Commentary On Entries in The Ballast Water Record Book (BWRB)
Commentary On Entries in The Ballast Water Record Book (BWRB)
Commentary On Entries in The Ballast Water Record Book (BWRB)
Commentary on Entries
in the Ballast Water
Record Book (BWRB)
Commentary on Entries in the
Ballast Water Record Book
(BWRB)
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© INTERTANKO 2020
While every effort has been made to ensure that the information contained in this publication is correct,
neither the authors nor INTERTANKO can accept any responsibility for any errors or omissions or any
consequences resulting therefrom.
11
Introduction
The following provides a commentary on entries in the ballast water record book (BWRB) for commonly used
ballast water operations on tankers. The commentary is based on questions and feedback from INTERTANKO
Members as well as feedback from several Administrations consulted by INTERTANKO and its Members in
relation to the BWRB.
As background and context to the commentary, this document also provides a brief summary of the requirements
of the International Convention for the Control and Management of Ships’ Ballast Water and Sediments, 2004
(BWM Convention) as it relates to the requirements for a BWRB under Regulation B-2. A sample BWRB format
is also included as an Annex to this document.
Background
Following the entry into force of the BWM Convention on 8 September 2017, all ocean-going vessels have
been required to record ballast operations in a BWRB. Appendix II of the BWM Convention (Form of Ballast
Water Record Book) specifies the ballast operations that should be recorded, as a minimum, in the BWRB.
However, based on the experience of INTERTANKO’s Members, it is evident that Appendix II of the BWM
Convention is open to a variety of interpretation and ambiguity by Flag Administrations, Class Societies, Port
State Control authorities and third-party auditors.
This commentary therefore: i. discusses some of the ambiguity that exists within Appendix II of the BWM
Convention; ii. considers variations of interpretation of the record-keeping entries specified in Appendix II, and;
iii. offers possible options for making entries in the BWRB under various ballast operation scenarios.
Disclaimer
Ship owners and managers should always consult their Flag Administration for their guidance and consent in
relation to the mandatory record-keeping requirements of the BWM Convention. This is particularly important
for any uncertainty in relation to the BWRB to ensure that the format and entries meet the requirements
established by the Administration.
INTERTANKO would like to thank the representatives from the various Administrations that were consulted for
taking time and effort to provide their interpretation of the scenarios and examples that were presented by
INTERTANKO Members.
INTERTANKO welcomes views and comments on this document as well as additional scenarios and examples
that are not taken into account, which will assist us in improving the document for future revisions.
1. Each ship shall have on board a BWRB. It could be an electronic record system or it could be integrated
into another record book or system, and which shall at least contain the information specified in
Appendix II of the BWM Convention.
2. Each operation concerning Ballast Water shall be fully recorded without delay in the BWRB. Each entry
shall be signed by the Officer in Charge of the operation concerned and each completed page shall be
signed by the Master.
3. In the event of the discharge of Ballast Water pursuant to regulations A-3, A-4 or B-3.6, or in the event
of other accidental or exceptional discharge of Ballast Water not otherwise exempted by the BWM
Convention, an entry shall be made in the BWRB describing the circumstances of, and the reason for,
the discharge.
4. The BWRB shall be kept readily available for inspection at all reasonable times. It shall be maintained on
board the ship for a minimum period of two (2) years after the last entry has been made and, thereafter,
in the Company’s control for a minimum period of three (3) years.
5. Port State Control Officers may inspect the BWRB on board any ship to which the BWM Convention
applies while the ship is in its port or offshore terminal, and may make a copy of any entry, and require
the Master to certify that the copy is a true copy. Any copy so certified shall be admissible in any judicial
proceeding as evidence of the facts stated in the entry. The inspection of a BWRB and the taking of
a certified copy shall be performed as expeditiously as possible without causing the ship to be unduly
delayed.
In relation to appropriate training for ships’ Masters and crews, this should include instructions on the ships’
Ballast Water Management plan including the completion of required records (2017 Guidelines for Ballast
Water Exchange (G6)).
If ballast water exchange is not undertaken for the reasons in Regulation B-4.4, i.e. if the Master reasonably
decides that such exchange would threaten the safety or stability of the ship, its crew, or its passengers
because of adverse weather, ship design or stress, equipment failure, or any other extraordinary condition,
then details of the reasons ballast water exchange was not undertaken are to be recorded in the BWRB.
Reference is made to BWM.2/Circ.63, ‘Application of the Convention to ships operating in sea areas where
ballast water exchange in accordance with regulations B-4.1 and D-1 is not possible’.
Information specified in Appendix II of the BWM Convention with the correct paragraph references:
Period of Operation
Name of Ship
IMO Number
Gross Tonnage
Flag
Total Ballast Water Capacity (in cubic metres)
Whether the ship is provided with BWMP
Diagram of ship indicating ballast tanks
Entries in BWRB shall be made on each of the following occasions;
Importantly, the sample format includes the three main headings as provided in the Sample BWRB Page in
Appendix II. Namely: Date; Item (number), and; Record of operations/signature of Officers in Charge. Optional
sub-columns have been inserted under Record of operations/signature of Officers in Charge may assist users
in breaking down the process of ballast water management and their record keeping. This is discussed further
in the commentary.
The format in the sample may also assist in the completion and submission of Ballast Water Reporting Forms
(BWRF) in ports where these are required. Although the BWRF is not a mandatory document, many port State
authorities request the submission of the report prior to the ship’s arrival. A model format of the BWRF is also
provided by the IMO in the 2017 Guidelines for Ballast Water Exchange (G6).
During the drafting and review of the commentary by the Environment Committee, it was observed that the
most concise and accurate interpretation of the BWRB (Appendix II) did not always provide the reassurance
that an inspecting authority may concur with the entry. Therefore, it was often observed that extra entries were
made in order to take into account any possible variation of interpretation by the inspecting authorities. This
is regardless of the additional administration that may create onboard.
For the sequential method, entries should be made in 3.1 and 3.3 during uptake and discharge respectively.
A record taken on a tank-by-tank basis may assist in managing the exchange operation and to demonstrate
that 95% volumetric exchange has been achieved, as per the BWM Convention requirements. See also the
commentary in ‘F’ on whether operations should be recorded on a tank-by-tank basis or total ballast volume.
For the flow through and dilution methods the same codes apply for ballast uptake, 3.1, and ballast discharge,
3.3. deballasting. To indicate that the necessary volume has been exchanged it may be necessary to accurately
record the start and stop time of the ballast water operation and the total volume. This can be entered in 3.2,
again with a note in the ‘Remarks’ section advising of the method of exchange used. A reference to the BWMP
may also be necessary (e.g. ‘According to the BWMP: Y/N’). The BWMP will provide the necessary details for
calculating the time required to pump three times the capacity of each tank with the percentage calculated by
dividing the number of units of water exchanged by the original volume of ballast water in the tank. The pump
rate capacity will also be referenced in the BWMP.
Note that during consideration of how to record ballast water exchange in the BWRB it was frequently the case
that there was no distinction made between which method of exchange was being used by the ship. As such,
advice that only 3.2 should be used for ballast water exchange purposes may be too general and therefore
confusing when a ship uses the sequential method.
Some further complexity may arise if ballast water uptake is conducted in two phases for the purpose of ballast
water exchange. For example, a vessel takes up 5000m3 of ballast water on 2 April which is recorded in 3.1.2.
A second uptake of 7000m3 of ballast water is then undertaken on 3 April and also recorded in 3.1.2. In these
situations, Members have been advised by port State inspectors to add an additional note in 3.1.2 referencing
the total volume that has been taken onboard. So in this example, an additional note (e.g. Total onboard;
12,000m3) following the 7000m3 uptake on 3 April would be added to clearly indicate the total volume now
taken up.
Many Administrations take the view that so long as the ballast water is used to control trim, list, draught,
stability or stresses then all ballast water taken on board should be recorded, regardless of whether it is treated
or untreated. 3.1 should therefore be used whenever ballast water is taken on board. So as an example, if
ballast water is treated while being taken on board, an entry should be made in 3.1 as well as 3.2.
Please note ‘C’ below that discusses the discharge of ballast water to a reception facility (3.4) and the use of
3.4.4 in reference to the volume of water taken up.
However, some ambiguity arises due to the text ‘or taken up’ used in 3.4.4. Because of this text in 3.4.4
then some Administrations have suggested an entry could be made in 3.4 when taking ballast water from a
reception facility. Presumably, this would be treated ballast water. Regardless of whether the company and the
Administration require an entry in 3.4 and reference to the discussion in ‘B’ above, then any ballast taken on
board should be accompanied by an insertion in 3.1.
When a reception facility is used then a reference should be included in 3.4.5 to the relevant section of the
BWMP that covers the use of reception facilities as a means of compliance with the BWM Convention. Note
that some Administrations have commented on the need to also make an insertion in 3.2 when a reception
facility is used. The reason for this additional entry may be based on the use of 3.2 to demonstrate in every
situation the means of compliance (treatment of management of the ballast water) with the BWM Convention.
This would be regardless of whether the ballast water is exchanged, treated with a BWMS or managed using
treated water taken from or discharged to a reception facility.
3.2.2 states that an entry in the ballast water record book shall be made:
‘3.2 Whenever Ballast Water is circulated or treated for Ballast Water Management purposes:…
The terms, ‘circulated or treated’, used together suggest a catch-all for any ballast water transfers undertaken
between tanks. This may include but is not limited to ballast water transfers for:
ii. general ballast water management for vessel trim, list, draught, stability or stresses, or;
iii. ballast transfers to maximise the mixing of chemicals (also referred to as active substances) with the
ballast water for treatment and/or neutralisation purposes.
More specifically, two schools of thought exist when recording the treatment of ballast water using a BWMS:
If the BWMS treats the ballast on uptake, for example using filtration and UV, then an entry should be
made in 3.1 and again in 3.3. It is in 3.3 that a clear reference should be made to the discharge being
undertaken in accordance with the BWMP and therefore in compliance with the BWM Convention,
Regulation D-2. This would appropriately be made in 3.3.3.
This logic can be applied to a BWMS that treats on discharge where the entry in 3.3.3 would draw
attention to the treatment method used as per the BWMP.
In many cases however, a BWMS will undertake treatment on uptake as well as an additional treatment
upon discharge, e.g. an additional UV irradiation in order to overcome re-growth. Again, 3.1 and 3.3
(with a clear reference to the BWMP in 3.3.3) could be used.
Again, dependant on the type of BWMS used, there may be a need to make an entry in 3.2. An example
would be the dosing of the ballast water with an active substance and/or the mixing of the ballast water
with an active substance or neutralising agent. In this case a reference to the treatment can be made in
3.2. This would be in addition to the entries made for uptake, 3.1 and discharge, 3.3. The latter would
again include an entry in 3.3.3 to reference the BWMP and the BWMS used.
Some Administrations have recommended the use of 3.2 every time a BWMS is used. The justification
for an additional entry here relates to the interpretation of the text in Annex II of the BWM Convention
and an entry being made, ‘whenever the ballast is treated for ballast water management purposes’. 3.2
requires a signed entry to be made for the date, time and volume of ballast water treated as well as a
reference to the BWMP. As such, and if the total volume of ballast treated is inserted, as opposed to a
tank-by-tank entry, then the administrative burden of such an entry can be minimised.
Specific questions have been raised regarding the neutralisation of active substances. This may be during
the voyage, in tank or during discharge. As neutralisation is considered part of the overall treatment process
associated with the BWMS then it may not be appropriate to make a separate entry just for this process. If a
record has been included relating to the neutralisation process of the BWMS then this should accompany the
necessary reference to the BWMP which should in turn provide the necessary details and explanation of the
neutralisation process as a step in the overall treatment of the ballast water.
It has been observed that some vetting inspectors have requested that neutralisation be recorded in 3.3.3.
However, it is commonly the case that BWRBs are formatted in such a way as to allow entries to be made on
a tank-by-tank basis. There are several reasons that this option may be used:
i. The BWRB has been created electronically to facilitate a tank-by-tank entry. It is recognised that tank-
by-tank entries in a paper BWRB could create excessive record keeping administration on board.
ii. Breaking the ballast volumes down tank-by-tank may assist with the overall management of ballast
water on board. This may be particularly relevant for ballast water exchange or BWMS that utilise in-
tank dosing.
iii. When undertaking ballast water exchange, reference should be made to the IMO’s Guidelines for Ballast
Water Exchange 2017 (G6) which refers specifically to ballast water tank.
iv. Many BWRFsand ballast logs require tank-by-tank records to be made. As such, some BWRBs are
formatted so entries are made only once but can then be used for several purposes, namely; the BWRB,
ballast water reporting or ballast water log.
v. Tank-by-tank entries are useful for keeping track of ballast management on chemical/product parcel
tankers when partial loading/discharging is common. Similarly, it may be more straightforward to record
internal transfers of ballast between tanks if a tank-by-tank record keeping format is used.
vi. In the event a ballast water exchange cannot be completed in full, and only some tanks have been
exchanged, then a tank-by-tank record may facilitate the ballast discharge from a compliance perspective.
Regardless of whether total volume or tank-by-tank entries are made in the BWRB, the BWMP should reflect
how records should be maintained in partial treatment, part ballast loading and other circumstances where
ambiguity may occur in the overall management of the ship’s ballast water.
As ballast water is taken in and then discharged, many Administrations advise on entries in 3.1 and 3.3
respectively. The key entry however would be in 3.6 ‘Additional operational procedure and general remarks‘
which would detail the actual operation undertaken.
When making the entry in 3.3 and specifically 3.3.3 in relation to the BWMP, then the full flushing procedure
should be included in the BWMP.
In addition, the malfunction of a ballast water pump while the vessel is conducting ballast water exchange
should also be recorded in the BWRB, 3.6.
However, some Administrations are recommending results of any sampling be kept with the record book
together with a reference date, the materials and methods of the testing, the results and the company/person
that conducted the sampling. This could be recorded in 3.6.
Some manufacturers are also recommending sample and testing results to be recorded, although this may be
achieved outside of a formal entry in the BWRB, e.g. by using the manufacturer’s manual or equipment log
book.
Some BWMPs now include procedures for the management and record keeping of sampling and testing as
a means of satisfying any unilateral, statutory (e.g. by Port State Control) requirements as well as possible
voluntary (ship or equipment specific) initiatives.
K. What if the ship does not undertake BWE for safety purposes?
This provision exists in the BWM Convention, Regulation. If the Master reasonably decides that undertaking
Ballast Water Exchange to meet Regulation D-1 would threaten the safety or stability of the ship, its crew
or its passengers because of adverse weather, ship design or stress, equipment failure, or any extraordinary
condition, details of the reasons should be recorded in the BWRB, 3.6.
For chemical tankers it is logical to follow the same principle as above. So for chemical tankers requiring the
ballasting/deballasting of cargo tanks for traditional stability or safety reasons, such operations are governed
by MARPOL Annex II regulations, specifically Annex II – Regulation 13.2, 13.6.1, and 13.7.2. Some companies
also advocate that both the ballasting and deballasting operation be conducted at a distance of not less than
12 nautical miles from the nearest land.
Name of Ship:
IMO Number:
Distinctive number or letters:
See reference on page 13 and the sample ballast water record book.
v
Esti
Depth in Estimated
Date Item Number Location/ Time Time metres (if Tank uptake
inta
Initial Final rece
Position Started Completed outside Number (from sea,
Content Content faci
port) where
(wh
applicable)
app
Notes
Item Number
Item Number
Item Number Location/Position Time Completed
Item Number
Item 3.1 When Ballast Water is taken onboard Geographic location of Alternatively and
3.2 Whenever Ballast Water is circulated ship (Port or Lat and depending on diagram
or treated for Ballast Water Management Long) of ship, Ballast Tank
purposes Identity or Name may
be more suitable than
3.3 When Ballast Water is discharged into the
number.
sea
3.4 When Ballast Water is discharged to a
reception facility
3.5 Accidental or other exceptional uptake or
discharges of Ballast Water
3.6 Additional operational procedure and
general remarks
Record of Operations
volume (m3)
Estimate Signature
imated
Estimate Estimate discharged Method
ake from
circulated discharged to port Employed
Based on Is this an accidental or of Officer
eption BWMP? (if Salinity Remarks exceptional uptake or in Charge
or treated into sea, reception (Pump/
ility applicable) discharge? If yes, please fill up
(where (where facility Gravity)
here Appendix 1
applicable) applicable) (where
plicable)
applicable)
Item Number
Item Number
Tank Number
Item Number Salinity Accidental or
An alternative to Salinity is not part Exceptional Uptake or
two columns for of the record of Discharge
Time Started / Time Operations but Please see Appendix 1
Completed, a single frequently requested in sample provided on
column with Time / ballast water reporting page 11.
Duration may also be forms.
considered.
Above is an example of a sample Ballast Water Record Book – we recommend you zoom in to view it.
Clicking through the following link:
https://bit.ly/2YhcmK3
... will take you to an identical Microsoft Excel spreadsheet where you can access various notes and spreadsheet
data (you will need a login to view).
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