Intertanko releases Commentary on Entries in the Ballast Water Record Book

Intertanko releases commentary on entries in the ballast water record book (BWRB) for commonly used ballast water operations on tankers. The commentary is based on questions and feedback from INTERTANKO Members as well as feedback from several Administrations consulted by INTERTANKO and its Members in relation to the BWRB.

As background and context to the commentary, the document also provides a brief summary of the requirements of the International Convention for the Control and Management of Ships’ Ballast Water and Sediments, 2004 (BWM Convention) as it relates to the requirements for a BWRB under Regulation B-2. A sample BWRB format is also included as an Annex to this document.

In the absence of both a harmonised coding system for BWRB entries and clear guidance from the International Maritime Organization (IMO) on how to interpret Appendix II of the BWM Convention, it has not been possible to produce a definitive guide providing specific and precise details of how to make entries in the BWRB. The ambiguity of Appendix II of the BWM Convention and subsequent range of interpretations has therefore necessitated the development of a commentary rather than a guidance document.

Following the entry into force of the BWM Convention on 8 September 2017, all ocean-going vessels have been required to record ballast operations in a BWRB. Appendix II of the BWM Convention (Form of Ballast Water Record Book) specifies the ballast operations that should be recorded, as a minimum, in the BWRB. However, based on the experience of INTERTANKO’s Members, it is evident that Appendix II of the BWM Convention is open to a variety of interpretation and ambiguity by Flag Administrations, Class Societies, Port State Control authorities and third-party auditors.