It isn’t often that I hear an opinion and think, ”I’ve never looked at it like that before”. But that was what I felt when I exchanged emails with the respected ballast water management specialist Jad Mouawad last week. I had seen him quoted as calling for port state control sampling of ballast water to be abolished, which I found a very odd thing for someone so passionate about defeating the problem to say.
He explained his position to me by saying that we should either type-approve systems and ensure they are installed properly and then trust that they do the work, or we sample ballast water during discharge for compliance regardless of how that has been achieved. His argument is that, since regulators have backed type-approval, sampling is unnecessary.
But let’s think about the alternative of simply sampling for compliance. That would make it a goal-based standard. Now, IMO is supportive of goal-based standards when it comes to safety and design matters and I looked on IMO’s website to see what it says about them there.
It sets out four basic principles for goal-based standards and regulations, one of which is this: they should be “clear, demonstrable, verifiable, long standing, implementable and achievable, irrespective of ship design and technology.”
Did you catch that? “Irrespective of … technology.” You might argue that the journey towards goal-based standards is being driven by IMO’s Maritime Safety Committee and ballast treatment comes under the Marine Environment Protection Committee, but the first of the basic principles says that goal-based standards should be “broad over-arching safety, environmental and/or security standards.” So goals can be set for environmental matters.
I think Jad has made a strong point but I am still mulling over whether to hang my hat on it. Will anyone bring this up at next month’s MEPC 71?
Tell me what you think about this goal-based approach. Has Jad scored a screamer from the spot, or has he tripped on his approach and sent the ball over the bar?