MEPC 71 reached a highly anticipated compromise agreement on compliance dates for ballast water discharge and on implementation dates for the so-called D-2 discharge standard.
The long-awaited agreement will have global impact providing certainty to the maritime community regarding mandatory compliance dates for ballast water discharge treatment. From its entry into force on September 8, 2017, all vessels for which the convention is applicable, shall conduct ballast water exchange in accordance with an approved ballast water management plan until compliance with the D-2 regulation becomes mandatory.
Compliance with the D-2 standard refers to the date individual ships must have a ballast water treatment system installed. The agreement ensures full global implementation by September 8, 2024 and contains following key elements:
- ships built (keel-laid) on or after the date of entry into force on September 8, 2017, must comply with the D-2 standard on delivery
- existing ships must comply with the D-2 compliant by the first IOPP renewal after that date
- ships should be D-2 compliant on the second IOPP renewal survey following September 8, 2017, if the first renewal survey following that date is completed prior to September 8, 2019 and if conditions* are not met.
* Survey is completed on or after September 8, 2019. Renewal IOPP survey completed on or after September 8, 2014, but prior to September 8, 2017.
This means that:
- ships due for an IOPP renewal survey between September 8, 2017 and September 8, 2019 cannot decouple their IOPP survey for a second renewal before September 8, 2019 without then having to comply with the D-2 standard
- ships built before September 8, 2017 and delivered (including the initial IOPP survey) after that date, need to comply with the D-2 standard at the first IOPP renewal survey after delivery
- ships to which the IOPP renewal survey does not apply (generally ships less than 400 GT in size) should be D-2 compliant no later than September 8, 2024.
- vessels with the last IOPP renewal carried out before September 8, 2014 have nothing to gain by decoupling, but rather risk losing up to two years on the D-2 implementation date by doing so
The applicable USCG implementation requirements on ballast water is totally unaffected by these recent MEPC discussions/decisions. Vessels trading, or planning to trade, in the US should make sure they are compliant but with the US ballast water management requirements.
Notwithstanding changes to the D-2 implementation schedule, the D-1 deadline stays firm, being September 8, 2017. By this date, affected ships should have onboard an International ballast water management certificate, meaning a plan should be submitted for approval and order the initial survey.