1. Ballast Water Management DEPUTY MANAGING DIRECTOR
Latin American Panel
October 31, 2012
Ballast Water Management
JOSEPH ANGELO
DEPUTY MANAGING DIRECTOR 1

2. Different regimes INTERTANKO Actions IMO Response
International
National/Regional
Local
INTERTANKO Actions
IMO Response 2

3. IMO Ballast Water Management Convention Adopted in 2004
INTERNATIONAL
IMO Ballast Water Management Convention
Adopted in 2004
Entry into force requires ratification by 30 countries, 35% world’s grt
Currently, 36 countries, 29.06% grt 3

4. BWM Plan and Record Book BWM System performance standard
INTERNATIONAL
BWM Plan and Record Book
BWM System performance standard
Compliance schedule to install BWMS
Survey and certification requirements
Port State Control procedures 4

5. NATIONAL – US Coast Guard Final regulations issued March 2012
Main requirements include:
BWM plan and record keeping;
BWM standard (same as IMO) with review in 4 years;
Compliance schedule (similar to IMO);
Acceptance of “Alternative”BWMS for years 5

6. Regulatory schedule - IMO Year of ship construction
Ballast capacity
Year of ship construction
Before 2009
2012+
> 5,000 m3
Ballast water exchange or treatment until 2016 Ballast water treatment only from 2016
Ballast water treatment only
Constructed
1,500 – 5,000 m3
Ballast water exchange or treatment until Ballast water treatment only from 2014
< ,1500 m3
Ballast water exchange or treatment until Ballast water treatment only from 2016
Erik, these are still just proposals and not legislation.
Enforcement 12 months after ratification i.e. - earliest October 2012 if ratified now - Installation at first Intermediate or Periodical Survey 6

7. Regulatory schedule - USCG
Implementation Schedule for Approved Ballast Water Management Methods
Vessel’s ballast water capacity (in cubic meters)
Date constructed
Vessel’s compliance date
New vessels
All
On or after Dec. 1, 2013
On Delivery
Existing vessels
Less than 1,500m3
Before Dec. 1, 2013
First scheduled drydocking after Jan. 1, 2016
1,500 – 5,000 m3
First scheduled drydocking after Jan. 1, 2014
Greater than 5,000m3
First scheduled dry-docking after Jan. 1, 2016
Erik, these are still just proposals and not legislation. 7

8. Vessel General Permit (VGP) Dec 2008 Main requirements include:
NATIONAL – US EPA
Vessel General Permit (VGP) Dec 2008
Main requirements include:
BWM plan and record keeping;
BWM exchange;
Allows states to impose additional requirements;
VGP required to be renewed in 5 years 8

9. LOCAL – New York and California
BWM standard that is 100x and 1000x greater than IMO
Considerable lobbying by industry coalition
EPA Science Advisory Board report – standard not possible with current BWM technology
Reason prevails, for the time being 9

10. BWM equipment not included in the Marine Equipment Directive (MED)
REGIONAL – EU
BWM equipment not included in the Marine Equipment Directive (MED)
EU is considering amending MED to bring in the equipment required by the BWM Convention as a mandatory standard
Legal amendments to MED to include BWM equipment is scheduled for October 2012
Possible “EU approval regime” could become reality in October 2013. 10

11. INTERTANKO Action The Key Challenges
Technical – treatment equipment and approval
Regulatory – BWM Convention implementation and its enforcement

12. Submission to IMO’s MEPC 64 (October 2012)
Policy background
ISTEC and Environmental Committee – March 2012
Details technical, operational and compliance challenges
Council – May 2012
Recommends comprehensive paper covering the challenges and proposing solutions be sent to IMO
Submission to IMO’s MEPC 64 (October 2012)
Jointly with Liberia, the Marshall Islands, Panama, BIMCO, CLIA, INTERCARGO, InterManager, IPTA, NACE and WSC - submitted August 2012

13. IMO MEPC 64 Submission Submission covers FOUR key areas:
Explains the challenges being faced for effective implementation of the BWM Convention and to provide proposals to address those challenges
Submission covers FOUR key areas:
Guidelines for approval of ballast water management systems (G8);
Availability of Ballast Water Management Systems (BWMS);
Survey and certification requirements
Procedures for port State control

14. 1. The need for revision of the Guidelines for approval of ballast water management systems (G8) to improve transparency and ensure appropriate robustness of Ballast water management systems (BWMS)
Greater transparency of information on the Type Approval Certificate and its enclosures
Total Rated Capacity, 60m3/hr tested but approved to 6000m3/hr
Type Approval process needs to more accurately reflect real-world environment aboard
Brackish and freshwater tests
High sediment waters
Proposals to strengthen Type Approval process
To ensure that a BWMS works in practice as well as theory
Reference MEPC 64/2/18 Paragraphs 5 to 11.

15. 2. The availability of BWMS and sufficient facilities to install BWMS
As the BWM Convention dates are progressively surpassed the number of ships to which the requirements apply 12 months after full ratification continually increases
Ship yards and BWMS manufacturers coming under increasing pressure to install systems within the time frame (implementation schedule)
Recommend discussion of ‘new’ BWMS installation dates
BWM Convention cannot legally be amended until convention enters into force
Problem was recognized in 2007 when limited technologies were available to meet first implementation date of 2009
IMO Assembly adopted resolution recommending acceptance by parties of delayed installation date
Reference MEPC 64/2/18 Paragraphs 13 and the Japanese submission from which this table is taken.

16. Current Estimated Installation Schedule Dates
2009
2010
2011
2012
2013
2014
2015
2016
2017
2018
2019
2020
Newly constructed Vessels (less than 5,000 cubic metres)
1,740
Newly constructed Vessels (greater than 5,000 cubic metres)
1,690
Existing Vessels (between 1,500 and 5,000 cubic metres)
2,500
Existing Vessels (less than 1,500 or greater than 5,000 cubic metres)
8,800
Vessels constructed from 2009 to 2011 (greater than 5,000 cubic metres)
TOTAL
3,430
5,930
16,420
13,920
Reference MEPC 64/2/18 Paragraphs 13 and the Japanese submission from which this table is taken.
MEPC 61/2/17 by Japan

17. 3. Survey and certification requirements for ships constructed prior to entry into force of the BWM Convention
No phase-in period for survey and certification of ships following entry into force
ROs required to review and approve BWM Plans as well as survey and certify ships within 12 month period
Solution provided at MEPC 63 – commence issuance of BWM Certificates prior to entry into force
Proposal to issue circular in this respect to increase awareness through industry and maintain uniform implementation
Reference MEPC 64/2/18 Paragraphs 18 to 20.

18. 4. Sampling and analysis procedures for port State control purposes
Urge harmonised standard operating procedure for sampling and analysis of ballast water by PSC.
Coupling of Type Approval process with the enforcement process
Currently the Type Approval process is separate from the PSC process so an approved BWMS may not meet the PSC analysis once installed on board.
Uncertainty in the PSC sampling and analysis process key impediment to further ratification
Reference MEPC 64/2/18 Paragraphs 21 to 23.

19. OUTCOME OF MEPC 64
Revision of the G8 Guidelines
Decided not to amend the G8 guidelines (at this time), BUT agreed to develop additional guidelines on the application of the G8 guidelines which to address the issues raised in our submission
2. Availability of BWMS
Established as correspondence group (lead by Japan) to develop an Assembly resolution regarding the implementation of Regulation B-3

20. OUTCOME OF MEPC 64
Survey and certification requirements
Agreed with our proposal to issue an MEPC Circular
Sampling and analysis procedures for PSC
Agreed with our proposal to instruct BLG (and FSI) Subcommittee that sampling and analysis procedures for PSC should be no more stringent than what is required for type approval of BWMS

21. Summary
“Positive” developments at MEPC 64, but more work needs to be done
Members learning on a day-by-day basis
Sharing of experience and information between members essential
Does the BWMS work?
Does it work as it was approved to work?
Does it meet the discharge standards?
Propose amendments to IMO’s BWM Guidelines based upon experience gained, while supporting their international and uniform approach
Concluding remarks
INTERTANKO, from the outset, has been committed to a global system of regulation and one that provides for the practical realities of ships trading in various biological and physical environments.
The issues raised in this paper have been brought together to illustrate the challenges the tanker industry is facing in meeting the forthcoming requirements of the IMO’s BWMC.
INTERTANKO’s members have undertaken extensive research that accounts for most of the details and information in this paper. Some owners have gone as far as installing systems on new buildings while others are signing contracts for installation on ships that begin construction in the near future. However, the vast majority of the membership of INTERTANKO is still undecided about the correct option for their vessels. Furthermore, the experience of and assessment undertaken by INTERTANKO’s members is very much limited to the installation of systems on new buildings. The installation of systems on existing vessels is largely considered to be technically, operationally and commercially unfeasible at this point in time.

22. Ballast Water Guidance
Finding, installing and operating systems on tankers?

23. Ballast Water Guidance
To assist members during selection, assessment and installation for existing and new built vessels:
INTERTANKO Guidance on the Selection and Installation of Ballast Water Management Systems for Tankers
Physical Installation
Pumping
Control – system approval and certification
Treatment type
Operating practicalities
Released January 2012

24. Thank you! www.intertanko.com Concluding remarks
INTERTANKO, from the outset, has been committed to a global system of regulation and one that provides for the practical realities of ships trading in various biological and physical environments.
The issues raised in this paper have been brought together to illustrate the challenges the tanker industry is facing in meeting the forthcoming requirements of the IMO’s BWMC.
INTERTANKO’s members have undertaken extensive research that accounts for most of the details and information in this paper. Some owners have gone as far as installing systems on new buildings while others are signing contracts for installation on ships that begin construction in the near future. However, the vast majority of the membership of INTERTANKO is still undecided about the correct option for their vessels. Furthermore, the experience of and assessment undertaken by INTERTANKO’s members is very much limited to the installation of systems on new buildings. The installation of systems on existing vessels is largely considered to be technically, operationally and commercially unfeasible at this point in time.