Dr. J. COWLEY CBE BSc PhD
Permanent Representative of the Republic of Vanuatu,
to the International Maritime Organization
Melton House, 21 Stanstead Road,
Caterham, Surrey, CR3 6AD.
Telephone: +44 (0)1883 345774 Fax: +44 (0)1883 341093
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To: Mr.L.J. Napuati, Commissioner of Maritime Affairs.
cc: Mr. D.J. Sheetz, Deputy Commissioner of Maritime Affairs
Captain K. Barnett, VMC
Mr. T. M. Bayer, Mr. R.M. Bohn, VMS

18 October 2004

IMO MEETING ON BALLAST WATER MANAGEMENT FOR SHIPS
4TH TO 8TH October 2004

Report by Dr. J. Cowley

Introduction

This Convention differs from others of the same status in that it is very brief and devoid of the detailed provisions necessary for its implementation. The reason is that the technology for its implementation has not yet been developed. Consequently, the Convention refers to the future development of the operating procedures for approval of substances and methods of reducing the organisms and pathogens in ballast water discharged from ships at loading ports.

Since the agendas of the Marine Environment Protection Committee are overloaded and as the urgency of finalizing the Guidelines for the approval of Ballast Water Management Systems is crucial, the Council instituted this Meeting and also Correspondence Groups to formulate the regulations.

Explanatory Note

When considering this report, it is useful to bear in mind that there are two distinct standards for Ballast Water discharges as now briefly indicated:

1. The standard exemplified by Regulation D1 which covers Ballast Water Exchange; and
2. The standard exemplified by Regulation D2 which specified a higher standard based on the number of organisms and pathogens present in the discharged ballast water which must not be exceeded.

The two standards must be met at various times after the entry-into-force of the Convention according to both the date of construction of ships and the amount of water ballast that they carry. The complicated regulations are reproduced in Annex 2 to this paper for convenience. In general, ships will first meet the regulation D1 standards and, at a later date, will be required to meet the regulation D2 standards.

A large number of different methods of treating ballast water in order to meet the D2 standards are under consideration. In brief, these include:

Filtration-Mechanical; Ultraviolet (UV) Radiation; ultrasound; Electro-Ionization; Magnetic/Electric Field; Biocide; Ozone; Heat; De-Oxygenation By Vacuum; De-Oxygenation by Venturi Oxygen Stripping; and De-Oxygenation with Elevated Carbon Dioxide using a Marine Inert Gas Generator. An outline discussion of their relative merits is provided at Annex 1.

As a means of dealing with the problems, a number of Guidelines have been established, initially designated by the letter “G” as follows:

G1: Guidelines for Sediment Reception Facilities;
G2: Guidelines for Sampling of Ballast Water and Analysis for Port State Control;
G3: Guidelines for Ballast Water Management Systems;
G4: Ballast Water Management Plan Guidelines;
G5: Guidelines for Ballast Water Reception Facilities;
G6: Guidelines for Ballast Water Exchange (Operational);
G7: Guidelines for Risk Assessment;
G8: Guidelines for Approval of Ballast Water Management Systems;
G9: Approval of Active Substances;
G10: Procedure for Approval of Prototype Ballast Water Treatment Technologies;
G11: Guidelines for Ballast Water Exchange Design and Construction Standards;
G12: Guidelines for Sediment Control in Ships;
G13: Guidelines for Additional Measures including Emergency Situations.

At this Meeting, work continued on the Regulation D-5 Review Procedure and Guidelines as follows:

As highest priority to:

.1 finalise the draft Guidelines for Approval of Ballast Water Management Systems (G8) with the view to their approval, in principle, by the Committee.

.2 finalise the draft Procedures for the Approval of Active Substances (G9) with the view to their approval, in principle, by the Committee.

.3 finalise the “Recommendations for the Conduct of the Review of the Status of the Ballast Water Management Technologies set by Regulation D-5 of the Ballast Water Management Convention, taking into account Conference Resolutions 2 and 4”.

.4 further develop the guidelines for uniform implementation of the Ballast Water Management Convention and, in particular, the Guidelines for Ballast Water Management Plan (G4) and the Guidelines for Ballast Water Exchange (G6) after completion of items 1, 2 and 3 above.

.5 consider the remainder of the guidelines.

It was agreed to discuss principles in the plenary during the extended working hours (9.00 a.m. - 6.00 p.m. - further extended if necessary) and to establish small groups to draft the text for the guidelines outside of the main meeting after the working hours.

The meeting agreed to consider G8 and G9 Guidelines and the recommendations for D-5 review in the plenary, and to attach the agreed text as annexes to the final report of the meeting to be approved, in principle, by the Committee.

After an extensive debate regarding shipboard testing, the meeting agreed that there should not be a final shipboard testing stage within the type-approval procedure but could not reach an agreement on a first pre-candidacy shipboard testing stage and decided to develop the text on this particular subject in square brackets and seek advice from the Committee on this matter.

Review of the Procedures for approval of BWMS that make use of Active Substances (G9)

The use of Active Substances requires some explanation. These are chemicals with a short half-life which kill the organisms in the ballast water and then decay before the ballast is discharged at the loading port. The intention is that they are harmless to marine life at the time of discharge.

After the introduction of submitted documents, the meeting discussed the principles related to the approval of Active Substances and Ballast Water Management systems using Active Substances. A number of delegations shared the view that the process involves two approvals: firstly, IMO gives basic approval for Active Substances and Preparations; secondly, Final Approval by the IMO of Ballast Water Management Systems using Active Substances and Preparations based on information received from the type testing Administrations. Some delegations were of the view that G9 guidelines should focus on the environmental effects of the discharges resulting from the use of Active Substances. Some delegations expressed concern regarding the by-products resulting from the use of Active Substances and Preparations on board ships.

The Working Group agreed to further consideration of the aspects discussed in the plenary, and thereby established an informal after-hours group to review the text give its report to the Plenary on Thursday, 7 October 2004.

After considering the report of the informal group on G9 guidelines, the meeting conducted a paragraph-by-paragraph review of the text which was completed on Friday.

Consideration of D-5 review procedure

The meeting considered the Recommendation for the Conduct of the Review of the Status of the Ballast Water Management Technologies set by Regulation D-5 of the Ballast Water Management Convention taking into account Conference Resolutions 2 and 4. submitted documents , and agreed to incorporate a new Section 4 on a template for submissions from Administrations.

Progress on other guidelines

The Working Group further developed the G10 guidelines on Prototype Technologies based on a draft provided by Norway and discussed the relation between G8 and G10. Key Issues for G10 were identified as being less stringent and less prescriptive as G8. Prototype systems would be a promising technology with the potential to meet or exceed Regulation D-2.

Extensive discussions took place on G7 guidelines on Risk Assessment and G4 on Ballast Water Management.

As intended, the Chairman presented an oral report to the MEPC Plenary session on Monday, 11 October 2004 and received further instructions for a Working Group to consider in parallel with the Plenary session.

Further review of the Guidelines for approval of Ballast Water Management systems (G8)

The final version of the Draft Procedures for approval of Ballast Water Management Systems that make use of Active Substances (G9) is attached at Annex 3.

The remaining guidelines will be further developed intersessionally and the following focal points will co-ordinate the intersessional work as follows:

.1 United Kingdom for guidelines (G4), (G6), (G11), (G1), (G12) and (G5)

.2 Norway for guidelines (G7), (G10) and (G13)

.3 Germany for guidelines (G2)

.4 International Sailing Federation for guidelines (G3)

Concluding Comments

There is an immense amount of work still to do on this topic and much of it will be completed by correspondence.

For convenience, as all readers will not wish to download Annex 3, this report is being e-mailed as an attachment and its three Annexes are being transmitted separately as attachments.

J. Cowley

www.vanuatuships.com