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Pollution

Ballast water management

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A bulk carrier sailing empty carries tens of thousands of tonnes of seawater to stay upright, and pumps it out at the other end of the world. Everything living in it goes too. Ballast water management is the regime built to stop that, and its commercial edge is not the biology: it is that deballasting is now a treated, metered, recorded operation that can limit how fast a ship loads.

The convention

The International Convention for the Control and Management of Ships’ Ballast Water and Sediments was adopted on 13 February 2004 and entered into force on 8 September 2017, after a ratification process that took thirteen years. It applies broadly to ships of 400 gross tonnage and upwards on international voyages, and it requires each of them to carry:

D-1 and D-2

Two standards, and the whole implementation story is the move from the first to the second.

Regulation D-1 is the exchange standard. The ship exchanges her ballast at sea, far from the coast, so that coastal organisms are replaced by open ocean organisms that are unlikely to survive at the discharge port. The convention requires 95 per cent volumetric exchange, and pumping through three times the volume of each tank is accepted as meeting it. It costs nothing in equipment and it costs time and, in bad weather, safety, because exchanging ballast at sea means running tanks at intermediate levels on a ship designed for full or empty.

Regulation D-2 is the performance standard. The discharge itself must contain fewer than 10 viable organisms per cubic metre of 50 micrometres or greater, and fewer than 10 viable organisms per millilitre for the size band below that, along with limits on indicator microbes. That cannot be achieved by moving water around. It requires a type approved ballast water management system on board, filtering and treating by ultraviolet light or by chemical means.

D-2 was phased in against each ship’s survey dates, and the phase-in has ended. Since 8 September 2024 every ship subject to the convention must meet the D-2 standard. D-1 is history for compliance purposes, and a hull that had not fitted a system by that date is not a trading proposition.

The United States is a separate regime

This is the trap, and it is the reason a ship can hold a valid international certificate and still be turned away.

The United States is not a party to the convention and enforces its own rules, principally under 33 CFR part 151, with systems type approved by the United States Coast Guard under 46 CFR part 162. A treatment system approved by a flag state under the IMO regime is not automatically acceptable in United States waters. There is a bridging mechanism, the alternate management system acceptance, under which the Coast Guard accepts a foreign-approved system for a limited period, and it is deliberately a transitional route rather than a permanent equivalence.

The practical rule for a desk is short: for a voyage to the United States, IMO compliance is not the question. The question is whether the ship’s specific system holds Coast Guard type approval or a valid acceptance, and whether the crew can produce the records to prove it. There are also state level requirements in some waters, and the discharge of ballast in certain areas is regulated separately again.

What it does to cargo operations

This is the part that reaches laytime, and it is under-appreciated ashore.

A bulk carrier loading cargo is deballasting at the same time. Loading rate and deballasting rate are coupled, because the ship has to keep her stress and stability within limits at every stage of the load plan. If the deballasting rate falls, the loading rate falls with it, whatever the terminal’s conveyor can do.

A treatment system sits in that path. Filters block, especially in silty or turbid water, and turbid water is exactly what many loading berths sit in. Ultraviolet treatment on discharge takes time. Some systems have to treat on uptake, some on discharge, some on both, and a system in trouble can force the ship onto a contingency measure agreed with the flag and the port state rather than simply pumping. All of that is a potential brake on a load rate that was written into a charterparty as a flat tonnes-per-day figure.

The corresponding question at the load port is whether the ship may take ballast there at all, and at the discharge port whether she may discharge it. Some ports and some regions restrict both, and a ship that cannot ballast normally cannot sail on the intended draught. Compare loadable quantity, which is the same class of problem approached from the cargo side: the number a ship can actually work with is a physical result, not a headline figure.

Who carries the risk

The ship’s obligation to comply is the owner’s. Owners fit the system, maintain it, and hold the certificate. Under a time charter the charterer directs the ship, so the exposure runs the other way at the margins: a charterer ordering a ship to a port where she cannot lawfully ballast, or to United States waters with a system that is not acceptable there, is directing her into a problem the owner cannot solve on the day.

The clause that resolves this is charterparty drafting rather than convention, and the point of diligence at fixing is narrow. For a voyage anywhere: does she have a working type approved system and a valid certificate. For a voyage to the United States: is the system Coast Guard approved or accepted. For a tight load rate at a silty berth: has anybody asked what her deballasting rate is with the system in circuit rather than on the original trim and stability booklet.

What the record book is for

As with the oil record book under MARPOL Annex I, the ballast water record book is the document an inspector reads first, and the deficiencies it generates are ordinary and avoidable: entries not signed, positions missing, a gap between an operation and its record. An accurate contemporaneous record is the cheapest protection there is, and an inaccurate one converts a technical problem into a credibility problem in front of the one person who can stop the ship.

References

The MARPOL annexesSix annexes, six different things a ship may not put into the sea or the air. Which are optional, which produce record books, and which cost freight. Port state control and detentionsA detained ship cannot perform. What an inspection actually records, and how to read a hull's record without over-reading one bad day. What a ship can actually liftA 58,000 deadweight ship does not lift 58,000 tonnes, and at a shallow berth she may not lift 52,000. The arithmetic nobody does in their head. How to calculate laytime and demurrageWhere the clock starts, what stops it, how the demurrage figure is actually worked out, and why most claims are lost on the paperwork rather than the merits.

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