Ballast Water Management Challenges: Compliance with D2 Standards and Record-Keeping

Since the implementation of the D2 ballast water discharge standard on September 8, many ships have faced issues with detention and fines due to non-compliance. In this article, we’ll discuss how to handle ballast water quality challenges, how to properly record ballast water operations, and what to do to avoid penalties.

1. What Does the D2 Standard Require?

The ballast water management convention requires that all ballast water discharged into the sea must meet the D2 standard. This means that before water is released, it must be treated and meet specific quality standards. However, the convention does not require ballast water being taken on board to be treated—only the water being discharged must meet these standards.

2. Challenges with Water Quality

In some cases, ships encounter poor water quality, such as muddy water, which can clog the filtration system and cause high pressure. When this happens, the ballast water treatment system may not function properly. Ships may need to bypass the system to continue taking on ballast water.

For example, in one case, a ship had to bypass the treatment system when it was unable to pump water due to clogged filters. The ship then carried out a water exchange operation in the Pacific, following the management plan to replace the ballast water.

3. How to Record Ballast Water Operations

The ballast water record book must accurately document every operation. The new record-keeping requirements have changed. The previous version was simple, with columns for water uptake, discharge, and inter-tank transfers. However, under the new version (BWM.2/Circ.80), starting in February 2025, ballast water operations are classified into 8 categories (A to H).

If there’s an issue with water quality and the ship needs to bypass the treatment system, the record should reflect this. In the example above, the correct codes to use would be:

• A: For taking in ballast water
• F: For issues with water quality (e.g., clogged filters)
• A: For the operation when ballast water is finally taken into tanks.

The record should look something like this:

Date: 11.1.2024

• A: Start and end time, port code, tank name, and amount of ballast water taken.
• F: Note the issue with the filter and the failure to fix the problem.
• A: Final water uptake, stating if it meets the D2 standard or not.

4. How to Avoid Detention or Fines

To avoid detention or fines during Port State Control (PSC) inspections, it is crucial that ships properly record their ballast water operations. If the water doesn’t meet D2 standards, it should be treated by the ballast water treatment system before being discharged.

If a ship bypasses the treatment system, this must be clearly recorded, and the ship must ensure the water is treated and meets the D2 standard before being released into the sea. Otherwise, it could face penalties.

5. What Should You Do If You Encounter Poor Water Quality?

• Step 1: If the water quality is bad, try to fix the issue by cleaning the filters or adjusting the system settings.
• Step 2: If the system still can’t work, bypass the treatment system but make sure to record this in the ballast water logbook.
• Step 3: After bypassing, the ballast water must be treated and meet D2 standards before discharge.
• Step 4: Ensure all operations are correctly documented, following the new record-keeping guidelines.

Compliance with ballast water discharge standards is crucial to avoid detention or fines. By following proper procedures and keeping accurate records, ships can ensure they meet the D2 standard and avoid problems during inspections.