BALLAST WATER Commentary on entries in the ballast water record book Submitted by INTERTANKO to MEPC76
The correct and accurate completion of the BWRB by ships' crews is a critical step in the compliance process. The criticality of ensuring that entries in the BWRB are correct is equally relevant for those on board as well as those inspecting and auditing the ship for regulatory compliance purposes.
INTERTANKO's has provided a commentary and suggestions for improving the entries in the BWRB to MEPC76 as guidance for member countries and have made it freely available as general information. It is based on questions and feedback from INTERTANKO members as well as feedback from several flag Administrations and port State Authorities consulted by INTERTANKO and its members in relation to BWRB entries. The information applies equally to all vessels with BWTS.
The document notes that INTERTANKO's members have encountered differing interpretations by Administrations, port State Authorities, class societies and third-party auditors and inspectors when examining ballast water activities that are recorded in the BWRB. The Commentary therefore discusses the following areas: the ambiguity that exists within Appendix II of the Convention; a consideration of the variations of interpretation of the record-keeping entries specified in Appendix II, and; possible options for making entries in the BWRB under various ballast operation scenarios.