DNV GL WEBINAR 2017-06-21
BALLAST WATER MANAGEMENT CONVENTION Q&A SESSIONS
SESSION 1: 09:00-09:45 CET
1. What will be the consequence if we have only D2 in the certificate after enforcement date?
Then vessel must adhere to the Convention requirements to the D-2 Discharge Standard; D-1
will not be accepted method of compliance.
2. Can the vessel apply for only D1 and not D2 approval on certificate despite having a BWTS
onboard?
In certain cases, yes. If the system installation is not completed or has not yet been
commissioned, then a certificate for only D-1 may be issued provided vessel has approved BWMP
for D-1 Standard. The vessel may utilize D-1 until their required IMO D-2 compliance date.
However, if vessel is approved for both methods, it is acceptable to list both methods on the
Certificate. At the vessel’s D-2 compliance, the certificate shall be re-issued to the D-2 Standard
only.
3. If a vessel has a BWTS onboard and not operational. Can the vessel get D1 as a means of
meeting BWM requirements post sept 2017?
As long as the vessel is still allowed to perform exchange (D1) according to the IMO compliance
time table, yes.
If the vessel is required to meet the D-2 Discharge Standard, in principle, the Convention does
not allow for use of exchange methods when the requirement is to treat the water. However, a
PSC may accept exchange as a contingency measure.
In this case, the D-1 Standard would not be mentioned in the International Ballast Water
Management Certificate.
4. Could you maybe provide some examples of US diverging regulations? Which states do have
such requirements and how do they differ from IMO standards? thank you!
The US has their own Regulation, both on a National and State level. The USCG Treatment
Standard is already in effect. Furthermore, they require BWTS to hold USCG type approval. The
USCG maintain an web portal where you may find information related to US compliance:
https://homeport.uscg.mil/mycg/portal/ep/channelView.do?channelId=-
18366&channelPage=%252Fep%252Fchannel%252Fdefault.jsp&pageTypeId=13489
There is also contact information where you may submit questions directly to USCG.
Of course, DNV GL can assist with interpretations, but the final word must be given by USCG.
5. For vessels with BWTS installed and have D1 and D2 mentioned in their BWM certificate, then in
such a case is the vessel free to choose the means of compliance as they deem fit?
If a vessel is approved for both the D-1 and D-2 standard, they may utilize either until the
vessel’s required IMO D-2 compliance date. This will be less likely option in US Waters, as USCG
Treatment Standard is already in effect.
6. I understand the ballast water record book is the Oil record book as it is connected to the IOPP
certificate, correct?
No, this is not correct. The ballast water record book is separate documentation to document
ballast water operations. It could be in an electronic record book, or in a table or other means. In
our Ballast Water Management Generator app on My DNV GL we have included a record book
template when generating the plan.
DNV GL Headquarters, Veritasveien 1, P.O.Box 300, 1322 Høvik, Norway. Tel: +47 67 57 99 00. www.dnvgl.com
DNV GL Webinar on BWM Convention -
Questions and answers_21-06-17.docx
, Page 2 of 6
7. In case IMO agrees for delay for 2 years, will it affect/delay plan approval and certification or will
only affect BWTS installation?
This proposal, if accepted, will only affect the BWTS installation/D-2 compliance date.
From Entry into Force (2017-09-08) all vessels must show compliance with D-1 Standard
(approved BWMP, record book, International Certificate/Certificate of Compliance) until their
scheduled D-2 compliance date.
8. We have various ships already installed with different types of BWTS, but we are having issues in
terms of operating them smoothly ... some or other parts malfunction & the plants aren't
working 100% at any time. What would be the challenges to face after 8th Sep 2017 & what are
the best ways advised by DNV, so that the vessel is not delayed/rejected by any port or fined.
We do not know how strictly the requirements of the Convention will be applied immediately
upon Entry into Force. It is advised that vessel be approved for D-1 as possible contingency
measure. Also, the manufactures should be asked to provide information regarding time
estimates for replacement parts, service appointments, or emergency attendance.
9. Is there any thought process for holding the makers accountable for repeated failures of their
system?
This is an issue that must be addressed directly between owner and manufacturer.
10. Will there be a standardized Ballast Water Record Book like Oil Record Book or is it being
discussed/ reviewed under the convention/ MEPC 71?
Please refer to question no 6 above
11. How is the IOPP decoupling done outside of the annual /periodical surveys? Do we need any
declaration, documentation etc.?
If you wish to decouple your IOPP renewal survey from the Harmonized System of Survey and
Certification (HSSC), please contact us via our DATE service in My DNV GL (alternatively via
or your Key Account Manager. We will correspond with flag as necessary and do
the necessary change of the survey scheme. When this is concluded, you may order your IOPP
de-coupling survey directly from the local station.
12. Should we understand that if vessel is not doing international navigations this convention does
not apply?
If vessel is not making International voyages, then Convention requirements may not apply;
Article 3 Application
2 This Convention shall not apply to:
(b) ships of a Party which only operate in waters under the jurisdiction of that Party, unless the
Party determines that the discharge of Ballast Water from such ships would impair or damage
their environment, human health, property or resources, or those of adjacent or other States;
(c) ships of a Party which only operate in waters under the jurisdiction of another Party, subject to
the authorization of the latter Party for such exclusion. No Party shall grant such authorization
if doing so would impair or damage their environment, human health, property or resources, or
those of adjacent or other States. Any Party not granting such authorization shall notify the
Administration of the ship concerned that this Convention applies to such ship;
(d) ships which only operate in waters under the jurisdiction of one Party and on the high seas,
except for ships not granted an authorization pursuant to sub- paragraph (c), unless such
DNV GL Webinar on BWM Convention -
Questions and answers_21-06-17.docx
BALLAST WATER MANAGEMENT CONVENTION Q&A SESSIONS
SESSION 1: 09:00-09:45 CET
1. What will be the consequence if we have only D2 in the certificate after enforcement date?
Then vessel must adhere to the Convention requirements to the D-2 Discharge Standard; D-1
will not be accepted method of compliance.
2. Can the vessel apply for only D1 and not D2 approval on certificate despite having a BWTS
onboard?
In certain cases, yes. If the system installation is not completed or has not yet been
commissioned, then a certificate for only D-1 may be issued provided vessel has approved BWMP
for D-1 Standard. The vessel may utilize D-1 until their required IMO D-2 compliance date.
However, if vessel is approved for both methods, it is acceptable to list both methods on the
Certificate. At the vessel’s D-2 compliance, the certificate shall be re-issued to the D-2 Standard
only.
3. If a vessel has a BWTS onboard and not operational. Can the vessel get D1 as a means of
meeting BWM requirements post sept 2017?
As long as the vessel is still allowed to perform exchange (D1) according to the IMO compliance
time table, yes.
If the vessel is required to meet the D-2 Discharge Standard, in principle, the Convention does
not allow for use of exchange methods when the requirement is to treat the water. However, a
PSC may accept exchange as a contingency measure.
In this case, the D-1 Standard would not be mentioned in the International Ballast Water
Management Certificate.
4. Could you maybe provide some examples of US diverging regulations? Which states do have
such requirements and how do they differ from IMO standards? thank you!
The US has their own Regulation, both on a National and State level. The USCG Treatment
Standard is already in effect. Furthermore, they require BWTS to hold USCG type approval. The
USCG maintain an web portal where you may find information related to US compliance:
https://homeport.uscg.mil/mycg/portal/ep/channelView.do?channelId=-
18366&channelPage=%252Fep%252Fchannel%252Fdefault.jsp&pageTypeId=13489
There is also contact information where you may submit questions directly to USCG.
Of course, DNV GL can assist with interpretations, but the final word must be given by USCG.
5. For vessels with BWTS installed and have D1 and D2 mentioned in their BWM certificate, then in
such a case is the vessel free to choose the means of compliance as they deem fit?
If a vessel is approved for both the D-1 and D-2 standard, they may utilize either until the
vessel’s required IMO D-2 compliance date. This will be less likely option in US Waters, as USCG
Treatment Standard is already in effect.
6. I understand the ballast water record book is the Oil record book as it is connected to the IOPP
certificate, correct?
No, this is not correct. The ballast water record book is separate documentation to document
ballast water operations. It could be in an electronic record book, or in a table or other means. In
our Ballast Water Management Generator app on My DNV GL we have included a record book
template when generating the plan.
DNV GL Headquarters, Veritasveien 1, P.O.Box 300, 1322 Høvik, Norway. Tel: +47 67 57 99 00. www.dnvgl.com
DNV GL Webinar on BWM Convention -
Questions and answers_21-06-17.docx
, Page 2 of 6
7. In case IMO agrees for delay for 2 years, will it affect/delay plan approval and certification or will
only affect BWTS installation?
This proposal, if accepted, will only affect the BWTS installation/D-2 compliance date.
From Entry into Force (2017-09-08) all vessels must show compliance with D-1 Standard
(approved BWMP, record book, International Certificate/Certificate of Compliance) until their
scheduled D-2 compliance date.
8. We have various ships already installed with different types of BWTS, but we are having issues in
terms of operating them smoothly ... some or other parts malfunction & the plants aren't
working 100% at any time. What would be the challenges to face after 8th Sep 2017 & what are
the best ways advised by DNV, so that the vessel is not delayed/rejected by any port or fined.
We do not know how strictly the requirements of the Convention will be applied immediately
upon Entry into Force. It is advised that vessel be approved for D-1 as possible contingency
measure. Also, the manufactures should be asked to provide information regarding time
estimates for replacement parts, service appointments, or emergency attendance.
9. Is there any thought process for holding the makers accountable for repeated failures of their
system?
This is an issue that must be addressed directly between owner and manufacturer.
10. Will there be a standardized Ballast Water Record Book like Oil Record Book or is it being
discussed/ reviewed under the convention/ MEPC 71?
Please refer to question no 6 above
11. How is the IOPP decoupling done outside of the annual /periodical surveys? Do we need any
declaration, documentation etc.?
If you wish to decouple your IOPP renewal survey from the Harmonized System of Survey and
Certification (HSSC), please contact us via our DATE service in My DNV GL (alternatively via
or your Key Account Manager. We will correspond with flag as necessary and do
the necessary change of the survey scheme. When this is concluded, you may order your IOPP
de-coupling survey directly from the local station.
12. Should we understand that if vessel is not doing international navigations this convention does
not apply?
If vessel is not making International voyages, then Convention requirements may not apply;
Article 3 Application
2 This Convention shall not apply to:
(b) ships of a Party which only operate in waters under the jurisdiction of that Party, unless the
Party determines that the discharge of Ballast Water from such ships would impair or damage
their environment, human health, property or resources, or those of adjacent or other States;
(c) ships of a Party which only operate in waters under the jurisdiction of another Party, subject to
the authorization of the latter Party for such exclusion. No Party shall grant such authorization
if doing so would impair or damage their environment, human health, property or resources, or
those of adjacent or other States. Any Party not granting such authorization shall notify the
Administration of the ship concerned that this Convention applies to such ship;
(d) ships which only operate in waters under the jurisdiction of one Party and on the high seas,
except for ships not granted an authorization pursuant to sub- paragraph (c), unless such
DNV GL Webinar on BWM Convention -
Questions and answers_21-06-17.docx
