Rev. 3.

2
27 May 2008

Ballast Water Management

Convention 2004

Frequently Asked Questions and Answers

May 2008

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 Rev. 3.2
27 May 2008
BALLAST WATER MANAGEMENT
Frequent Asked Questions

Note : The use of this document is subject to Terms and Conditions :

BW – Ballast Water
BWM – Ballast Water Management
BWMP – Ballast Water Management Plan
BWM 2004 – Ballast Water Management Convention 2004
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referred to in this clause as the ‘Lloyd's Register Group’. The Lloyd's Register Group assumes no responsibility and shall not be liable
to any person for any loss, damage or expense caused by reliance on the information or advice in this document or howsoever
provided, unless that person has signed a contract with the relevant Lloyd's Register Group entity for the provision of this information
or advice and in that case any responsibility or liability is exclusively on the terms and conditions set out in that contract.

QUESTION
Q1 Regarding BW Exchanges, the volumetric changes of BW of
95% or flushing the tanks 3 times, how would that be
confirmed if the Master has actually carried sufficient
volumetric changes while in the mid voyage? Is the
declaration by the Master in the BW Record Book sufficient
to convince the PSC officers?
ANSWER
A1 This operational is up to the master to keep proper records to prove that three times
the tank volume has been exchanged. It is very easy to do - just tank volume divided
by rated capacity of the pump(s) used times the hours run of course an allowance
needs to be made for starting up and slowing down etc. to ensure the calculation will
equate to volume of water pumped through is three time tank volume.
The Master has to declare in meeting the required BW Exchange standards, and to
record the proper actions taken in the Record Book. Depending on the Flag/Port
legislation, it can be a criminal offence if fraudulent action is taken by the Master.

The current requirement in the Great Lake areas is that inspection is done before the
ship is granted permission to transit the Seaway/Great Lakes system to ensure
compliance with ballast water regulations. Regulatory bodies test the salinity in
certain ballast tanks in order to confirm that the salinity meets the minimum required
salinity of 30 ppt (parts per thousand). Ships that do not comply with the minimum
salinity of 30 ppt are required to retain all non-compliant ballast water onboard,
return to sea and conduct a full ballast water exchange or treat the non-compliant
ballast water with an approved treatment. Ballast water salinity is checked using a
handheld salinity refractometer (Vee Gee Model A366ATC or Fisher 13-946-27) or
with an electronic meter; such as, the YSI meter.

Q2 A written comment in the feedback form completed by a
major shipbuilder who was at the BLG11 and MEPC56
sitting in the BW WG - "As I said, it is very difficult to
follow/apply the requirements due to limited space in cargo
pump room in tanker vessels. Hence requirements must be
When the BWM Convention 2004 relating to BW Treatment is in force, it will be able
to provide qualitative check to ensure post-treated BW is meeting the Reg. D-2
standards.
A2 A PSC may ask for samples from two places firstly they may wish to sample the
water in the tanks in which case normal tank access points (man holes , tank lids,
dipping points etc.) can be used. For treatment systems the D-2 standard is a
discharge standard therefore a sampling point will be required near to the ballast
overboard.

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QUESTION
deleted or modified....." What are the requirements in terms
of sampling points? Are they needed to be located in the
cargo pump room?
Q3 As per BWM 2004, it also applies to FPSO and FSU. Since
during most of its life FPSO/FSU are stationed in one place,
and Ballast exchange and treatment does not make sense.
How would the BW be managed?
Q4 The intent of BWM is to minimise the spread of non-
indigenous species to areas other than their native waters.
Most drill ships are operating in limited areas for a prolonged
period, and may only make limited number of transits to
other areas (say 4, 5 times) throughout the useful life of a
drill ship. How would BWM affect this ship type? Do they
need to be dealt with in the same way as other oceangoing
ships? Any exemption or concession is allowed in applying
BWM practices?
Q5 What are the Ballast Water Management requirements of
the US Gulf?
Q6 What are the principles of Sequential Method, Flow-through
Method, and Dilution Method?
Rev. 3.2
27 May 2008
ANSWER
Unfortunately the IMO have not yet completed and approved the guidelines for
sampling so it is not finalised what PSC will be entitled to do in way of sampling and
what sampling points will be acceptable.
A3 BWM would only apply to the voyage to the final station not while the vessel was on
station as ballast taken up and discharged in the same location is not subject to the
convention
A4 BWM would only apply to the voyage to the final station not while the vessel was on
station as ballast taken up and discharged in the same location is not subject to the
convention.
A5 US Federal ballast water regulation would apply as ships in the US Gulf will be
operating within the US EEZ i.e. 200 mile limit. Therefore exchange before arrival is
required. For ships operating within the Gulf there is an exemption for crude oil
tankers on 'coastwise' trade and ships operating in what is termed the same Captain
of the Port (COTP) zone - we assume that this means within the limits of an area
under the Control of one port captain.
A6 Sequential method – a process by which a ballast tank intended for the carriage of
ballast water is first emptied and then refilled with replacement ballast water to
achieve at least a 95 per cent volumetric exchange.
Flow-through method – a process by which replacement ballast water is pumped into
a ballast tank intended for the carriage of ballast water, allowing water to flow
through overflow or other arrangements.
Dilution method – a process by which replacement ballast water is filled through the
top of the ballast tank intended for the carriage of ballast water with simultaneous
discharge from the bottom at the same flow rate and maintaining a constant level in
the tank through out the ballast exchange operation.
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27 May 2008
QUESTION ANSWER
Q7 My ship is trading within a short international trip only (for A7 As per BWM Convention texts, the requirement of managing BW is applicable to
example, Busan-Shanghai-Tokyo). The marine life in these ships on international voyages. There is no exception.
areas are similar, and ballast water taken up and discharged
in these areas should not have effects on ecological
balance. In the BWM Convention 2004, is there any
exemption granted in such cases?

Q8 My ship is trading along the coast within the territorial waters A8 There are two cases here.
of the same country (e.g. Seattle to Los Angeles , or Tianjin
to Shanghai). My ship is not doing international voyages.
If a ship is flagged and operates in the waters of that country, BWM is not required
Does my ship need to carry BW management?
under the convention unless national regulations apply.

If a foreign flag ship operates only in the waters of another country, then under the
Convention BWM would not apply provided the country in which it operates gives an
exemption from the BWM requirements. However, local national regulations will
apply if any.
Q9 My ship was built in the 1980’s and is well maintained, but A9 As per BWM Convention texts, there is no exemption in such cases.
there are physically no room for retrofitting ballast treatment
system. Also the electricity supply would not be sufficient for
additional consumption due to the ballast water treatment
system. In the BWM Convention 2004, is there any
exemption granted in such cases?

Q10 At MEPC 56, there were discussions on the possible delay
in the generic implementation date from 2009 to 2010 or
2011. If the delay is agreed in MEPC 57, would the set of
implementation dates (2012, 2014, and 2016) be all
postponed accordingly?
A10 Regarding the postponement of the set of dates (2012, 2014, 1026), it is not sure at
this stage. This will be discussed at MEPC 57.
Furthermore, the IMO Secretary General has made a proposal to the IMO 25TH
Assembly meeting to be held in 3-14 December 2007. The proposal is to effectively
delay the 2009 date until either option (a) 2011 or option (b) until entry into force of
the convention but in any case no later than 2014.

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QUESTION
Q11 Does Class approve BW Treatment systems? Can such a
system approved by one Flag (or Class) be accepted by
other Flag (or Class)?
Q12 In the BWM Convention Reg. B-3, the terms “until 2014” and
“until 2016” are used. Should these be understood to be “1
Jan 2014” or “31 Dec 2014”, and “1 Jan 2016” or “31 Dec
2016” respectively?
Q13 Does maintenance procedures and requirements of the BW
Treatment system need to be included in the BWMP? It
does not seem to be included in LR’s Model BWM Plan.
Q14 For the BW treatment system which are using active
substance (e.g. chemicals), are there any guidelines and
requirements for the onboard handling, storage, etc. and
also fire/safety aspects available for designers and
operators?
Rev. 3.2
27 May 2008
ANSWER
A11 Approvals are undertaken by flag administrations or a recognised organisation(e.g.
Class) their behalf in the same way as, for example, the oil/water separators are
approved. So a system approved by, for example, the UK would be acceptance for a
Panama registered flag.
LR will be a recognised organisation for the UK.
[ref. Graham’s email to Sakamoto-san dated 21 May 2007]
A12 This matter is being raised at IACS and IMO, and is expected to have a clearer
indication at MEPC 57.
A13 Maintenance procedures and requirements of the BW Treatment system are not
required to be included in the BWMP, but manufactures manual must be onboard
and these must contain maintenance procedures.
A14 At present there are no IMO guidelines for fire/ safety handling, storage etc. however
it is believed that the safety issues will be raised at the IMO with a view to producing
guidelines but it is not known when this might occur.
LR is aware that there are safety issues with at least one of the chemicals being
proposed for use in treatment systems.
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QUESTION
Q15 1. Sediment removal should be done with Ballast water
treatment system in accordance with the Rules?
2. Hamann acquired Final Approval in MEPC 57 at last!!!
Is it right? (Please refer to the underlined pages.)
http://marinenorway.etp.no/sider/tekst.asp?side=2907
Rev. 3.2
27 May 2008
ANSWER
A15 1. Sediment removal and Ballast water treatment system
1.1 As given in Guidelines G8, the following are defined:
3.2 Ballast Water Management System (BWMS) means any system which
processes ballast water such that it meets or exceeds the Ballast Water
Performance Standard in Regulation D-2. The BWMS includes Ballast Water
Treatment Equipment, all associated Control Equipment, Monitoring Equipment and
Sampling Facilities.
3.3 The Ballast Water Management Plan is the document referred to in Regulation
B-1 of the Convention describing the ballast water management process and
procedures implemented on board individual ships.
3.4 Ballast Water Treatment Equipment means equipment which mechanically,
physically, chemically, or biologically processes, either singularly or in combination,
to remove, render harmless, or avoid the uptake or discharge of Harmful Aquatic
Organisms and Pathogens within Ballast Water and Sediments. Ballast Water
Treatment Equipment may operate at the uptake or discharge of ballast water,
during the voyage, or at a combination of these events.
1.2 In Regulation D-2, Ballast Water Performance Standard is given, and limiting
the maximum amount of viable organism and indicator microbes. There is no specific
limitation on the amount of sediment.
1.3 Therefore Ballast Water Treatment system do not necessarily require to be
able to remove sediment prior to discharge. However, it is not desirable to
accumulate excessive amount of sediment in the ballast tanks as this may likely
reduce the cargo carrying capacity. Also, in accordance with the Reg. B-1 of BWM
2004, details of procedures in the disposal of sediments at sea and to shore are to
be included in the BWM Plan, and Reg. B-5 requires that ships to be designed and
constructed to facilitate the safe removal and sampling of sediments.
1.4 In the final draft version of the guidelines G2 (BLG 12/WP.5 Annex 1) Section
6.2.3 states that "the sampling protocol should take account of the potential for a
suspended sediment load in the discharge to affect sample results". Hence it is not
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27 May 2008
QUESTION ANSWER
unexpected to have sediment to be present in the treated ballast water.

2. Status of Hamann in receiving Final Approval in MEPC 57

2.1 Flag Administration of Germany submitted a discussion paper MEPC 57/2/5

requesting MEPC to grant Final Approval to the system SEDNA® using
PERACLEAN® OCEAN which is a product manufactured (directly or under licence)
by the company HAMANN AG.

2.2 This system received recommendation, by the GESAMP in the discussion

paper MEPC 57/2/10 with GESAMP report attached thereto (GESAMP-BWWG 5/9),
in receiving Final Approval.

2.3 MEPC 57 agreed to grant Final Approval to this system in April 2008.

2.4 However, please note that for the system to be accepted as meeting BWM
2004 Reg. D-2 requirements, the system still has to obtain Type Approval which is
yet to be granted by the Flag Administration.

Q16 Would you mind to notice me the country names which the
ballast water exchange has been regulated and the vessel
should carry out ballast water exchanging in the region up till
now.
Q17.1 What type of vessels are likely to need deck solutions?
Q17.2 Are there any vessels that are likely to be limited to dosing
solutions rather than the filtering/UV/electrolysis etc
systems?
A16 Please see LR’s document “NATIONAL BALLAST WATER MANAGEMENT
REQUIREMENTS“ dated May 2008.
A17.1 It is recommended that installation is made in the Engine Room or Pump Room
closer to the ballast pumps. Depending on the chosen Ballast Water Treatment
System (BWTS), there will be a variety of existing ships which may have insufficient
space underdeck, hence on-deck installations will be an alternative solution.
However, precautions should be taken. For tankers (including those carrying oil,
chemical, gas), if the location is in an explosion zone, then the installation of
electrical equipment will need to be intrinsically safe. Electrical equipment can be
certified as intrinsically safe products, but there is a cost penalty for this.
A17.2 1. Chemical dosing systems and some other systems (such as oxygen
deprivation and ozone systems) are more suitable at present for treating larger
volumes of ballast. Filter/UV/electrolysis type and similar systems have at present
limited treatment capacity is terms of tonnes per hour and may not be suitable for
ships with large volumes of Ballast Water (BW) with higher pumping rates e.g. large
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27 May 2008
QUESTION ANSWER
tankers and bulk carriers. It is possible to use filter/UV/electrolysis type and similar
systems to treat large volumes however multiple units would be required to cope with
the pumping rates with added initial and running costs.

2. Some of the chemical systems may require the storage of large quantities of
chemical which would require additional space and can require fire detection and
preventions measures to be provided together with suitable handling equipment and
procedures. The availability of stocks of chemicals world wide from accredited
supplies may also be an issue.
Q17.3 How can newbuilds be prepared for the later fitting of A17.3 For new buildings (keel laying from now on), it is advisable to prepare for meeting
systems in the engine room? BWM 2004. However in view of the fact that there is currently only one type
approved system available it is not easy to prepare a ship at the design stage for
later fitting of the system. Even when a number of approved systems are available
unless the prospective owner of the ships specifies one or perhaps a few options of
systems they intend to retrofit it is still not easy for designers especial as most yards
offer standard designs. In any case, here below are some of the basic preparations
which may be considered:

• Include BW exchange (which is acceptable only up to 2014 or 2016) and

Q17.4 Any other design considerations that would be important for
owners choosing between systems?
BWTS in your newbuild specification, or specify only BWTS in your new
build specification.
• Reference to promising BWTS (those which have already received type-
approval), allow space, pumping & piping, electrical supply, etc. in the design
of your new ships.
• The information as to requirements of space, piping/pumping capacity,
electric power, storage of active substance (if applicable), etc., and their
updates, can be obtained from the potential promising suppliers.
• When selecting BWTS, it is needed to consider capital investment,
consumables (active substance or chemicals), training needs, fire & safety,
ease of retrospective installation.
• Ensure the approved BW Management Plan is onboard, with suitable class
notation to confirm compliance.
A17.4 The following are additional matters that could be considered in selecting BWTS (in
no particular order of importance):
• Type-approval granted
• Reliability
• Ease of operation
• Training needs
• Safety precautions
• Technical /maintenance support

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QUESTION
Q18 For animal carrier we will never be requested BWMS
installation because we use reverse osmosis water for
balancing the ship and the tanks are declared as Fresh
water and not Ballast water. Actually from time to time we
are used to discharge fresh water while we are moored in
the harbour in order to adjust trim of the ship.
Is that correct? Is there any writing about this issue?
Rev. 3.2
27 May 2008
ANSWER
• Availability of supplies of chemical/active substance, spare parts
• Capital costs, installation costs, running costs, maintenance costs
• Ventilation requirements, pumping capacity, sampling points access,
redundancy/backup of system
• Easy or retrofit
• Treatment capacity
A18 It is unusual to use fresh water as ballast. When using reverse osmosis no doubt
many organisms from the original sea water would be ‘killed’ however reverse
osmosis alone does not remove all organisms or microbes such as vibrio cholerae
and E coli without some kind of additional disinfection process as such the D-2
standard in the Convention would not be met.
The BWM Convention applies to all ships – ballast water is defined in article 1 of the
Convention as “water with its suspended matter taken on board a ship to control trim,
list, draught, stability or stresses of the ship”
The ‘animal carrier’ would therefore be subject to the requirements of the Convention
and would be required to treat any water used as ballast as defined above in
accordance with the provisions of the Convention.
Therefore once the Convention enters into force the ship would be required to
exchange ballast and at a later date in accordance with regulation B-3 treat the
ballast water using and approval treatment system.
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