Many owners and operators seem to have overlooked the fact that the BWMC is in force and port inspections are taking place, says Paul Gunton
It is easy to forget that IMO’s Ballast Water Management Convention has actually come into force. There has been so much discussion about the delay to equipment installation deadlines that some seem to have mistaken that for a delay in the convention’s entry-into-force. That is not a mistake that any BWTT reader would make, of course.
Yet many shipowners are making an error that is just as significant, which is to assume that, along with delayed installation dates has come delayed port state control (PSC) action. That is the only conclusion I could come to when I looked at the information freely available to everyone on the Paris MOU’s website.
It is simple to interrogate the database to make your own checks. Choose the ‘Deficiency risk area’ dialogue box and scroll down to ‘Pollution prevention (ballast water)’ [they are not in alphabetical order. I don’t know why, either] to repeat the search I carried out when I had nothing better to do a couple of Sundays ago.
What I found was that, between 8 September 2017 and 18 March, ballast treatment deficiencies had been found in 145 inspections on 144 ships, of which 15 had been detained. Most of those detentions recorded the ballast deficiencies as among a number of ISM-related deficiencies, with ISM problems collectively listed as a ground for detention. But for two ships – if you want to know their names, they are in the database – the ballast water deficiency itself was listed as a ground for detention so could, on its own, have justified those ships’ detentions.
Secretary general of the Paris MoU on Port State Control, Richard Schiferli told me that a message he would like to get across to owners from the data is that the convention is in force and is being enforced by PSC inspectors.
Class society DNV GL has done much the same analysis, covering the period up to the end of 2017, and issued a checklist for owners to help them prepare for port state control inspections.
According to its review of the data, DNV GL said that about a third of ballast water management system deficiencies are for incorrect, not properly filled-in or missing entries in the BWM record book, or the book itself is missing. Another 25% are the result of incorrect ballast water exchange; either that it was not exchanged at all or the amount of water exchanged was insufficient. Other deficiencies included BWM plans that had not been approved, were incorrect or missing.
To my mind, these deficiencies betray either ignorance of what the BWMC requires, an assumption that port state control inspections are not yet being carried out or both. If I had time, I would contact all 144 ships that I identified from the database and ask their managers which of those two options applies to them. And we’re not talking about small companies flying obscure flags: some of the ships are operated by well known owners flying quality flags and with ISM documents issued by reputable class societies.
I encourage any owner reading this to do the simple research I did, to heed Mr Schiferli’s plea and to study DNV GL’s checklist. I will repeat the analysis in another six months and I hope I will find a marked reduction in ballast treatment-related deficiencies.
• Do you have experience of a ballast treatment-related PSC inspection? Share your experience with me at firstname.lastname@example.org