Operational Guide · Registers & Logbooks

# Ballast Water Management Convention In Depth

Beyond the record book: how PSC sampling, BWMS commissioning testing and Same Risk Area exemptions actually work — details many Companies underestimate.

BWM Convention BWMS Code commissioning testing Same Risk Area

## Operational Explanation

While keeping the Ballast Water Record Book is covered in the MARPOL Operations module, this topic goes deeper into the broader Convention framework: the BWMS Code (Code for approval of Ballast Water Management Systems, Res. MEPC.300(72)) sets out the technical requirements a system must meet to obtain type approval, while commissioning testing verifies, after installation on board, that the specific system operates in accordance with the D-2 standard under the ship's actual operating conditions.

PSC sampling for D-2 standard compliance verification is structured on two levels: a rapid onboard indicative analysis (giving a preliminary indication of compliance) and, in case of doubt, a detailed laboratory analysis of the samples taken. Same Risk Area exemptions allow pairs or groups of ports with similar biological characteristics to agree specific waivers to treatment requirements for dedicated routes between those ports, subject to a documented risk assessment.

MEPC 84 update (April-May 2026): amendments to the BWM Convention Annex and related guidelines were approved, strengthening requirements on BWMS operation and maintenance, certification and management of challenging water quality. The most relevant practical changes: more detailed record-keeping, a strengthened review of the Ballast Water Management Plan, and an Annual Survey that from now on also includes a BWMS performance test, not just a documentary check as before. The amendments are expected to enter into force from May 2028. At the same time, MEPC 84 adopted the new 2026 G4 Guidelines for drafting Ballast Water Management Plans, with a more practical and standardized implementation approach than the previous version.

## Regulatory Reference

BWM Convention, with the BWMS Code (Res. MEPC.300(72)) for system type approval; guidelines for PSC sampling and analysis (BWM.2/Circ.42, as updated); provisions on Same Risk Area exemptions per Regulation A-4 of the Convention. MEPC 84 (April-May 2026): amendments approved on BWMS operation/maintenance, certification, management of challenging water quality, record-keeping and BWM Plan review, extending the Annual Survey to include a BWMS performance test; entry into force expected May 2028. New 2026 G4 Guidelines adopted for Ballast Water Management Plans.

## Scope of Application

Every ship fitted with a BWMS subject to D-2 standard compliance verification, including ships operating on routes potentially eligible for a Same Risk Area exemption.

## Procedure / How to Complete It

1. Verify that the BWMS installed on board holds type approval per the BWMS Code in force at the time of installation.
2. Keep on board the complete commissioning testing documentation carried out after installation, demonstrating actual operational compliance with the D-2 standard.
3. Prepare for PSC sampling by understanding the difference between onboard indicative analysis and detailed laboratory analysis, and the implications of each outcome.
4. For dedicated, recurring routes between ports with similar biological characteristics, assess the possibility of requesting a Same Risk Area exemption, with the corresponding documented risk assessment.
5. Maintain a log of the BWMS's operational performance (treatment parameters, alarms, maintenance) to support demonstration of ongoing compliance.
6. Ahead of the entry into force (May 2028) of the MEPC 84 amendments, plan in good time for the integration of a BWMS performance test into the Annual Survey, and update the Ballast Water Management Plan per the new 2026 G4 Guidelines.

## Practical Example

Management example: a ship operating exclusively on a dedicated route between two ports with biological characteristics documented as similar starts, together with the coastal Administrations concerned, the assessment process for a Same Risk Area exemption, reducing the need for full treatment on that specific route.

## Real Cases

The distinction between indicative and detailed analysis in PSC sampling has in some cases been a source of operational confusion: a doubtful indicative result does not automatically equate to a confirmed non-conformity, but requires detailed laboratory analysis for a definitive determination, a process some Companies had not adequately planned for in terms of time and cost.

## Common Mistakes Mistake Library

Mistake | Consequence | How to avoid it
--- | --- | ---
Commissioning testing documentation not systematically kept on board | Inability to demonstrate the BWMS's actual operational compliance in the event of a verification | Always keep the complete commissioning testing documentation on board
No assessment of possible Same Risk Area exemptions for recurring dedicated routes | Full treatment requirements applied even where a documented exemption would have been possible | Systematically assess eligibility for a Same Risk Area exemption for recurring dedicated routes
BWMS operational performance log not maintained consistently | Difficulty demonstrating ongoing compliance between inspections | Maintain a constant log of BWMS treatment parameters, alarms and maintenance

## PSC Observations

PSCOs may carry out sampling with an onboard indicative analysis; a doubtful result may lead to detailed laboratory analysis, with possible operational consequences (discharge restrictions, requests for further verification) pending final results.

## Operational Tips

- Always keep the complete BWMS commissioning testing documentation on board, not just the type approval certificate.
- Systematically assess eligibility for a Same Risk Area exemption for your ship's recurring dedicated routes.
- Maintain a constant log of BWMS operational performance to support demonstration of ongoing compliance.

## Checklist

- BWMS type approval verified per the BWMS Code in force at installation
- Commissioning testing documentation kept on board
- Difference between indicative and detailed PSC analysis understood by the crew
- Eligibility for Same Risk Area exemptions assessed for recurring dedicated routes
- BWMS operational performance log maintained consistently
- MEPC 84 updates (annual survey with performance test from 2028, 2026 G4 Guidelines) monitored and planned for

## FAQ

What does BWMS commissioning testing verify?
That the system, after installation on board, operates in accordance with the D-2 standard under the specific ship's actual operating conditions, distinct from the general type approval obtained per the BWMS Code.
What happens if the PSC indicative analysis gives a doubtful result?
It does not automatically equate to a confirmed non-conformity: it requires a detailed laboratory analysis of the samples taken for a definitive determination, a process that can involve additional time and cost.
What is a Same Risk Area exemption?
A waiver to ballast water treatment requirements agreed between ports with similar biological characteristics, for recurring dedicated routes between those ports, subject to a documented risk assessment per Regulation A-4 of the Convention.
What changes with the 2026 MEPC 84 amendments?
They strengthen requirements on BWMS operation/maintenance, certification and management of challenging water quality, with more detailed record-keeping and an Annual Survey that will also include a BWMS performance test; entry into force expected May 2028. The new 2026 G4 Guidelines for Ballast Water Management Plans were also adopted.
🎬 Additional photos, videos and interactive diagrams for this topic will be available in a future version of the platform.

## Related Topics

Ballast Water Management Biofouling Management

### Leave feedback

Help us improve the platform during the beta -- it takes thirty seconds.

How useful do you find the platform so far?
Comment (optional)
Sign me up for the newsletter
Role