Dennis L. Bryant, Principal, Bryant's Maritime Consulting

https://www.brymar-consulting.com
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Dennis L. Bryant

The term morass is defined as “an entanglement or a disordered situation, especially one impeding progress.” Shipowners and operators understand that this term clearly applies to the current state of ballast water management systems.

The International Maritime Organization adopted the Ballast Water Management Convention in 2004. The Convention is scheduled to enter into effect on Sept. 8, 2017. In the meantime, the IMO is busy trying to amend certain provisions relating to testing of ballast water management systems and to the dates by which vessels are required to have approved systems installed.

In the United States, which is not party to the Convention, the US Coast Guard is testing several systems to determine whether they meet the stricter US requirements. None have been approved to date, but several may achieve USCG approval in the near future. In the meantime, the Coast Guard has been granting temporary authorizations under its Alternative Compliance System (AMS) for vessels that have installed an IMO type-approved system. Unfortunately, the Environmental Protection Agency has specifically declined to officially endorse the Coast Guard AMS program. While no vessel has yet been penalized by the EPA for use of an IMO type-approved system, the threat looms.

A number of ships, particularly those constructed after 2004, have installed ballast water management systems that met the current IMO type-approval standard. It now appears that those systems may have to be replaced at some time in the future, particularly if the vessel expects to operate in US waters. The maritime industry deserves better.