Commissioning Testing of Ballast Water Management Systems
Amendments to Regulation E-1 of the BWM Convention, adopted at MEPC 75 by resolution MEPC.325(75) require a commissioning test at the time of initial/additional survey upon installation of BWMS.
Commissioning test is to be conducted in accordance with 2020 Guidance for the commissioning testing of ballast water management systems (BWM.2/Circ.70/Rev.1), as may be amended.
The commissioning testing applies to any new installation of BWMS on or after 1 June 2022.
This test is required even if the system has been partially installed and/or commissioned before 1 June 2022.
The commissioning test is also mandatory for the additional commissioning survey required after a change, replacement or significant repair of the BWMS necessary to achieve full compliance with the D-2 standard.
IMO at MEPC 74 clarifies that “commissioning testing should not be applicable to ships that had already installed a BWMS and were certified for compliance with regulation D-2” (MEPC 74/18 para. 4.55)
The purpose of the commissioning testing is to validate the installation of a ballast water management system (BWMS) by demonstrating that its mechanical, physical, chemical and biological processes are working properly.
The commissioning testing is not intended to validate the design of type-approved BWMS that are approved by the Administration.
WHO PERFORMS IT?
Firms engaged in Commissioning Testing of Ballast Water Management Systems (BWMS), are to be approved by Classification Society, as per IACS UR Z17, Rev.16, effective from 1st January 2022.
The collection and analysis of the representative samples should be independent of the BWMS manufacturer or supplier and to the satisfaction of the flag administration.
HOW TO PERFORM IT?
Sampling and analysis are to be carried out in accordance with BWM.2/Circ.42/Rev.2 (G2 Guidelines).
Orient Chartering and Logistic Ltd. offers safe asbestos testing, removal, air sampling and waste collection & disposal services across the Black Sea coast. We are licensed to provide preparation of asbestos free certificates for the ships that were specified to contain asbestos in their IHM.
What is the correct course of actions, if asbestos is found on board ship?
Where the IHM reveals asbestos containing materials on board the correct course of action depends on whether or not the asbestos containing materials complies with IMO’s Safety of Life at Sea (SOLAS) Regulation II-1/3-5:
- Ships constructed before 1st July 2002 are permitted to have asbestos containing materials anywhere on board, provided that they do not pose a risk to crew health.
- Ships constructed between 1st July 2002 and 31st December 2010 are only permitted new installation of asbestos containing materials for specific purposes (insulation, joints and vanes).
- From 1st January 2011 new installations of asbestos containing materials anywhere on the ship are prohibited without exception, for all ship types.
When an Asbestos Management Plan is required?
If the asbestos containing materials was installed in compliance with the above requirements, then it is not necessary for it to be removed, provided that it is not damaged and does not pose a risk to health. In these instances, it is essential to create a comprehensive Asbestos Management Plan and put in place within 3 months of the asbestos being first identified. The asbestos containing materials should be managed and protected from damage. The crew should be made aware of the dangers of asbestos, its location and how to safely deal with asbestos, if disturbance of the asbestos containing materials cannot be avoided. Exemption from Flag State is not required.
When an Asbestos Removal is required?
If the asbestos containing materials was not installed in compliance with the above regulations it should be removed. The removal should be undertaken by a professional asbestos removal company (not crew) within a period of 3 years from the date that the contravention was discovered.
Owner/Operators have to present action plan for the management/removal of the asbestos containing materials to Flag State and Recognized Organization (Class Society). The Class Society should amend the Cargo Ship Safety Construction Certificate, stating that an exemption has been issued and the expiry date. Exemption from Flag State and is required.
What is the purpose of an additional asbestos survey?
The samples of the materials suspected of containing asbestos were taken for testing of hazardous content, based on random spot checks only. These samples were analyzed by an accredited laboratory. If asbestos has been determined within a specific system or at specific locations, similar findings can be expected at other, non-sampled locations. In such cases additional sampling will create a better overview of asbestos containing material presence at these locations.
When asbestos abatement methods as encapsulation or enclosure could be used?
When the SOLAS Regulation II-1/3-5 permits, damaged asbestos containing materials and/or that pose a risk to health can be encapsulated or enclosed, as less expensive asbestos abatement methods, than the asbestos removal.
Inventory of Hazardous Materials (IHM) Certification
- The aim of Hong Kong Convention and EU Ship Recycling Regulation (EU SRR) is to ensure safe and environmentally sound recycling by identification of materials present in a ship’s structure, systems and equipment, that may be hazardous to health or the environment.
- EU flagged internationally trading ships ≥ 500 GT;
- Non-EU flagged internationally trading ships ≥ 500 GT, when calling EU ports / anchorages.