Question 1

What document must any instructions relevant to preventing this bypass scenario be incorporated into, according to ABS's recommendations?

Accepted Answer

The ship's Ballast Water Management Plan Recommendation 4 specifically requires relevant instructions on preventing simultaneous bypass-valve operation to be included in the Ballast Water Management Plan, ensuring it forms part of the vessel's formally approved and auditable safety documentation.

Question 2

What is the core PSC deficiency being raised in ports under the Tokyo MoU concerning BWMS arrangements?

Accepted Answer

The piping arrangement may permit the ballast water management system to be bypassed during ballast uptake and discharge operations without activating an alarm The deficiency centres specifically on undetected bypass capability — valves that allow ballast water to be taken on or discharged without passing through, or being recorded as bypassing, the treatment system.

Question 3

Under Section 7.2 of the BWMS Code (Resolution MEPC.300(72)), what is required of any bypass or override fitted for ship/personnel safety in an emergency?

Accepted Answer

It must be connected to the BWMS so that any bypass activates an alarm, and the bypass event must be recorded both by the control/monitoring equipment and in the Ballast Water Record Book Section 7.2 explicitly requires that any bypass connected to and used in conjunction with the BWMS triggers an alarm and is recorded both electronically and in the Ballast Water Record Book — this is the dual-logging, dual-alarm requirement at the heart of the issue.