IMO Convention faces more delays
At MEPC 71 a revised implementation scheme for the BWM Convention was adopted
With two months to go before the entry into force of the international BWM Convention on September 8th 2017, MEPC 71 reached a highly anticipated compromise agreement on the implementation dates for the so-called D-2 discharge standard.
Generally, compliance with the D-2 standard translates to the date individual ships must have a ballast water treatment system installed. The new agreement ensures full global implementation by September 8th 2024 and contains the following key elements:
Ships constructed (keel-laid) on or after September 8th 2017 need to comply with the D-2 standard upon delivery.
Existing ships should be D-2 compliant on the first International Oil Pollution Prevention Certificate (IOPPC) renewal following entry into force if:
• 1) this survey is completed on or after 8 September 8th 2019, or
• 2) a renewal IOPPC survey is completed on or after 8 September 8th 2014
but prior to September 8th 2017.
Furthermore, the ship should be D-2 compliant on the second IOPPC renewal survey following entry into force, if the first renewal survey following the date of entry into force of the Convention is completed prior to September 8th 2019 and if conditions 1) or 2) above are not met.
This means that a ship which is due for an IOPPC renewal survey between September 8th 2017 and 8 September 8th 2019 cannot “decouple” its IOPPC survey for a second renewal before September 8th 2019 without then having to comply with the D-2 standard. Until recently, renewal of the IOPPC has invariably taken place as ships undergo special surveys every five years. However, by “decoupling” renewal of the IOPPC from the special survey, some owners have been able to postpone the date by which installation of treatment systems would have been required.
Ships constructed before September 8th 2017 and delivered (including the initial IOPPC survey) after that date, need to comply with the D-2 standard at the first IOPPC renewal survey after delivery.
It was also agreed that a ship to which the IOPPC renewal survey does not apply (generally ships less than 400gt in size) shall be D-2 compliant no later than September 8th 2024.
The agreement implies that vessels with the last IOPPC renewal carried out before September 8th 2014 have nothing to gain by decoupling, but instead actually risk losing up to two years on the D-2 implementation date by doing so.
An MEPC resolution text to ensure that this agreement is effective from the Convention’s entry into force date, September 8th 2017, was also agreed to.
