Floating platforms, floating storage units (FSUs) and floating production, storage and offloading units (FPSOs) (i.e. floating offshore installations at fixed locations) are normally not required by the Convention to undergo surveys or to have international convention certification, unless they transit or relocate to another location, at which time the requirements of the Convention become applicable.
International BMW Certificate
Owners should ensure they meet the requirements of the Administration¹ where they are operating. Should the Administration not require such units under their jurisdiction to have an International BWM certificate, the owners/operators should obtain this agreement for exclusion from the Convention. The flag Administration (if applicable) should then be notified of this decision (refer to BWM.2/Circ.52).
In any case, the Administration is to establish measures for ensuring that the Convention’s provisions are complied with (regulation E-1.2).
¹ "Administration" means the Government of the State under whose authority the ship is operating. With respect to a ship entitled to fly a flag of any State, the Administration is the Government of that State. With respect to floating platforms engaged in exploration and exploitation of the sea-bed and subsoil thereof adjacent to the coast over which the coastal State exercises sovereign rights for the purposes of exploration and exploitation of its natural resources, including Floating Storage Units (FSUs) and Floating Production Storage and Offloading Units (FPSOs), the Administration is the Government of the coastal State concerned.
Memoranda of Understanding (MoUs)
An International BWM Certificate will be required by September 8, 2017. The Certificate can be issued after an approved BWM plan, describing how the requirements of the Convention will be met, has been put in place, after a survey has been carried out. Ballast water record book entries are to be maintained on board for a minimum of two years.
Owners could meet the requirements of the Convention by, for example, installing a permanent treatment system, installing a temporary treatment system or discharging untreated ballast water and sediments to other ships or barges. BWM.2/Circ.46 provides the option for an internal circulation method to be used.
What to do next?
Clarify with your coastal state administration whether your offshore unit needs an International BWM Certificate and if required, obtain an International BWM Certificate by September 8, 2017.