Interview: Frank H. Marmol, Principal Surveyor of ICS Class about BWMC:

  1. How would you assess the preparedness of shipowners to comply with the requirements of Ballast Water Management Convention?

A/ ICS Class strong recommends to shipowners and shipoperators the revision of circulars issued by flag State administrations take into account the different about the policy, guidance and instructions regarding the applicability and implementation of the requirements of the Ballast Water Management Convention. For example, according to Panama Maritime Authority the Ballast Water Management Plan (BWMP) will be evaluated, revised and approved only by Panama as well as the issuance of the International Ballast Water Management Certificate (IBWMC-Full Term) valid for five (5) years, this information is available on Merchant Marine Circular (MMC-345) for a good reference.        

  1. What have been the major challenges of classification societies in helping owners adhere to the BWMC?

A/ First the theoretical training, learning and updating of many surveyors of classification societies as well as the training courses designed for masters, deck and engine officers, seafarers in general including shipowners and shipoperators.      

  1. There were certain market estimates that owners might opt to demolish older vessels instead of making them compliant with the Convention as the expenses of fitting such ships with the necessary equipment could reach up to USD 2 million. What direction are owners taking, demolition or retrofits?

A/ Demolitions is always a permanent solution to very old vessels but never to avoid the enter into force of a new international convention like BWMC, 2004 or other conventions; in this scenario the best solution stablished by IMO and flag States consist in the de-harmonization of the International Oil Pollution Prevention Certificate (IOPP) grating enough time (around five (5) years more) to shipowners and shipoperators to comply with the installation of the Ballast Water Management Systems (BWMS) during the next renewal survey of the IOPP Certificate and not from September 8, 2017 when the BWMC, 2004 enters into force.   

  1. In late 2016, Moore Stephens informed that vessel operating expenses for both 2016 and 2017 were expected to rise, mainly driven by upgrades being made ahead of September 8, 2017. With the pressure also arising from an overall depression seen in the shipping industry, are owners willing to invest in retrofits?

A/ In our opinion for old ships the solution is not the retrofits but for an average ship (15-20 years old) the solution will be considered by shipowners and shipoperators at the time of installation or not of Ballast Water Management Systems (BWMS) for every particular ship.    

  1. Are owners likely to bring forward fourth special surveys in order to delay retrofitting BWM systems to the fifth special survey?

A/ According our own experience more that 85% of the ships certified by ICS Class already requested the de-harmonization of the IOPP Certificate to extend the date of installation for the Ballast Water Management Systems (BWMS) until 2022 therefore the bottleneck that we envisage would occur approximately within 5 years counted from 2017.   

  1. So far, four ballast water treatment specialists have received a type approval certificate from the United States Coast Guard Marine Safety Center. Do shipowners already have favorites among the BWMS providers? Could we soon see more companies obtain the necessary type approvals?

A/ Definitely all maritime community needs more BWMS providers with the corresponding type approval certificate. Panama Maritime Authority will be accepted the BWMS Type Approval approved by other flag State administrations provided it´s been approved in accordance with the ´Guidelines on the Type Approval process for BWMS´ [Resolution MEPC.174(58) or Resolution MEPC.279(70)], as applicable. Manufacturers interested to obtain approval for their BWMS by the Panama Maritime Authority may request a Recognition Certificate for the BWMS through a legal representative located in Panama (Refer to MMC-345 available on for a best reference).        

  1. Does the IMO have grounds to delay the entry into force date?

A/ Based on the provisional agenda for the IMO Marine Environment Protection Committed (MEPC) – seventy-first session (MEPC 71), the following proposal are presented by member States including the following primary discussion points:

-Deadline for installation of BWMS for existing ships linked with IOPP Certificate renewal after entry into force (immediately after entry into force, or given a two (2) year period of grace).

-Installation for new ships (construction -keel lay- on or after entry into force of giving two (2) year period of grace)

-What to do for small ships (not having IOPP Certificate – what could be the deadline?)     

  1. What are companies doing in the field of training personnel on how to operate the new equipment? Are there enough opportunities for seafarers to obtain the necessary knowledge and skills?

A/ Crew training and familiarization including the training and education of officers and crew is not optional or voluntary, this is a mandatory requirement according to BWMC, 2004- Section B, Regulation B-6 and     MEPC.127 (53)-Part B, Regulation 3.9.5. Theoretical training by means of distant learning or on-site training courses is strong recommended and then practical instructions on the application of ballast water and sediment management, ballast water exchange and treatment procedures used on board the ship, in this way ICS Class developed InterTraining , this is a training platform for a qualification of surveyors and auditors of recognized organizations, port state control officers, personnel from maritime administrations, port and harbor masters, P&I clubs and flag state surveyors, the BWM course will also be beneficial to ship owners, operators, CSOs, DPAs, marine superintendents and masters; providing an online training system 24 hours every day; more information is available here: and the application for BWM training be submit to:

  1. From an engineering point of view how difficult is it to retrofit a ship, and whether, and in what way, does the new system impact the ship’s operability?

A/ From the engineering point of view we think that is not difficult the retrofit of any ship and the ship´s operability we don’t think it is so affected, in our view the problem is closely related to a global economic crisis affecting the maritime transport and also relates to the ability of manufacturers to provide BWMS properly approved in due time as well as shipyards or specialized workshops that will have to provide these services to shipowners and shipoperators that includes thousands of ships that will have to comply with the regulations of the BWMC, 2004 sooner or later.