Ballast Water Record Book
Following the entry into force of the International Convention for the Control and Management of Ships' Ballast Water and Sediments, 2004 on 8 September 2017, all ocean-going ships have been required to record ballast operations in a ballast water record book (BWRB), a requirement under regulation B-2 of the Convention. Appendix II of the Convention (Form of Ballast Water Record Book) specifies the ballast operations that should be recorded, as a minimum, in the BWRB.
The correct and accurate completion of the BWRB by ships' crews is a critical step in the compliance process. The criticality of ensuring that entries in the BWRB are correct is equally relevant for those on board as well as those inspecting and auditing the ship for regulatory compliance purposes.
INTERTANKO Members have encountered differing interpretations by Administrations, port State Authorities, Class Societies and third-party auditors and inspectors when examining ballast water activities that are to be recorded in the BWRB.
INTERTANKO notes the ambiguity associated with the "code" that should be used to record entries in the BWRB as offered in paragraphs 3.1 to 3.6 of appendix II to the Convention. However, unlike the coding system used with the Oil Record Book for MARPOL Annex I, the BWRB does not strictly follow a coding system. The "code", as interpreted by the majority of owners and Administrations, is based on the numbering in paragraph 3 of appendix II to the annex to the BWM Convention.
Based on the experience gained and information gathered from Members, INTERTANKO is requesting for the International Maritime Organization (IMO)’s Marine Environment Protection Committee (MEPC) to include a review of appendix II to the Convention focusing on the following areas:
- identify any areas where the evidence demonstrates a need for an improvement of the Convention in light of experience gained (Article 2.5 of the Convention) with the BWRB and whether any such improvements may be included in the package of amendments following the conclusion of the ballast water experience-building phase (EBP); and
- consider whether additional guidance on entries in the BWRB is necessary. Such guidance exists for entries in the Oil Record Book (ORB) Part 1 (MEPC.1/Circ.736/Rev.2) and is widely used by those on board and the relevant inspection authorities.
The EBP includes a systematic and evidence-based process for reviewing and improving the Convention in order to ensure that any amendments to the Convention are developed holistically through an objective, transparent and inclusive approach.
INTERTANKO has submitted INTERTANKO’s commentary on entries on in the ballast water record book, reflecting the questions and feedback from INTERTANKO's Members as well as feedback from several Flag Administrations and port State authorities consulted by INTERTANKO in relation to BWRB entries, to the MEPC for their consideration.