Ballast Water Exchange and Scrubber Waste - Captain Michael McCarthy

The aim of the Atlantic Blue Ports project is to motivate the maritime community to stop discharge at sea of marine pollutants such as contaminated ballast water and non-compliant scrubber waste.

Our project addresses an important environmental challenge in consensus to the "Blue Port Services" for 2020 and beyond. It also supports the ESSF, PRF working groups coordinated by EMSA and DG Move, ports, shipping companies and member states to reach consensus on appropriate port services and to translate it into acceptable and applicable regulations.

Designing and investing in “ideal” port reception and treatment facilities requires the support of national, regional, trans-national communities and influential bodies, to create awareness, and consensus on the need/solution. The demand is growing for such port services especially for scrubber waste and contaminated ballast waters as the overall cost of on board treatment and discharge is prohibitive, leading to the temptation to discharge at sea.

The International Convention for the Control and Management of Ships’ Ballast Water and Sediments (BWM Convention) entered into force on September 8, 2017 having been adopted by the International Maritime Organization (IMO) in 2004. Shipboard ballast water management systems must be approved by national authorities, according to a process developed by IMO and must undergo a strict approval procedure and be verified by IMO. The aim is to stop the spread of potentially invasive aquatic species in ships ballast water and requires vessels to manage their ballast water to remove, render harmless, or avoid the uptake or discharge of aquatic organisms and pathogens within ballast water and sediments to the marine environment.

In May 2018, ESPO published its position paper on the Port Reception Facilities for ship waste (ESPO 2017 Sustainability Report European) stating “for European ports, ship waste has been one of the main environmental priorities and ports believe that better enforcement of the obligation for ships to deliver waste at shore are welcome”. “Member States shall allow the use of emission abatement methods by ships of all flags in their ports, territorial seas, exclusive economic zones and pollution control zones, as an alternative to using marine fuels that meet the requirements of Articles 4a and 4b, subject to paragraphs 2 and 3 of this Article”. The emission abatement methods shall comply with the criteria specified in the instruments referred to in Annex II. For exhaust gas cleaning systems the criteria for use are: Resolution MEPC.184(59) adopted on 17 July 2009.

The meeting of the IMO Marine Environment Protection Committee (MEPC 75) was held remotely on the 16-20th November 2020. A statement was issued that the IMO considers exhaust gas scrubbers to be an acceptable means of reducing vessels sulphur 2 emissions and ensuring compliance with MARPOL Annex VI. A separate guideline Resolution MEPC.259(68), specifies the requirements for the verification, testing, survey and certification of scrubber systems and sets out the criteria for discharging scrubber wash water into the sea. Although exhaust gas scrubbers are an accepted abatement technology to meet IMO’s SOx emission rules for 2020, their use is not accepted globally. Many states and some coastal states and ports have implemented local regulations with more stringent requirements that restrict or completely prohibit the discharge of wash water from open loop scrubbers or prohibit the use of scrubbers, creating misconceptions surrounding the true environmental impact of these systems.


The International Maritime Organization (IMO) is the global regulator of shipping, however the implementation of many IMO regulations are being nationally and regionally interpreted or not being adhered to. Although IMO’s EGCS Guidelines have established wash water discharge and monitoring criteria to safeguard against environmental damage, coastal states and ports throughout the world have implemented local regulations with more stringent requirements that restrict or completely prohibit the discharge of wash water from open loop scrubbers or prohibit the use of scrubbers.

This is damaging the IMO’s Reputation. Ship owners have already made significant financial investments in these systems. All ports aim at setting high standards for environmental friendly shipping in their port and to reach this goal through monitoring and assessments of the long term environmental impacts of the use of exhaust gas scrubbers.

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Posted 2021-03-09 10:34:28

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