Environmental Engineering Reference
In-Depth Information
Exceptions from BWM
Further to the above mentioned exemptions, the BWM Convention also includes
provisions for cases where vessels do not need to manage their ballast water at all.
This refers to vessels being in line with the Regulation A-3 Exceptions . Exceptions
are identifi ed for specifi c cases including (IMO 2004 ):
1. ballast water uptake or discharge is needed for ensuring the safety of a ship in
emergency situations;
2. accidental discharge results from damage to a ship or its equipment;
3. uptake or discharge of ballast water is used to avoid or minimize pollution
incidents;
4. uptake and discharge of the same ballast water is conducted on the high seas; or
5. uptake and discharge occurs at the same location, provided no mixing occurs
with other locations.
The “high seas” and “same location” exceptions may apply permanently if this is
a regular vessel operation. Granting an exemption or a permanent exception means
that a vessel is not required to install a ballast water treatment system with the clear
benefi t of avoiding capital and operational costs as well as burdens associated with the
certifi cation and inspections. However, the BWM Convention is not specifi c in defi n-
ing the term “same location” (IMO 2004 ; Gollasch and David 2012 ; David et al.
2013 ). Therefore the concept is subject to different interpretations which depend on
the interpreters' approach and this may be based on one or a combination of the fol-
lowing: environmental parameters, hydrological regimes, biological meaningful
parameters, or political aspects. The shipping industry would benefi t from a larger
“same location”, as it avoids ballast water management requirements on voyages
inside each such location. In contrast maximizing environmental protection requires
that a “same locations” should be as small as possible. As a result, the “same location”
may be of different dimensions, including a mooring, port basin, port, anchorage, part
of a sea, or even an entire sea with numerous ports. These different interpretations
introduce diffi culties in the uniform implementation of the BWM Convention, includ-
ing an opportunity for the secondary transfer of organisms between ports within a
large “same location” (Gollasch and David 2012 ; David et al. 2013 ).
In light of the above the identifi cation of a “same location” for ballast water
management is not an easy task. This should be port specifi c and each port has its
unique peculiar situation regarding the number of port basins, it may extend over
waters of different salinity regimes, and ports likely have different cargo patterns
resulting in different ballast water operation profi les. The issue becomes more
complex when the same location needs to be explained in biologically meaningful
terms addressing aquatic species invasions. To biologically identify a “same loca-
tion” the species diversity and their abundance may be considered. This assessment
should include indicator microbes and human pathogens as listed in the D-2
standard. Should all species, including indicator microbes and human pathogens,
be identical and their abundance is very similar, this area could be considered as the
same location (Gollasch and David 2012 ; David et al. 2013 ).
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