DE48　日本提案　原文

　

SUB-COMMITTEE ON SHIP DESIGN AND

EQUIPMENT

48th session

Agenda item 2

　

　

1 This document contains comments for the draft Guidelines for approval of Ballast Water Management System (G8) on document MEPC52/WP.7. This document has been submitted in accordance with the provisions of paragraph 4.10.5 of the Guideline on the organization and method of work of the MSC and MEPC and their subsidiary bodies (MSC/Cire. 1099/MEPC/Circ.405).

　

2 The draft guideline for approval of Ballast Water Management Systems (G8) was approved, in principle, by last session of MEPC as contained in annex 1 to document MEPC 52/WP.7. The Committee asked the DE Sub-Committee (DE 48) to consider the guideline to input the comments from the DE with the view to adopt the guidelines at MEPC 53 (see DE48/2/1, paragraph 6).

　

3 The Annex of this document contain the comments from Japan on the draft Guidelines for approval of Ballast Water Management System (G8), as contained in annex of MEPC52/WP.7.

　

　

4 The Sub-Committee is invited to consider the comments contained in the annex hereto and take action as appropriate.

　

　

Comments for the draft Guidelines for approval of Ballast Water Management System (G8)

　

Comment:

 Insert wording "which included test barge or test ship" after "pilot plant".

　

Reason:

1. Wording oof "Land-based Testing" implies limiting the test facilities on the land. If a test of the BWMS can be carryed out at a pilot plant on a barge or a ship in accordance with part 2 and 3 or the Annex to the Guidelines, such facilities should also be available for testing. It is helpful not only for administration but also manufactures on the aspect of cost effectiveness and carrying out the tests within the time frame envisaged by the Ballast Water Management Convention

　

2. Test facilities of land-based testing for BWMS are needed to be representative of the characteristics and arrangements of the types of ship. And also tanks for land based testing are needed to be simulated actual ship's ballast tanks. (Paragraph 2.2 of part 2 of the Annex to the Guidelines) Therefore, if the tests carry out at pilot plant on beige or ship in accordance with part 2 and 3 of the Annex to the Guidelines, it is more realistic a test than the test carried out at land facilities.

　

Comment:

 Whole paragraphs of paragraph 5 "Land-based testing equipments for approval of ballast water management systems" are to be moved to 2.3 Land-based testing of part 2.

　

Reason:

 These paragraphs are describes the scaling requirements for land based tests. Requirements for land-base tests have been described at 2.3 Land-based testing of part 2. Therefore. whole paragraphs of paragraph 5 are more appropriate to be placed in paragraph 2.3 Land-based testing of part 2.

　

Comment:

 Description of the mesh size are needed to be amended to "in the side dimension" from "in the diagonal dimension" to comply with D-2 regulation.

　

Reason:

 According to D-2 regulation, length of target organism for each categories are specified as "50 micrometers in minimum dimension and less than 50 micrometers in minimum dimension and greater than or equal to 10 micrometers in minimum dimension." The minimum dimension are meant to be the side dimension in practice　(See figures 1 and 2 below).

 On the other hand, paragraph 2.3.26 and 2.3.27 of current draft G8 describe, "if samples are concentrated for enumeration, the samples should be concentrated using a sieve no grater than 50 micrometers mesh and 10 micrometers mesh in the diagonal dimension."

 Therefore, the mesh size are needed to amend to "in the side dimension" from "in the diagonal dimension" to comply with D-2 regulation.

(Standard specification of plankton nets in markets are also "in the side dimension".)

　

　

　

　

　

Comment:

 Bacteria name is needed to be amended to "indicator microbes specified in regulation D-2" from "for heterotrophic bacteria."

Reason:

 Collected samples for bacteria should be analysed for Vibria cholerae (serotypes 01 and 0139), E, coil and intestinal Enterococci in accordance with paragraph 2.3.16 in Part 2 and paragraph 4.7.4 to 4.7.8 of Sample Analysis Methods described in Part 4.

 Therefore, bacteria name, which is described in Paragraph 2.3.25.3, is needed to be adjusted to those appearing in paragraphs quoted above. Accordingly the bacteria name is to be amended to "indicator microbes specified in regulation D-2" from "for heterotrophic bacteria."