We would like to bring to your attention the recent developments at Saudi Arabia with regards to Ballast Water Management.
There was a meeting conducted by authorities with reference to BWM Convention that will enter into force on 8 September 2017. Saudi Aramco has charted out an plan to enforce on ships calling Saudi Arabian ports to comply with the regulation.
Ras Tanura & Juaymah Ports shall be a part of the pilot run and Saudi Aramco has given 2 months’ notice to this effect.
With effect from 1st of May 2017, all ships that call Ras Tanura and Juaymah Terminals will be required to have the ballast water sampling done by an approved inspection agency as per Article 9 of the convention.
The tests would have to be arranged by the Vessel Owners or Operators at their own cost.
Master will have to declare the BW test status as per the attached Saudi Aramco data form provided. The prelim test report will need to be attached with this declaration.
If it is determined that the vessel has not complied, then further samples may be taken from vessel’s ballast tanks and will be sent ashore for detailed analysis with initial samples.
At this juncture, Saudi Aramco has indicated that vessel will not be detained but the reports will be conveyed to the respective Flag State, Class & Port States departments besides Saudi Government and Environment Protection Agencies to highlight the non-compliance of vessels.
Attached FYI copy of Sample Data Form (not clear though).
Crude Oil Vessels are often cleared by special permission due to rough weather. Will port allow the vessel to berth if samples are not taken. On many occasions, vessels conduct cargo operations without cargo surveyors also.
Saudi Aramco is yet to formulate a process to be followed in exceptional cases similar to above. Their intention is to initiate the process and to follow the original plan.
Exceptional situation as it may arise might have to be conveyed to authorities and wait for their decisions. Saudi Aramco has not confirmed if any waiver or dispensation would be given and recorded. They are expected to update us during the actual enforcement. This we foresee is the reasoning behind the early implementation of the convention (on 1/May) ahead of the actual date of implementation of BWMS (8/Sep).
2. Are there sufficient Approved Inspection Agencies in Saudi.
Inspection agencies were invited. Inspectorate, Intertek, Saybolt and Future Corners had attended. They are likely to be part of the service providers. We shall check with them over the course of time on their capabilities and can advice yourselves. Any delays due to lack of vendor availability will be highlighted to Saudi Aramco.
3. Anticipated increase in costs.
In due course, we will follow up with the inspection agencies with regards to their costs and charges for the service. Additional Boat hire charges are expected.
4. Will vessel be allowed to berth if sample analysis results are awaited. Are sample analysis results required prior berthing or prior sailing or can it be received after sailing also.
No specific advice from Saudi Aramco on these lines. It is likely to be known during the implementation in May. As customs and coast guard approvals are also required for the operation, more information is likely to be available with the involvement of all authorities.
5. Is waiting time expected to increase, or can it be tackled without any additional delay or cost.
It would be ideal to carry out inspection while vessels may await at anchorage and during inward clearance. However, we anticipate that, vessels which may have berthing scheduled on arrival (subject to futuristic implementation) might suffer short delays for sampling. It is the responsibility of us as agents to clear vessel inwards on arrival in any case (for vessels that have imminent berthing). However, over the course of time, we could update yourselves with possible changes in berthing delays.
Suggestions to decrease cost
Send the inspector along with agents to anchorage during inward clearance (Depending on weather though)
If cargo surveyors are appointed for Ballast water inspection, it could be possible to minimize the cost in the long run
We have tried our best to compile as much information as possible and shall keep yourselves posted of further developments.