Article
Steve Candito
Is Your Ballast Water Management System Compliant: Understanding the AMS BWMS and IMO BWMS Code Requirements By Steve Candito, CEO Ecochlor
Time is running out and shipowners need to understand the latest ballast water management system (BWMS) regulations for their installed systems in regard to the USCG AMS deadlines and IMO BWMS Code Type Approval. AMS BWMS extensions are expiring The U.S Coast Guard (USCG) created the Alternative Management System (AMS) program to allow shipowners to move forward with ballast water management system (BWMS) installations while the USCG worked with manufacturers to type approve a wide variety of treatment technologies. The program was a temporary measure to provide five years to develop enough USCG Type Approved BWMS for every vessel type and/or shipping route to satisfy shipowners. At the time, the new U.S. BWMS guidelines required “newbuild vessels constructed after 1 December 2013 to have an installed BWMS - including AMS accepted - upon delivery and for most retrofits to be D-2 compliant at the first scheduled drydocking after 01 January 2016.” The first USCG BWMS was not type approved until July 2016 (i.e. 6 months after the original deadline). Thus, initially the USCG automatically issued deadline waivers (i.e. extensions to the next scheduled dry dock). Now, the temporary approval of many of the early AMS BWMS is expiring in 2020. As a result, if the installed AMS BWMS on board the vessel does not have U.S Coast Guard Type Approval then the owner must either file for an extension or install a USCG Type Approved BWMS. The USCG is allowing some short-term extensions, which are reviewed on a case-by-case basis. These extensions allow shipowners to continue to sail in US waters until the manufacturer can finalize their Type Approval. Typically, extensions have been granted if the BWMS vendor is in the process of testing or are only a few months away from achieving Type Approval. Another important issue for owners to understand is that if the installed AMS BWMS has since gained USCG Type Approval, it does not automatically mean that the installed system is compliant. All modifications or upgrades required to make the AMS BWMS
54 NAFS | November 2020
match the USCG approved system model must be carried out by the end of the five-year AMS period. Many manufacturers are working with owners to make sure that these systems are updated prior to the AMS expiration, including an extension if needed. Owners should also be aware that some first-generation BWMS may require extensive upgrades to become compliant. Lastly, there are several installed AMS accepted BWMS that are not pursuing Type Approval or it is doubtful they will be able to achieve it. This situation will be very problematic for shipowners wishing to continue trading to the United States and may require a new system installation for the vessel.
Updates in BWMS Code Type Approval vs. G8 Any shipowner who has trade routes outside of the United States and does not have a BWMS on board their vessel will be impacted by the BWMS Code Type Approval if their chosen system is not compliant. The requirements came into effect on 28 October 2020. According to MEPC.300(72) paragraph 1.5, “Approval of a system is intended to screen out BWMS that would fail to meet the standards prescribed in regulation D-2 of the Convention. Approval of a system, however, does not ensure that a given system will work on all ships or in all situations.” In addition to an updated testing protocol, the BWMS Code Type Approval process has a number of changes, which result in notations on the Type Approval certificate. A few are addressed below. The first is a section addressing System Operating Parameters that addresses the salinity and temperature of the water the BWMS can treat. Prior to the BWMS Code, manufacturers could test their BWMS in only two different salinities, but received an approval for all three water types – fresh, salt and brackish water. Under the new requirements, manufacturers must test in all three salinities to receive approval for all three. A BWMS that has not been tested in all salinities will have their limitations included within the Type Approval Certificate. The second change focuses on System Design Limitations (SDLs). The Type Approval Certificate must identify each relevant operational parameter together with the validated low and/or high parameter values. The system’s design capacity is a critical parameter since it must match the vessel’s ballast flow rate. For
