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Upcoming BWMS compliance due dates – some practical recommendations

DNV is forecasting a peak season for global Ballast Water Treatment System (BWTS) installations, and the industry should get prepared for a busy 2022. This statutory news contains some timely reminders to ensure compliance with the Ballast Water Management (BWM) Convention.

Relevant for ship owners/managers, design offices, yards, suppliers and flag states.

Below are some practical recommendations on compliance dates and other information to comply with the BWM Convention:

According to the MEPC 71 meeting in June 2017, ships constructed before 8 September 2017 must comply with the BWM D-2 standard by the first IOPP renewal after 8 September 2019.

Due to the schedule for the BWM Convention D-2 compliance dates, and for the IOPP certificate de-couplings of individual ships, DNV forecasts a peak season during 2022. This is when about 30% of the world’s vessels in international voyage are scheduled to comply with the D-2 regulation. This high share of BWMS commissioning in 2022 covers 63% of the total sum of installations for the DNV-classed fleet scheduled between 2022 and 2024. The figure below illustrates the respective share of D-2 due dates for 2022, 2023 and 2024:

TecReg_graph

Figure 1: BWMS not yet installed with D-2, due dates 2022-2024

Use the Compliance Planner for a complete overview 

To support this and other regulatory regulations, DNV has launched a tool called “Compliance Planner”, available for DNV customers only under My Services on Veracity. This tool enables you to easily track the requirements and deadlines of upcoming statutory legislation for your vessels and your entire fleet. In the Compliance Planner you will also see the due dates for the BWM Convention. This is how the feature could look in your Compliance Planner:

BWM treatment system

Contact DNV for approval at least four months in advance

DNV advises all customers to proactively start preparation for the BWTS installation retrofit, if not yet scheduled, with their technical consultants and treatment system manufacturers. In addition, it is recommended that you contact DNV for the approval project initiation at least four months before the planned installation date.

To support you, we have established under My Services the “Request Alteration approval” button that directly sends requests to the responsible DNV approval organization, who will then initiate the alteration project.

Upon receiving the alteration request, DNV will reply with a detailed questionnaire about the planned modifications and scope of work. Based on this, we will prepare a tailor-made requirement on documentation and an appropriate offer. Following this, we will send a comprehensive guideline to you on how to handle alteration projects under My Services on Veracity

Commissioning testing by sampling required from 1 June 2022

The MEPC.325(75) with amendments to Regulation E-1 and Appendix I of the International Convention for the Control and Management of Ships’ Ballast Water and Sediments, 2004 is entering into force on 1 June 2022. Vessel owners shall observe the requirement for a commissioning test at any BWTS commissioning survey completed on or after 1 June 2022. This test requires ballast water samples at the discharge line after treatment by the new BWTS and analysis of the samples by accepted laboratories.

Hence, mandatory commissioning testing / sampling should be arranged with an approved service supplier of biological ballast water testing when commissioning after 1 June 2022.

Recommendations

DNV recommends that you carefully plan your ships’ BWM Code dates to ensure compliance in due time, considering the capacity limitations within the industry.

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