ship has to comply with the D-2 Standard:
• Check the type of equipment installed. If equipment has still not been installed, check the deadline for installation, where it is planned to install it, and any available documents;
• Check if the type approval certificate is available (if active substances are used, check the IMO certificate as well). It is not necessary to have the original on board, but you should at least have a copy;
• Check if manufacturer’s instructions and manuals are available;
• Check that key personnel are familiar with BWM procedures. If possible, check the knowledge of all crew engaged in ballast water operations. Pay attention to safety considerations first of all, especially if your treatment equipment uses active substances. Pay special attention to emergency procedures, and check your training plans;
• Try to obtain sampling results to check the actual performance of your equipment.
Finally, I would like to stress that all ballast water operations on board need the Master’s attention anyway, regardless of which BWM method is used. They are connected with moving huge weights, thus changing the ship’s stability and strength parameters — be careful.
Don’t forget about proper record keeping. It is very easy to make a small mistake in the volume of water taken or discharged (for example), which could cost far too much.
So, welcome to the era of Ballast Water Management!
Автор: Captain Alexander Sagaydak FNI
Источник: Seaways. — 2017. — November. — P. 12.