Commissioning testing and annual checks of ballast water systems

When a commissioning test is required

Resolution MEPC.325(75) amended regulation E-1 with effect from 1 June 2022. The initial survey, and any additional survey for the installation of a BWMS, “shall confirm that a commissioning test has been conducted to validate the installation” by demonstrating that the system’s “mechanical, physical, chemical and biological processes are working properly”.¹ DNV’s reading is that this applies to systems on newbuilds and existing ships whose initial commissioning survey is completed on or after 1 June 2022, even if the system was partly installed earlier, and to additional surveys after a change, replacement or significant repair.⁷ The resolution also states that the analysis in commissioning testing “should be indicative”.¹

How the test is done (BWM.2/Circ.70/Rev.1)

The 2020 Guidance for the commissioning testing of ballast water management systems (BWM.2/Circ.70/Rev.1, 9 December 2020) sets the method:²

1. Its purpose is to validate the installation, not the type-approved design.
2. Local ambient water is used, however challenging it is for the system.
3. After installation, and after all ballast equipment (pumps, piping) is installed and tested:
   • at uptake, a sample may be taken to characterise the ambient water (an indicative analysis is enough);
   • at the corresponding discharge, after full treatment, a representative sample is taken at the sampling point described in the G2 sampling guidelines, with a total volume of at least 1 m³ (or a smaller volume that has been validated as representative);
   • the sample is analysed for both D-2 size classes (50 micrometres and above; 10 to under 50 micrometres) using indicative methods from BWM.2/Circ.42/Rev.2;¹²
   • the system’s self-monitoring parameters are assessed against its design limits and all sensors are confirmed to work.
4. The test is successful when the indicative analysis shows that the discharge samples meet D-2 for the size classes analysed.

The Isle of Man registry and DNV both add that sampling and analysis must be independent of the BWMS manufacturer or supplier and acceptable to the flag or its recognised organisation; DNV asks for a DNV-approved service supplier or an organisation accepted by the flag.⁵⁷ The test report goes to the attending surveyor and, where required, the flag: methods, results with raw data, and the self-monitoring readings.⁷

Getting it right the first time

Practical experience from testing laboratories points the same way:⁸

• clean the ballast tank and piping used for the test as well as possible, because organisms and sediment left in the tank or pipes after installation can fail an otherwise good system;
• confirm beforehand that the sampling point exists, is accessible and fits the tester’s equipment;
• ballast the test tank through the BWMS with full treatment and respect the holding time in the type approval certificate before discharging;
• de-ballast long enough for sampling (laboratories typically sample over about an hour of discharge);
• expect the 50 micrometre and larger class to be the critical one.

If the test fails, DNV advises investigating the cause and repeating the test, possibly in another port, and informing the flag Administration and following its advice if a successful repeat is not possible in time.⁷

Surveys of the BWMS after commissioning

Regulation E-1 sets the same survey cycle as other statutory certificates: an annual survey within three months either side of each anniversary date, an intermediate survey around the second or third anniversary replacing one annual survey, a renewal survey at intervals not exceeding five years, and additional surveys after any change, replacement or significant repair.⁴ Before the IBWM Certificate is first issued after installation, the BWMS Code asks the Administration to verify the documents on board (type approval certificate, OMSM, BWMP, installation specifications and commissioning procedures) and that the installation conforms.³

Running and maintaining the system

The BWMS Code expects the control and monitoring equipment to record proper functioning or failure, store at least 24 months of data and produce a report for official inspections.³ The OMSM is the maintenance authority: filters, lamps, electrodes, sensors and neutralisation equipment are serviced to the manufacturer’s schedule, by the crew where the manual allows and by the manufacturer’s service engineer where it does not. The BWRB records failures and inoperability under code F.⁶ The experience-building phase protects a ship from penalties solely for a D-2 exceedance only if the system has been maintained to the manufacturer’s instructions and operated to the BWMP, which is a strong reason to keep maintenance records you can show.¹¹

What the 2026 amendments add

As approved at MEPC 84 for adoption at MEPC 85, the amended regulation E-1 would require renewal and intermediate surveys to confirm that the BWMS is properly installed and achieves D-2; annual surveys to verify required maintenance through the BWRB or an equivalent system and to include annual sampling of residual active substances; and an additional survey when a ship moves from regulation D-4 (prototype) to D-2. A commissioning test would then be needed for that transition unless an identical type-approved system passed an equivalent test in the previous 12 months. After a defect that substantially affects compliance, the owner would have to send a time-bound repair plan to the flag and destination port States.⁹