Enforcement of Ballast Water Sampling at Saudi Arabia

Further to our messages, please find below costs received for carrying out BW sampling:

Quote by SGS (Ras Tanura & Juaymah) – Refer attached Proposal from SGS

Sample testing costs  : USD 800

Man day charge        : USD 700 (During normal days Sun to Thu)

Total                 : USD 1500

Man day charge rate increments during weekends Fri – Sat : 50% of normal man day charge

Number of technicians available: Yet to be advised

Number of portable equipment: Expected to be receive 5 of them and will be ready for testing by 20th Aug

Quotes by GSA(Global Strategic Alliance) – (Ras Tanura & Juaymah)

They are a service provider for BW testing based in KSA.

Sample testing costs   : USD 1500 (duration per call 6 hour basis)

In addition to 6 hours : USD 100 per hour

Currently they do  not have port passes and same needs to be arranged by handling Agent

Number of technicians available: 2

Number of portable equipment: 4

As per GSA, their technicians are already dedicated to Bahri (Saudi Local carrier) and they expect to have additional staff and equipment in place by end of August or first week of September.

Additional Costs:

Launch charges USD 480 per trip for Ras Tanura & USD 1334 per trip for Juaymah will be applicable

Launch charges are basis 1 hour waiting alongside

As the authorities will leave immediately after inward clearance hence additional boat trip will be involved for arranging return of these technicians

Handling and Co-ordination charges shall be applicable considering the additional tasks involved.

Perceived FAQs:

  1. Can Surveyor attendance be arranged via same launch used for inward clearance (Single Trip)

Subject to availability of Surveyor for BW testing

As mentioned above, Launch charges are basis 1 hour waiting alongside

However, authorities will leave immediately after clearance and will not prefer waiting alongside for the surveyors to complete sampling

In this case, an additional boat trip shall be involved for arranging return of the technicians.

Further, as it is important to clear vessels on arrival, authorities shall not await the surveyor availability (which is likely to be the bottleneck) to proceed to vessel.

Availability of boats are also a concern at Ras Tanura.

  1. What is the Deadline for sampling

Sampling has to be completed prior commencement of loading.

As it may not be able to board vessel at berth (for Crude Oil tankers), sampling may have to be completed at anchorage prior berthing

  1. Possibility of appointing the same surveyor used by cargo charterer

Depends as per the agreement terms between the survey company and charterer/owner whoever they are contracted with.

As mentioned above, only SGS has the equipment while other survey companies like Saybolt, Intertek, Inspectorate and Geochem do not have the approval for equipment

As per our verbal conversation with SGS, cost may still not go down, as the personnel used by them who are certified for Ballast water sampling is dedicated only for this task (as only few personnel are approved by Port).

  1. What is the procedure for partly loaded vessels that may not discharge Ballast Water

As per feedback from Aramco, there are exemptions, which need formal pre-request from ship, as per the convention and they recommend referring to the same.

Please refer to GUIDELINES FOR RISK ASSESSMENT UNDER REGULATION A-4 OF THE BWM CONVENTION (G7)

  1. What is the Expected delays in Berthing

As very limited service providers are available currently, this cannot be forecasted at this juncture

We shall work closely with authorities explaining the difficulties as and when there shall be an estimated delay

  1. What can be expected in delays when there is rough weather

Vessels are usually cleared inwards by special clearance when weather is rough.

In case of Ballast Water sampling, weather report has to be submitted by agents to port authorities and special approval is likely to be given for the vessels.

Additional information:

  1. Discharging vessels naturally does not require Sampling, as there will be no pumping out of Ballast Water.
  2. Time duration expected for taking samples (as claimed by the respective service providers)

SGS Equipment : Around 30 mins

GSA Equipment : Less than 30 mins

MESSAGE DATED 28.07.17

Further to the following mails, kindly note that, Ballast Water Sampling requirement shall to be implemented from 16th of August.

Attached are the reporting forms and the work flow chart.

With Effect from 16th of Aug 2017, all ships calling Saudi Aramco Ports & Terminals in KSA are required to arrange for the ballast water indicative sampling .

Sampling is to be arranged by vessels/owners at their own costs & expense, which comprises of survey costs for sampling & boat charges (only if additional boat is required) through their port agents.

Sampling is to be carried out on board upon arrival of vessel by local survey companies who are equipped with ballast testing devices that are approved by Aramco.

The nature of tests is that, the approved surveyor boards the vessel upon arrival, draws the samples from two different locations/tanks, and subsequently carries out the tests through the equipment before finally declaring the test results.

Based on the test results if it is proved that the vessel has not complied according to BWM then the vessel’s Flag state, class, Port states departments, besides Saudi Government and Environment Protection Departments will be informed about the non compliance.

As indicated by Aramco, there will be no delays caused to the vessel or cargo operation and neither the vessel will be detained.

But if the vessel is found non compliant for the second time during her next voyage, the consequences will be decided by Aramco based on the trend experienced.

One of the local survey companies have already conveyed us their capability to carry out the requirement (approved equipment and systems).

MESSAGE DATED 08.03.17

We have been notified by port authorities that, presentation is not to be considered as an official document and is for reference only.

Official details shall be provided on their website for reference.

There shall also be an official circular when the actual implementation is being made.

MESSAGE DATED 08.03.17

We would like to bring to your attention the recent developments at Saudi Arabia with regards to Ballast Water Management.

There was a meeting conducted by authorities with reference to BWM Convention that will enter into force on 8 September 2017.

Saudi Aramco has charted out an plan to enforce on ships calling Saudi Arabian ports to comply with the regulation.

Ras Tanura & Juaymah Ports shall be a part of the pilot run and Saudi Aramco has given 2 months’ notice to this effect.

With effect from 1st of May 2017, all ships that call Ras Tanura and Juaymah Terminals will be required to have the ballast water sampling done by an approved inspection agency as per Article 9 of the convention.

The tests would have to be arranged by the Vessel Owners or Operators at their own cost.

Master will have to declare the BW test status as per the attached Saudi Aramco data form provided.

The prelim test report will need to be attached with this declaration.

If it is determined that the vessel has not complied, then further samples may be taken from vessel’s ballast tanks and will be sent ashore for detailed analysis with initial samples.

At this juncture, Saudi Aramco has indicated that vessel will not be detained but the reports will be conveyed to the respective Flag State, Class & Port States departments besides Saudi Government and Environment Protection Agencies to highlight the non-compliance of vessels.

Attached fyr copy of Sample Data Form & handouts of the presentation (not clear though).

FAQs:

  1. Crude Oil Vessels are often cleared by special permission due to rough weather. Will port allow the vessel to berth if samples are not taken. On many occasions, vessels conduct cargo operations without cargo surveyors also.

Saudi Aramco is yet to formulate a process to be followed in exceptional cases similar to above. Their intention is to initiate the process and to follow the original plan.

Exceptional situation as it may arise might have to be conveyed to authorities and wait for their decisions. Saudi Aramco has not confirmed if any waiver or dispensation would  be given and recorded. They are expected to update us during the actual enforcement. This we foresee is the reasoning behind the early implementation of the convention (on 1/May) ahead of the actual date of implementation of BWMS (8/Sep).

  1. Are there sufficient Approved Inspection Agencies in Saudi.

Inspection agencies were invited. Inspectorate, Intertek, Saybolt and SGS had attended. They are likely to be part of the service providers. We shall check with them over the course of time on their capabilities and can advice yourselves. Any delays due to lack of vendor availability will be highlighted to Saudi Aramco.

  1. Anticipated increase in costs

In due course, we will follow up with  the inspection agencies with regards to their costs and charges for the service. Additional Boat hire charges are expected.

  1. Will vessel be allowed to berth if sample analysis results are awaited. Are sample analysis results required prior berthing or prior sailing or can it be received after sailing also

No specific advice from Saudi Aramco on these lines. It is likely to be known during the implementation in May. As customs and coast guard approvals are also required for the operation, more information is likely to be available with the involvement of all authorities.

  1. Is waiting time expected to increase, or can it be tackled without any additional delay or cost

It would be ideal to carry out inspection while vessels may await at anchorage and during inward clearance.  However, we anticipate that, vessels which may have berthing scheduled on arrival (subject to futuristic implementation) might suffer short delays for sampling. It is the responsibility of us as agents to clear vessel inwards on arrival in any case (for vessels that have imminent berthing). However, over the course of time, we could update yourselves with possible changes in berthing delays.

  1. Suggestions to decrease cost
    1. Send the inspector along with agents to anchorage during inward clearance (Depending on weather though)
    2. If cargo surveyors are appointed for Ballast water inspection, it could be possible to minimize the cost in the long run

IMO D2-MA20170810-001


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