Page 10: of Maritime Reporter Magazine (April 2016)

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A Vessel Owner Dilemma During

This Uncertain Time

Ballast Water Regulations are casusing a great dea of vessel owner confusion

By Steve Candito

Ballast Water (BW) regulations pliance. Delayed IMO rati? cation has effectively com- 3. Establish engineering and installation resources have been pending for 12 years. pressed the compliance schedule for 35,000+ vessels. A

In the U.S., it’s been over four compliance schedule planned for 12+ years is now 6+ 4. Request an extension from the USCG

IMO years since the U.S. Coast Guard (USCG) regulations years. The USCG extension program is complex and were passed, but even the USCG regulations are not will be even more of a challenge once a certi? ed BWTS 5. Request the issuance of a new MARPOL Annex fully implemented. These delays con? rm BW Treat- is available. Although the USCG offered guidance in 1 IOPP Certi? cate, and ment and BW regulatory compliance is complex. Upon its Marine Safety Information Bulletin (MSIB) No. 13- full implementation of the BW regulations, compliance 15, issued October 20, 2015, the process is not clear. 6. When available, purchase a USCG approved will be achieved by using a treatment system or ap- The MSIB 13-15 notes extensions will be granted to the BWTS that meets the parameters identi? ed for proved alternative and increased record keeping – some vessel’s next scheduled drydocking, after the vessel’s your vessels.

of which is appropriate today. required implementation date. Further, the vessel’s ? rst scheduled drydocking date will be determined based on when the vessel enters the drydock. Existing extensions

Background with a January 1 date will not be re-issued. The change Posted on to Ballast Water

Over this 12 years 60 different Ballast Water Treat- will be made when a vessel applies for a supplemental Regulations Blog by Steve Candito on April 1, 2016 ment Systems (BWTS) have entered the market, which extension. Supplemental extensions are required (i.e. has led to high pressure sales and signi? cant confusion. there will be no blanket extension). The process is fur-

Unfortunately, BWT is expensive, complex and does ther complicated by the fact that the EPA does not know

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Professional App for very little, if anything to improve vessel operations. For if its “low enforcement priority” will remain an unchal- iPhone, Android and many, the issue has become tiresome. lenged practice.

Windows devices

Implementation Dates Likely in 2016 Solution

It is likely the IMO Convention will be rati? ed during Many owners have completed some BWT plan- or before MEPC 70 in October 2016. Rati? cation ap- ning, some have already installed BWTS – some have

The Author pears likely because 30 countries with 35 percent of the installed systems and already removed them because world’s Gross Registered Tonnage (GRT) are required they failed, other BWTS will follow – a high price to

Steven Candito is Founder, President and CEO of for passage and 49 countries comprising 34.8 percent pay for an owner being proactive. With every vessel on

Foresea. Foresea provides various advisory servic-

GRT have already rati? ed the Convention. It also ap- a known compliance timetable, a complex BWTS has es including strategic planning, regulatory compli- pears a BWTS will be approved by the USCG in Q2 or to be selected and installed timely and cost effectively. ance and crisis management to the maritime and

Q3 2016. Implementation of the IMO and USCG regu- The system will be chosen from a limited set of cred- environmental communities.Previously, Candito lations places every vessel on a timetable for compli- ible BWTS manufacturers and engineering/ installation was President and CEO of NRC. During his over ance. The fact USCG approval of a BWTS will come resources. The regulatory landscape is established. The 20 years career with NRC he grew the business four years after US regulations were published and 12 tools for compliance are available. Planning for effec- from a start up to the leading global emergency years after IMO regulations were ? nalized, is a clear tive economic operationally compatible compliance response and environmental services ? rm. Candito indication that choosing and installing a reliable BWTS should be started now to: has also served as a marine engineer aboard Exxon will be a complex and dif? cult endeavor.

USA’s domestic tanker ? eet from 1980 to 1985. 1. Determine which type of BWTS is best for your

Candito is a graduate of Hofstra University School vessels of Law and the United States Merchant Marine

What is Required Now?

Academy. Candito is also a past President of the

For most vessels, nothing. However, doing nothing is 2. Ensure there is suf? cient space to install the se-

Spill Control Association of American (SCAA) likely a costly option, in dollars and operational ? exibil- lected BWTS ity. Once rati? ed every vessel is on a timetable for com- 10 Maritime Reporter & Engineering News • APRIL 2016

MR #4 (10-17).indd 10 4/8/2016 10:52:15 AM

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