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MEPC 43/4
ANNEX 1
Page 3

・    It is suggested that the adoption of the new ballast requirements be implemented progressively (with a time schedule of measures/requirements which could be implemented in the next years), in older to avoid a reactive attitude/behaviour, to create difficulty for the entry into force of the Annex ? regulations and to avoid unilateral measures from the States.

・    The safety aspects of the ship ballast water exchange at high seas needs to be better evaluated, as was defended by IACS in the last MEPC 41st session, Certainly. MSC should examine this question again (including also works for DE and SLF Sub-Committees). See also MSC/Circ.865 (dated 30 June 1998).

・    The need to detail and to establish clear procedures, at the highest possible level, is of paramount importance, mainly in the Code. The Members of the Ballast Water Working Group should bear in mind this, in order to avoid misunderstandings and different interpretations by whom will be responsible for ships' inspection and ballast evaluation/acceptance (Port State Authorities/Officers).

・    The sampling and analysis techniques, the ballast water acceptance standards (which need to be internationally agreed) and the shore institutional organization and infra-structure for the ballast water control are other relevant factors that need to be improved, in global terms, to enable the international ship ballast water management end control.


Conclusion
   Based on the above considerations. Brazil understands that it is necessary more time to discuss and to elaborate the new Annex ? of MARPOL 73/78 on Ship Ballast Water. It would be, perhaps, premature to finish the technical discussion in the MEPC 42nd session without solving the several problems that still exist.


United States
Alternate compliance mechanism - Assuming the absence of a broad exemption to ballast water management, we believe the instrument must still provide a flexible framework for encouraging the development of new technologies. This goal could be reached through a provision that allows for the testing and application of new ballast water management methods that meet stated criteria or a standard. Such a provision should maximize compliance with the instrument, promote the development and implementation of effective management methods that address the problem of the translocation of marine organisms, and minimize the disruption to traditional vessel operations and schedules.

At this time, ballast water exchange is generally the only feasible ballast water management method available to ships. As the guidelines and draft instrument provide necessary exemptions for situations where exchange cannot be conducted safely, as well as require ballast water exchange only for deep sea voyages, it is understood that ships will not perform ballast water exchanges on 100% of their voyages. Therefore ballast water exchange must be viewed as only an interim solution to the problem of the spread of marine organisms. The new treaty must therefore encourage the development of new, safer 8nd more effective ballast water management technologies.

The existing instrument provides for review and amendment to incorporate new and emerging ballast water treatment methods. Research and development programs testing a variety of ballast water treatment methods are underway and data is being quantified. However, the instrument does not contain a provision by which these methods could be field tested and evaluated relative to ballast water exchange.

Some of the most effective international environmental protocols are those that foster pollution prevention through incentive programs that encourage technological innovation. To encourage the development of new, safer and Inore effective ballast water management technologies, it is recommended that provision for the testing and application of new and developing ballast water management methods be incorporated into the instrument.

 

 

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