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The Ballast Water Management Convention and its impacts on the shipping
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 CONTENTS
Shipping Magazine

010 Opening Remar ks: Two Answers for One Problem!

015 IRISL: IRISL to Develop its Fleet
Published quarterly by IRISL
Volume 5, Summer 2017 016 IRISL Seeks to Develop its Fleet
ISSN: 1027-1058 018 Active Participation of IRISL in the International Arena
with Fleet Renewal
020 Unprecedented Performance of IRISL’s Container Division
During 19 years
024 Expanding the Scope of Activities from European Ports to
South America
028 Start of a New Era for IRISL
Legal Representative:
Ali Akbar Ghonji 030 Iran’s Membership in International Insurance Clubs
034 Purchase of New Container Wagons and Boosting of Rail
Editor-in-chief: Transportation
Amir Fallah 036 MITD to Provide Marine Industry with Software
m.fallah@irisl.net
039 Marine: Emission, Recycling and BWM
Journalists: 040 The Ballast Water Management Convection and its
Behrooz Ghahremani, Seyed Majid Motahari Impacts on the Shipping Industry
Leyla Beyranvand , Fatemeh Moonesan, 060 Implementation of Three Major Acts by IMO Comes to
Sarah Zeinalzadeh, Fatemeh Bayat, Force
Fereshteh Azizkhani, Vahid Basereh ,
066 Targeting and Market Segmentation in Shipping Industry
Narges Ehsandar, Sepide Yousefi, Mehri Azizi,
Sahar Eyvaziadli 070 Safety Regulatory Framework of Offshore Structures
078 A New Setting for Lines’ Venture to and from Iran
Designer:
080 Iran; Connecting Bridge between Asia and Europe
Fatemeh Abedini
084 Qatar’s Big ‘’If ‘’ for Convincing ship- owners in the
Financial-Administrative Department: World
Golnoosh Afrooshe 090 Milestone for Expanding Iran-Germany Collaboration
093 Iran: Rouhani’s Accompolishments
Photographer:
Ali sobhan hosseini 094 Positive Change
098 JCPOA re-launched Economy Train of Iran
104 IRISL Receives 10-Figure Insurance Coverage

ADDRESS: 108 We Will Promote Iran’s Position in the Global Steel Market
No.523, Asseman Tower, Shahid Lavasani 112 Iran – Brazil Tie Intensifies
(Farmanieh) Junction, Pasdaran Ave. 120 Iran’s Industrial Sector; An Opportunity to Gain Profit
Tehran - Iran.
124 Iranian Handicrafts Exports Tripled
P.o.Box: 19395/1311
Tel: (+98 21) 26100368 128 Carmakers Cross the Sanctions’ Red Light
Fax: (+98 21) 26100371 133 Energy: In Counterpoint to Sanctions
134 Fruits of Energy Diplomacy and Smile in Gas Capital of Iran
140 Security of Foreign Investment Is Provided in Iran
144 Total Waiting for Entrance to Iran’s Petrochemical
Gateways
148 The $3 billion Financing of Siraf Project by the Foreign
General Manager of Consortium
Advertising Department:
Alireza M.Sadeghi 154 850 Tankers Have Docked at Kharg since JCPOA’s Execution
158 OPEC members united against Trump’s oil policy
To advertise in Payam-e-Darya, please contact
Alireza M.Sadeghi at 162 The European Companies Entertained in Tehran Oil
Tel: +989121001769 Exhibition
Email: al_m_sadeghi@yahoo.com 166 Investment Attractions in Iran’s Oil Industry
m_sadeghi@irisl.net
169 Bulletin: The silk Road Revival of Silk Road Passes
Through the Sea
170 News
 Ar ticle

The
Ballast Water
Management
Convection
and its Impacts
on the
Shipping
Industry
Payam Darya Volume.5 / Summer 2017

By : Mehdi Rastegary
Sina Ports and Marine Services Co.

40
Head of Research and Development, Sina Ports and Marine Services Co.
By the rise of global dependence on the maritime transport in the past
decades, shipping is seen as one of the most essentially needed industries
for sustaining human life on the planet. E. Mitropoulos once said: ‘Without
shipping, half the world would freeze and the other half would starve.’ In other
words, with dependence of 90 percent of international trade on the shipping,
our globalized world cannot be perceived without it.
Although shipping is seen as one of the most environment-friendly modes
of transport, the scale and scope of activities in the industry amasses the large
magnitude of the environmental aspects and impacts of it on the worldwide
scale. This has raised global concerns on several environmental aspects of
shipping and their consequences in terms of pollution control and environmental
resources management. Yet, the industry is standing on the horns of a dilemma:
on the one hand, the shipping shall take immediate and effective measures to
keep itself in the track of sustainable development. On the other hand, in the
current deteriorated markets, the expenses of environmental measures seem
like a hefty burden to the firms in the industry.
Among the critical aspects of the shipping industry, Ballast Water Management
(BWM) has proved to have significant impacts on ecosystems, food chains
and people’s way of life. It is estimated that the merchant shipping transfers
3-5 billion tons (equivalent to 3-5 trillion liters) of ballast water throughout
the world annually. Ships are largely dependent on ballast water and they are
designed to carry huge amounts of ballast water. The following table provides
the ballast water capacity of various types of ships as a percentage of their
DWT.

Payam Darya Volume.5 / Summer 2017

The ballast water is a key element in keeping the ship’s stability and
seaworthiness. The Ballast waterfunction is most important in cargo loading
and unloading operations in ports where the ship’s stability is maintained by
deballasting and ballasting. These operations are also practiced for navigating
in shallow water areas, raising the vessel’s bow for sailing in storms, trimming
the stern to balance the fuel consumption enroute , lowering the airdraft of
vessel in certain operations, and minimizing hull tensions.
In terms of biosecurity, the ballast water in maritime transport can act as
a vector for conveying Harmful Aquatic Organisms and Pathogens (HAOPs)
from one part of the world to the other parts. The HAOPs include pathogens,
planktons, algae, eggs, larva, or other organisms that if introduced to the marine
environment or the fresh water resources can hazard human health, property,
environment, biodiversity, or other legitimate use of such areas. HAOPs come 41
 Ar ticle

in large quantities and variety in the ballast water and can contribute towards
loss of marine species, harms to the food resources of human or marine species,
and health risks for human from contamination of water to food chains.

-
Among the historically environmental disasters caused by HAOPs we can
point to:
• Outbreak of golden mussels in South America and its devastating
effects on fisheries (since 1990s);
• Spread of Mnemiopsis leidyi (comb jelly) in the Black Sea Azov,
Marmara and Eastern Mediterranean and its contagion to the Caspian Sea
and its tragic effects on marine ecosystems and fisheries ( since 1982);
• Release of Vibrio cholera from Ballast water to drinking water
resources in Peru that was accompanied by an epidemy of cholera that
infected one million people and killed 10,000 people (1991);
• Deterioration of food webs by spread of Zebra mussel in Great Lakes
( since 1980s).
Payam Darya Volume.5 / Summer 2017

The containment of ballast water risks has been a significant issue at the
international level for decades and a great number of legal instruments and
initiatives have been developed to address it, including:
 The Convention on Biological Diversity (CBD) has been adopted and
practiced by UNEP members since 1992 to address the protection of
biodiversity in ecosystems. In 1995, the contracting parties to CBD
also adopted the “Jakarta Mandate on Marine and Coastal Biological
Diversity” which included the introduction of alien species as a thematic
issue.
 IMO has raised the issue since 1973, the year of adoption of MARPOL
convention, by pointing to the potential presence of pathogens in the
ballast water in her resolution and requesting the joint study of WHO and
IMO on the issue.
 Later in early 1990s, IMO organized a Ballast Water Working Group
under the Marine Environment Protection Committee (MEPC) that has
42
 been continuously working to address the issue effectively. In 1991, the
working group published Guidelines for Preventing the Introduction of
Unwanted Organisms and Pathogens from Ship’s Ballast Waters and
Sediment Discharges, and updated it in 1993. In 1997, it published the
‘Guidelines for Control and Management of Ships’ Ballast Water to
Minimize the Transfer of Harmful Aquatic Organisms and Pathogens
(Resolution A.868(20)).
 Following her work on the issue, IMO prepared the Ballast Water
Management (BWM) convention, which was adopted in February 2004.
Further, IMO adopted over 15 sets of guidelines and other documents
contained in its Marine Environmental Protection Committee (MEPC)
resolutions and circulars.
 IMO also participated in launching the GloBallast initiative with
Global Environmental Facility (GEF), and UN Development Program
(UNDP) in 2000. The Globallast program has acted towards making
a global momentum in implementing IMO ballast water guidelines,
reducing the transfer of HAOPs in ships’ ballast water, and preparing for
implementation of BWM convention in the past 17 years.
Ballast Water Management Convention
After decades of international concern and follow-up of ballast water issues,
the Ballast Water Management Convention will eventually come into effect in
September 2017. This convention that enjoys the accession of 58 parties and
involvement of more than 35 percent of the global merchant shipping tonnage,
requires all ships of 400 gross tonnage and above (including existing ships,
except floating platforms, FSUs and FPSOs) to possess International Ballast
Water Management Certificate (IBWMC). This is an important milestone in
terms of global biosecurity.

Payam Darya Volume.5 / Summer 2017

As a groundbreaking legal instrument, the BWM convention involves the

interplay of coastal states, the port states and the flag states in their regulation
on the Ballast Water issue. It is expected that the synergistic resultant of
such regulation and enforcements can drive the merchant shipping towards
mitigating the adverse impacts of ballasting throughout the world.
Ballast Water Management Convention (2004) structure
Sources: IMO (2005), Lloyd’s Register (2014),American Bureau of Shipping
(2017)
43
44
Payam Darya Volume.5 / Summer 2017
Ar ticle
 Compliance with the BWM convention is emerging as a basic requirement
for the owners and operators of ships around the world. The Ballast Water
Management process depends heavily on ship type, trade pattern, operation
systems, and technology and may differ significantly from one ship to another.
In this sense, the ship owners should work closely with ship operators, ship
designers and builders to develop an efficient and effective BWM system in
the ship.

In order to prepare for compliance with BWM convention, each ship requires:
 Outlining the ship’s obligations under the Ballast Water Management
Convention
 Review of the existing Shipboard BWM arrangements
 Development of the ship’s Ballast Water Management Plan (BWMP)
 Assigning a Ballast Water Management officer
 Selection and installation of a Ballast Water Treatment System
 Developing an efficient training program for the ship’s staff
 Development of final BWMP
 Submission for survey and certification
The BWM convention requires each ship to develop and maintain a Ballast
Water Management Plan. The BWMP explains the needed actions to implement
the BWM convention requirements in detail, and elaborates the resources,
responsibilities and timings of such actions in terms of procedures. BWMP
needs to be documented for each ship and approved by the administration and
submitted for the surveys of the flag state or competent classification societies.
The document will be used as the main reference in the surveys of the ballast
water management system. The BWMP document should include:
 Ship particulars
 Record of circulation
 Record of Amendments
Payam Darya Volume.5 / Summer 2017
 Purpose of the Plan
 Plans and drawings of the ballast system
 Description of the ballast system
 Ballast water sampling points
 Operation of the ballast water management system
 Safety procedures for the ship and the crew
 Operational or safety restrictions
 Description of the methods used on board for ballast water
management and sediment control
 Procedures for the disposal of sediments
 Methods of communication
 Duties of the Ballast Water Management Officer
 Recording Requirements
 Crew training and familiarization
 Exemptions
45
 Ar ticle

The flag state or a competent classification society surveys the equipment,

procedures, documents and practice of Ballast Water Management for
compliance with BWM convention and in case of acceptable conformity, the
flag state will provide the ship with an International Ballast Water Management
Certificate (IBWMC) or a Certificate of Compliance. The BWM convention
requires that BWMP, BWM record book, and IBMWC (or a certificate of
compliance where the flag state has not ratified the convention) to be always
available aboard the ship.
In order to practice the BWMP in compliance with the BWM convention,
the following steps shall be implemented by reliance of the former planning:
 Identifying and appointing the Ballast Water Management Officer
 Training the staff on the Ballast Water Management practice due to the
BWMP
 Full implementations of all BWM procedures according to the ship’s BWMP
and ensuring the compliance with BWM convention in the discharge of ballast and
sediments.
 Keeping the BWM record book up to date
 Operations and maintenance of BWM equipment according to the
manufacturer’s recommendation
 Monitoring the performance of the BWM system aboard the ships
 Reviewing the BWMP by considering the performance, the emerging
requirements (e.g. for sailing in a new shipping route), corrective and preventive
actions, the results of surveys, and the recommendations for improvement.
 Ensuring that the surveys are kept in place in terms of the commensurate
timing.
Although some solutions like Port Reception Facilities and Return-to-Origin
of ballast water are also considered, Ballast Water Management is mainly
underpinned on practice of two sets of IMO standards, namely D1 standards
for Ballast Water Exchange (BWE), and the D2 standards for Ballast Water
Performance. These general standards provide the basis for developing the
ship-specific Ballast Water Management Plan (BWMP) for most of the ships.
According to Regulation B-3 in BWM Convention, all ships are required to
Payam Darya Volume.5 / Summer 2017

meet the IMO-D2 standard on ballast water performance standard. Yet, as the
ballast water exchange will be maintained in the industry, IMO-D1 standard
will apply to it.
Up to the date (May 2017), Ballast Water Exchange between the coastal origins
and open waters in oceans and seas has been the most implemented BWM
method. It is assumed that the oceanic environment is inhospitable for species
that live in the coastal, estuarine, and fresh water environments and the distance
between them will not allow the HAOPs to travel back to such similar places.
In this sense, IMO-D1 standard requires the ships to conduct BWE at least 200
nautical miles from the nearest land and in water at least 200 meters in depth
(open oceanic waters). According to the standard, the ballast water exchange
can be performed in three ways:
• Sequential Flow Method – This method involves sequential discharge of
each ballast tank (to the most possible pumping level) and filling it with oceanic
water until 95% exchange of its content is achieved. This is the most widely used
46
method in the industry as it takes less time to perform. It can utilize existing pumps
and piping systems on the vessel and the operations does not interfere with works on
deck. It also does not affect the vessel’s cargo. However the method has navigational
and stability restrictions that cannot be overlooked.
• Flow-through Method - In this method, the ship in the exchange point pumps
volumes of new water into the tank from the bottom to generate an overflow of the
ballast content from the top of it. The 95% ballast water content exchange is expected
to be achieved by pumping 3-times of volume of the tank into it. Although this method
has advantages in maintaining the ship stability and strength which is especially
useful in adverse weather conditions, it takes much time and need painstaking control
to protect the tank structure, the deck structure, and the vessel’s cargo. It can also be
problematic in low temperature conditions.
• Dilution Method - The dilution method is the least used method in which new
water is pumped into the ballast tank from above while the tank content is emptied
from its bottom. Likewise, it is assumed that the 95% ballast water content is achieved
by pumping 3-times of the volume of the tank into it. In addition to the advantages of
the flow-through method, this level raises the BWE efficiency and enhances sediment
control. It also eliminates the risks of exposing the crew to HAOPs. However, the
overpressurization in the tank can harm the tank structure. Any changes in the filling
level of the tank can risk the ship stability, and specifically the failure of the filling
pump can be troublesome.

As a BWM alternative, ballast water exchange has many restrictions as:

 The time spent in permitted exchange (in oceanic waters) may not be sufficient
for the complete deballasting and ballasting cycle. This is particularly true in
the shortsea shipping, and in the liner shipping where the ship calls at many
ports on her route. Payam Darya Volume.5 / Summer 2017
 The loading and discharge of the ballast occurs in the dynamic sailing
conditions where the ballast exchange can influence the stability and
structural strength of the ship.
From 8th September 2017, compliance with IMO-D1 standard will be
mandatory for ships unless the ship install and operate the Balance Water
Treatment (BWT) systems onboard or use an alternative method for compliance
with BWM convention requirements.
Ballast Water Treatment
Considering the restrictions of Ballast Water Exchange and other alternative
BWM methods, Ballast Water Treatment onboard the ship seems to be the
most efficient BWM solution. The BWM Convention is obligating all ships to
comply with the IMO-D2 standards and equip with Ballast Water Treatment
systems in the following order:
• The IMO-D2 standard becomes mandatory for all existing vessels
after the first IOPP renewal date following the entry into force date. 47
 Ar ticle

• Vessels keel-laid or underwent major conversion after the entry into

force date shall comply with the regulation IMO-D2 upon delivery.
According to this standard, the ballast water in ship shall be treated in an
environmentally sound way, so that the following concentrations may not
exceed in the discharged ballast water:
 less than 10 viable organisms per cubic meter, greater than or equal to 50
micrometres in minimum dimension
 less than 10 viable organisms per milliliter, less than 50 micrometres
in minimum dimension and greater than or equal to 10 micrometres in minimum
dimension;
IMO-D2 also states that the indicator microbes shall not exceed the specified
concentrations as below:
 Toxicogenic Vibrio cholerae (O1 and O139) with less than 1 colony forming
unit (cfu) per 100 millilitres or less than 1 cfu per 1 gram (wet weight) zooplankton
samples;
 Escherichia coli less than 250 cfu per 100 millilitres;
 Intestinal Enterococci less than 100 cfu per 100 millilitres.
Payam Darya Volume.5 / Summer 2017

Typical arrangement of Ballast Water Treatment System in a ship

As shown in the above figure the Ballast Water Treatment is fitted to the ballast
tanks and pipings aboard the ship. Several processes, mechanisms and systems
have been proposed for ballast water treatment, many of which have been
approved and made available in the market. The BWT systems are generally
categorized by the types of treatment processes and incorporated technologies
in them. These include mechanical and chemical separation of solid particles
and organisms from water, and chemical or physical disinfection of it. The
following table gives a list of the BWT processes and a brief description
for each of them. Most of commercialized Ballast Water Treatment systems
incorporate a combination of both separation and disinfection processes. BWT
48 systems are tested and examined by IMO protocols (Guidelines G8 and G9), and
 Payam Darya Volume.5 / Summer 2017

49
 Ar ticle

IMO has published an extensive list of the approved BWT systems, including
56 basic approvals for systems including active substances, 41 final approvals
for systems including active substances, and 69 type approval certifications
for BWT systems.
According to data published by Lloyd’s Register(2017), among all approved
and certified systems in IMO’s list, 25 products have established 95.11% of
sales in the marketplace (which included the selling of 10631 BWT systems
to ships around the world) . As indicated in the following chart, ten ballast
water treatment processes have been incorporated in the most purchased BWT
systems. 83% of the sold systems use mechanical separation processes and
only 13.7% of them did not incorporate such processes. Also 77% of the sold
BWT systems utilized chemical disinfection processes and 68.2% of them
used physical disinfection processes.
Payam Darya Volume.5 / Summer 2017

50
Selection of Ballast Water Treatment System
The selection and specification of the appropriate ballast treatment systems
is a very important decision for the shipping business: it is a technically
sophisticated, financially burdensome, and strategically critical to sustain the
business in the coming years. In making such a decision, a number of interacting
cost factors, ship-specific parameters, and ballast system considerations shall
be concerned collectively and systematically to equip the ship with optimum
ballast water treatment system.

As far as technology is concerned, filtration, Ultra Violet, and electrolysis/

electrochlorination are estimated to be the least expensive BWT processes.
Accordingly, these are also the most used BTW processes, respectively with
79.3%, 49%, and 35% shares in the most purchased BWT systems.

Payam Darya Volume.5 / Summer 2017

51
 Ar ticle

The following table provides a list of most-purchased Ballast Water Treatment

on a worldwide scale and their specifications.

Key role-players in the conduct of BWM Convention

The BWM convention is expected to have significant impacts on the shipping
industry. According to a scheme by King,D.M. et al (which is enhanced by the
author), there are twelve stakeholders with key roles in the implementation
of BWM convention. Let us review the impact of BWM convention on each
of them:
 International Maritime Organization (IMO) – Entry into force of BWM
convention is an achievement for IMO. After two decades of work, the endeavors of
IMO has led to international acknowledgement and enforcement of environmental
control against HAOPs. Yet, IMO shall still encounter extensive pressures against the
intended changes. Such pressures can come from ship owners and operators, trade
associations, flag states, non-member states, etc. One instance is the request of some
flag states that are requesting for delays in entry into force of IMO-D2 standards,
an issue that is expected to be discussed and concluded in MEPC in July 2017.
Moreover discrepancies between the requirements of some national authorities (e.g.
US Coast Guard) and IMO, and the practical obscurities in this sense has brought
some encumbrances to practical conduct of BWM convention.
 Flag States –The BWM convention practice is founded and supported
by the accession of 58 flag states ( as reported in May 2017). The flag states certify
Payam Darya Volume.5 / Summer 2017

the type approval of BWT systems that can be used aboard ships. Flag states are also
the main institutional actors in terms of the surveys and certifications in the BWM
context: they issue the International Ballast Water Management Certificate (IBWMC)
for the ship that is required to be permanently available onboard along with BWMP
and ballast water management record book. The flag states act as the protectors of
the benefits of their registered fleet and this can be reckoned as considerable issue,
specifically in case of those that function as flag of convenience. Some flag states (i.e.
China, Greece, Brazil, Liberia, Norway, UK, India, and Cook Island) have requested
for a two-year delay in the implementation of IMO-D2 standard. A number of them
(e.g. Marshal Islands) will permit early IOPP survey renewal (before September
2017) for ships under their registry to provide an opportunity for a five year delay for
compliance with IMO-D2 for their registered ships. In many cases, this will need a
decoupling of IOPP survey from the other ship surveys as outlined by the Harmonized
System of Survey and Certification. This may lead to preference of such flag states by
the ship owners over others.
52
 Payam Darya Volume.5 / Summer 2017

53
 Ar ticle

 Port States – By Adoption of Resolution MEPC.252(67)in IMO, the port

states are requested to inspect the entering ships under the BWM convention. The
inspection includes the verification of the IBWM certificate or statement, checkup
of the BWM record book, and the sampling of ballast water due to IMO regulations.
Some port states (e.g. US ports) may implement more strict controls in terms of their
national regulations. The reported incompliances may cause more strict inspections,
warnings, prohibition from the ship’s entry or stay in the port , and requiring the
ship to exchange her ballast water in oceanic waters or in other safe facilities, or
requiring it to undertake any needed repair according to the BWMP. After a 3-years
Payam Darya Volume.5 / Summer 2017

trial implementation of the port states’ controls, the port states can also detain high-
risk ships, and apply criminal sanctions against the noncomplying ships. Moreover,
the results of the port states inspections are critical to the ship owners and the flag
states as the resultant of them will present the positioning of the ship and the flag
in the white, black and grey lists reported to IMO. Port state procedures may also
conflict with some flag states on issues like the decoupling of IOPP from SS surveys.
 The Ship Owners and Operators – The ship owners and operators who are
experiencing the pits of their businesses, will have to afford the costs of buying,
installation/retrofit, operations, and maintenance of Ballast Water Management
systems. . A BWM system can cost between five hundred thousand to five million US
dollars. It is estimated that by entry of BWM convention into force, around 50,000
vessels around the world are obligated to have such systems onboard by 2020,and
according to ICS the total incurred costs in the industry can reach 100-billion USD.
This is occurring in a market where:
• Within the 2030 horizon, the average long-term seaborne trade volume
54
 growth is forecasted to be as low as 1 percent per year.
• The supply of shipping is outpacing the demand. Between 15 to 20
percent of the capacity of shipping fleets in the global level are idle,
and the potentials for the improvement of utilization rates is low.
• The freight rates are faintly rising from their historic bottom levels in
2016.
• The economic lifetime and the asset value of ships are declining.
• A general rise in the fuel prices is expected, with some other rises
coming from air pollution control regulations ( one report estimating
up to US$60 billion of additional costs for the industry from 2020 in
terms of Sulphur cap requirements).
• The shipping revenues have experienced a freefall in comparison to
the 2000s, when the BWM convention was adopted (see the chart
below).
In other words, the BWM convention is entering into force when the shipping industry
is in her worst shape. This can accelerate undesirable trends like increases in early
ship demolition or filing for insolvency among the ship owners and operators.
 Masters – The shipmasters play a critical role in the implementation of
BWM convention. Acting as the commander of a ship, master is the one who is
practically in charge of operating the ballasting operations inline with other functions
of the ship. The masters are responsible for organizing and resource mobilization
for compliance with BWM convention requirements in the BWMP, briefing (and
possibly training) the staff and crew, regulating the conduct of ballasting procedures,
deciding over operations affecting ship structural strength or stability, validating the
BWMT systems functional effectiveness, verifying and undersigning the records of
BWM, and many more. In other words, due compliance of the BWM convention’s
requirement totally depends on the masters’ attitudes, behaviors, and actions.

Payam Darya Volume.5 / Summer 2017

55
 Ar ticle

 National Regulatory Bodies – as mentioned, the BWM convention enjoys

the accession and support of 58 states and IMO is inviting other states to ratify it.
Moreover, transnational regulatory bodies are calling the states to ratification and
compliance with this convention and other environmental management instruments.
For instance in Regulation (EU) No 1143/2014, the European Parliament and Council
invite the states to ratify the BWM convention and comply with it. In other parts of
the world, some national regulatory bodies are demanding compliance with differ-
ent requirements in terms of national regulations. One good instance is the US Coast
Guards regulations. There are several discrepancies between the conducts of BWM
convention and USCG/EPA ballast water management including the pre-arrival re-
port, methods of ballast water sampling, self-monitoring of BWM performance by
the ship in terms of Vessel General Permit (VGP), requirement of Alternate Manage-
ment System (AMS)’s certificate with temporary approvals from USCG for the com-
ing five years, and the provided list of type approvals for the ships entering into US
ports. This has raised the obscurities around the selection and installation of ballast
water treatment systems for the ship owners.
 Classification Socieities- as the main implementers of surveys and
inspections, classification societies act mainly as the arms of the flag states. As they
are directly and practically involved in the surveys and inspections, their performance
has significant effects on regulation and compliance levels in the field. Moreover their
extensive knowledge and experience can be seen as a rich resource for innovation in
the BWM convention context.
 Charterers and Cargo Owners- Entry into force of the BWM convention
also affects the charterers and cargo owners as the major customers of the freight
industry. Due to the recorded figures of purchased ballast water treatment systems
at the date of BWM convention’s entry into force, a great number of ships have not
been equipped according to the IMO-D2 standards. Accordingly, many ships cannot
comply with the convention’s requirements and will not be eligible for calling at a
great number of ports. This can affect the supply of the ships, and the chartering
and freight rate in many shipping routes. However according to the current trends
in the industry, compliance with BWM convention cannot be seen as a long term
competitive advantage in the freight industry and it is rather considered as a basic
characteristic of fungible vessels in the future of shipping.
Payam Darya Volume.5 / Summer 2017

 P&I Clubs and other Marine Insurances – The BWM convention will
bring a new set of requirements into force, and noncompliance with it will incur
fines and penalties to ship owners and ship operators. The P&I Clubs will be
reluctant to indemnify such losses as it opposes their intents for mutual benefit and
risk minimization. P&Is will also see such noncompliances as bad records for the
newly joining members and the existing members. Therefore we can expect that
P&Is contribute towards enhancement of the worldwide compliance with the BWM
convention. The marine insurances will also act in the same direction.
 Trade Associations – The shipping associations (ICS, WSC, BIMCO,
INTERTANKO, etc.) are generally trying to act as the voice of ship owners and
operators in the international level. Nearly all of them support the purpose of the
convention, and yet they are trying to alleviate the harsh existing conditions for their
members. Indeed, they sound to be more realistic than governments, and international
regulatory bodies. They are requesting for supports like two-year delay in IMO-D2
implementation scheme, adoption of a revised mandatory type approval code by
IMO, minimal effects of ballast samplings on ship operations in ports, acceptance of
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first generation of IMO-type approved BWMS in ports, cost-neutrality of tests and
inspections of ports and national authorities on ships, etc. In addition, such associations
can function as sources of consultancy, boosters of research and development, and
organizers of Communities of Practice for implementation of BWM convention.
 Shipyards and BWMS manufacturers- The entry into force of BWM
convention has developed a very large demand and a lucrative marketplace for
the BWMT systems. Due to the hard financial conditions of the ship owners and
operators and the uncertainties in selection of the type approved BWMT, only one-
fifth of the fleet has been equipped with the needed IMO-D2 systems. On the other
side most of the available BWT systems are technologically novel and practical use
of them may require enhancements in them. The resultant demands for installation
and/or improvements of BWT systems in 40,000 ships (and 10.6 thousand formerly
equipped vessels) within the coming five years will also entail a jam in the shipyards.
Although shipbuilding activities have slowed down considerably in the past two
years, many shipyards have been closed. Such work peaks can congest the shipyards
with a following lag in the entire maritime transport pipeline.
Payam Darya Volume.5 / Summer 2017
 Professional Initiatives – Within the past years, a number of global initiatives
have been developed to boost the implementation of BWM convention. The most
renowned initiative is Globallast that has been in place from early 2000s. Such
initiatives can be utilized to serve the implementation schemes in many ways including
knowledge and information exchange, training, online access to compliance records,
knowledge leverages, and many other functions.
According to the depicted roles of these interacting stakeholders, along with the
targeted improvement of the merchant shipping’s environmental impacts, the
requirements of the BWM convention can lead the industry to grave problems
in near future. In this sense, the entry into force of the BWM convention is a
great challenge for the shipping industry.

The Impacts of BWM Convention on the Shipping Industry

The entry into force of the BWM convention is an undoubted milestone
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 Ar ticle

in terms of the management of environmental impacts of merchant shipping.

We mentioned that merchant ships transfer 3-5 billion cubic meters of ballast
water around the world. The historical evidences plainly show that ballast
water can be the vector for conveyance of invasive organisms from one part
of the world to the other parts. Such species have the capacity to harm the
ecosystems, economy, and human health.
However, this big change is happening in hard times of the industry that are
characterized by weak demand, high oversupply, freefall of freight and charter
rates, reduction of asset values and their economic life, reluctant financiers
and investors, and emaciating businesses and firms. While the ship owners
and operators are under severe pressures, the requirements of environmental
protection are building a new gradient of costs and restrictions in the industry
level that will trigger a negative cycle:
a) It is estimated that the installation of Ballast Water Treatment systems will
incur a total cost of 100-billion USD in the industry level;
b) Most ship owners and operators are suffering indecision in selection of
BWT systems as a matter of existing obscurities;
c) Many of the BWT systems are based on novel technologies and may need
enhancements in the practical use;
d) The accumulated number of installations needed in the global fleet is many
times more than the available shipyard capacity;
e) If the ships do not succeed in equipping themselves with BWT systems,
they will have to suffer the consequences of non-compliance with the BWM
convention in the months ahead;
f) And eventually the shipping lines shall endure the equally heavy costs and
restriction of other forthcoming environmental management conventions in
the same period.
The mentioned negative cycle will plainly act towards deteriorating the
shipping markets. It will strengthen a number of destructive trends including
increase of costs, hardening the cash flow management, harder entry of
many ships to many ports, reduction of revenues, diminishing profitability,
Payam Darya Volume.5 / Summer 2017

and adding restrictions into the industry’s business environment. It will also
contribute towards lessening of asset value of ships and reduction of their
economic lifetime, increase of early ship demolitions, development of a high-
risk and intimidating profile of shipping for financiers and investor, bringing
the ship owners and operators to the verge of financial crisis, and shifting
the market structure towards a more concentrated oligopoly. Considering the
critical role of shipping in the modern global economy, it is definitely the time
to ask whether these harms can be avoided?
Why should we haste into such an abysmal destruction of shipping? It is
time to slow down and pace thoughtfully to avoid the unnecessary harms. We
should tackle many issues before taking our other step: the type approval issues
shall be resolved to allow the ship owners to decide over the needed investment
in BWT systems. The BWT technologies must prove their effectiveness,
robustness and efficiency in practice. Adequate time shall be provided for the
ship owners to install the required BWT systems onboard their ships. Financial
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 facilitation should be made
available for the ship owners
to equip their vessels to the
required BWT systems. All of
these measures need time and
haste should be avoided in this
respect.
The recommendation of
a 2-year delay for entry into
force of BWM convention can
provide this needed time. By
resolving the critical issues
and providing the needed
incentives, IMO and the flag
states can encourage the ship
owners to implement the
IMO-D2 standard voluntarily
within the two-year interim
period and prepare for the
mandatory compliance in
the coming years. The meant
period will also provide the
industry with the time to
recuperate in terms of her
business cycle. In this case, the change can be worked out with minimum
harm to the industry and the environment. In this sense, the industry and the
environment will commonly benefit the conduct of Ballast Water Management
convention.

Final Words
The conduct of Ballast Water Management is a mission that shall be
accomplished in the merchant shipping. More than one-third of member- Payam Darya Volume.5 / Summer 2017
states in IMO have supported the conduct of this convention that serves the
biosecurity in a global level. This is a valuable opportunity for shipping to
enhance her environmental performance in the global context.
Nevertheless, the BWM convention is coming into effect in the hard times
of shipping. Merchant shipping is currently in the trough parts of one of her
longest business cycles, and entry into force of the convention will increase
the level of costs, obscurities, encumbrances and difficulties in the business.
Yet, the relevant issues with the convention can be identified and overcome by
negotiations, planning, use of technologies, and most importantly development
of synergistic and supportive action in the industry level and beyond it.
In this sense, the world can act positively in a way that the conduct of
BWM convention is seen as a challenge rather than a problem for the shipping
industry. This attitude will serve the environment, the merchant shipping and
the global economy at the same time.
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