07 May 2020
Applicability: shipowners, ship operators, ship managers, designers, ship builders, manufacturers and all vessels installing BWTS.
Further to Class News No. 16/2017, which outlined the required schedule for installation of Ballast Water Treatment Systems (BWTS/BWMS).
Such systems to be installed* on or after 28 October 2020 must be approved in accordance with the IMO Code for Approval of Ballast Water Management Systems (BWMS Code), as required by BWM Convention Regulation D-3 and the BWMS Code (IMO Res. MEPC.300(72). Noting that BWMS approved in accordance with the 2016 Guidelines (G8) adopted by resolution MEPC.279(70) are deemed to be in accordance with the BWMS Code.
In cases where BWTS installation drawings have been approved by Lloyd’s Register based on an IMO Type Approval Certificate in accordance with IMO Res. MEPC 174(58), issued by a Flag State Administration (FSA), the system should be installed* before 28 October 2020. Such BWTS would have been type approved prior to 28 October 2018, taking into account IMO G8 guidelines (IMO Res. MEPC.174(58).
If installation* can only take place after 28 October 2020, owners will need to arrange for installation of a system having a FSA IMO Type Approval Certificate in accordance with the BWMS Code. This may necessitate the purchasing of upgrade kits, or a new system, and reapproval of BWTS installation drawings.
*Note: The word "installed" means the contractual date of delivery of the BWTS/BWMS to the ship. In the absence of such a date, the word "installed" means the actual date of delivery of the BWTS/BWMS to the ship.
Delays due to COVID-19
The COVID-19 pandemic has disrupted the operations of shipyards and disrupted the supply chains for ballast water management system providers, which may have an impact on equipment installation schedules.
- IMO Circular Letter No.4204/Add.7 gives guidance concerning new construction projects and the unforeseen delays in the delivery of ships due to COVID-19.
- For information on postponements of USCG ballast water management requirements due to COVID-19 see Marine Safety Information Bulletin No. MSIB-14-20.
- Information on the latest Flag and Port State instructions on COVID-19 (Coronavirus) here.
What should owners and operators do now?
If owners are unsure to which performance standard their proposed system is approved, or are unsure about the contractual delivery date of any planned BWTS/BWMS installation, they should contact the vessel’s Flag Administration and the system manufacturer for more information.
In cases where original installation dates cannot be met and changes may occur to the proposed system design, owners should contact Lloyd’s Register to determine which documents/drawings may need to be submitted for approval.
For delays related to the COVID-19 pandemic, Owners should contact Lloyd’s Register to make suitable arrangements with Flag Administrations.