MANDATORY COMMISSIONING TESTING OF BALLAST WATER MANAGEMENT SYSTEMS (BWMS)

1. - Amendments to regulation E-1.1.1 and E-1.1.5 of BWM Convention – Entry into Force 1 June 2022 - Mandatory commissioning testing of BWMS installed on or after 1 June 2022

IMO MEPC 75 adopted the amendments to the BWMC (resolution of MEPC.325(75)) which introduce mandatory commissioning testing of BWMS at the initial survey for new ships and at an additional survey for new BWMS to be installed on existing ships.

The commissioning testing applies to any new installation(1) of BWMS on or after 1 June 2022.

(1) Refer to below IMO Unified Interpretation for the date to be used for determining the implementation of mandatory commissioning testing (BWM.2/Circ.66/Rev.2):
“Irrespective of new ships under construction subject to regulation E-1.1.1 or existing ships retrofitting ballast water management system(s) (BWMS) on board subject to regulation E-1.1.5, the commissioning testing of individual BWMS taking into account the guidelines developed by the Organization* should be conducted if the initial or additional survey is completed on or after 1 June 2022. If the initial or additional survey is completed before1 June 2022, the commissioning testing of individual BWMS remains subject to the specific requirements of the [Flag State] Administration(s).
*Refer to the 2020 Guidance for the commissioning testing of ballast water management systems (BWM.2/Circ.70/Rev.1), as amended.”

Note : 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)

2. 2020 Guidance for the commissioning testing of ballast water management systems (BWM.2/Circ.70/Rev.1)

The commissioning testing shall be performed taking into account the 2020 Guidance for the commissioning testing of ballast water management systems (BWM.2/Circ.70/Rev.1).

Refer to attached BWM.2/Circ.70/Rev.1

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.

The collection and analysis of the representative samples should be independent of the BWMS manufacturer or supplier and to the satisfaction of the Administration (BWM.2/Circ.70/Rev.1 para.7). For that purpose sampling and analysis of ballast water and Verification of the self-monitoring equipment have to be conducted by a BV approved Service Supplier, in accordance with the requirements of IACS Unified Requirement UR Z17, or by a Service Supplier acceptable to the flag Administration.