American Club Circular No. 20/17 1 JULY 14, 2017 CIRCULAR NO. 20/17 TO MEMBERS OF THE ASSOCIATION Dear Member: INTERNATIONAL CONVENTION FOR THE CONTROL AND MANAGEMENT OF SHIPS' BALLAST WATER AND SEDIMENTS AND US BALLAST WATER MANAGEMENT (BWM) REGULATIONS Background Reference is made to Circular No. 01/17 of January 16, 2017 on the IMO’s International Convention for the Control and Management of Ships' Ballast Water and Sediments (the Convention) which will enter into force on September 8, 2017, and the US Coast Guard (USCG) regulations requiring the installation on most vessels operating in US waters of a BWM system which meets the USCG’s stricter testing standards at the first scheduled dry docking after January 1, 2016. On July 7, 2017, the 71 st session of the IMO’s Marine Environmental Protection Committee (MEPC) reached agreement on a revised implementation schedule for the installation of a BWM system under the Convention. The revised schedule effectively postpones by two years the compliance deadline for installing an approved BWM system for ships constructed before September 8, 2017. It is important to note that this has no effect on the compliance dates stipulated in the USCG regulations. IMO BWM Convention – revised implementation schedule Circular 01/17 of January 16, 2017 informed Members that, under the Convention, all ships in international trade are required to manage their ballast water and sediments to a certain standard, according to a ship-specific BWM plan. In addition, all ships are required to carry on board a ballast water record book and an international BWM certificate, with the current BWM standards being phased in over a period of time. The above Circular also informed Members that, eventually, most ships would need to install an onboard ballast water treatment system that meets the IMO’s standards by the date of a vessel’s first International Oil Pollution Prevention (IOPP) renewal survey after the Convention enters into force on September 8, 2017. The new, revised implementation schedule applies to approved BWM treatment systems and specifies the acceptable levels of viable organisms left in ballast water after treatment in accordance with the Convention’s D-2 Ballast Water Performance Standard. The revised implementation schedule (included in an amended Regulation B-3 1 of the Convention) now contains the following deadlines: 1 The specific requirements for ballast water treatment systems are contained in regulation B-3 (Ballast Water Management for Ships) of the Convention which provides that ballast water treatment systems used to comply with the Convention must be approved by the Flag Administration taking into account the Guidelines for approval of ballast water management systems (G8). Further information on these specific requirements can be found at: http://www.imo.org/en/About/Conventions/ListOfConventions/Pages/International-Conventionfor-the-Control-and-Management-of -Ships'-Ballast-Water-and-Sediments-(BWM).aspx American Club Circular No. 20/1 7 2 • Vessels constructed (keel laid) on or after September 8, 2017 should have a BWM system installed on delivery; and • The revised compliance date for existing vessels (keel laid before September 8, 2017) will depend on when the IOPP renewal survey occurs. The MEPC text has been agreed as follows: Existing vessels will have until: 10.1 The first [IOPP] renewal survey... following the date of entry into force of the BWMC if: .1 This survey is completed on