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.