The Ukrainian authorities confirmed at the end of April 2019 that segregated ballast water could now be discharged in Ukrainian ports without any restrictions. This brings Ukraine into line with MARPOL 73/78.
Previously the State Ecological Inspectors could take samples of ballast water and would sometimes seek to impose large fines on ships for alleged pollution.
The control of segregated ballast in Ukrainian ports has been cancelled and ecological inspectors are no longer permitted to inspect vessels for the purposes of “ecological control”, including taking and analyzing samples of ballast water.
Resolution No 367 dated March 27th states that the mentioned cancellation is not permanent, but will remain in force until new protocols for sampling and testing of ballast water have been adopted.
Britannia Club advised Members to contact local agents or correspondents if there are any requests to take samples of ballast water in Ukrainian waters.
Ballast water sampling and analyzing in Ukrainian ports for “ecological control” had been an issue for some time.
Local correspondents Legat Odessa LLC told Britannia that it was likely that ecologists would continue to inspect the ballast systems, log books and ballast water exchange logs to look for evidence of documentary non-compliance. Furthermore Legat Odessa said that the ecologists might also look at evidence in the form of visible pollution due to improper cleaning of the vessel’s “grey” water.
Britannia said it was important that vessels calling ports in the Ukraine follow the below recommendations:
· All masters calling ports in the Ukraine should confirm with their agents that the designated berth does not have any visible traces of pollution prior to arrival. It is also important for the ship’s crew to ensure that the ship’s side is clear of any traces of pollutants while the vessel stays at berth.
· The ship’s crew should periodically check over side of any traces or pollutants and report any issues to the authorities and at the same time inform their P&I club.
· Although the ecologists may not sample or test the ballast water Britannia reiterated its previous recommendation that Members should strictly adhere to the SIPBS (State Inspection for Protection of the Black Sea) requirements, such as exchange of ballast water when entering the Black Sea, document the exchange in the appropriate logs and the IMO ballast water reporting form, and declare to the agent the quantity of ballast the vessel will discharge in port. Members should pay particular attention to tank maintenance, where the ballast is taken, draining of the tanks when emptied and sampling routines when SIPBS inspectors are on board.
· As most port state control visits onboard vessels will normally start with an examination of relevant certificates and documents, it was also important to ensure that the vessel’s ballast water management documentation is complete and up-to-date prior to a port entry. Under the requirements of the International Ballast Water Management Convention, vessels must have onboard a ballast water management plan, a ballast water record book and an International Ballast Water Management Certificate. The certificate is required for ships of 400 GT and above under a flag which is a Party to the Convention, however, also other vessels will need to demonstrate compliance with the requirements of the Convention.