US Coast Guard - Implementation Schedule

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INTERTANKO
Annual General
Meeting
Lagonissi
20th May 2015
International Association of
Independent anker Owners
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INTERTANKO’s
Payment
Performance
System
Bill Box
Senior Manager Communications & External Relations
INTERTANKO AGM
Lagonissi
20 May 2015
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Payment Performance System
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INTERTANKO – tanker sustainability
Practical commercial/operational assistance to Members
with arguments that work in all markets, bad and good:
 Unbalanced, eroded c/p terms and inconsistent,
subjective vetting practices
 Delays in freight and demurrage settlement
*hit owner’s cashflow
*increase owner’s working capital req’t
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Sustainability Project
ty
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Sustainability Project
Contractual obligations NOT met
Freight payable on completion of discharge
Pilot study:
Typical 6-8 days
Demurrage payable on receipt owner’s invoice
Pilot study:
Typical over 110 days
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Sustainability Project
Ultimate Aim:
to change
ingrained
bad habits
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Payment Performance System (PPS)
What does this mean for you?
10 ship fleet
Each fixing once a month
5% cost of funds
Average F & D amounts per pilot study
Typical payment delays per pilot study
F&D payment delays cost > $450,000 a year
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PPS: Output and Deliverables
What you get …
 Top 20 best payment performers
 Average delays in freight payments
 Average delays submitting, negotiating, paying
demurrage claims
 Comparison between charterers
 Comparison between different tanker types
 Cost of late payments
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PPS Data needs
What you give …
Basic info:
Vessel + charterer
Voyage dates
Freight/Demurrage $$
F & D invoices sent & settled dates
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S o w h a t ?!
This data enables
INTERTANKO to raise its head above the parapet
on behalf of its Members
and
challenge charterers with
their poor performance
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Payment Performance System
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Payments Performance System
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Payments Performance System
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Payments Performance System
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Payments Performance System
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PPS needs your participation
32 Members have agreed to participate or are preparing
data or have actually submitted and entered data
Over 2,600 datapoints in so far
We will assist your post-fixture staff
PPS participants may note on f & d invoices
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Rescue of Migrants at Sea
Dr Phil Belcher
Marine Director
INTERTANKO AGM
Lagonissi
20 May 2015
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Rescue of migrants- Scale of the
problem
2014:
• 882 ships diverted
• 254 rescue operations
• 42,000 rescued
• INTERTANKO members- c500 per week
2015:
• UN estimate a doubling of numbers
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Tankers- The safety concern
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Embarkation problems
Ratio of crew to migrants
Security
Carrying sources of ignition
No comprehension of safety
Belief they are now safe
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Main issues
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Medical care
Food and water
Sanitation
Rest area
Security
Rapid disembarkation
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Advice
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Piracy
Dr Phil Belcher
Marine Director
INTERTANKO AGM
Lagonissi
20 May 2015
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Attacks in 2010
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Attacks in 2014
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Gulf of Aden and Indian Ocean
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No attacks (3 years since last)
Few suspicious approaches
But intent and means remain
Only opportunity removed
Naval force reduction post 2016
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HRA
• Name proposed to be
changed to:
• Piracy Risk Area
• Push to change in Red Sea
• Some flexibility in
negotiations
• Any changes with RT
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GoG 2014
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Threat to tankers
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Critically exposed sector
Extreme vulnerability
Lack of faith in security
Unable to self-protect
Continue to work with region and others
Continue to recommend MTISC-GoG
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SE Asia
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Attacks on small clean product tankers
Joint naval patrols in operation
Working with various agencies and coastal States
Will develop RT advice on anti-piracy
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Next steps- World Wide Piracy
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Rewriting of BMP
Global BMP
Common areas
Regional annexes
Must reflect reality
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Cyber Security
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Both overt attacks and operational failures
New area of regulation
RT developing guidance
Plan for this to be base doc in IMO
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Vetting
Ajay Gour
Senior Manager – Vetting & Chemicals
INTERTANKO AGM
Lagonissi
20 May 2015
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Overview of VC
India, 4%
Russia, 4%
China, 4%
Cyprus, 7%
Chile, 4%
UAE, 4%
China
Cyprus
Denmark, 4%
Denmark
Belgium, 4%
Greece
Hong Kong
UK, 7%
Greece, 14%
Italy
Monaco
Netherlands
Norway
Singapore
USA
Germany, 7%
Hong Kong, 4%
Germany
UK
Belgium
USA, 7%
Italy, 7%
UAE
Chile
Monaco, 4%
Singapore, 7%
Norway, 7%
Netherlands, 4%
India
Russia
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Vetting Issues
Inspections &
Audits
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Numbers & Costs
Inspector Stds
VIQ - Guidance
Inspector Availability
TMSA Revision
Vetting Policies
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Transparency
Officer Matrix
Terminal Inspections
Maiden Voyages
Incident Reports
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Close cooperation with:
• OCIMF – SIRE Focus Group
• CDI
• PSC MoU’s
• Other stakeholders
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INTERTANKO Initiatives:
• Benchmarking Platforms
• Ship Inspection Feedback Forms
• Seminars & Training
• Publications
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Reducing Greenhouse Gas Emissions
from Ships
Dragos Rauta
Technical Director
INTERTANKO AGM
Lagonissi
20 May 2015
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EFFICIENCY OF SHIPS IN OPERATIONS
The Concept: Three phase-in legislation
Phase I – data monitoring, reporting and verification;
Phase II – trial period for verification of enforceability of the set target
Phase III – enforcement
The Proposals:
IMO by: USA, Japan, Germany and EC/EMSA
EU Monitoring, Report and Verification (MRV) regulation
All ships > 5,000 GRT calling to EU ports, reporting CO2 emissions when
ships travel:
• between EU ports,
• an incoming and outgoing voyage between an non-EU and an EU port
Monitor ship’s average energy efficiency at least with the following criteria:
Total annual CO2 emissions / total annual distance travelled
Total annual CO2 emissions / total annual transport work
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EU PROPOSED REGULATION on MRV
Dates for implementation EU MRV:
1st July 2015 – enter into force
31st August 2017 – companies should submit to “verifiers”
Monitoring Plan
1st January 2018 – starts first annual reporting period
2019 and after
– by 30th April each year, companies shall submit a verified
emissions report to the EU Commission and to the Flag State
– by 30th June each year, the EU Commission will make the
emissions reported by ships publicly available
. . . Awaiting for the IMO development . . . . .
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GHG EMISSION REDUCTIONS - IMO
No policy decision taken yet – voluntary, mandatory . . . ?
Developed text for possible amendment to MARPOL Annex VI
Agreed:
• Application all ships > 5,000 GRT
• Report: Total annual fuel consumption, by fuel type
To be decided:
• “Transport Work” and/or “ Proxies” such as distance
travelled, service hours, cargo weight/volume
• Verification of data submitted – possible guidelines
• If mandatory Certification and role of PSC – possible
guidelines
• Confidentiality
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IMPACT ANALYSIS OF THE MANDATED IMPROVEMENTS
Int. Aviation
3%
Int. Shipping
Waste
3%
Others
1%
4%
Agriculture
9%
Energy
production
28%
Households/service
15%
Land Transport
19%
~ 180 mt CO2
Land Industry
18%
~ 0.5% of global CO2
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Terminal Conditions of Use
Dragos Rauta
Technical Director
INTERTANKO AGM
Lagonissi
20 May 2015
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TERMINALS
CONDITION OF USE (CoU) DOCUMENTS
. . . neither XXX (i.e. Terminal), its co-venturers, their parent
companies, subsidiaries, or affiliates, nor its or their
servants, agents or contractors in whatever capacity they
may be acting shall be in any way whatsovere responsible
or liable for any contribution with respect to any loss,
personal injury, including death, damage or delay, from
whatsoever cause, including the negligence of XXX or its
servants, co-venturers, agents contractors arising whegther
directly or indirectly in consequence of any assistance,
advice or instructions whatsoever given or tendered in
respect of any Vessel . . . .
In all circumstances the Master of any Vessel shall remain
solely responsible on behlaf of his or her Owner(s) . . .
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Terminal
Terminal Operator
Country - Port
Terminal COU Ref Nr
Terminal Booklet
TOTAL EXPL. ANGOLA
Angola
N/A
CLOV QA 002 REV03 Rev. 06/14
PTTEP
Australia
Yes - MV-OP-D32-808318
N/A
FPSO CIDADE DE ANCHIETA
SBM do Brasil Ltda - PETROBRAS
Brazil
Appendix 11 - Issued: 02/10/20 12
N/A
English law - London Arbitr.
FPSO CIDADE DE PARATY
SBM do Brasil Ltda - PETROBRAS
Brazil
Appendix 11
N/A
English law, - London Arbitr.
SBM Golfinho operacoes Maritimas Ltds,
SBM Espirito Do Mar Inc. - PETROBRAS
Brazil
Appendix 12 ISSUE NO 2 Issued: 1/6/12
N/A
English law,
London Arbitration
BRUNEI SHELL
Nation of Brunei
Conditions of berthing
and unberthing services
N/A
Cameroon
Yes / NO REF NR
N/A
N/A
CLOV Angola
MONTANA VENTURE
FPSO CAPIXABA
Brunei
Sonara - Limbe
NTL offshore
IMTT-NTL Ltd.
Canada - Whiffen Head
Ref: 1120.29 - June 2013 - ev TR0020
OCENSA TLU2
ECOPETROL S.A./OSENSA
Colombia - Covenas
July 2010 - 8th Edition
N/A
TULLOW OIL
Ghana
Rev.4-31/5/12
TGL-OPS-MAN-10-0002
Rev.4-31/05/12
VOTL Vadinar
ESSAR
India
Yes - REV.:02- JAN-12 - VOTL/SPM/003
N/A
Butinge SPM
AB MAZEIKIN NAFTA
Lithuania - Butinge
Appendix 2 - REVISION G
N/A
CHEVRON
Nigeria
Yes / NO REF NR
N/A
Esso Exploration and Production Nigeria Limited
Nigeria
Appendix E/D NO REF NR
N/A
MOBIL PRODUCTING IGERIA
Nigeria
N/A
Ref: N. 0791 (02-02)
SHELL
Nigeria
N/A
Ref: OPRM-2003-0105 Ver
Nigeria
Yes - EBK/TH/001 REV.03
N/A
JUBILEE
Agbami offshore
Usan offshore
Qua Iboe offshore
Bonga offshore
EBOC
OKWORI
SINOPEC/ADDAX PETR.
Nigeria
Revision 05-2009
N/A
Ukpokiti
SHEBAH EXPLORATION & PRODUCTION Co. Ltd
Nigeria - Trinity Spirit
30/04/2005 Rev 1
N/A
GALP ENERGIA, PETROGAL
Portugal - LeixoesP
March 2014 - Rev 06
N/A
STATOIL (Bahamas)
Bahamas - South Riding Point
Yes / NO REF NR
N/A
AMT - YANBU
SAUDI ARAMCO
Saudi Arabia
Yes / NO REF NR
Yes / NO REF NR
RAS TANURA
SAUDI ARAMCO
Saudi Arabia
Yes/ NO REF NR
N/A
BP
Spain
N/A
Rev. No 6 March 2013
Oceanido Galp Leca
South Riding Point SSRP
CBM CASTELON
Law & Jurisdiction
English Law
High Court of London
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Ballast Water Management
Tim Wilkins
Senior Manager – Environment. Regional Manager Asia Pacific
INTERTANKO AGM
Lagonissi
20 May 2015
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Ballast Water Management
Outline
1. IMO
1. Where we are today
2. MEPC 68 Report
2. US
3. Ballast Water Technology – approvals
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Ballast Water Management
1.1 IMO: Where we are today
Ballast Water Management Convention
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Adopted in 2004
Entry into force requires ratification by 30
countries, 35% world’s grt
Currently, 44 countries, 32.86% grt
Bahamas, China, Greece, Malta, Panama,
Singapore or UK, each alone could bring
the convention into force
Argentina and Italy in the process – 34.2%
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Ballast Water Management
1.1 IMO: Where we are today
Ballast Water Management Convention
MEPC 64 INTERTANKO et al. submission:
THREE key challenges:
1.
Logical implementation schedule for the Convention
2.
Balanced procedures for port State control
3.
Guidelines for approval of ballast water management
systems (G8)
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Ballast Water Management
1.1 IMO: Where we are today
1. Logical Implementation schedule
Assembly Resolution A.1088 (28) adopted, Dec 2013 recommends governments:
1.
implement the Convention based on the entry into force date of the
Convention
2.
considers ALL vessels constructed before entry into force as existing vessels
3.
existing vessels to install a BWMS at the first renewal survey (IOPP Certificate
under Annex I of MARPOL) after entry into force of the Convention
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Ballast Water Management
1.1 IMO: Where we are today
2. Balanced Port State Control Procedures
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Trial Period (initially for 3 years) following entry into force
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During this period, port states will ‘refrain from detaining a ship or
initiating criminals sanctions in the event a BWMS does not meet the
discharge standard’ (USA reserved position)
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Sampling only after clear grounds and any indicative sample should not
form the basis for a decision on compliance – 4 Stage approach:
1.
2.
3.
4.
Initial inspection
More detailed inspection
Indicative sampling
Detailed sampling
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Ballast Water Management
1.1 IMO: Where we are today
3. Guidelines for approval of ballast water management
systems (G8)
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Better quantity and quality of information with increased transparency
– (Resolution MEPC.228(65), BWM.2/Circ.43, BWM.2/Circ.33 and
BWM.2/Circ.28)
MEPC Resolution (adopted MEPC 67):
• Commence a review and revision of the type approval guidelines
(G8) taking into account all the industry concerns
• Also take into account the US approval procedures and standards
• Protection for early-movers : those owners who’ve installed
BWMS approved to current G8
• Reminder of the PSC trial period
Details of ‘Grandfathering’ discussed at MEPC 68
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Ballast Water Management
1.2 IMO: MEPC 68
MEPC 68, May 2015
1. Completed revised G8 Guidelines?
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Ongoing but not likely to be completed until end-2016
2. Indication of extent of Grandfathering - protection of early movers?
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shipowners that have installed BWMS approved to the current type approval
guidelines should not be required to replace these systems once the new
guidelines are introduced
if current BWMS are installed, maintained and operated correctly then they
should not be required to be replaced for the life of the ship or the BWMS,
whichever comes first, due to occasional lack of efficacy
early movers should not be penalized (sanctioned, warned, detained or
excluded) solely due to the occasional lack of efficacy of the BWMS
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Ballast Water Management
2. US
US Coast Guard
Final regulations issued March 2012 (effective 21 June ‘12)
Main requirements include:
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BWE prior to discharge in US waters
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BWM Plan: reporting and record keeping (fouling management as well)
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BWM discharge standard (same as IMO), review in 4 yrs
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Compliance schedule (similar to IMO), (no intent to align schedule with IMO)
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Acceptance of “Alternative” BWMS for 5 years
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BWMS not required if no discharge in US waters (12 nautical miles)
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Ships may request an extension to compliance date for installation of USCG TA
BWMS
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Ballast Water Management
2. US
US Coast Guard - Implementation Schedule
•
Decision Tree
…
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US Ballast Water Decision Tree
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Ballast Water Management
2. US
US Coast Guard - Implementation Schedule
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Decision Tree
Model Extension Request (MER) Letter
Still in use and
still relevant!
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Ballast Water Management
2. US
US Coast Guard - Extension Requests
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January 1, 2016 extension date given to ships whose drydocking was
scheduled for 2014
January 1, 2017 extension date given to ships whose drydocking was
scheduled for 2015
Extensions for ships with drydockings in 2016 being considered
Availability of USCG approved BWMS will be a factor in determining the
length of time for future extensions
INTERTANKO has developed Model Extension Request (MER) letter for
members wishing to request extension
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Ballast Water Management
2. US
US Coast Guard – BWMS Approvals
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CG has advised that 17 BWMS manufacturers have submitted “Letter of
Intent” to pursue USCG approval
(54 AMS accepted by USCG)
For proprietary reasons, USCG cannot tell who those BWMS manufacturers
are
INTERTANKO has contacted BWMS manufacturers to determine which of
them have submitted “Letter of Intent” (results on INTERTANKO web site)
Only after the testing is completed and the results have been evaluated,
will a BWMS manufacturer then submit an application to the USCG for
approval of their BWMS
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Ballast Water Management
3. Ballast Water Technology - approvals
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4 independent laboratories authorised
Testing is fully independent and on market-ready BWMS
USCG Accepted
Laboratory
NSF International
DNV GL AS
Korean Register of
Shipping (KR)
Control Union
Certifications BV
Sub Laboratory
Country
MERC, GSI, Retlif, American Bureau of
Shipping; Curtis Strauss LLC (BWMS)
DHI-Denmark, Golden Bear Facility, Applica,
DELTA-Denmark (BWMS)
USA
Norway
KOMERI, KTL, SGS Giheung Lab
Rep. of Korea
IMARES, NIOZ, GoConsult, Dr. Matej David
Consult, TNO
Netherlands
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Ballast Water Management
3. Ballast Water Technology – US approvals?
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
11.
NK 03
Coldharbour Marine
Erma First BWTS
RWO – Cleanballast
Hyde Guardian (UV)
Techcross Electrocleen
Samsung – Purimar
Trojan Marinex (UV)
Evoqua – SeaCure BWTS
NEI – Venturi Oxygen Stripping
Optimarine – OBS EX (UV)
12.
13.
14.
15.
16.
17.
Oceansaver Mk II
Wartsila – Aquarius EC
Severn Trent – Balpure
DESMI – Ray Clean (UV)
Alfa Laval – Pureballast (UV)
??
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Ballast Water Management
3. Ballast Water Technology - approvals
The dilemma:
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Currently no BWMS is USCG type approved
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Ship operator must decide to:
1. install AMS (and hope it gets USCG approval)
OR
2. request an extension and wait until there is a CG approved BWMS
BUT
what if Convention enters into force before we have a CG approved
BWMS?
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Thank you
INTERTANKO AGM
Lagonissi
20 May 2015
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