2025 BWM Campaign: Paris MoU and Tokyo MoU PSC Compliance Guide

The September–November 2025 joint Concentrated Inspection Campaign (CIC) on Ballast Water Management (BWM) coordinated by the Tokyo and Paris Memoranda of Understanding marks the most intensive BWM enforcement effort to date. With broad regional participation and aligned inspection questionnaires, vessel operators must treat this period as a critical compliance checkpoint: one BWM-focused PSC inspection during the campaign can determine operational continuity and financial exposure.

Scope and intent: The campaign seeks consistent verification of IBWMC validity, Ballast Water Management Plans (BWMP), approved Ballast Water Management Systems (BWMS), and accurate Ballast Water Record Books (BWRB). Inspectors will assess system operation, maintenance records, crew competency and the integrity of documentation; five areas are identified as potential detention triggers, emphasising the importance of administrative and technical readiness.

Documentation is the most common fail point. Ensure your IBWMC, BWMP and BWMS type-approval certificates are valid and onboard; reconcile all documentation with physical system configuration. Electronic BWRBs are acceptable only with explicit flag-state approval — have printed backups and exportable logs ready for inspection. Minor inconsistencies often become major findings when combined with other deficiencies.

Operational readiness: BWMS must be fully operational with functional alarms and sufficient spare parts. Inspectors may request on-the-spot demonstrations; be prepared to run a treatment cycle and show alarm responses. Maintain current maintenance records and chemical inventories where applicable. Non-operational or bypassed systems are primary detention causes.

Human factors: Crew competency is a formal inspection element. Conduct shipboard briefings and mock interviews before arrival — officers should explain BWMP procedures, demonstrate BWMS operation and show accurate BWRB entries. High crew turnover increases risk; ensure all recent joiners receive immediate training and documented sign-off on BWMP responsibilities.

Detention triggers and consequences: Five mandatory detention areas include missing/invalid IBWMC, unapproved BWMP, unapproved BWMS, non-operational BWMS and demonstrable crew unfamiliarity. Detention results in delay, potential access refusal, and significant commercial cost. Progressive enforcement ranges from correction time-limited notices to immediate detention for serious failures.

Practical checklist: start preparation 60 days before transit—complete system audits, run maintenance tests and confirm spare parts. At 30 days, finalise documentation and crew drills; at 14 days, verify electronic log integrity and perform mock PSC interviews. On approach, submit all BWM documentation via agent and be ready to present exports, printed backups and evidence of recent maintenance.

Contingency planning: If BWMS fails, immediately stop discharge operations, document the failure, implement BWMP contingency measures (exchange where permitted, retention onboard, or shore treatment), and notify flag/port authorities as required. Keep detailed failure logs — timestamps, parameter readings and crew actions — to support corrective action claims and avoid prolonged detention.

Statistics and risk: Historical PSC data indicates BWM deficiencies are often administrative: Paris MoU figures show a large proportion of BWM findings arise from record-keeping errors. Nonetheless, technical failures occur and are scrutinised during this campaign. Given the campaign’s concentrated focus, even small paperwork errors can escalate if combined with operational concerns.

Final advice: digitise and verify records but retain printed backups; train the crew and rehearse interviews; maintain BWMS and spare parts inventories and ensure flag-state approvals for any electronic systems. Early, documented corrective actions and transparent communications with agents and PSC officers reduce the likelihood of detention and demonstrate good faith during focused enforcement. The 2025 CIC provides an opportunity to close compliance gaps — treat it as a priority for fleet readiness and risk management.