BALLAST WATER RECORD-KEEPING AND REPORTING REQUIREMENTS – UPCOMING CHANGES
Starting in 2025, two IMO resolutions come into effect specifying a new format for the ballast water record book (BWRB) and mandating approval of electronic BWRBs when replacing hard copy versions on board vessels. More about these new requirements for ballast water record-keeping and reporting in this statutory news.
New format for the ballast water record book (BWRB) and new guidance on BW record-keeping and reporting – from 1 February 2025
The new guidance on ballast water (BW) record-keeping and reporting, adopted in Circular BWM.2/Circ.80, aims to assist ship crews by clarifying the record-keeping and reporting process under the BWM Convention. The circular includes guidance on completing the BWRB, including:
- Updated example ballast water reporting form (Appendix II)
- Example form for voluntary tank-by-tank logging of BW operations
- Example of logging operations when encountering challenging water qualities (included in Circular BWM.2/Circ.80/Rev.1 approved at MEPC 82)
Moreover, Resolution MEPC.369(80) amended the BWM Convention Appendix II with an updated form of the BWRB, and this amendment will enter into force on 1 February 2025.
Hence, starting from 1 February 2025 onwards, all ships with an approved BWM plan should start:
- Record-keeping of ballast water operations in the BWRB in accordance with guidance BWM.2/Circ.80, and
- Apply the new codes A to H together with the specific item number for different BW operations specified in MEPC.369(80).
Crews should familiarize themselves with the new BWRB form, as port states and flag administrations will require records to be kept accordingly.
It is expected that the BWRB can be amended without having to also amend the ballast water management plan (BWMP). Hence, no re-approval of the BWMP is considered necessary when adjusting the format of the BWRB.
To follow up the implementation of the new requirements for BW record-keeping and reporting:
- DNV will shortly issue a “Retroactive Requirement” (RR Ref.1034l) under “Vessel Status” in Veracity for all ships with an approved BWMP.
- DNV surveyors will at the first periodical survey or occasional survey after 1 February 2025 check if the BWRB has been amended as required and, as applicable, delete the RR.
Approval of electronic record book system and ship-specific declaration for using electronic BWRBs – from 1 October 2025
Regulation B-2 of the BWM Convention permits the use of electronic record books, and MEPC 80 has adopted MEPC.372(80) providing guidelines for their implementation. Moreover, MEPC 81 has adopted MEPC.383(81) amending Regulations A-1 and B-2 of the BWM Convention to include the use of electronic BWRBs. This amendment to Regulations A-1 and B-2 is mandatory from 1 October 2025 and requires the following:
- The approval of an electronic BWRB based on the guidelines provided by MEPC.372(80) if replacing the hard-copy record book by an electronic one
- A ship-specific declaration to be carried on board confirming that the installation of the electronic BWRB meets the requirements of the IMO guidelines
The declaration may be issued by the flag administration or by DNV, where authorized by the flag administration. Some flags have already confirmed that they have no objection to an early implementation of the approval of electronic BWRBs.
DNV is prepared to approve electronic recording systems and is updating the DNV class programme DNV-CP-0569 to include type approval of electronic systems for BWRBs.
DNV is also prepared to perform ship-specific surveys for approving the use of the electronic BWRB on board ships prior to issuing the declaration, where authorized by the flag. The Liberian administration approves electronic BWRBs and issues declarations for them directly.
To follow up the requirement of a declaration in the case that an electronic BWRB is used, DNV will issue a “Retroactive Requirement” (RR Ref.1034m) in early 2025 under “Vessel Status” in Veracity to all ships with an approved BWMP.
Recommendations
DNV recommend keeping these four actions in mind:
- Update BWRBs to comply with the new requirements for BW record-keeping and reporting, effective from 1 February 2025.
- Ensure your electronic recording system is approved by flag or type approved by DNV/other RO when using electronic recording system following the guidelines in Res. MEPC.372(80).
- Get the declarations for electronic BWRBs by 1 October 2025 or earlier if advised by the flag administration.
- Order a survey via My Services if flags accept early approval.
Ref: https://www.dnv.com/
