Reference is made to Circulars 1/17 and 6/17 concerning developments with respect to IMO's International Convention for the Control and Management of Ship's Ballast Water and Sediments "The BWM Convention" as well as the status of the US Ballast Water Management (BWM) Regulations.

Circular 6/17 has provided Members with details of IMO's revised implementation schedule for the installation of a BWM system under the BWM Convention. Although this will provide in many cases an additional period of time up to which vessels are required to install an approved BWM system for compliance with the D-2 standard, Members are reminded that in all other respects, vessels need to fully comply with the Convention when it enters into force on 8 September 2017. This means that apart from the requirement for vessels in international trade to carry a ship-specific BWM plan, ballast water record book and an International BWM certificate, they must also comply with the D-1 standard for ballast water exchange during the transitional period from entry into force of the Convention up to the applicable IOPP renewal survey at which they will be required to meet the D-2 standard.

Circular 6/17 has also reminded Members that the United States is not a party to the BWM Convention and that vessels discharging ballast water into US territorial waters must comply with the US BWM regulations regardless of a vessel's status under the IMO BWM Convention. With particular reference to ballast water exchange, USCG Marine Safety Information Bulletin (MSIB) 07-2017 of 30 June 2017 advises that under the US BWM regulations, meeting the BWM Convention requirements for sequential ballast water exchange is not an acceptable BWM method for vessels beyond the compliance date specified in 33 CFR 151.1512 & 151.2035 without a valid Coast Guard extension. The approved management methods are listed in Circular 6/17.