New ships have been installed with ballast water treatment units (BMTS) at the time of construction, applicable existing ships have been modified and updated with BWMP during ship repairs, and other ships that have not yet been modified have also been orderly promoted in accordance with the special maintenance ship plan. BMTS equipment management and ballast water operation management will become part of the daily work of the ship, and the shore base and the ship will have to pay attention to it.
The interim and final emission standards for ballast water established by the State of California are too high to be revised in view of the inability of existing equipment and technology to meet their discharge requirements. The new emission standards are aligned with USCG requirements and have an effective date in line with USCG. As for the ultra-stringent emission standards of California, the United States is now adjusted to: the provisional standard is expected to take effect on January 1, 2030; the final emission standard will be effective on January 1, 2040.
California's new law on ballast water management will take effect Jan. 1, 2022, exempting ships including warships and "harmless passageships," i.e. foreign ships that pass only through U.S. territorial waters, do not enter or leave U.S. ports, or do not enter inland waterways, and do not discharge ballast water into U.S. waters or waters that may have an impact.
USCG Emission Standards
While California's emissions standards are downgraded to USCG standards and IMO's common standards don't need to be trivialized, its inspection requirements for foreign ships operating in waters are worth learning. Considering the current situation that BMTS is commonly used in various companies for a long time or rarely used, it may cause unskilled personnel operation, equipment cannot operate normally, equipment maintenance is missing, and related testing equipment is not calibrated as required, including defect-related records and documents. Meeting the inspection requirements of the California authorities in the United States usually also meets the inspection requirements of other port state authorities for BMTS, which is also helpful in improving the management level of the fleet itself.
Be aware of when sailing to California
1. The ballast water management system shall operate according to the design restrictions specified in the IMO BWMS Type Approval Certificate or the USCG Type Approval Certificate issued by the competent authority;
2. Strengthen the monitoring of equipment operating parameters according to the manufacturer's suggestions to ensure that it is within the normal range;
3. All applicable sensors and other control equipment shall be calibrated at the frequency recommended by the manufacturer;
4. Keep relevant records on board, including:
● Paper or electronic records of equipment function monitoring and calibration in the past two years;
● Paper or electronic records of microbiological testing in the past two years, including the time of testing, personnel/institutions, and methods;
● Type Approval Certificate or "Alternative Management System (AMS)" letter issued by USCG;
● Equipment fault handling procedures;
• Keep records of all ballast water operations, including the use of common system water as an alternative to ballast water.
5. Ensure that the relevant personnel should be convenient to approach the sampling port to complete the sampling operation;
6. Contact the agent for the latest requirements and related information before arriving in California.
Possible problems in the day-to-day management of BMTS
1. How many ships with BMTS are actually put into service or used occasionally?
2. Has the treated ballast water been sampled for inspection, and does the result meet the IMO emission standards?
3. After the crew is replaced, can the ship's personnel be proficient in operating the relevant equipment?
4. Has the relevant sensor of the device been regularly verified according to the manufacturer's requirements?
5. Can I provide paper or electronic records of equipment function testing and calibration?
6. Can I show equipment maintenance records on board?
7. Is there a fault handler for the device on board?
The management recommendations are as follows
1. Do a good job in the training of on-board personnel to ensure that the equipment can be skillfully operated;
2. Ships that have never been put into service, trial in suitable waters, and keep data records related to equipment operation;
3. Refine the inspection, maintenance and inspection cycles of different components, equipment and systems in the PMS with reference to the instructions;
4. According to the requirements of PMS (manufacturer) for equipment maintenance, calibration and testing, and keep relevant records;
5. The sensor that needs to be sent to a professional organization for verification should be performed according to the requirements of the manufacturer and the relevant certificates and records should be retained;
6. If it is missing, please formulate emergency procedures for equipment failure;
7. Keep the ballast water test report.
Additional information
The revised emission standards for VIDA 2018 (The Vessel Incidental Discharge Act) will take effect no earlier than the end of 2022.
Vida 2018 not only consolidates ballast water regulations in each region, but also allows states the flexibility to manage and enforce ballast water discharge requirements of particular concern to states. With the enactment of VIDA 2018, the regulations will take effect for certain states when the act goes into effect.
The Great Lakes region, including Illinois, Indiana, Michigan, Minnesota, New York, Ohio, and Wisconsin.
Requirements include: ships from any port outside the U.S. and Canadian EEZ should be replaced not less than 200 nautical miles ashore, or completely replaced or cleaned within not less than 50 nautical miles from any port within the U.S. and Canadian EEZ.
Pacific coastal waters, including: Alaska, California, Hawaii, Oregon, and Washington. Requirements include:
VIDA 2018 Pacific Regional Low Salt Ballast Water Exchange Exemption Standard
Supplementary source: BALLAST WATER MANAGEMENT 12thedition (2021 edition)