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.


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.


Sampling and analysis are to be carried out in accordance with BWM.2/Circ.42/Rev.2 (G2 Guidelines).

Asbestos Removal

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.

Ships concerned:

  • EU flagged internationally trading ships ≥ 500 GT;
  • Non-EU flagged internationally trading ships ≥ 500 GT, when calling EU ports / anchorages.

Preparation of Inventory of Hazardous Materials Part I has the following five steps:

Collection of HM information

The information collected from: certificates, manuals, ship's plans drawings, technical specifications and information from sister ships. The information is collected by the HazMat Expert and required ship owner assistance.

Assessment of collected information

Collected data is assessed by HazMat Expert, in order to identify every item (equipment, systems or areas) suspected to contain Hazardous Materials, based on the indicative list shown in IMO resolution MEPC.269(68). Every item on board (equipment, system, and/or area) is classified accordingly “contained”, “not contained”, “unknown”.

Preparation of Visual/Sampling Check Plan

A checking plan is prepared by HazMat Expert to determine that every item (equipment, system and/or area) of the previous step is checked visually or by sampling, depending on its classification.

Onboard Visual/Sampling Check

Onboard Visual Check and onboard Sampling Check is conducted by our duly qualified HazMat Experts and the results are recorded in “checklist”. The samples are sent to approved laboratory for analysis.

Preparation of IHM and related documentation

When the analysis of all samples is completed and all the items onboard containing Hazardous Materials are identified, approximate quantities of them are estimated by the HazMat Expert. Based on all above information an Inventory of Hazardous Materials Part I, complying with EU SRR requirements is prepared by our HazMat Expert.

• Survey & Certification

To obtain EU hazardous materials certification, after the receiving of the IHM from Orient Chartering and Logistic Ltd, the ship owner has to approach a Classification Society for survey & certification. The ship owner could choose a Classification Society from the list of approved by Flag State Classification Societies. The Class Surveyor will perform consistency documentary check and onboard survey. After successful onboard survey Class Surveyor will issue on behalf of the Flag State the following certificates:

  • EU Inventory Certificate for new & existing EU flag ships;
  • Statement of Compliance for non-EU flag ships.

Contents of an IHM

A complete IHM consists of the following parts:

  • Part I: Materials contained in the ships structure (table A + B)
  • Part II: Operationally generated waste (table C)
  • Part III: Stores (table C+D)
  • Table A Materials listed in Annex 1
  • Table B Materials listed in Annex 2
  • Table C Potentially Hazardous items
  • Table D Regular consumable goods potentially containing hazardous materials