It is also worth noting that:
• The IMO Biofouling Guidelines are currently being reviewed by IMO Member States and a new version is expected to be approved in 2023. The aim is to make the guidelines clearer by being more specific on the recommended biofouling measures, how to implement the measures, as well as on the procedures for inspection and cleaning. The next version of the IMO Biofouling guidelines will remain non-mandatory and will hence not provide specific international rules or standards for the regulation of biofouling management.
• Although there is an obvious relationship between the mandatory IMO Convention on the Control of Harmful Anti-fouling Systems (AFS) on Ships and biofouling management, implementation of the Convention does not equate to having a biofouling management policy. The AFS Convention provides a framework to limit the impact of harmful AFS but does not regulate or set performance standards for the AFS.
The time to act is now
Finding the ‘right way’ to handle biofouling can present some challenges as the biofouling risk and management options will be different for each vessel depending on design, operating profile, and trading routes. However, with new biofouling regulations entering into force, and the IMO GHG reduction targets looming on the horizon, we encourage vessel operators to revisit and, if necessary, update their biofouling management procedures. Steps should be taken to ensure regulatory compliance with mandatory biosecurity requirements where in force. An additional benefit is that it will optimize operations in terms of fuel consumption, maintenance frequencies, and emissions into the atmosphere.
Although not all regional biofouling regulations are the same, compliance with the IMO Biofouling Guidelines will go
82 | The Report • September 2022 • Issue 101
a long way towards allowing access to ports with mandatory biofouling requirements. The establishment of ship specific biofouling management strategies and procedures in the form of BFMPs is key, as is proper onboard record keeping. An up-to-date BFRB will assist port officials to assess a vessel’s potential quickly and efficiently for biofouling risk and thus minimize any delays to its operation.
As individual ports may impose restrictions on in-water cleaning, depending on the methods and chemicals involved, we recommend that operators verify the applicable requirements with the vessel’s local agent well before arrival at the planned location for cleaning. Advice should also be taken from the industry standard on in-water cleaning of ships published by BIMCO and the International Chamber of Shipping (ICS).
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