The IMO Resolution MEPC.325(75) incorporates amendments to the BWM Convention that enter into force on 1 June 2022. Vessel owners and yards shall therefore observe the new requirement for mandatory commissioning testing at the initial BWMS’s commissioning survey completed on or after 1 June 2022. Read more about this requirement in this statutory news.
Relevant for ship owners and managers, design offices, shipyards, suppliers as well as flag states.
Commissioning testing in accordance with IMO guidance BWM.2/Circ.70/Rev.1 is now mandatory for Ballast Water Management Systems (BWMSs) installed on newbuilds and existing ships of all flag administrations when the initial BWMS commissioning survey is completed on or after 1 June 2022.
This test is required even if the system has been partially installed and/or commissioned before 1 June 2022.
The commissioning test is also mandatory for the additional commissioning survey required after a change, replacement or significant repair of the BWMS necessary to achieve full compliance with the D-2 standard.
The IMO has also approved a Uniform Interpretation (UI) of regulation E-1 in BWM.2/Circ.66/Rev.2. This UI clarifies that if the initial or additional survey is completed on or after 1 June 2022, the commissioning test is mandatory. If the initial or additional survey is completed before 1 June 2022 the commissioning test of the BWMS remains subject to the specific requirements of the flag administration.
How to take the commissioning test and who performs it?
The commissioning test shall be arranged either with a DNV-approved service supplier or by an organization/supplier accepted by the flag administration. The test requires ballast water samples to be taken at the discharge line after treatment by the BWMS and analysed by the selected service supplier.
DNV-approved service suppliers can be found in the “DNV approval finder” by selecting “Approval of Service Suppliers” and then “Service Suppliers engaged in testing of Ballast Water Management Systems (validation of biological efficacy at commissioning)” or “Commissioning testing of ballast water management systems (BWMS)”. The link to the “DNV approval finder” is provided below. See also the question “Which test facilities can ship owners contact …” on the DNV BWM Internet page for FAQs.
The collection and analysis of the representative samples should be independent of the BWMS manufacturer or supplier and to the satisfaction of the flag administration.
Local ambient water should be used for testing regardless of the level of challenge this poses to the BWMS. If the ambient water is not appropriate for the commissioning testing, alternative testing should be carried out to the satisfaction of the flag administration (e.g. another port may be chosen).
Analysing the results
The representative samples should be analysed for the below two size classes of organisms specified in the D-2 standard. Indicative analysis methods listed in BWM.2/Circ.42/Rev.2 may be used.
| Size class | Criteria |
| ≥ 50 μm | Viable organisms less than 10 per m3 |
| ≥ 50 μm < 50 μm | Viable organisms less than 10 per millilitre (ml) |
Please note that some indicative analysis methods do not provide an organism count and instead provide an indication of compliance with the D-2 standard only. With the commonly used ATP method, for example, an ATP measurement of < 150 000 pg/m3 indicates compliance with the D-2 standard for organisms ≥ 50 μm.
On a voluntary basis, the sample may also be analysed for the three indicator microbes Escherichia coli, Enterococci and Vibrio cholerae.
Reporting
A written report, including the methods used, results (including raw data) and information on the self-monitoring parameters, should be provided to the surveyor and, if required by flag, to the flag administration.
If the report is not completed before vessel departure
If the vessel’s D-2 compliance date has been met but the report is not completed before departure, the flag administration’s advice should be followed.
In addition, in case a laboratory is not available, the flag administration may allow the test to be postponed on a case-by-case basis. In such a case, the BWM certificate for D-2 is to be issued or endorsed as advised by the flag administration and a statutory condition may be issued in addition.
In all the above-mentioned cases, our surveyor or flag liaison should approach the flag on request.
If the commissioning test is not successful
The commissioning test is successful if the indicative analysis indicates that the discharge samples do not exceed the D-2 standard for the two size classes of organisms – ≥ 50 μm and ≥ 10 to < 50 μm – and the self-monitoring equipment indicates correct operation.
If the test is not successful, the possible reasons for non-compliance need to be investigated, and the commissioning test must be repeated in possibly another port. If a successful repetition of the commissioning test is not possible before the D-2 compliance date of the vessel, the flag administration needs to be informed and its advice followed.
Recommendations
DNV recommends that customers observe the new requirement at the initial BWMS survey for a commissioning test in accordance with IMO guidance BWM.2/Circ.70/Rev.1 applicable from 1 June 2022. Due dates of new requirements are also available in the DNV Compliance Planner (available for customers only).
Source: https://www.dnv.com/news/mandatory-bwms-commissioning-test-required-from-1-june-2022-225958