Use this reference matrix to tag Ballast Water Management audit checklist items with their primary Convention regulation and the IMO/MEPC guidance normally used as audit evidence. It should sit beside the ship-specific approved Ballast Water Management Plan, Ballast Water Record Book, International Ballast Water Management Certificate, BWMS type-approval documents, commissioning records and maker's manual.
The BWM Convention requires an approved BWMP under Reg. B-1 and a BWRB under Reg. B-2 [3]. D-1 is the ballast water exchange standard and D-2 is the ballast water performance/treatment standard [
6]. The Convention is also supported by IMO guidelines, MEPC resolutions and BWM circulars [
8].
Abbreviations used
- IBWMC: International Ballast Water Management Certificate
- BWMP: Ballast Water Management Plan
- BWRB: Ballast Water Record Book
- BWMS/BWTS: Ballast Water Management System / Ballast Water Treatment System
- CWQ: challenging water quality
- RO: Recognized Organization
- COTP: Captain of the Port, for U.S. port calls
Fast reference map
| Audit area | Primary Convention reference | Main IMO/MEPC reference to attach |
|---|---|---|
| Certificate and statutory survey | Reg. E-1/E-2; certificate form in Appendix I | Commissioning and certificate re-issue points are linked to Reg. E-1.1.5 and Appendix I [ |
| Approved BWMP | Reg. B-1 | IMO BWMP guidance, including G4/MEPC.127(53), as applicable; the BWM Convention requirement for an approved BWMP is explicit [ |
| BWRB, entries, signatures and retention | Reg. B-2; Appendix II | BWM.2/Circ.80/Rev.1 for record-keeping and reporting [ |
| Ballast water exchange | Reg. D-1 | Use only where D-1 exchange is an approved or contingency method; DNV summarizes D-1 as the exchange standard [ |
| Ballast water treatment/performance | Reg. D-2 | DNV summarizes D-2 as the treatment/performance standard [ |
| BWMS approval | Reg. D-3, supporting D-2 compliance | BWMS Code / MEPC.300(72), or earlier G8/G9 approval basis stated on the certificate; ClassNK notes that BWMS should be Administration-approved under IMO Guidelines G8/G9 to comply with D-2 [ |
| Commissioning test | Reg. E-1.1.5; Appendix I | BWM.2/Circ.70/Rev.1 where applied by Flag/Class; a cited class summary links commissioning testing to Reg. E-1.1.5 and BWM.2/Circ.66/Rev.4 for major modification or upgrade cases [ |
| Contingency, bypass and failure | Reg. B-1, B-2 and D-2, depending on the event | BWM.2/Circ.62 for contingency measures; LR lists BWM.2/Circ.62 as IMO contingency guidance [ |
| Challenging water quality | Reg. B-1 and D-2 | MEPC.387(81), Interim Guidance on the Application of the BWM Convention to Ships Operating in Challenging Water Quality Conditions [ |
| Sediment/reception facility cases | Reg. B-5; Reg. B-3.6 where discharge is to a reception facility | The Convention framework includes technical regulations and supporting MEPC guidance; GloBallast notes the Reg. B-3.6 reception-facility route [ |
| U.S.-only items | Not an IMO BWM Convention requirement | Check USCG, EPA/VGP/VIDA and local COTP requirements separately; do not cite them as MEPC compliance items [ |
Detailed BWM compliance audit matrix
| Audit question or check | Main BWM Convention anchor | MEPC circular, IMO guidance or audit evidence |
|---|---|---|
| IBWMC available onboard, valid and issued or endorsed by Flag/RO | Reg. E-1/E-2; Appendix I certificate form | Carry with statutory certificates; commissioning-related changes may require re-issue after major BWMS modification or upgrade [ |
| IBWMC shows D-2 as the ship's management method | Reg. D-2; certificate endorsement under survey/certification regime | Confirm against the approved BWMP and the certificate; D-2 is the performance/treatment standard [ |
| Commissioning test report available onboard, if applicable | Reg. E-1.1.5; Appendix I | BWM.2/Circ.70/Rev.1 where applied by the Flag/Class; commissioning testing is specifically tied to Reg. E-1.1.5 in the cited class summary [ |
| IMO BWMS type-approval certificate available | Reg. D-3, linked to D-2 | BWMS Code / MEPC.300(72), or the earlier IMO G8/G9 approval basis stated on the certificate [ |
| USCG type-approval certificate available, if trading to the U.S. | Not a BWM Convention requirement | Treat as a separate U.S. regulatory check, not an IMO/MEPC finding [ |
| Approved, vessel-specific BWMP onboard | Reg. B-1 | IMO BWMP guidance, including G4/MEPC.127(53), as applicable; LR notes the approved BWMP requirement [ |
| BWMP identifies D-2 as the principal method and only permits Flag-approved contingency methods | Reg. B-1; Reg. D-2 | BWM.2/Circ.62 contingency guidance and the approved BWMP [ |
| Procedure for temporary storage of sewage or grey water in ballast tanks, if applicable | No standalone BWM Convention permission; use Reg. B-1 only if the operation affects ballast management | Must be specifically accepted in the approved BWMP, Flag/Class instructions and any relevant MARPOL/SMS procedure; do not treat it as a routine BWM allowance |
| Ballast tank stripping procedures included in BWMP | Reg. B-1; record effects under Reg. B-2 | Approved BWMP plus BWM.2/Circ.80/Rev.1 for recording related operations [ |
| Designated officer specified for BWMP implementation | Reg. B-1; crew familiarization aspects may also connect to Reg. B-6 | IMO BWMP guidance, including G4/MEPC.127(53), as applicable [ |
| Treatment system in good working condition | Reg. D-2; Reg. E-1 survey regime | BWMS Code / type-approval limitations and maker's operation and maintenance manual [ |
| Major BWMS components accessible and identified | Reg. E-1 survey regime; Reg. D-3 approval context | Type-approval documentation, approved drawings and maker's manual |
| BWMS control panel operational | Reg. D-2; Reg. E-1 | Type-approval documentation, alarms/self-monitoring records and maker's manual |
| Remote BWMS operation panel fitted and operational, if applicable | Reg. D-2; Reg. E-1 | Type-approval documentation and maker's manual; not a standalone Convention clause |
| UV BWMS lamp warm-up mode available during uptake, where applicable | Reg. D-2 | Maker's approved operating instructions and type-approval limitations |
| Electro-chlorination BWMS salinity, mixing and first-water operation limitations understood | Reg. D-2 | Maker's manual and type-approval limitations; use MEPC.387(81) if the issue arises in CWQ conditions [ |
| Chief Officer or Engineer Officer can demonstrate BWMS data, alarm log and download function | Reg. B-2; Reg. D-2; Reg. E-1 | BWM.2/Circ.80/Rev.1 for records/reporting and BWMS self-monitoring evidence [ |
| Ballast planning discussed during pre-arrival or cargo meetings | Reg. B-1 | Approved BWMP and company SMS; use as supporting evidence rather than a standalone Convention clause [ |
| Officers understand BWMS minimum flow, trip limits and operating limits | Reg. B-1; Reg. D-2 | Maker's manual, approved BWMP and type-approval limitations |
| Approved stripping procedure followed during deballasting | Reg. B-1; Reg. D-2 | Approved BWMP, type-approval limitations and maker's manual |
| Stripping flow routed through BWMS where the approved design requires it | Reg. D-2 | Type-approval limitations, approved piping/design documents and maker's manual |
| Water eductor fitted for stripping, or alternative approved arrangement in place | Reg. B-1; Reg. D-2 where it affects compliant discharge | Approved BWMP and approved design/piping documents; not a freestanding Convention clause |
| BWMS bypassed during stripping in the last 12 months | Reg. B-2; Reg. D-2 | BWM.2/Circ.80/Rev.1 for BWRB entries; BWM.2/Circ.62 for contingency/bypass context [ |
| Bypass incidents recorded in the BWRB | Reg. B-2 | BWM.2/Circ.80/Rev.1 gives detailed ballast-water record-keeping guidance [ |
| Ship-specific BWMS and stripping procedure included in BWMP | Reg. B-1 | Approved BWMP and IMO BWMP guidance [ |
| Bypass not used for deballast unless required by approved contingency or safety procedure | Reg. B-1; Reg. D-2 | BWM.2/Circ.62 contingency guidance and Flag/Class instructions [ |
| BWMS bypass only after triggers specified in BWMP are met | Reg. B-1; Reg. D-2 | BWM.2/Circ.62, approved BWMP and maker's manual [ |
| Post-bypass tank decontamination carried out where required, such as BWE plus BWT on each pass | Reg. B-1; Reg. D-1/D-2, depending on the approved method | BWM.2/Circ.62 contingency guidance; record the operation under BWM.2/Circ.80/Rev.1 [ |
| Officer informed and permission process followed for each CWQ uptake, as required by ship procedure | Reg. B-1; Reg. D-2 | MEPC.387(81) for CWQ conditions, approved BWMP and company/Flag instructions [ |
| CWQ location and operational details confirmed and recorded, as far as practicable | Reg. B-1; Reg. B-2; Reg. D-2 | MEPC.387(81) plus BWM.2/Circ.80/Rev.1; BV notes that Rev.1 aligns BWRB entries with CWQ scenarios [ |
| CWQ procedures followed and coordinated with company guidance | Reg. B-1; Reg. D-2 | MEPC.387(81); BWM.2/Circ.62 if contingency measures are used [ |
| BWMS operational failures in the last 12 months recorded in BWRB | Reg. B-2; Reg. D-2 | BWM.2/Circ.80/Rev.1 and BWM.2/Circ.62 [ |
| Port authority informed when required after D-2 non-compliance | Reg. B-1; Reg. B-2; Reg. D-2, plus Flag/port-State instructions | BWM.2/Circ.62 for contingency steps; BWM.2/Circ.80/Rev.1 for records [ |
| Office or company informed immediately for BWMS failure | Reg. B-1, through approved BWMP and company procedure | Approved BWMP, company SMS and BWM.2/Circ.62 where contingency measures apply [ |
| Flag State informed and acceptance or instruction obtained before bypass, where required | Reg. B-1; Reg. D-2 | BWM.2/Circ.62 and Flag instructions [ |
| Port State informed as per Flag instructions | Reg. B-1; Reg. B-2 | BWM.2/Circ.62 and BWM.2/Circ.80/Rev.1 [ |
| USCG/COTP concurrence obtained for U.S. ports | Not a BWM Convention requirement | Separate U.S. port-call requirement; track outside the IMO/MEPC audit column [ |
| Failures, alarms, untreated uptake, untreated discharge and contingency measures recorded correctly in BWRB | Reg. B-2 | BWM.2/Circ.80/Rev.1; Rev.1 is the updated record-keeping and reporting guidance [ |
| Corrective actions taken before normal operations resume | Reg. D-2; Reg. E-1 | BWM.2/Circ.62, BWMS Code/type-approval limitations and maker's manual [ |
| BWRB format follows the amended Appendix II form, if applicable | Reg. B-2; Appendix II | MEPC.369(80), Flag instructions and BWM.2/Circ.80/Rev.1; BV notes upcoming record-keeping changes with entry into force on 1 February 2025 [ |
| BWRB entries consistent with BWMS alarm and data logs | Reg. B-2 | BWM.2/Circ.80/Rev.1 [ |
| BWRB pages signed by the Master | Reg. B-2 | BWM.2/Circ.80/Rev.1 [ |
| Exceptional uptake or discharge recorded under company guidance | Reg. B-1; Reg. B-2 | BWM.2/Circ.80/Rev.1; BWM.2/Circ.62 if contingency action is involved [ |
| BWRB retained onboard for the required minimum period | Reg. B-2 | BWM.2/Circ.80/Rev.1 and the approved record-control procedure [ |
| Officers trained on BWMP and BWMS operation | Reg. B-1; Reg. B-6 where crew familiarization is being checked | Approved BWMP, maker's manual, company SMS and IMO BWMP guidance [ |
| Training conducted at SMS frequency | Reg. B-1; Reg. B-6 where applicable | Company SMS and approved BWMP |
| Officers demonstrate operational understanding | Reg. B-1; Reg. D-2; Reg. B-6 where applicable | Maker's manual, type-approval limitations and approved BWMP |
| Master reviews BWMS alarm log before signing BWRB | Reg. B-2 | BWM.2/Circ.80/Rev.1; this is good audit evidence even if the exact review workflow is ship/company-specific [ |
| BWMS maintenance routines included in PMS as per maker's manual | Reg. D-2; Reg. E-1 | BWMS Code/type-approval limitations and maker's approved maintenance manual [ |
| Maintenance carried out as per maker's manual | Reg. D-2; Reg. E-1 | PMS records, maker's manual, calibration records and defect/repair history |
| BWMS files available onboard | Reg. B-1; Reg. B-2; Reg. D-3; Reg. E-2 | Approved BWMP, BWRB, IBWMC, type-approval certificate, maker's manual and commissioning report [ |
| Spare UV lamps, TRO sensors or other system spares available, as applicable | Reg. D-2; Reg. E-1 as evidence of continued system capability | Maker's manual, PMS and spares list; not a standalone Convention clause |
| VGP ballast sample test carried out as required | Not a BWM Convention requirement | U.S. EPA/VGP/VIDA check where applicable; keep separate from IMO BWM/MEPC compliance [ |
| BWMS sensor calibration completed as per manufacturer and any applicable U.S. requirement | Reg. D-2; Reg. E-1 for IMO system condition; U.S. rules only where applicable | Maker's manual, PMS and U.S. regulatory evidence where relevant [ |
Notes for issuing audit findings
- Do not cite a maker-specific operating point as a freestanding Convention breach unless it is linked to the approved BWMP, type-approval limitations, Reg. D-2 performance, Reg. E-1 survey condition or Reg. B-2 records.
- For any bypass, untreated discharge, BWMS failure or CWQ event, the practical control set is normally the approved BWMP, BWM.2/Circ.62, BWM.2/Circ.80/Rev.1, Flag instructions and the relevant port-State requirements [
2][
3].
- For BWRB findings, use the amended Appendix II format and BWM.2/Circ.80/Rev.1 where applicable; BV notes that BWM.2/Circ.80/Rev.1 revokes the earlier BWM.2/Circ.80 guidance [
9].
- Keep U.S.-specific items such as USCG type approval, COTP concurrence and VGP/VIDA sampling or calibration in a separate regulatory column. They may be critical for a U.S. call, but they are not IMO BWM Convention or MEPC circular requirements [
12].
