Upcoming Changes to Ballast Water Record-Keeping Requirements – Entry into force on 1 February 2025

Summary:

From 1 February 2025, the format of the Ballast Water Record Book (BWRB) is to be updated. The upcoming amendments introduce significant updates aimed at ensuring standardized and efficient record-keeping, with standardized operation codes from A to H to categorize various ballast water activities. Comprehensive guidance on completing BWRB entries has also been approved, including examples of scenarios involving challenging water quality. To meet the new requirements, shipowners must adopt specific measures and , from 1 February 2025, all ships subject to the BWM Convention must implement   the revised BWRB format, ensuring adherence to the new structure and operation codes.

Background:

In 2017, IMO established an experience-building phase (EBP) associated with the BWM Convention, in order to carry out a systematic and evidence-based review of the BWM Convention, potentially leading to review of the Convention and development of a package of amendments. One of the first output is that BWRB entries were found to be an issue faced by PSC,  and IMO recognized that the current form did not provide sufficient clarity, and this had an impact on the operation of ships.

Extract of document MEPC 78/4/1

Consequently, at MEPC 80, IMO adopted the following  amendments related to ballast water record-keeping.

New Format of Ballast Water Record Book (BWRB) (resolution MEPC.369(80))

IMO adopted amendments to appendix II of the Annex to the BWM Convention in relation to the Form of Ballast Water Record Book (resolution MEPC.369(80)). This comes into force on 1 February 2025.

This revised Form of BWRB proposes the list of items to be recorded in "Code" (letter A to H) and "Item" (number) format and additional details that must be recorded for different ballast water operations, similarly to the Oil record book.

Note: Records must be retained onboard for two years and under the company control for an additional three years. To ensure compliance during inspections, BWRBs (old and revised) must be properly maintained and readily available for review without causing delays. (BWMC reg. B.2.2).

Guidance on ballast water record-keeping and reporting (circular BWM.2/Circ.80/Rev.1)

IMO approved the Guidance on Ballast Water Record-Keeping and Reporting (BWM.2/Circ.80) to provide detailed instructions on when and how to record ballast water operations in the BWRB. The guidance includes standardized format, examples and instructions for chronologically recording each ballast water operation, as well as requirements for storing the records.

In addition, it includes an updated example of ballast water reporting form (BWMRF) which may be submitted before reaching a port, as well as an example form for voluntary tank-by-tank logging of ballast water operations.

Note: MEPC 82 approved the 2024 Guidance on Ballast Water Record-Keeping and Reporting (BWM.2/Circ.80/Rev.1), which revokes BWM.2/Circ.80. This updated guidance provides instructions for documenting operational scenarios involving challenging water quality (CWQ) in the Ballast Water Record Book (BWRB), aligning with the Interim Guidance on the Application of the BWM Convention to Ships Operating in Challenging Water Quality Conditions (resolution MEPC.387(81)).

Consequential amendments of the Ballast Water Management Plan (BWMP) (resolution MEPC.370(80))

For consistent implementation of the changes introduced for the record-keeping and reporting process under the BWM Convention, IMO adopted amendments to the Guidelines for Ballast Water Management and development of Ballast Water Management Plans (G4) (MEPC.370(80)).

Consequently, BWMPs shall be appropriately updated, in particular the part “RECORDING REQUIREMENTS” to reflect the changes introduced in record keeping and reporting process with the proper reference to BWM.2/Circ.80/rev.1.

Retroactive application on existing ships

Existing ships are required, from 1 February 2025, to amend BWRBs, BWMPs, as appropriate, and record ballast water operations taking into account the IMO Guidance on Ballast Water Record-Keeping and Reporting.

Unless otherwise instructed by the ship’s Flag, BV will, during the first periodical survey under the BWMC on or after 1 February 2025, verify that:

• BWRB comply with the new format outlined in resolution MEPC.369(80)
• BWMP is updated to reflect the changes introduces in record keeping and reporting process with the proper reference to BWM.2/Circ.80/rev.1, as per resolution MEPC.370(80).