Proposed amendments Regulation 4.1
(continued)
Hong Kong, China comments 12
Greece proposes the following:
"Except as provided in this
annex, ships to
which this Annex apply shall:
(a)
conduct on all
[Deep Sea Voyages] at
least one of the
Ballast Management Options
contained in
Appendix 1 , Part A,
Section I ; and
(b)
conduct on all
voyages Other Precautionary
Practices listed
in Appendix ? , Part
A Section 2."13
12 4.1(b) requires ships to conduct
on all
voyages precautionary practices and one
practice is to remove
ballast sediments on a timely basis.
Where practicable,
routine cleaning of the ballast tank
to remove sediments
should be carried out. Then it raises
a question that how
often should a ballast tank be cleaned
up. Existing practice
is to remove ballast tank sediments only
for inspection or
maintenance purpose. It is proposed that
ballast tank
sediments should be removed if considered
necessary by the
ship's master for the purpose to minimize
the transfer of
harmful aquatic organisms.
13 Text can be simplified and made
consistent with
the other Annexes of MARPOL. In this
regulation as well as in
others, requirements are imposed to ships
flying the flags of
"Parties" putting such ships
at a disadvantage
vis-a-vis ships of "non Parties".
This policy has
to change throughout the Annex because
it will discourage
acceptance.
Also the reference in subparagraph (a)
to the
"Options" contained in Section
1 of Part A is not
realistic. Retention of ballast on board
is a negative way of
operating a ship since it reduces available
cargo spaces and
for that reason it should be regarded
as a last resort
option. As experience has shown, problems
exist with regard
to inadequacy or unavailability of port
reception facilities.
Thus, the regulation should be redrafted
based on the IACS
"conclusions" (MEPC 41/9/2)
by taking particularly
into account that some ships cannot safely
perform the
sequential method and some others cannot
perform ballast
water exchange by the flow-through method.
In essence, this
conclusion means that for most ships
there is only one
option. The regulation should also contain:
a general
reference to Part A (which will become
mandatory), the
commitment on reception/treatment facilities,
the statement
that the ships' safety is of paramount
importance (as in
resolution A 868(20)).
