However, from 8 September 2019 all existing vessels built prior to the convention coming into force on 8 September 2017, will have to fit a ballast water treatment system (BWTS) at their next special survey if they do not already have one if the vessel is to continue international trading.
This gives owners a five year window in which to comply between 2019 and 2024 depending on when the vessel’s IOPP is due. While this may seem like plenty of time recent weeks have seen several organisations flag up that owners should not delay fitting systems until the last minute, given the tens of thousands of ships that require systems and the limited shipyard and engineering capacity to do this.
It is easy to understand why owners are trying to delay fitting a BWTS to the last possible minute. There is a simple fact of cost – they do not come cheap – and the investment is required at a time when shipping markets, although generally improved (excluding tankers) are hardly booming. Many early adopters have found that the systems they installed did not work as advertised, and in more extreme cases were deemed “inoperable”.
It also comes at a time when owners already have the cost of complying with the sulphur cap – be that fitting scrubbers, or for the majority the great unknown of how much low sulphur fuels will be from 1 January 2020.
But the Ballastwater Equipment Manufacturers’ Association (BEMA) sees these factors as reasons that owners should sort out compliance with the BWM Convention. Now a cynic might suggest “well they would say that wouldn’t they?”, but Mark Riggo president of BEMA also had point when in an open letter to shipowners on 21 September cautioning that it was “already the last possible minute”, while also recognising the difficulties some owners had experienced.
“September 8, 2019 is a very short time away. Between now and then, you will contend with a myriad of regulatory changes and disruptive events that impact your business. Between the sulphur cap on fuels, cyber-challenges, and shifts in global trade, you will be tasked with a number of challenges this year. Do not forget about ballast water treatment,” Riggo warned.
“Start your process now. If you have not installed a system on one of your ships, you absolutely need to now so you can learn how the system really works, how the company really performs, and what your crew needs to know before compliance is mandatory.”
But it is not just the manufacturers saying this we’ve also had warnings from class and insurers.
ClassNK is advising owners to fit BWTS well ahead of time as it sees a large spike in retrofit numbers in 2022. Of 5,400 vessels registered with the Japanese class society that are yet to fit a system slightly over half, 2,832 vessels, have installation deadlines in 2022.
P&I Insurer Gard is also advising members that have not made a decision on BWTS installation to start preparatory work as soon as possible. “Even if the installation deadline may not be for several years, in order to save time and money there are multiple decisions that should be addressed now, e.g. to make sure the installation coincides with a scheduled dry docking,” it said in an alert.
While it is understandable that owners want to put of the time and cost of installing a BWTS till the last possible moment it is clear that is better to be prepared in advance rather than scrambling to comply at the last moment.