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Latin American Panel October 31, 2012 Ballast Water Management JOSEPH ANGELO

Latin American Panel October 31, 2012 Ballast Water Management JOSEPH ANGELO DEPUTY MANAGING DIRECTOR. Different regimes International National/Regional Local INTERTANKO Actions IMO Response. INTERNATIONAL IMO Ballast Water Management Convention Adopted in 2004

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Latin American Panel October 31, 2012 Ballast Water Management JOSEPH ANGELO

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  1. Latin American Panel October 31, 2012 Ballast Water Management JOSEPH ANGELO DEPUTY MANAGING DIRECTOR

  2. Different regimes International National/Regional Local INTERTANKO Actions IMO Response

  3. INTERNATIONAL IMO Ballast Water Management Convention Adopted in 2004 Entry into force requires ratification by 30 countries, 35% world’s grt Currently, 36 countries, 29.06% grt

  4. INTERNATIONAL BWM Plan and Record Book BWM System performance standard Compliance schedule to install BWMS Survey and certification requirements Port State Control procedures

  5. NATIONAL – US Coast Guard Final regulations issued March 2012 Main requirements include: BWM plan and record keeping; BWM standard (same as IMO) with review in 4 years; Compliance schedule (similar to IMO); Acceptance of “Alternative”BWMS for 5 years

  6. Regulatory schedule - IMO Enforcement 12 months after ratification i.e. - earliest October 2012 if ratified now - Installation at first Intermediate or Periodical Survey

  7. Regulatory schedule - USCG

  8. NATIONAL – US EPA Vessel General Permit (VGP) Dec 2008 Main requirements include: BWM plan and record keeping; BWM exchange; Allows states to impose additional requirements; VGP required to be renewed in 5 years

  9. LOCAL – New York and California BWM standard that is 100x and 1000x greater than IMO Considerable lobbying by industry coalition EPA Science Advisory Board report – standard not possible with current BWM technology Reason prevails, for the time being

  10. REGIONAL – EU BWM equipment not included in the Marine Equipment Directive (MED) EU is considering amending MED to bring in the equipment required by the BWM Convention as a mandatory standard Legal amendments to MED to include BWM equipment is scheduled for October 2012 Possible “EU approval regime” could become reality in October 2013.

  11. INTERTANKO Action • The Key Challenges • Technical – treatment equipment and approval • Regulatory – BWM Convention implementation and its enforcement

  12. Policy background ISTEC and Environmental Committee – March 2012 Details technical, operational and compliance challenges Council – May 2012 Recommends comprehensive paper covering the challenges and proposing solutions be sent to IMO Submission to IMO’s MEPC 64 (October 2012) Jointly with Liberia, the Marshall Islands, Panama, BIMCO, CLIA, INTERCARGO, InterManager, IPTA, NACE and WSC - submitted August 2012

  13. IMO MEPC 64 Submission Explains the challenges being faced for effective implementation of the BWM Convention and to provide proposals to address those challenges • Submission covers FOUR key areas: • Guidelines for approval of ballast water management systems (G8); • Availability of Ballast Water Management Systems (BWMS); • Survey and certification requirements • Procedures for port State control

  14. Greater transparency of information on the Type Approval Certificate and its enclosures Total Rated Capacity, 60m3/hr tested but approved to 6000m3/hr Type Approval process needs to more accurately reflect real-world environment aboard Brackish and freshwater tests High sediment waters Proposals to strengthen Type Approval process To ensure that a BWMS works in practice as well as theory 1. The need for revision of the Guidelines for approval of ballast water management systems (G8) to improve transparency and ensure appropriate robustness of Ballast water management systems (BWMS)

  15. As the BWM Convention dates are progressively surpassed the number of ships to which the requirements apply 12 months after full ratification continually increases Ship yards and BWMS manufacturers coming under increasing pressure to install systems within the time frame (implementation schedule) Recommend discussion of ‘new’ BWMS installation dates BWM Convention cannot legally be amended until convention enters into force Problem was recognized in 2007 when limited technologies were available to meet first implementation date of 2009 IMO Assembly adopted resolution recommending acceptance by parties of delayed installation date • 2. The availability of BWMS and sufficient facilities to install BWMS

  16. Current Estimated Installation Schedule Dates MEPC 61/2/17 by Japan

  17. No phase-in period for survey and certification of ships following entry into force ROs required to review and approve BWM Plans as well as survey and certify ships within 12 month period Solution provided at MEPC 63 – commence issuance of BWM Certificates prior to entry into force Proposal to issue circular in this respect to increase awareness through industry and maintain uniform implementation • 3. Survey and certification requirements for ships constructed prior to entry into force of the BWM Convention

  18. Urge harmonised standard operating procedure for sampling and analysis of ballast water by PSC. Coupling of Type Approval process with the enforcement process Currently the Type Approval process is separate from the PSC process so an approved BWMS may not meet the PSC analysis once installed on board. Uncertainty in the PSC sampling and analysis process key impediment to further ratification • 4. Sampling and analysis procedures for port State control purposes

  19. OUTCOME OF MEPC 64 Revision of the G8 Guidelines Decided not to amend the G8 guidelines (at this time), BUT agreed to develop additional guidelines on the application of the G8 guidelines which to address the issues raised in our submission 2. Availability of BWMS Established as correspondence group (lead by Japan) to develop an Assembly resolution regarding the implementation of Regulation B-3

  20. OUTCOME OF MEPC 64 Survey and certification requirements Agreed with our proposal to issue an MEPC Circular Sampling and analysis procedures for PSC Agreed with our proposal to instruct BLG (and FSI) Subcommittee that sampling and analysis procedures for PSC should be no more stringent than what is required for type approval of BWMS

  21. Summary • “Positive” developments at MEPC 64, but more work needs to be done • Members learning on a day-by-day basis • Sharing of experience and information between members essential • Does the BWMS work? • Does it work as it was approved to work? • Does it meet the discharge standards? • Propose amendments to IMO’s BWM Guidelines based upon experience gained, while supporting their international and uniform approach

  22. Ballast Water Guidance Finding, installing and operating systems on tankers?

  23. Ballast Water Guidance To assist members during selection, assessment and installation for existing and new built vessels: INTERTANKO Guidance on the Selection and Installation of Ballast Water Management Systems for Tankers Physical Installation Pumping Control – system approval and certification Treatment type Operating practicalities Released January 2012

  24. Thank you! www.intertanko.com

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