TECHNICAL AND REGULATORY NEWS No.

12/2019 – Statutory

BWM – SOME PRACTICAL

RECOMMENDATIONS BEFORE
8 SEPTEMBER 2019
Relevant for ship owners and managers, design offices, shipyards, suppliers and flag states.

June 2019

With next IOPP renewal survey completion on or after 8 September 2019, a substantial number of
vessels which presently only comply with the D-1 standard will be required to install a D-2 standard
ballast water treatment system. This statutory news provides some recommendations on how to
effectively install a system in due time.

Below you will find some hands-on recommendations for going
ahead with the ballast water management implementation:
Ship owners’ checklist – the most important tasks for a ship
owner or operator, in order of their priority:
ƒƒ Retroactive Requirements (RR): For your individual vessels,
compare the overview of IOPP renewal dates you have pre-
pared, with their specific RR messages, and posted under
My Services on Veracity. These RR messages help you to
manage due dates and to take the necessary actions to
ensure the proper follow-up of the retrofit requirements
(e.g. RR Ref. 1034f, RR Ref. 1034g and MO Ref. 287).
ƒƒ Any IOPP renewal completion on or after 8 September 2019
triggers at the same time the installation of a ballast water
treatment system (BWTS), as from that date (BWMC Reg.
B-3.10.1.1 applies).
ƒƒ For ships with the last IOPP renewal before 8 September 2014:
Check your fleet and verify whether the last IOPP renewal survey
was done before 8 September 2014. If this is the case, the next
IOPP renewal should be completed before 8 September 2019
(ref. Reg. B-3.10.2). This ensures you take full advantage of the
due date for D-2 compliance which is then on the second IOPP
after entry into force. Otherwise, the BWMC Reg. B-3.10.1.1
applies and the D-2 compliance date changes, becoming the
first IOPP renewal on or after 8 September 2019. Yes, this may
seem complicated; the graphic on page two illustrates this
point (MO Ref. 287 have been issued on these ships).
ƒƒ IOPP re-coupling is advantageous for the BWM D-2 due date
only on IOPP de-coupled ships, which had the last regular IOPP
renewal before before 8 September 2014. Any IOPP re-cou-
pling for these ships must be done before 8 September 2019.
Consent by the flag administration is required. Any request for
IOPP re-coupling shall be submitted via DATE (Direct Access to
Technical Experts; for customers only) to profit from a smooth
process.
ƒƒ For ships with an IOPP renewal between 8 September 2014
and 7 September 2017:
The due date of 8 September 2019 is not relevant for these
ships. The BWMC Reg. B-3.10.1 applies and the D-2 compli-
ance date is the first IOPP renewal after 7 September 2017.
ƒƒ Plan your retrofit, and ensure relevant documents are
forwarded to class for approval as early as possible.
ƒƒ Beware: Normally it takes 6 to 9 months from ordering the
BWTS, 3D scanning and design, and class approval of instal-
lation drawings, to installation and commissioning.

Page 1/2
 IOPP renewal survey and BWM D-2 compliance date

Reg. B-3.10.1: D-2 Due date:

2017-09-08 First IOPP
2014-09-08 EIF* BWMC renewal after EIF*

First IOPP renewal

after EIF*
= D-2 compliance

ca. 5 years D-2 Due date:

Reg. B-3.10.1.1: First IOPP renewal
2019-09-08 after 2019-09-08
First IOPP
renewal after
2019-09-08
First IOPP
= renewal after EI
D-2 compliance

ca. 5 years and more (e.g. laid up)

Reg. B-3.10.2: D-2 Due date:

2017-09-08 Second IOPP
2014-09-08 EIF* BWMC 2019-09-08 renewal after EIF*

First IOPP Second IOPP

IOPP renewal renewal after EIF*
renewal survey
survey
after EIF* = D-2 compliance

ca. 5 years ca. 5 years

EIF* : Entry into Force of the BWM Convention on 2017-09-08

Approval
2 process
DNV GL © 2015 27 June 2019 ƒƒ BWM Plan: This should, as a minimum, contain what is in
The approval of the installation drawings depends on the quality our template; see template “BWM plan template for D-2” at
of the drawings, the quality of the design, vessel type, and ballast dnvgl.com/bwm (please provide D-2 BWMP only if D-1 has
water treatment system technology. The installation should been approved previously)
comply with the BWM Convention and the DNV GL rules.
When all the documents are approved and the system has been
DNV GL has developed a list of required documents (a DocReq) installed, there must be a commissioning and an initial survey
for the different types of treatment technology, including a by a DNV GL surveyor. If everything is in order, the surveyor will
minimum of drawings that should be submitted for approval. issue an International BWM Certificate (IBWMC), with the box
The document shall be sent upon request when applying for “D-2” ticked off.
approval. The approval process should be initiated at least
3 months before the scheduled installation to account for the Recommendations
handling of comments and follow-up, when required. ƒƒ Review the ship owners’ checklist above – and take action.
ƒƒ Start the approval process in due course – and at least 3
Below is a list of some items which, based on our experience, months before installation.
require attention from owners and designers: ƒƒ Ask class, flag and manufacturers should you have any
questions.
ƒƒ Type and model of the BWTS: The name, model and treat-
ment capacity of the system must be clearly stated in all References
documentation. DNV GL webpage on BWM
ƒƒ Valid Type Approval Certificate (TAC): All systems shall have Technical & Regulatory News, Sept 2018
a valid TAC, issued by the flag or accepted by the flag of
the vessel, e.g. issued by a RO to the flag (or has otherwise
formally acknowledged the TAC).
ƒƒ Bypass in general and gravity bypass: All ship bypasses, and CONTACT
not only the treatment system bypass valve, shall be logged For customers:
and given an alarm. DATE – Direct Access to Technical Experts via My Services on Veracity.
ƒƒ Sampling ports for D-2 compliance: Sampling pipe details, Technical and approval enquiries:
location and access to sampling ports. bwm@dnvgl.com
ƒƒ For systems using active substances (G9 systems, e.g.
electrolyzed, chemical or ozone): Location and capacity of
ventilation and monitoring of dangerous gas/liquid in the
space of installation to be considered.

DNV GL – Maritime, Brooktorkai 18, 20457 Hamburg, Germany, Tel: +49 40 36149 0, www.dnvgl.com/maritime DNV GL Disclaimer of Liability